EagleClaw Capital Management, LLC ("EagleClaw") is an SEC-registered, independent investment advisory firm founded in 2005 and located in Boston, Massachusetts. Mr. David W. Donahue, Jr. is the principal owner of EagleClaw. EagleClaw concentrates its efforts on working with families and individuals, as well as not-for-profits and endowments. Staying focused allows us to give each of our clients the attention they require and to work with them to make the choices necessary to create the future they desire. We build portfolios comprised of individual securities (both stocks and bonds) and pride ourselves on the broad, enduring relationships we share with our clients. We understand that money is not an end in itself but a means to an end. We have a well-defined process we use with our clients to identify what their real aspirations are and to determine the tradeoffs they are willing to make to get there. The path toward the "ideal" life is carefully monitored and updated within the context of an "acceptable" outcome. Our investment philosophy incorporates fundamental analysis with a technical overlay, and emphasizes a non-consensus contrarian style. We focus on: 1. Buying good businesses  Dominant market share  Recurring revenue streams  Well-managed 2. Invest with a two- to five-year time horizon  Act as a business owner, not a stock trader  Look for catalysts to increase the valuation 3. Powerful earnings growth  Strong balance sheet  Look in all market capitalizations  Take a contrarian view 4. Consider the impact of taxes  Capital gains taxes are one of several factors considered  Tax rates are an important component of any income stream 5. Portfolio diversification  Ample diversification, not over diversification PORTFOLIO ADVISORY SERVICES (PAS) In EagleClaw’s Portfolio Advisory Services (PAS), the firm manages client accounts on a discretionary or nondiscretionary basis. EagleClaw clients complete an Account Form for the purpose of determining the client's investment needs, objectives, and risk tolerances. The client's personal financial information forms the basis of the investment strategy recommended by EagleClaw. For example, clients with a long-term investment view and who are interested in capital appreciation will need a strategy that is different from an investor with a short-term investment view and who is interested in generating income. Accordingly, EagleClaw uses a wide variety of investments, including equity (large-cap, mid-cap, small-cap, and all-market capitalization portfolios), debt securities of various kinds (including high yield bonds), and investment company securities. Such investment company securities are generally placed with no associated sales charge; however, investment company securities that have been transferred into the program may have

been purchased with a sales charge prior to the establishment of the client's respective portfolio. Such securities should have been held at least 12 months prior to their inclusion in the client PAS portfolio. Initial public offerings will not be offered in PAS accounts. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Foreign issues  Warrants  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Mutual fund shares  Exchange-Traded Funds  United States government securities  Option contracts on securities Because some types of investments involve certain additional degrees of risk, they will only be purchased when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Eagleclaw advisors may also use one or more third party so-called Wrap Fee programs sponsored by un-affiliated third party broker dealers / investment advisers as listed below to manage your assets. Programs available include the following (as of the date of this Part 2A Brochure) and are available on a fee-only basis: Wrap Fee Program Name Sponsor Separately Managed Account Programs offered through RBC Correspondent Services are listed below:  RBC Advisor  RBC Unified Portfolios  RBC Consulting Services RBC Capital Markets (“RBC CM”), a securities broker dealer registered with the SEC and FINRA. Please see the Part 2A, Brochure Supplement that we provide to you for each of these programs (the so-called Wrap Fee Disclosure Brochure). This Brochure identifies all relevant fees, expenses and other charges (and how the program works) to you. SUB-ADVISER ACCOUNTS Eagleclaw’s Advisory Services can also be accessed through separately managed account/sub-adviser programs. Under these programs, an adviser has a contract with its client to perform services as an investment manager and possibly custodian services. The adviser, in turn, establishes a contract with Eagleclaw to provide advisory services to the adviser’s client. Eagleclaw establishes a contract with the adviser on the client’s behalf. Eagleclaw may from time-to- time establish other such relationships. The advisers that have contracted with Eagleclaw include: CJ Gilbert Financial, LLC Eagleclaw acts as sub-advisor on these accounts and transactions are executed by Eagleclaw as authorized by the program provider at their chosen. ASSETS UNDER MANAGEMENT As of June 30, 2023, EagleClaw had $540,090,877 in customer assets under management, all of which are managed on a discretionary basis.