OUR FIRM Westover Capital Advisors, LLC (“Westover” or “WCA” or “Firm”) is an SEC-registered investment advisor which began conducting business in 1999. Westover’s office is located in Wilmington, Delaware. Our controlling officers are Harold Murray Sawyer, Jr., President and Harold “Chip” Murray Sawyer, III, Vice President and Chief Investment Officer. As of December 31, 2023, Westover had $401,243,103 of clients' assets under management, all of which was managed on a discretionary basis. As of this date, our firm did not offer advice on a non- discretionary basis. WCA’s regulatory assets under management calculations include accrued interest which is reported to our firm and calculated by Tamarac. Westover offers a variety of advisory services, which include investment management, wealth advisory, consulting and other wealth management services as disclosed, herein. Prior to WCA rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with WCA setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. INVESTMENT MANAGEMENT AND WEALTH ADVISORY SERVICES WCA works with our clients to provide individually tailored investment management and wealth advisory services, based on the client’s unique needs and circumstances. Investment Management and Wealth Advisory services include a broad range of services that constitute investment supervisory services, wealth planning and consulting. Our Firm meets with clients initially and will continue to meet with clients as needed throughout the length of the relationship. WCA clients with investable assets of at least $1,000,000 under WCA’s management are provided such Wealth Advisory Services as WCA and the client mutually believe is appropriate for their individual circumstances without their payment of an additional fee. WCA clients who are investment advisory clients and who do not meet the $1,000,000 minimum threshold may elect to receive certain of WCA’s Wealth Advisory Services outlined herein, but they are provided as additional services and for an additional fee. WCA offers clients a broad range of investment management, wealth advisory and consulting services, which may include any or all of the following services: Investment Strategy and Research Investment policy development Customized asset allocation plan In-house fundamental and quantitative research Manager/strategy due diligence Investment Implementation Individual stock and bond selection Portfolio diversification, by size, style and sector Ongoing monitoring and rebalancing Portfolio management External investment oversight Risk and liquidity management Wealth Advisory Services These services are included with no additional fee for clients with assets of $1.0M AUM: Life Planning (cash flow, net worth, stock options, large purchase, feasibility analysis, etc.) Tax planning Charity and charitable trust planning Retirement planning Social Security planning Estate, wealth transfer and legacy planning Client Reporting Monthly performance and benchmark reports Customized benchmarking when requested Online account access for client and third parties Account aggregation and consolidated reporting Client Appreciation Exclusive invitation to Westover’s Annual Spring Summit with a national presenter Holiday party get together Client Communications Economic and market updates Newsletters and market insights Coordination with third-party advisors Regular and convenient in person visits Special Advisory Services From time to time, the proper interaction of a client relationship requires special services (e.g., trust services or bill paying are but two examples). These services call for the payment of an additional fee dependent on the complexity of the engagement. Clients are advised to promptly notify WCA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if WCA 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. Our investment management and supervision are provided on a discretionary basis and seeks to ensure that, on a continuous basis, client portfolios are managed in a manner consistent with the client’s identified needs and objectives. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We are an investment advisor. Accordingly, our investment recommendations are not limited to any specific product or service which might be offered by a broker-dealer or insurance company. WCA utilizes a broad-range of securities to meet a client’s specific needs. These securities include publicly traded equities, fixed-income products, ETFs and occasionally options, where and when appropriate. Because all investments involve degrees of risk, they are only implemented when we conclude they are consistent with the client's investment objectives, tolerance for risk, liquidity and suitability. These matters are reflected in the client’s executed Asset Allocation Agreement. CONSULTING AND RELATED SERVICES In addition to our Investment Management, Wealth Advisory and Special Advisory Services, WCA offers clients a broad range of additional consulting advice and financial planning services which include any or all of the following: Assets Under Advisement Private Foundation and Donor-Advised Fund Recommendations Financial Planning Family philanthropy, education and governance services and strategies

