Exeter Financial LLC (“Exeter,” “we,” “our,” “us”) is an Arizona limited liability company formed November 16, 2006. Exeter is a wholly owned subsidiary of Alkeme Holdings, LLC (“Holdings”). Holdings owns Exeter through two intermediary wholly- owned entities. The only owner of Holdings with a greater-than-25% interest is GCP Capital Partners IV, LP. Peter Helms and Steve Harrison provide investment advice to Exeter’s clients, and oversee all day-to-day operations of the firm. Steve Harrison is the Chief Compliance Officer. Alkeme Intermediary Holdings, LLC, is the managing member. None of Holdings’ executive officers perform investment advisory functions or participate in the routine management of the adviser. Exeter’s team is comprised of specialized professionals in the areas of investing, estate and trust planning, and tax planning. Exeter’s estate and trust and tax planning services are limited to areas related to investing and financial planning. We are not lawyers or accountants and do not provide legal or tax advice, though we value working collaboratively with clients’ other professional advisors. Exeter provides high net worth individuals, families, and related entities with comprehensive and integrated wealth management services which include strategic planning, investment consulting, alternative investment strategies, single stock risk management, and estate and tax planning through professional intermediaries. Advisory services are tailored to the individual needs of each client. While we do not limit the types of securities we advise on, client portfolios usually hold individual equities and bonds, along with some mutual funds and exchange-traded funds (ETFs). In rare cases, we may also recommend private placements for clients who can tolerate the risks, including lack of liquidity and significant risk of loss The planning process begins by working closely with our clients to identify their long-term goals and objectives. We then seek to develop a comprehensive, integrated wealth management plan helping out clients to achieve what is important for them. We work closely with each client to implement the mutually agreed upon wealth management plan. Specifically for the investment arena, we review each client’s portfolio on an ongoing basis and evaluate possible adjustments in response to economic changes, market trends or client needs. We are committed to identifying and providing access to some of the best, most innovative

investment strategies and opportunities. Prior to engaging Exeter to provide advisory services, the client will be required to enter into an Investment Advisory Agreement with Exeter setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Exeter commencing services, if any. In performing its services, Exeter does not verify information received from the client or from the client’s other professionals, and clients understand that Exeter relies on the information provided. If requested by the client, Exeter may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Exeter. Moreover, all clients are advised that it remains their responsibility to promptly notify us of any changes in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Exeter’s previous recommendations and/or services. Clients may impose reasonable restrictions on investing in certain securities or types of securities. When we recommend that you rollover retirement assets or transfer existing retirement assets (such as a 401(k) or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional revenue when we manage more assets. In making the recommendation, however, we do so only after determining that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory recommendations and discretionary asset management services, as described in the advisory agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be described in the advisory agreement. As of December 31, 2023, Exeter had approximately $334.3million in assets under management (AUM), with approximately $332.8 million managed on a discretionary basis and approximately $1.5 million managed on a non-discretionary basis.