Description of Services and Fees Wallington Asset Management is a registered investment adviser based in Indianapolis, Indiana. We are organized as a limited liability company under the laws of the State of Indiana. Wallington was founded in 1988 and has been providing investment advisory services continuously since that time. Terence P. Weiss is our principal owner. As of December 31, 2023, we manage $1,050,668,660 in client assets on a discretionary basis. We do not manage client assets on a non-discretionary basis. Currently, we offer the following investment advisory services, which are personalized to each individual client:
• Portfolio Management Services
• Investment Consulting Services
• Financial Planning Services
• Qualified Retirement Plan Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Wallington Asset Management and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person or Investment Adviser Representative throughout this brochure. As used in this brochure, our Associated Persons or Investment Adviser Representatives are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information ("suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. Once we construct an investment portfolio for you, we will monitor your portfolio's investments and make adjustments as we deem appropriate. If you experience changes in your financial goals, investment objectives or risk tolerance, please contact us. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the Investment Advisory Agreement you sign with our firm, a limited power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Portfolio management services are offered through our Asset Management and Capital Advisory programs as described below: Asset Management Program A. Our Asset Management Program is offered to those individuals and entities, including qualified retirement plans, who consent to allow us to manage assets using an agreed upon investment approach. While our current preferred custodian is Schwab Institutional, a division of Charles Schwab & Co. ("Schwab"), an unaffiliated securities broker-dealer and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), other qualified custodians may be utilized if agreed upon prior to signing our Investment Advisory Agreement. B. Investment Policy Formulation: Management of your portfolio requires a well-defined investment policy which specifies long-term financial goals and investment guidelines. During the investment policy formulation process, we will determine asset allocation parameters and select a relative benchmark for you as appropriate. C. Asset Allocation: Asset allocation adjustments may be made within pre-defined limits based upon the relative risk-return profile determined for you. These decisions are made solely for risk management purposes rather than performance enhancement through the employment of market timing strategies. D. Types of Investments: Our Asset Management Program utilizes primarily, but is not limited to, individual common stock and fixed income securities. Our analysis and selection will include:
• Common Stock - We employ a blended approach to construct and manage portfolios of common stocks. This approach is used in an effort to reduce the risk of significant underperformance in any given portfolio over an extended period of time. With regard to specific security selection, we use a multi-factor framework for making decisions which encompasses several models to assess the risk-return profile of each stock.
• Fixed Income - We establish a target duration to help manage sensitivity to changes in interest rates. The target duration seeks to meet your investment objectives based on your risk tolerance, liquidity needs, tax considerations and time horizon. We primarily select intermediate-term bond maturities which we believe allows us to capture the majority of the returns offered in longer-dated maturities while incurring proportionately less interest rate risk. Macroeconomics, yield curve and fundamental analysis are utilized to formulate fixed income strategies which might include composite duration adjustments, sector swaps or individual security swaps. E. Fees: Our standard fee for our Asset Management Program is based on a percentage of your assets we manage and is set forth in the following fee schedules: Equity and Balanced Account Fee Schedule * On the first $1,000,000 1.00% On the next $4,000,000 0.85% On the next $5,000,000 0.60% Over $10,000,000 0.50% 100% Fixed Income Account Fee Schedule ** On the first $10,000,000 0.50% Over $10,000,000 0.30% *Generally, a minimum client account size of $1,000,000 is required to participate in our Equity and Balanced Asset Management Program. When the client account size is below the minimum or the client’s investment advisory agreement was executed under the terms of a prior version of Form ADV Part 2A, certain client accounts may be subject to a higher annual percentage rate not to exceed 1.25% of assets under management. The minimum client account size may be waived or lowered at our firm's sole discretion. **Generally, a minimum client account size of $1,000,000 is required to participate in our 100% Fixed Income Asset Management Program. When the client account size is below the minimum or the client’s investment advisory agreement was executed under the terms of a prior version of Form ADV Part 2A, certain client accounts may be subject to a higher annual percentage rate not to exceed 1.00% of assets under management. The minimum client account size may be waived or lowered at our firm’s sole discretion. Capital Advisory Program A. Investment Policy Formulation: Management of your portfolio requires a well-defined investment policy which specifies long-term financial goals and investment guidelines. During the investment policy formulation process, we will determine