A. The Firm and its Owners. ADCM, LLC is an investment adviser that was formed in September 2009 by its sole Founder, Chief Executive Officer and Chief Compliance Officer, Lydia Alexandra Renders (formerly Dest). Paul A. Farella owns a minority interest in ADCM. ADCM provides investment supervisory services to individuals, pension and profit-sharing plans, trusts and estates, charitable organizations, corporations and other business entities. In November of 2018, ADCM received certification by the State of Massachusetts as a woman business enterprise (WBE). ADCM is now listed in the Supplier Diversity Office (SDO) Business Directory. In March of 2020, ADCM received certification from WBENC as a nationally recognized women’s business enterprise. In February of 2020 ADCM became a certified B Corporation, meeting the highest standards of verified social and environmental performance, public transparency, and legal accountability to balance profit and purpose. B. The Firm's Services. ADCM offers the following services to clients: Investment Supervisory Services: ADCM provides investment supervisory services, defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client. ADCM generally manages accounts on a discretionary basis and can provide investment supervisory services on a non-discretionary basis. Collaborating with the client, ADCM establishes investment goals, objectives, time horizon and risk tolerance, as well as core financial-related values. ADCM then creates and manages a portfolio based upon those objectives and its macro overview. ADCM is a top-down portfolio manager. The strategy begins with an overview of global and domestic economic conditions. Within this framework a core/tactical approach is utilized which includes long-term and/or short-term purchases. Further, active asset allocation for most clients is used based on both the clients' objectives and ADCM's analysis of the economic and technical market conditions. Investments are spread among a number of domestic and foreign asset classes and sectors (for example, cash; domestic stocks vs. foreign stocks; large cap stocks vs. small cap stocks; corporate bonds vs. government securities). When appropriate for certain clients, ADCM recommends the use of margin or options transactions. Because margin and options involve a certain degree of additional risk, they will only be recommended when consistent with the client's stated tolerance for risk. ADCM has discretionary authority over the accounts of our investment supervisory clients. In some cases, ADCM meets informally with the client to discuss specific investment goals and strategies. While these discussions do not result in formal restrictions on our discretionary authority, they can provide guidance for our investment decision-making processes. At times, ADCM provides advice regarding interests in partnerships that invest in real estate, oil and gas, private equity, and venture capital funds. 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 of 1974, as amended (“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:
• 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. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An employee uses a combination of those options, such as; (i) leave the funds in the former employer’s plan, if permitted, (ii) roll over the funds to a 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 individual’s age, result in adverse tax consequences). If your designated IAR recommends that you rollover your retirement plan assets into an account to be managed by our firm, such recommendation creates a conflict of interest insofar as we will earn an advisory fee on the rolled over assets. You are under no obligation to roll over retirement plan assets to an account managed by us. Financial Planning Services: ADCM does not offer formal financial planning services; however, in the review of a client's specific situation, ADCM's review includes a review of certain aspects of a client's current financial situation, including the following components: cash management, risk management, education funding, goal setting, and retirement planning. ADCM meets with the client to review risk tolerance, financial goals and objectives, and time horizons. C. Miscellaneous Information About the Firm's Services. In connection with the provision of ADCM's services, (1) ADCM tailors its advisory services to the client's individual needs, (2) clients can impose reasonable restrictions on ADCM's services, which could include restrictions on investing in certain securities or types of securities, (3) ADCM is authorized to rely on any and all information that is provided to ADCM by the client or any of the client's other professionals (such as the client's attorney or accountant), and shall not be required to independently verify any such information, and (4) each client is responsible to promptly notify ADCM if there is ever any change in their financial situation or investment objectives so that ADCM is positioned to review, evaluate and possibly revise its previous recommendations and/or services. D. Wrap Fee Programs: ADCM does not participate in a wrap fee program. E. Assets Under Management: As of December 31, 2022, ADCM's total amount of assets under management was $132,360,252. All assets are managed on a discretionary basis.