Kemp Financial Management, LLC. (“Kemp Financial”) is a registered investment adviser that has provided investment advisory services since 1996. The owner of and principal investment adviser representative for Kemp Financial is Robert J. Kemp. Kemp Financial has been in business since 1988 and has approximately $229,965,525 million in non- discretionary regulatory assets under management as of December 31, 2023. At Kemp Financial our mission is to provide our clients with the potential for greater investment success through the application of investment strategies that are designed to ultimately lead to financial independence, security, and peace of mind. Our intent is to understand our clients’ current financial situation and to provide investment solutions that are consistent with their stated goals and risk tolerance. Kemp Financial provides complete, personalized advice so that our clients can make solid, well-informed decisions about their investments and retirement plans. Our strategies are based on the concepts of the Nobel Prize-winning Modern Portfolio Theory, which seeks to identify the most efficient combination of assets to establish a growth or income portfolio that preserves those assets with a risk level appropriate for each individual investor. Once the asset mix has been determined, Kemp Financial implements the allocation strategy on a non-discretionary basis. For clients maintaining certain legacy retirement and non- retirement accounts, Kemp Financial continues to recommend one or more third party money managers that it had previously recommended to such clients (each, a “Third-Party Adviser”) to help implement the allocation strategy. Kemp Financial does not manage assets on a discretionary basis. While Kemp Financial’s goal is to help our clients achieve investment success, we offer no guarantee that our advice will result in profit or protection from loss. All our clients come to us through introductions from existing clients or from relationships with other professionals like Certified Public Accountants, estate planning attorneys and insurance professionals. When Kemp Financial receives introductions from other financial professionals, there is no compensation or “referral fee” paid to those other professionals and they do not participate or share in any revenue earned by Kemp Financial. Kemp Financial provides a number of other services, usually in conjunction with our advisory services discussed above. We often coordinate our planning and advice with attorneys, insurance representatives and accountants to help our clients with various aspects of financial, tax and estate planning. We have no attorneys or accountants on staff, so we do not provide either legal or tax advice, but we are happy to work with our clients' attorneys and accountants, and we do so periodically. Kemp Financial concentrates on asset class allocation and provides continuous investment supervision of client assets based on individual client needs. In some cases, clients may elect to hold a portion of their existing holdings due to tax consequences; such existing holdings will be used as part of our recommended asset allocation model. The details of how a specific client’s account will be managed are set forth in the client’s investment advisory agreement and other account opening documentation. In general, client accounts are managed in accordance with the client’s individual needs, risk tolerance, objectives and reasonable investment restrictions by purchasing and/or selling securities set forth in their personal Investment Policy Statement. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the assets in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an individual retirement account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Kemp Financial recommends that a client roll over his or her retirement plan assets into an account to be managed by Kemp Financial, such a recommendation creates a conflict of interest if Kemp Financial will earn an advisory fee on the rolled over assets. Kemp Financial will typically recommend rolling over assets into an IRA so that the client can gain access to the types of investments recommended, which allows the client to maintain a portfolio that is consistent with his or her investment policy. Kemp Financial addresses this conflict of interest by seeking to obtain the current fees clients are paying along with past performance data within their retirement plan, in conjunction with an analysis of other comparable information, so that clients can compare their options and make informed decisions about their options with their existing retirement plans. No client is under any obligation to roll over retirement plan assets to an account managed by Kemp Financial. Kemp Financial generally recommends that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”), a FINRA-member broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although Kemp Financial generally recommends that clients establish accounts at Schwab, it is the client’s decision to open one or more brokerage accounts with Schwab. Kemp Financial is independently owned and operated and not affiliated with Schwab. Schwab provides Kemp Financial with access to its institutional

trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Institutional. These services are not contingent upon Kemp Financial committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For Kemp Financial client accounts maintained in Schwab’s custody, Schwab generally does not charge separately for custody but is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Kemp Financial reserves the right to recommend alternative custodial broker-dealer options should the need arise. All existing and prospective clients go through our four-step process prior to becoming a client. Our process includes, but is not limited to: 1) Get to know you 2) Client data gathering and education 3) Investment Policy Statement (IPS) presentation 4) Engage Kemp Financial Our goal is to help our clients manage their financial assets and resources to support their current and future lifestyle objectives. Every client has a different set of values, financial resources, time horizon and lifestyle objective. These four factors are utilized to design a Legacy Action Plan or Client Action Plan as well as an Investment Policy Statement (IPS) personalized to their unique set of circumstances. Before becoming a client, each individual must go through our four-step process before engaging Kemp Financial. Implementation is completed after an IPS has been created and approved by each client. This document covers a client’s resources, short, mid and long-range financial desires as well as tolerances for risk. In addition, each IPS contains a policy framework for investing a client’s assets through our advisory service. Our process for asset allocation involves creating a portfolio based on the three primary asset classes: stocks, bonds and cash. Within these broad-based asset classes, we create a diversified portfolio by purchasing mutual funds and occasionally exchange traded funds (“ETF”) that represent a wide range of sub-asset classes. For example, the stock portion of the portfolio may in part consist of US Large Cap, US Small Cap along with International Large and International Small cap stocks. Our management of these accounts and each client’s underlying objectives is an ongoing process. We work to keep the client portfolios in alignment with their associated IPS. In addition, we seek to meet with our clients regularly to ensure or adjust to any changes in their desires, financial resources or life events that might lead towards a change in their IPS. Clients may from time to time impose restrictions on investing in certain types of securities or asset classes so long as such restrictions may reasonably be implemented by Kemp Financial. For a minority of legacy client accounts, certain Third-Party Advisers have been engaged for the provision of select investment advisory services, such as retirement plan advisory services. This practice has been sunsetted for new clients and the majority of Kemp Financial’s current clients. Recommendations for or selections of a particular Third-Party Adviser are typically made after gathering pertinent information from the client about the client’s financial situation and investment objectives and are generally based upon the following factors: i) the individual preference of Kemp Financial’s investment adviser representatives; ii) the client’s risk tolerance, goals and objectives, as well as investment experience; and iii) the size of client assets available for investment. Any securities transactions executed through the Third-Party Adviser is in conjunction with the client’s selected custodial broker-dealer. Third-Party Advisers generally charge additional advisory or administrative fees above and beyond fees charged by Kemp Financial. Any additional costs are fully disclosed to the client and approved by the client in the Third- Party Adviser’s agreement. These fees are also disclosed in the Third-Party Adviser’s ADV Part 2. 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 (“ERISA”) and/or the Internal Revenue Code (the “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: a. Meet a professional standard of care when making investment recommendations (give prudent advice) b. Never put our financial interests ahead of yours when making recommendations (give loyal advice) c. Avoid misleading statements about conflicts of interest, fees, and investments d. Follow policies and procedures designed to ensure that we give advice that is in your best interest e. Charge no more than is reasonable for our services; and f. Give you basic information about conflicts of interest.