asset allocation parameters and select a relative benchmark for you. B. Asset Allocation: Asset allocation adjustments may be made within pre-defined limits based upon the relative risk-return profile determined for you. These decisions are made solely for risk management purposes rather than performance enhancement through the employment of market timing strategies. C. Types of Investments: The Program utilizes mutual funds and ETFs in lieu of individual securities. Our analysis, selection and monitoring of mutual funds and exchange traded funds utilized in each asset allocation category will include the following factors: effective diversification, historic volatility, present and future expected risk exposures, past performance, quality of fund management, portfolio manager tenure and fees. Based on account size we may use a diversified approach across sub-asset classes in an effort to enhance performance and reduce under-performance of sub-asset classes. Market capitalizations and sector exposures may also be adjusted. D. Fees: Our standard fee for our Capital Advisory Program is based on a percentage of your assets we manage and is set forth in the following fee schedule: Capital Advisory Program Fee Schedule *** On the first $1,000,000 0.60% On the next $4,000,000 0.50% On the next $5,000,000 0.35% Over $10,000,000 0.25% ***Generally, a minimum client account size is not required to participate in the Capital Advisory Program. When the client’s investment advisory agreement was executed under the terms of a prior version of Form ADV Part 2A, certain client accounts may be subject to a higher annual percentage rate, not to exceed 0.90% of assets under management. Information Regarding Portfolio Management Programs Our annual advisory fee is billed and payable quarterly in advance based on the market value of all assets in your account, including cash and accrued interest, on the last trading day of the preceding calendar quarter. If the Investment Advisory Agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which your account is managed. Our advisory fee is negotiable and may vary depending on individual client circumstances. Under no circumstance will we require or solicit prepayment of more than $1,200 of fees, six months or more in advance. Specific services requested that are outside the realm of our portfolio management services may be billed as investment consulting

services or financial planning services according to our fee schedules listed below. We may, in our sole discretion, determine when incidental investment consulting services and financial planning services become sufficiently specific and extensive to require a separate agreement and fee. The fee schedules set forth above are current as of the date of this Form ADV Part 2A. Clients who have established accounts or executed an Investment Advisory Agreement before the date of this Form ADV Part 2A may be charged fees in accordance with different fee schedules that were in effect at that time. At our discretion, we may combine the account values of certain related accounts to determine the applicable advisory fee for the client account. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We will deduct our advisory fee only when you have given your custodian written authorization permitting the fees to be paid directly from your managed account(s). Further, the qualified custodian of your managed account will deliver an account statement to you at least quarterly. The custodian’s account statement will reflect all disbursements from your managed account including our advisory fees. You should review your statement for accuracy as custodians do not verify investment advisory fees. Either you or our firm may terminate the Investment Advisory Agreement within five days from the date of acceptance without penalty to you. After the five-day period, either you or our firm may terminate the Investment Advisory Agreement upon 10-days' written notice to our firm. You will incur a pro-rata charge for services rendered prior to the termination of the Investment Advisory Agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which your account was managed. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Investment Consulting Services We offer investment consulting services which primarily involve advising clients on specific financial matters. These may include, but are not limited to, research and analysis on identified investment alternatives; review of investment portfolios; estate valuations; cost/basis determinations; composite asset allocation determination and analysis; establishment of an investment policy statement encompassing investment objectives, guidelines, asset allocations, etc.; implementation of investment policy statement; periodic consultation on investment portfolios which may encompass asset allocations, portfolio performance, and individual security performance; investment analysis and selection of specific securities; historical valuations and performance analysis; analysis of proposals from financial institutions; and/or an independent evaluation of other asset managers. Wallington does not maintain a standard fee schedule for investment consulting services. Accordingly, we may charge a fixed fee (typically between $150 per year and $1,200 per year), an hourly fee, or a fee based on the market value of assets identified for investment consulting services. The fees are negotiable depending on the scope and complexity of services to be rendered. Our consulting fee is payable pursuant to the terms of each respective Investment Consulting Agreement, generally quarterly, semi-annually or annually. Consulting fees will only be automatically deducted from client’s managed accounts if authorized in writing by the client with its custodian. We will only provide investment