AJG and GBS, established Gallagher in 2008. Gallagher is the registered investment adviser subsidiary of Gallagher Benefit Services, Inc. (“GBS”), one of the nation’s largest employee benefits consulting firms. GBS, in turn, is owned by Arthur J. Gallagher & Co. (“AJG”), the New York Stock Exchange-listed insurance brokerage and risk management firm (trading under the symbol “AJG”). Gallagher provides retirement, investment advice/consulting and decision-making to institutional investors, which include public and private sector employee benefit plans (including multiemployer plans), charitable institutions, foundations, endowments, labor organizations, state or municipal government entities, hospitals, non-profit organizations, private trusts, corporations or business entities, and individuals. For more information regarding Gallagher’s institutional investor services, please see our separate ADV 2A Brochure for institutional investors. This Brochure provides information regarding our investment services for individuals. Investment Services Investment services are provided on a non-discretionary and discretionary basis, at the direction of the client. Clients engaging us on either basis will be asked to grant such authority upon signing the Client Agreement. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for investment services, we will meet with you at the beginning of our advisory relationship to determine your investment objectives, time horizon, risk tolerance, and other relevant information. After we meet with you, we will develop a portfolio customized to your specific needs as we understand them based on our discussions with you. This portfolio may be comprised of, but is not limited to, equities, mutual funds, fixed income and exchange-traded funds. If the client selects a discretionary basis, the client grants Gallagher ongoing and continuous discretionary authority to make and to enter orders with a broker-dealer for the execution of its investment recommendations in accordance with the client’s suitability information without the client’s prior approval of each specific transaction. All transactions in the clients’ account shall be made in accordance with the directions and preferences provided to Gallagher by the client. As part of our investment management services, we may use one or more third-party money manager(s) to manage a portion of your account on a discretionary basis. While the chosen third-party money manager(s) will provide advice on specific securities and/or other investments in connection with this service, our firm has discretionary authority to hire and fire such managers and reallocate assets among them as deemed appropriate. If the client selects a non-discretionary basis, the client grants Gallagher ongoing and continuous non-discretionary authority to make its investment recommendations in accordance with the suitability information provided by the client. However, Gallagher must obtain the client’s approval of each specific recommendation prior to entering orders with a broker-dealer for the execution of its investment recommendations. We will monitor your accounts on an ongoing basis to ensure that they are meeting your investment objectives and other requirements. If any changes are needed to your investments, we will either make the changes or recommend the changes to you. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Portfolio Management Services We also offer risk-adjusted model portfolios and strategies that are designed to meet the needs of our clients. The model/strategy fee is in addition to your advisory fee and may cost up to 50 basis points, depending on the model/strategy selected. The investment management services provided by us may cost more or less than obtaining the same or similar services through an unaffiliated investment manager. No Client or advisor is under any obligation to utilize our portfolio management services. The asset allocation within our models attempts to provide consistent, risk-adjusted performance, but we cannot make any guarantees that our model allocations will produce the desired results. Results depend upon a variety of factors and risks, some of which are outlined below and many of which are beyond our control. Although we continually monitor our models, client positions are rebalanced not less frequently than quarterly. We primarily allocate client assets among various mutual funds, exchange- traded funds (“ETFs”), and individual debt securities in accordance with each client’s stated investment objectives. ETF prices, like stocks, can fluctuate over a wide range in the short term or over extended periods of time. These price fluctuations result from factors affecting individual companies, sectors or the securities market as a whole. When buying or selling an ETF, you will pay or receive the current market price, which can be more or less than the underlying net asset value of its individual holdings. There is no guarantee that the stock or bond markets or any particular mutual fund, ETF, or other security will increase in value. We tailor our advisory services to meet the needs of our individual clients and we seek to ensure, on a continuous basis, that our clients’ portfolios are managed in a manner consistent with those needs and objectives. We consult with clients initially, at the outset of our relationship, and continually in an ongoing manner to assess each of their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their portfolios as they change over time. Clients are instructed and encouraged to promptly notify us if there are changes to their financial situations or if they wish to place any reasonable restrictions or limitations on the management of their portfolios (so long as we determine that the conditions would not materially affect the performance of a management strategy or prove overly burdensome to our ability to provide our services). Financial Planning and Consulting Services Gallagher may provide financial planning services to Clients as part of the investment advisory engagement or as a separate engagement, depending on the Client's financial situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client's financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings and other areas of a Client's financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Gallagher may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, Gallagher will provide a written summary of Client's financial situation, observations, and recommendations. For consulting or ad- hoc engagements, Gallagher may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Gallagher and the interests of the Client. Clients are not obligated

