Advisory Services and Fees Charter Oak Capital Management, LLC (hereinafter “Charter Oak”), managed since 2002 is formed under the laws of Delaware. Charter Oak is registered with the Securities and Exchange Commission, and the States of Maine and New Hampshire as an investment adviser where physical offices exist. Charter Oak is a fee-based investment management and financial planning firm. The firm does not sell securities on a commission basis. The firm is not affiliated with entities that sell financial products or securities. Charter Oak’s primary services are managing investment portfolios on behalf of clients who grant Charter Oak discretionary investment authority, providing comprehensive financial planning services for clients, including furnishing advice to clients on matters not involving securities. Individuals who offer investment advisory services are known as Investment Adviser Representatives (IARs). These individuals are appropriately licensed, qualified, and authorized to provide advisory services on Charter Oak’s behalf. Portfolio Management Services Charter Oak provides discretionary portfolio management services on a continuous basis where the investment advice is based on the individual needs of the particular client as set forth in the client’s Investment Policy Statement (“IPS”) or other guiding investment principals. Charter Oak performs various functions without further approval from the client. Such functions include assessment of the clients’ goals and risk tolerance, preparation of an investment plan based on the client goals and constraints, execution of trades in accordance with the investment plan. Once the portfolio is constructed, Charter Oak provides continuous supervision and re- optimization of the portfolio as changes in market conditions and client circumstances may require. In addition, Charter Oak provides quarterly reporting of portfolio positions and performance. Charter Oak provides one on one reviews with clients to review their portfolios, reassess their goals and risk tolerance. In limited circumstances, Charter Oak may enter into non-discretionary arrangements with its clients where Charter Oak obtains client approval prior to the execution of a trade. Generally, the Account assets shall be held by Fidelity or Schwab as custodian (the “Custodian”), however, Charter Oak can utilize the services of other custodians Custody of assets are pursuant to a separate agreement between the Custodian and the Client. In addition to the advisory fee, there may be transaction charges involved when purchasing or selling securities or annual maintenance fees that encompass transaction costs. A complete disclosure of all fees charged to clients will be provided in a supplemental disclosure document provided with the account opening documents. A written confirmation of each transaction including all transaction charges will be sent to the client immediately following execution either by mail or electronically, unless the client has given written approval not to receive such notification. The Custodian will also provide to client, at least quarterly, a written or electronic statement showing beginning and ending portfolio values as well as all advisory fees, and any and all monthly fees deducted from the Account. The Custodian will provide such statements to both the client and the Adviser. The fee for Charter Oak planning, investing, and guidance services is assessed quarterly in advance based on the value of the assets under management on the last day of the preceding quarter, or based on flat fee, which is prorated in the event the portfolio management agreement is executed at any time other than the first day of a billing period. Fees based on portfolio values are also prorated for withdrawals and additions over each quarter. In addition, the Adviser may also reduce or waive management fees for its personnel, household members of the Adviser’s personnel, the family or friends of the Adviser’s personnel, or any other entity. Generally, Charter Oak requires a minimum quarterly fee of $1,250. On an annualized basis, Charter Oak’s fee for portfolio management is subject to negotiation, not to exceed 1.50% of assets under management. Fee Schedule per Relationship (Minimum Fee is $1,250 per quarter) Assets under Management Fee First 350,000 1.50% $350,000 to $1,000,000 0.85% $1,000,000 to $1,500,000 0.75% $1,500,000 to $2,000,000 0.65% $2,000,000 to $3,000,000 0.55% $3,000,000 to $4,000,000 0.50% $4,000,000 TO $7,500,000 0.40% $7,500,000 AND UP 0.30% Clients are subject to Charter Oak’s fee schedule in effect at the time the client entered into the advisory relationship. Clients who entered into the advisory relationship with Charter Oak prior to this revised fee schedule are grandfathered under the pre-existing fee schedule as evidenced in the Investment Advisory Agreement executed at the initial engagement of services. The fees charged are calculated as described above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds or any portion of the funds of an advisory client (SEC Rule 205(a)(1)). Charter Oak will either invoice the client directly for management fees or payment will be made by the qualified custodian holding the client’s funds and securities provided the client provides written authorization permitting the fees to be paid directly from their account. Charter Oak will not have access to client funds for payment of fees without client consent in writing. Either party, upon written notice to the other, may terminate the management agreement. The management fee will be pro-rated for the quarter in which the cancellation notice was given, and any unearned fees will be returned. Fees are subject to change upon the Adviser giving the Client thirty days written notice. The Client has the option of accepting the new fee schedule or terminating this Agreement pursuant to the termination provisions set forth in their Investment Advisory Agreement. Charter Oak’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Advice offered by Charter Oak may involve investment in mutual funds or Exchange Traded Funds. Clients are hereby advised that all fees paid to Charter Oak for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or Exchange Traded Funds (described in each Mutual Fund’s prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. Further, there may be transaction charges involved with purchasing or selling of securities. Charter Oak does not share in any portion of the brokerage fees/transaction charges

