GWM is a full-service investment advisory and wealth management firm that has been in business as an SEC registered investment adviser since April 2010. The Firm was founded by a group of seasoned investment professionals, including GWM’s current principal owners, Jeffrey L. Gitterman and Elias S. Rauch. GWM’s mission is to help its clients create and preserve assets through a consultative process, designed to make the most appropriate recommendations based on their individual needs, goals and risk temperance. The Firm seeks to provide clients with informative, unbiased research and select the best financial solutions from a wide universe of financial products and services. GWM’s wealth management business provides services to the higher education marketplace and high-net- worth individuals. Through Gitterman Asset Management (GAM), the Firm provides SMART (Sustainability Metrics Applied to Risk Tolerance)® Investing Solutions to serve the broader advisor and institutional market. As of March 14, 2024 GWM had $624,665,781.70 in assets under management, all of which was managed on a discretionary basis. Prior to engaging GWM to provide any of the foregoing services, clients are required to enter a written agreement with GWM setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). While this brochure generally describes the business of GWM, certain sections also describe the activities of Supervised Persons, which refer to any of GWM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on the Firm’s behalf and is subject to GWM’s supervision or control. Wealth Management Services The Firm manages clients investment portfolios on a discretionary basis. In addition, the Firm provides clients with investment management services which generally includes a broad range of financial planning and consulting services as well as discretionary management of investment portfolios. GWM primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and independent separate account managers (“Independent Managers”), as well as the securities components of variable annuities and variable life insurance contracts, in accordance with the investment objectives of the client. In addition, GWM may recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, and/or pooled investment vehicles when consistent with the clients’ investment objectives. GWM also provides advice about any type of investment held in clients' portfolios. From time to time, GWM may also provide its wealth management services to certain outside accounts. These are accounts not custody at the Firm’s primary custodian (Fidelity Institutional Wealth Services) and are custody at a qualified custodian at the client’s choosing. The Client provides GWM with limited power of attorney to access the account for trading. GWM is limited in the types of investments allowed to be used in these accounts based on the client’s relationship with the custodian. GWM also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, GWM either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. GWM tailors its advisory services to the individual needs of clients. GWM consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. GWM ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify GWM if there are changes in their financial situation or

investment objectives or if they wish to impose any reasonable restrictions upon GWM’s management services. Use of Independent Managers As mentioned above, GWM utilizes certain Independent Managers to actively manage a portion of its clients’ assets. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. GWM evaluates a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. GWM also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. GWM continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. GWM seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. SMART Investing Solutions The SMART (Sustainability Metrics Applied to Risk Tolerance) ® Investing Solutions is a proprietary suite of model portfolios focused on ESG (Environmental, Social and Governance) investing offered to GWM’s clients. The Firm’s investment committee oversees the investment philosophy underpinning the models as well as the policies, procedures and due diligence processes employed. Through GAM, GWM also provides its proprietary SMART® Investing Solutions Services to unaffiliated third-party advisors via sub-advisory services and other distributions channels, who provide the portfolios to their clients. GWM delivers its SMART® Investing Solutions in the following manner: Sub-Advisory Research: GWM provides the model line-up to sub-advised advisors when portfolio changes are made (i.e., at the start of the relationship or owing to a rebalance). The sub-advised advisor performs all trading for the client accounts invested in the model and fulfills the duties associated with its fiduciary client relationship management. The fee for this service is 10 basis points ("bps”) per year with a minimum fee of $833.33. The fee is charged in arrears either quarterly or monthly, depending on the agreement with the sub-advised advisor. Trading Models: GWM or its partners perform all trading in the client accounts and the sub-advised advisor fulfills the duties associated with its fiduciary client relationship management. GWM charges a sub-advisory fee of 20 bps for assets sub-advised. The fee is prorated and charged monthly, in arrears, based upon the average daily balance of the assets under management during the preceding month. The fee is billed directly to the client’s account. Models with Natixis Advisors, L.P. are charged a flat fee of 70 bps, which includes GWM’s fee, the overlay fee (18 bps) and Separately Managed Account management fees ranging from 23 bps to 50 bps per annum. GWM’s fee can vary as it’s based on the remaining balance after Natixis and the Separately Managed Account management fees are covered. Investment Advisers management fees, mutual fund and ETF expenses and custodial and trading fees may also apply. A conflict of interest exists to the extent that GWM or its Supervised Persons recommend the SMART® Investing models for its own clients. GWM enters into an agreement with the Trading Platform directly or with the sub-advised advisor and the Trading Platform via a tri-party sub-advisory agreement, depending on the Trading Platform. Model Strategist Services GWM also distributes its SMART® Investing Solutions via certain platforms (i.e., Envestnet) where there is no direct relationship between the financial professional offering the portfolios to their clients and GWM. The fees earned on assets invested in SMART Investing Solutions under these arrangements is 10 basis points.