Stillwater Investment Management, LLC (“Stillwater”) is an independent investment advisory firm registered with the Securities and Exchange Commission. Stillwater was founded by James K. Tonrey, Jr. in June, 2004. Mr. Tonrey remains the principal owner and CEO. Stillwater is a Limited Liability Company formed under the laws of the State of Minnesota. As of December 31, 2022, Stillwater’s Discretionary Assets Under Management (AUM) were $535,205,899 with $0 managed on a non- discretionary basis. Our business model takes the form of a Family Investment Counseling Office with important adjunct advocacy services. We specialize in providing balanced investment management services. What is a Family Investment Counseling Office? For centuries wealthy families have hired professionals to manage their substantial assets through a family business office model. They do this for effective intergenerational planning, greater control and flexibility, better coordination among tax, legal and investment disciplines, lower administrative costs and minimizing any conflicts of interest. These families have a professional, or sometimes a group of professionals, on staff to analyze all aspects of the financial management process and then recommend and implement the best course of action. Complete objectivity and fee transparency are very important. Stillwater’s mission is to restore the philosophy of the traditional Family Investment Counseling Office and to offer this valuable service to those individuals and families that are not in a position to establish their own. We act as their fiduciary as well as financial advocate. We minimize any conflicts of interest, stress open communication, offer a superior level of personalized service and provide accurate, timely reporting. Investment Advisory Services Stillwater is responsible for the administration and management of individual Advisory Accounts (“Accounts”) and will customize client portfolios based on client needs. Stillwater will design, advise and manage Accounts based on a formal investment management process. Advisory Representatives of Stillwater, through in-depth interviews and consultation, will assist the client in defining their investment objectives and overall investment strategies by collecting relevant information about their goals, assets, time horizon, risk tolerance, investment constraints, liquidity needs, tax considerations and investment experience (“Investment Information”). This information is gathered through a comprehensive interview process. See the following diagram of our Investment Management Process. After the client’s particular circumstances are established, Stillwater develops a client’s individualized Investment Policy Statement (“IPS”)

and creates and manages a portfolio primarily consisting of common and preferred stocks, convertible, corporate, government and municipal bonds, and exchange traded funds. The IPS will also include a descriptive page on the equity style and/or fixed income style to be used to manage the Account. The IPS is signed by the client and an officer of Stillwater. Stillwater will manage Accounts on a discretionary basis. Account supervision is guided by the stated objectives of the client within a balanced investment approach and other factors contained in the IPS. Clients have the opportunity to place reasonable restrictions or constraints on the way their Accounts are managed. The client retains the right to modify Account restrictions at any time. The Advisory Representative will periodically request and review updates to a client’s Investment Information to assist in managing or supervising the client’s Account, and to determine any necessary changes to the management of the client’s Account. The portfolios will be maintained in a brokerage account established at one of several custodians with which Stillwater has established a relationship. The custodians that Stillwater uses include Charles Schwab & Co., Inc. (“Schwab”) and TD Ameritrade Institutional, a Division of TD Ameritrade, Inc. (“TD Ameritrade”), both FINRA registered broker- dealers. Other custodians may be used if Stillwater and the client determine the client’s best interest will be served by using such other custodians. Accounts managed by Stillwater on a discretionary basis will be regularly monitored and modifications to investments can be made based on economic and market conditions or to periodically realign the portfolio according to the client’s current allocation plan, investment objectives, time horizon and risk tolerance, and for tax efficiency; however, there is no assurance that the objectives of the portfolio will be achieved. Upon request, Stillwater will also review holdings in client’s other investment accounts that are not managed by Stillwater. Advocacy Services Stillwater also provides advocacy services to our clients at no additional charge. We act as a client’s advocate to assist, evaluate and coordinate the various aspects of their financial assets. Examples of this service are: working with a client and their attorney to coordinate charitable planned giving strategies and the resulting investment of the assets, meeting with a client’s insurance professional to help develop an appropriate life insurance or long-term care plan, educating client’s children and grandchildren about the values and responsibilities associated with wealth, analyzing alternative investment opportunities and referring a client to tax or legal professionals.