Firm History and Principal Owner David Nightingale, currently our Chief Investment Officer and Senior Advisor, founded Drum Hill Capital in 1998. The firm is located in Westport, Connecticut, and serves clients in all areas of the country, predominantly in the Northeast. Originally registered with the State of Connecticut at its founding, Drum Hill Capital has been registered with the Securities and Exchange Commission (“SEC”) since 2006. (Please note that registration as an investment adviser with the SEC does not imply a certain level of skill or training.) Advisory Services Offered Drum Hill Capital offers advisory and financial planning services to individuals and families, along with assisting in their personal financial planning issues related to their businesses. The types of advisory services the firm offers fall into four categories: 1. Managed Account Services 2. Comprehensive Household Reporting 3. Financial Planning Services 4. Investment Consulting Services 1. Managed Account Services – Drum Hill Capital provides comprehensive advice and continuous management of a client’s portfolio based upon their specific needs. We prepare for each engagement by conducting personal discussions to identify a client’s goals and objectives. During this data gathering process, we determine the client’s individual objectives, time horizon, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as other unique circumstances that could affect the overall investment strategy and portfolio composition. From here, Drum Hill Capital develops a client's strategic asset allocation plan and manages the portfolio based on that plan. Primarily, client portfolios are managed using a “balanced” strategy, unless otherwise agreed upon. A balanced portfolio may include several asset classes in combination such as equity securities, fixed income securities, and real asset securities such as inflation protected securities. From our experience and our study of long-term market data, we believe that holding certain combinations of asset classes while balancing expected return, risk, and correlation will optimize the long-term performance of a client’s portfolio. We also believe that diversification across asset classes typically offers the best means of controlling risk in a client’s portfolio, although no strategy can completely control or eliminate risk. In addition, it should be stressed that we will not allocate funds blindly to an asset class or asset subsector that we feel is fundamentally overvalued. We manage these portfolios on a discretionary basis. Account supervision is primarily guided by the client's stated objectives (objectives such as capital appreciation, current income, or growth and income), as well as other considerations such as investment time horizon, tax sensitivity and cash withdrawal needs. Drum Hill Capital also offers to its clients the ability to invest in a focused strategy consisting solely of equity securities traded on European stock exchanges. This Focused European Equity strategy may be utilized as a component of a broader strategy (when deemed suitable) or, in the case of clients with more diversified holdings elsewhere, as a standalone investment offering. Our investment recommendations are not limited to any specific product or service. Typically, we will include advice regarding some or all of the following securities in our managed account portfolios: Equity Securities ETFs and Mutual Funds Fixed Income Securities Closed End Funds Money Market Securities Real Estate Investment Trusts Drum Hill Capital seeks to recommend securities which achieve a client’s objectives in the most cost- efficient manner possible. Unless the client so desires, Managed Account Services portfolios are designed using a portfolio consisting of individual equity securities, both domestic and international, with the intention of achieving equity market exposure through companies we believe to have the potential for capital appreciation. These are complemented by diversified ETFs (Exchange Traded Funds) and mutual funds where appropriate. Drum Hill Capital maintains specific criteria when deciding on the most appropriate type of security to achieve client objectives. For asset classes such as fixed income, where transaction costs remain high, the firm uses ETFs or mutual funds as opposed to individual securities. In portfolios where individual equity securities are included, Drum Hill Capital generally targets holding 18 to 22 companies at a time, as opportunities and circumstances warrant. These companies are diversified across sectors, market capitalization and country of domicile, with the advantage of realizing tax benefits that may arise when using individual securities in terms of controlling the security holding period and tax loss harvesting. Please note that some small client portfolios may solely contain ETFs and mutual funds due to the portfolios’ limited size with respect to appropriate diversification and any transaction costs in effect at the time of execution. Our Focused European Equity strategy seeks to invest in European equity securities, generally with a market capitalization of between $300 Million to $15 Billion that lack a liquid American Depository Receipt (ADR) on the various exchanges in the United States. This equity strategy targets owning approximately 15 to 20 companies at a time, as opportunities and circumstances warrant. Through diversification across sectors, market capitalization and country of domicile, it is the intention of this strategy to achieve equity exposure to non-US developed markets we believe to have the potential for capital appreciation. These accounts are managed according to a single model equity portfolio, with the intent being to minimize the level of customization on an account-by-account basis. While unique client circumstances and needs may cause slight deviations from this model, the need for customization (or lack thereof) will be a consideration in suitability for the provision of our services using the Focused European Equity strategy. This portfolio might also use select ETFs or mutual funds where appropriate. Note that certain legacy portfolios managed at Drum Hill Capital do not follow the portfolio conventions outlined above, and instead were based upon the client’s unique circumstances and the strategies used by Drum Hill Capital at the time the portfolio was designed and implemented. Because some types of investments involve certain additional degrees of risk, they will only be recommended and implemented when we believe the recommendation is consistent with the client's stated investment objectives, tolerance for risk, liquidity needs and suitability. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Where appropriate and with client approval we may recommend that certain options transactions be used in a client portfolio in an effort to reduce overall portfolio risk, increase portfolio income or reduce the risk of a concentrated position in a portfolio. Please note that certain option writing strategies may require the use of a margin account. Drum Hill Capital may also manage some portfolios on a more focused basis, consisting only of equity securities combined with an appropriate cash allocation. Clients might choose this strategy if they feel they have sufficient diversification in their investments held in outside accounts. In this situation, we examine a client’s other portfolios with an eye towards ensuring that the equity investments managed by Drum Hill Capital suitably complement the client’s entire financial position. Managed Account Services clients will receive access to a personal