to implement any recommendations made by Gallagher or maintain an ongoing relationship with Gallagher. If the Client elects to act on any of the recommendations made by Gallagher, the Client is under no obligation to implement the transaction through Gallagher. Ultimately the Client has the discretion to decide whether to implement the plan or recommendations, and takes responsibility for this decision. You are responsible for promptly notifying Gallagher of any material changes in the information furnished by you regarding your financial situation, investment objectives, time horizon, risk tolerance and other relevant information. You may at any time place reasonable restrictions on the management of your account by notifying us of such restrictions in writing. The Client Agreement outlines the responsibilities of both the client and Gallagher. Triad Wealth Management Platform We offer investment management services through various types of accounts established by Triad Advisors, LLC (“Triad”) on its Wealth Management Platform (“WMP”). The Triad WMP - Advisor Managed Portfolios Program (“Advisor Managed Portfolios”) provides comprehensive investment management of your assets through the application of asset allocation planning software as well as the provision of execution, clearing and custodial services through National Financial Services, Inc. (“NFS”). Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting, fund profiling and performance data, and portfolio optimization and re-balancing tools. Utilizing these tools and based on your responses to a risk tolerance questionnaire (“Questionnaire”) and discussions that you and your investment adviser representative (“IAR”) have together regarding, among other things, your personal investment objectives and goals, time horizon, risk tolerance, account restrictions, needs, personal circumstances and overall financial situation, we construct a portfolio of investments for you. Your IAR has the option to allocate your portfolio amongst a mix of stocks, bonds, options, exchange-traded funds (“ETFS”), mutual funds and other securities (“Program Investments”) which are based on your investment goals, objectives, and risk tolerance. Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. The Triad WMP - Unified Managed Account Program (“UMA”) provides you with the opportunity to invest your assets across multiple investment strategies and asset classes by implementing an asset allocation strategy. UMA is a Wrap Account program that offers these advisory services along with brokerage and custodial services for a single, annual, asset-based advisory fee. After you discuss your financial goals and objectives with your IAR, we will recommend an asset allocation model (“UMA Model”) to you which will consist of: a) Investment Strategies serviced and created by investment managers or your IAR that generally consist of a selection of mutual funds, exchange traded products, equities, and or bonds; b) Mutual funds and ETFs (“Funds”); c) or a combination of the preceding bundled together in an investment asset allocation model. We will recommend a UMA Model to you based on your responses to a Questionnaire and discussion that we have together regarding among other things, your personal investment objectives and goals, time horizon, risk tolerance, account restrictions, needs, personal circumstances and overall financial situation. In addition, you can place reasonable restrictions on investments held within your UMA account. All recommendations in the UMA are made on a discretionary basis, which means your IAR can act without your prior approval. For further details regarding the Advisor Managed Portfolios or UMA, please refer to the Triad Advisor Managed Portfolios Wrap Fee Program Brochure or the Triad WMP - Unified Managed Account Wrap Fee Program Brochure. We provide the relevant brochure to you prior to or concurrent with your enrollment in these programs. Please read it thoroughly before investing. Retirement Plan Rollovers 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. A conflict of interest arises when we advise clients to roll over retirement assets to accounts under our management or oversight. 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 money 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 we recommend that a client roll over their retirement plan assets into an account under our management or oversight by Gallagher, we have a conflict of interest as we will earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement plan assets to an account managed by us. Investment Advisor Representatives Our firm may offer services through our network of independent investment advisor representatives (“Reps”). Reps are not Gallagher employees and may have their own legal business entities whose trade names and logos may be used on separate marketing materials. The Client should understand that the businesses are legal entities of the Reps and not of our firm. The Reps are under the supervision of our firm and the advisory services of the Reps are provided through our firm. A complete listing of the entities is listed on our ADV Part 1. Wrap Fee Programs Some of our accounts are offered through Triad’s wrap fee programs as described above. Other accounts are offered through our wrap fee program that we sponsor at fidelity. The advisory fee paid by the client includes advisory services, brokerage services and custodial services in a single asset-based fee. We believe the charges and fees offered within each wrap fee program are competitive and reasonable when compared to alternative programs available through other firms. However, we make no guarantee that the aggregate cost of a particular program is lower than that which may be available elsewhere or if you were to receive these services separately. If you participate in a wrap fee program, we will provide you with a separate Wrap Fee Program Brochure explaining the program and costs associated with the program. Assets Under Management As of December 31, 2023, with respect to retail clients, Gallagher managed, on a discretionary basis, $867,596,889 in assets.