Trust and Estate Planning Advice Philanthropic and Charitable Giving Strategies Family Gifting Strategies While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail above). In performing these services, WCA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.). We are expressly authorized to rely on such third-party information. WCA may recommend certain clients engage the Firm for additional related services, such as Trust and/or bill-payer services (described above and below). Clients retain absolute discretion over all decisions regarding implementation of our advice and are under no obligation to act upon any of the recommendations made by WCA under our engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising WCA’s recommendations and/or services. A more detailed description of certain of our services follows. ASSETS UNDER ADVISEMENT SERVICES WCA offers clients consulting services in the form of continuous monitoring as well as our thinking regarding the assets “held away” at other advisors and brokers. As contracted by the client, our firm will continuously monitor a client’s non-Westover portfolio and, when and if requested, provide recommendations to the client as to the composition and allocation of client specific holdings, the nature and timing of the changes therein and the manner of implementing such changes. This advice includes recommendations as to specific securities and other assets to be purchased, retained, or sold by the client. WCA does not implement these recommendations for the client. It is solely up to the client to implement WCA’s recommendations and the timing of such implementation. WCA may give advice and take action with respect to any of its other clients or accounts which may differ from advice given to an Assets Under Advisement client(s). WCA will not limit its timing or nature of action taken with respect to any WCA Investment or Wealth Management client or other account to accommodate implementation of an advice-only client(s). FINANCIAL PLANNING SERVICES Clients who do not qualify as Wealth Advisory clients may also elect to separately contract for financial planning. Upon client request, we will develop a financial plan for our client and his or her family. Included in the analysis may be subjects dealing with health care costs, choosing a strategy to maximize social security benefits, planning for retirement, demonstrating the impact of risks and loss tolerance to a financial plan, demonstrating the impact of market corrections, early death or unexpected costs and providing our clients with a plan to focus on their long-term goals. CONSULTING SERVICES Clients not requiring a financial plan may also elect to receive investment and other financial advice on a limited basis for a separate fee. Some of the consulting services offered include investment advice regarding non-marketable securities, trust accounting, estate administration, preparation of legacy tax returns, and the preparation of an Investment Policy Statements (IPS) outside of a relationship for portfolio management. TRUST AND ESTATE PLANNING ADVICE Being aware of our client’s present and future financial needs and their potential interest in establishing a financial legacy, we will assist in navigating the complexities of wealth transfer, helping to integrate client’s vision into an estate plan. We will work with legal professionals and make recommendations for attorneys experienced in crafting appropriate legal documents to carry out our client’s desires. With this engagement, we may refer a client to an attorney or tax professional. WCA will not accept nor will we pay a referral fee under these circumstances. TAX PLANNING STRATEGIES WCA will work with our client’s tax attorneys and accountants to develop and craft a tax strategy which seeks to accomplish client’s tax minimization objectives. We will provide our in-depth understanding of client’s individual tax needs, along with our knowledge of existing and proposed national and state tax policies related to each engagement. *WCA has an affiliated tax preparation service. Please see important disclosures regarding this service in Item 10 of this brochure. FAMILY GIFTING, PHILANTHROPIC AND CHARITABLE STRATEGIES We recognize that for some of our clients, family gifting and charitable giving fulfills goals of great personal importance, providing a powerful way to enrich the lives of the donor and beneficiary. WCA will work with the client to aid in conceptualizing their goals and will then recommend various charitable instruments to accomplish our client’s charitable goals. TRUST SERVICES Should our client request and we agree to undertake the assignment, certain designated individuals of WCA will serve as a personal trustee with regard to the accounts of the trust beneficiaries of client(s) and will provide fiduciary investment management advice to the trust. Trust services are separate from wealth advisory services. With this engagement, we may refer a client to an attorney or tax professional to prepare tax returns and perform trust administration and estate settlement services for the trust. WCA will not accept, nor will we pay referral fees when recommending professionals for additional services. As WCA has an affiliated tax preparation entity, there is an incentive to recommend our affiliated company. Clients are never obligated to accept our recommendations and may use a professional of their own choosing. BILL PAYER SERVICES We will, upon request, provide online bill paying services to client. Clients will agree to this service in a separate agreement. We will establish an account in the client’s name with client’s permission to pay certain obligations of the client.