website portal that will show the client’s total portfolio and the individual accounts that comprise that portfolio. This website view will include performance reporting, transaction summaries, and income reports. This website also includes the ability to retrieve Drum Hill Capital’s quarterly reports from the client’s secure document vault. Drum Hill Capital may also provide clients periodic investment-related white papers, research reports or articles related to the client’s managed portfolio without charge as a part of its services. These would typically be delivered electronically, subject to the client’s approval to receive information in this manner. 2. Comprehensive Household Reporting – As an added service to complement the Managed Account Services program outlined above, Drum Hill Capital also provides the ability to compile a client’s other investment portfolio information from various bank, brokerage and investment accounts into a single, comprehensive report. As part of this service we may provide non-discretionary advice on a comprehensive and continuous basis on any or all accounts a client may have at other custodians (referred to as “held away” assets), if the client so chooses. We use a secure method to aggregate position and transaction data from third party sources and compile that data with our portfolio management analysis tools. These held away assets will be included on the client’s portfolio summary page on the client’s personal website portal, as described above, and as part of this service the client will receive quarterly reports on these assets including performance and transaction reporting. These held away assets will also be included in the client’s strategic asset allocation plan as described under the Managed Account Services section above. The responsibilities of Drum Hill Capital for each account included under this service will be clearly identified in the advisory contract. If a client chooses to have us provide non-discretionary advice regarding held away assets, the client may be responsible for implementing any investment recommendations given by Drum Hill Capital. If Drum Hill Capital does not have the authority to execute the recommendations, clients are responsible for acting on the advice in accordance with any instructions we may make. With regard to this service, any recommendation made by Drum Hill Capital is valid only on the day in which it is presented, unless otherwise indicated. At the discretion of the client, some accounts included in Comprehensive Household Reporting services might consist of positions in alternative investments that are subscribed to directly by the client and are included for reporting purposes only. These alternative investments might include, but are not limited to, hedge funds, real estate investment funds, venture capital investments, seed stage investments and private equity funds (“Alternative Investments”). Alternative Investments are generally much less liquid than traditional stocks, bonds, or money market securities and are subject to rigorous suitability requirements. Drum Hill Capital may at times perform initial and ongoing due diligence on venture capital investments as a service to our clients. This diligence could include providing capital-related guidance, such as fundraising strategy, to the founders and managers of these companies, as a service to our clients. While Drum Hill Capital may provide clients with analysis to aid in the decision-making process around these alternative investments, Drum Hill Capital will not accept actual custody or discretionary control of these assets. On client reports, Drum Hill Capital may show Alternative Investments held or controlled by a client or by a third party on behalf of a client for recordkeeping purposes. The description of the client’s held away assets, pricing or value will be provided by third parties. We will not be responsible for confirming that this information as provided by these third parties is accurate or reliable. Drum Hill Capital will not be responsible for the verification of any asset pricing, whether held away or with third parties, where we may have access to the clients account information. In addition, certain assets for which a current value is not available and to which the client subscribed directly, such as investment real estate, illiquid venture capital or private equity investments, may be shown at investment cost or an estimated value provided by the client on client reports to provide a complete investment overview, and as such should not be relied upon for any purpose by a third party. 3. Financial Planning Services – Drum Hill Capital offers a broad range of financial planning services to its clients. These planning services are available to clients upon request without additional charge based upon a tiered approach depending upon the level of assets under management in the Managed Account Services program. These services and the level of assets in Drum Hill Capital’s Managed Account Services program needed to receive these services without additional charge are as follows: Clients with under $250,000 in our Managed Account Services program can receive planning advice without additional charge on -
• Defining their financial goals and quantifying the savings and investment program necessary to reach those goals – a “Baseline Goals Plan”
• Budgeting and saving
• Liquidity and concentrated position management
• Analysis of business opportunities and business plan guidance Clients with between $250,000 and $1,000,000 in our Managed Account Services can receive planning advice without additional charge on all the planning services listed above as well as the following -
• Tax planning
• Retirement income planning
• Insurance review and business risk management Clients with over $1,000,000 in Managed Account Services can receive planning advice without additional charge on all the planning services listed above as well as the following -
• Multigenerational family planning
• Charitable giving strategies and family mission
• Review of outside Alternative Investment proposals, including diligence on hedge funds, venture capital, investment real estate and seed stage investments
• Estate planning review
• Assistance in procuring other Planning and Family Office Services as required 4. Investment Consulting Services – We also offer investment consulting services to formulate investment plans, analyze unique investment situations, and to provide investment and asset allocation advice. This service might be utilized by clients who wish to manage their own portfolios, have a pre-existing, long-term relationship with an investment manager, or who do not have sufficient assets under management in our Managed Account Services program to receive certain financial planning services without an additional fee. Clients will be responsible for executing any recommended portfolio changes under this service and for acting in accordance with any instructions we may give as part of this service. With regard to this service, any recommendation made by Drum Hill Capital is valid only on the day in which it is presented unless otherwise indicated. Unless agreed upon in writing, Drum Hill Capital shall not have any obligation to provide ongoing research with respect to any recommended investment or to monitor these investments. Client Assets Managed Regulatory Assets Under Management – As of December 31, 2023, Drum Hill Capital had the following client regulatory assets under management in the various services described above: Discretionary Assets Managed $148,614,995 Non-Discretionary Assets Managed $20,399,768 Total Regulatory Assets Managed $169,014,763