Principium Investments, LLC (Principium Investments), dba Principium, is a fee-only, SEC- registered investment adviser, wholly owned by The Michael P. Tracy Revocable Trust uad 09/19/2019. Principium Investments, LLC is a name change from Vinoy Capital, LLC, which took place on March 31, 2014. Principium Investments, LLC is therefore the successor to the registration and business of Vinoy Capital, LLC, which began conducting business in April 2008 as a combination of two previously established investment advisory firms – Global Capital Advisors, LLC and Sarasota Asset Management, Inc. – both of which had been in operation since 2003. Principium Investments offers a range of investment advisory services, which include investment supervisory and management services, financial planning, estate planning, philanthropic planning and investment consulting. As of December 31, 2022, Principium Investments had approximately $153,102,780 in assets under management, predominantly managed on a discretionary basis. Prior to the rendering of the foregoing advisory services, clients are required to enter into a written agreement with Principium Investments setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). While this brochure generally describes the business of Principium Investments, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or any other person who provides investment advice on Principium Investments’ behalf and is subject to the Firm’s supervision or control. Investment Management Services Individual Accounts Principium Investments manages client investment portfolios by actively allocating assets between one or more of its 6 “Client Account Risk Profiles”. In managing each of these 6 account profiles, the Firm uses a variable mix of globally diversified investment strategies, which seek to obtain asset class exposure primarily through exchange-traded funds (ETF’s) and individual stocks, and to a lesser degree, both mutual funds and variable unit subaccounts within client retirement plans. These portfolios are held at one of our recommended custodians including Fidelity Investments, Inc. (Fidelity), Charles Schwab & Co., Inc. (Schwab), Goldman Sachs Advisor Solutions (formerly Foliofn Investments, Inc.), and Nationwide (for fee-only advisory annuities). Principium Investments provides an additional service for accounts not held at our recommended custodians but where we do have discretion and may leverage an Order Management System to implement asset allocation or rebalancing strategies on behalf of the client. These are primarily employer-sponsored retirement accounts (i.e. 401Ks), qualified tuition plans (i.e. 529 plans), variable annuities, and other assets not held at our recommended custodians but rather maintained at the custodian designated by the plan’s provider. We regularly review the current holdings and available investment options in these accounts, monitor the accounts, rebalance and implement our strategies as necessary. Principium Investments tailors its advisory services to accommodate the needs of its individual clients, and continuously seeks to ensure that its clients’ portfolios are managed in a manner consistent with their specific investment profiles. Principium Investments consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other factors relevant to the management of their portfolios. Clients are advised to promptly notify Principium Investments if there are changes in their financial situation, or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Principium Investments determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Principium Investments does not limit its advice to any specific types of investments. These investment management services do not include securities brokerage services, as Principium Investments does not serve as the sponsor or manager to a wrap fee program (i.e., an arrangement where brokerage commissions

and transaction costs are absorbed by the Firm). Group Retirement Plans under ERISA Principium Investments also provides Fiduciary 3(38) Investment Management Services to employee benefit plans which are established and maintained by the sponsor of the plan (“Plan”) in accordance with applicable provisions of the Internal Revenue Code and the Employee 5 Retirement Income Security Act of 1974 (“ERISA”). The Plan provides that the investment authority of its assets is vested in the sponsor, and that the sponsor is a “named fiduciary” thereunder as contemplated by Section 402(c)(3) of ERISA; and has the power to appoint investment managers as that term is defined in Section 3(38) of ERISA. The 3(38) investments provided include, but are not limited to, an investment line-up using securities representing a spectrum of asset classes and risk levels, certain of Principium Investments’ Model Portfolios, and a qualified default investment alternative (or “QDIA") for the Plan, if required. Acknowledgement of Fiduciary Status When Principium Investments provides investment advice to our clients regarding their retirement plan accounts or individual retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with client interests, so we operate under a special rule that requires us to act in our clients’ best interests and not put our interest ahead of theirs. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of our clients’ when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in our clients’ best interests;
• Charge no more than is reasonable for our services; and
• Give our clients basic information about conflicts of interest. Financial Planning Principium Investments offers a collaborative financial planning process that pairs advice from a Certified Financial Planner (CFP®) with powerful financial planning software to build financial plans that are based on live data and constantly updated. Principium Investments’ financial planning system gives clients a consolidated view of their financial picture and offers both goals- based and cash-flow-based analyses, simulations and projections. Estate Planning Principium Investments offers estate planning, wealth transfer planning, charitable giving and other legacy strategies. Non-legal estate planning services include modeling financial implications of various wealth transfer scenarios and decisions in addition to general CFP® estate planning and charitable giving advice. Legal documents such as estate plans, wills, living wills, trusts, financial durable power(s) of attorney, medical durable power(s) of attorney and other related documents are prepared by a licensed estate attorney chosen by the client. Consulting Services Principium Investments may also offer clients a variety of consulting services. In performing these services, Principium Investments is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. Principium Investments may recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Principium Investments recommends its own services. Clients are under no obligation to act upon any of the recommendations made by Principium Investments under a consulting engagement or to engage the services of any such recommended professional, including Principium Investments itself. Clients retain absolute discretion over all such implementation decisions. Clients are advised that it remains their responsibility to promptly notify Principium Investments if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Principium Investments’ previous recommendations and/or services.