imposed by the custodian holding the client funds or securities. The client should review all fees charged by mutual funds, Charter Oak, and others to fully understand the total amount of fees to be paid by the client. Such charges, fees and commissions are exclusive of and in addition to Charter Oak’s fee, and Charter Oak shall not receive any portion of these fees and costs. Charter Oak does not represent warranty or imply that the services or methods of analysis employed by the firm can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Charter Oak from properly servicing the client account, or if the restrictions would require Charter Oak to deviate from its standard suite of services, Charter Oak reserves the right to end the relationship. Retirement Plan Consulting Services Charter Oak provides consulting services to individual participants of Retirement plans, and other qualified plans. In general, these services will consist of asset allocation advice, investment monitoring, or on-going management services. The annual fee for these consulting services is billed quarterly in advance based upon the market value of the assets on the beginning of the first day of the quarter. On an annualized basis, Charter Oak’s fee is subject to negotiation, not to exceed 1.50% of assets under management. Fees will be assessed pro rata in the event the agreement is executed at any time other than the first day of a billing period. Charter Oak will provide consulting services to the plan participants as described above. Typically, the named plan fiduciary must make the ultimate decision as to retaining the services of such investment advisers as Charter Oak recommends. Either party may terminate the agreement by providing written notice to the other party. In the event there are any prepaid unearned fees, Charter Oak will promptly refund a pro rata share to the client. Charter Oak does not have custody of any client funds or securities, as the services of an independent custodian will be used for these asset management services. Except, as relates to Charter Oak’s contractual ability to authorize the deduction of investment management fees from certain accounts, or by virtue of certain authorizations that allow Charter Oak to facilitate the movement of funds on behalf of clients. Charter Oak may use a third-party platform, Pontera, to facilitate management of held away assets such as 401k accounts, with discretion. The platform allows Charter Oak to avoid being considered to have custody of client funds since Charter Oak does not have direct access to client log-in credentials to affect trades. Charter Oak is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, Charter Oak will review the current account allocations. When deemed necessary, Charter Oak will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Financial Planning and Consulting Services Charter Oak also provides financial planning and consulting services, which typically involves providing advice to clients on matters such as cash flow & budgeting, retirement goal setting, insurance and risk management needs analysis, wealth transfer strategies, and tax and estate planning. Charter Oak may also provide investment-related consulting services to clients that may include, but are not limited to, advice on existing or potential investment products, account re-balancing, education funding, and/or asset allocation. As part of the services provided, various life, health, and disability insurance policies may be reviewed. Charter Oak does not typically charge a separate fee when providing financial planning services to portfolio management clients. However, when Charter Oak deems it appropriate to charge a fee, the fee for such services would be a negotiated hourly rate or another mutually agreed upon compensation structure. When the scope of the financial planning or consulting services has been agreed upon, a determination will be made as to the applicable fee. The final fee, subject to negotiation, is directly dependent upon the facts and circumstances of the client’s financial situation and the complexity of the financial plan or service(s) requested. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, Charter Oak will notify the client and may request that the client pay an additional fee. Either party may terminate the financial planning agreement by providing written notice to the other party. In the event there are any prepaid unearned fees, Charter Oak will return a pro rata share to the client. Seminars Seminars may be presented for the general public from time-to-time at no charge. Amount of Assets upon Which Investment Advice is Provided. As of December 31, 2023, Charter Oak provides advice on approximately $1,109,715,192 of discretionary assets under management for total of approximately 1,257 family households. Family households may consist of more than one client (i.e., client and spouse, plus one or more adult or minor children, trusts, and defined benefit plans for which the client serves as a sponsor). Of these family households, approximately 312 contain a “high net worth” client (i.e., generally, more than $1 million of assets under advisement or net worth exceeding $2.1 million (not including the primary residence)). These statistics do not include assets upon which advice is given for Charter Oak associated persons and their immediate families. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. 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 yours 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 your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.