consulting services in regard to a specific scope of services as agreed upon in writing. Either party to the consulting agreement may terminate the agreement within five days from the date of acceptance without penalty to you. After the five-day period, either party may terminate the agreement upon 10-days' written notice to the other party. The fees will be prorated for the quarter in which the termination notice is given, and any pre-paid, unearned fees will be refunded to you. Financial Planning Services We offer financial planning services that integrate factors such as your personal and financial goals and objectives, family dynamics, financial situation, and risk tolerance to develop detailed strategies and recommendations. We also offer financial planning consulting services which primarily involve advising you on specific concerns related to financial planning without the preparation of a financial plan. We are able to offer assistance implementing our recommendations, which may include coordination with your other professionals such as accountants and/or attorneys. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendations. Our financial planning services require a written Financial Planning Agreement that will set forth the terms and conditions of the engagement, describing the scope of the services provided and the fees. The fees can either be a fixed amount or determined on an hourly basis. Financial planning fees typically range from $3,000 to $10,000 on a fixed fee basis, and from $150 to $400 on an hourly basis. The standard fees quoted may be negotiable depending upon the relationship, the level and scope of the services required, and the professionals rendering the services. Financial planning fees are due at the conclusion of services. In some instances, when the financial planning services are extensive, we may request payment of fees based upon percent of completion of the proposed project fee throughout the engagement. We will send you an invoice for the payment of our financial planning fee which may be paid by check or deducted directly from your managed account. We will deduct our financial planning fee only when you have given your custodian written authorization permitting the fees to be paid directly from your managed account. Further, the qualified custodian of your managed account will deliver an account statement to you at least quarterly. The custodian’s account statement will reflect all disbursements from your managed account. You should review your statement for accuracy as custodians do not verify financial planning fees. Qualified Retirement Plan Consulting Services We offer consulting services to qualified retirement plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. These accounts are regulated under the Employee Retirement Income Securities Act ("ERISA"). Typically, the named plan fiduciary must make the ultimate decision as to retaining the services of such investment advisers or investment companies as we recommend. The plan fiduciary is free to seek independent advice about the appropriateness of any recommended services for the plan. In general, these services may include an existing plan review and analysis, asset allocation advice, money management services, communication and education services to plan participants, investment performance monitoring, and/or ongoing consulting. Our firm may have agreements with third party administrators ("TPA") to provide our qualified retirement plan consulting services as part of the TPA's agreement with a plan. In these instances, the TPA may pay us a portion of the fee charged to the plan for their services. In other instances, we may be introduced to a plan through a TPA where we provide services directly to and receive fees directly from the plan. We may hold educational seminars for the plan employees and provide information on the plan specifics and allocation choices. We may also meet with individual plan participants and offer personalized information based on their individual objectives. The provisions of these services will normally be at the discretion of the plan sponsor. In certain instances (i.e. 401(k) plans), you are responsible for determining the asset allocation adjustments that are to be made. We may provide educational services to you as a plan participant regarding financial planning and investment fundamentals in order to assist you in defining your individual financial goals, risk tolerance, and time horizon. Fees for qualified retirement plan consulting services will be based on the same fee schedule as our Asset Management Program described previously in this brochure. At our discretion, for participant-directed qualified retirement plans utilizing a mutual fund menu approach, the following fee schedule may be introduced if the asset base and service level of the plan substantiates such a fee. Qualified Retirement Plan Consulting Fee Schedule On the first $5,000,000 0.40% On the next $5,000,000 0.30% Over $10,000,000 0.05% Either party to the qualified retirement plan consulting agreement may terminate the agreement within five days from the date of acceptance without penalty to you. After the five-day period, either party may terminate the agreement upon 10-days' written notice to the other party. The fees will be prorated for the quarter in which the termination notice is given, and any pre-paid, unearned fees will be refunded to you. Types of Investments We offer advice on equity securities, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities, U.S. Government securities, options contracts on securities and commodities, futures contracts on securities and commodities, and interest in partnerships investing in real estate, equipment leasing, oil and gas interests, and/or private equity. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.