Pettinga is an investment advisor registered with the SEC and is a successor to Pettinga Financial Advisors, Inc., which was first registered with the SEC in 1994. Pettinga succeeded to the business of Pettinga Financial Advisors, Inc. on December 31, 2010. Assets Under Management As of December 31, 2023, Pettinga managed $974,371,136 of client assets on a discretionary basis and $28,094,765 on a non-discretionary basis. Focus Financial Partners Pettinga is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Pettinga is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with CD&R. Investment vehicles affiliated with Stone Point are indirect owners of Focus LLC. Because Pettinga is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Pettinga. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Investment Management Services Pettinga provides investment management services to clients who are primarily high net worth individuals and other individuals, as well as trusts, estates, pension and profit-sharing plans, charitable organizations and foundations, and businesses. Services are typically provided on a discretionary basis; however, the Firm’s financial advisors work with clients on a non- discretionary basis if requested. Each client works with a specific financial advisor who seeks to understand the individual client’s goals, objectives, time horizon, risk tolerance and tax position then allocates the client’s investment portfolio among various asset classes based on their understanding of these factors. The Firm’s financial advisors manage customized investment portfolios for some clients. In these instances, advisors typically invest client accounts in mutual funds and exchange traded funds. Other investment types, such as (but not limited to) investment grade fixed income securities, limited partnerships or other alternative investments, covered calls, third-party separate account managers and individual stocks, are used if the financial advisor and client agree that the asset or investment is appropriate for the client. For other clients, the Firm’s financial advisors utilize model portfolios. The development and maintenance of these models is materially supported by BlackRock Fund Advisors and/or its affiliates, including BlackRock Investments, LLC (collectively “BlackRock”), which provides the Firm with investment research, model recommendations and marketing support at no cost. Research and recommendations provided by BlackRock to Pettinga predominantly favor the use of iShares ETFs, which are distributed by BlackRock. While Pettinga is under no obligation to utilize iShares ETFs in the management of the models, such models will predominantly and sometimes exclusively utilize iShares ETFs in their construction. Further information on this conflict of interest is available in Item 10 of this Firm Brochure. Finally, we implement investment advice on behalf of certain clients in held-away accounts that are maintained by independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). Financial Planning Services Pettinga also offers financial planning services to clients. Basic financial planning services are included in the investment management services we offer to clients, for clients who are interested in the service. We offer more intensive or complex financial planning services for a separate fee. The objective of our financial planning is to review and analyze a client’s personal financial situation, prepare a comprehensive financial planning report, and make recommendations for implementing the financial plan. Our analysis and recommendations are based on information provided by the client. The initial phase of our financial planning process involves accumulating and organizing facts about a client’s financial status, identifying specific goals and objectives, and agreeing upon planning assumptions. The typical areas of discussion include (but are not limited to) retirement planning, estate planning, life insurance planning, college funding, and investment allocation analysis. After information is received, the data is analyzed, and projections are made. We then meet with the client to review their comprehensive financial planning report which contains recommendations in all relevant areas of their financial situation. If necessary, the report is amended to reflect changes or alternative courses of action. Clients are responsible for all decisions regarding implementation of the recommendations. The methods clients choose for implementing their financial planning recommendations are at their discretion. Pettinga is available to assist clients with implementation of their chosen strategies or to coordinate implementation with other financial professionals of the client’s choosing. ERISA Plan Services Pettinga provides investment management and investment advisory services to retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), including

participant-directed defined contribution plans, such as 401(k) plans and defined contribution plans that are not participant-directed (“ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an investment management or investment advisory agreement with Pettinga describing the services that Pettinga will perform for the ERISA plan and its participants. Pettinga provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. ERISA Plan Fiduciary Services: Pettinga provides fiduciary services either as a discretionary investment manager or a non-discretionary investment advisor.  ERISA Plan Investment Management Services: Pettinga provides investment management services to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA Section 3(38) and in that capacity, Pettinga’s investment decisions are made in its sole discretion with the ERISA Plan Client’s prior approval. Each ERISA Plan Client who engages Pettinga to perform investment management services is required to enter into an investment management agreement. For participant-directed ERISA Plans, Pettinga’s investment management services include selecting a broad range of investment options consistent with ERISA Section 404(c), making decisions about the selection, retention, removal and/or addition of investment options and if the ERISA Plan Client has determined that the Plan should have a qualified default investment alternative (a “QDIA”) for participants who fail to make an investment election, selecting the investment that will serve as a QDIA. For ERISA Plan Clients that are not participant-directed, Pettinga’s investment management services include developing asset allocations and portfolio modeling, selecting investments to populate the asset allocation categories, rebalancing, and making changes to the asset allocations and investments when appropriate.  ERISA Plan Investment Advisory Services: Pettinga also provides investment advisory services on a non-discretionary basis for participant-directed plans and in that capacity, the ERISA Plan Client retains, and exercises, final decision-making authority and responsibility for the implementation (or rejection) of Pettinga’s recommendations or advice. Each ERISA Plan Client who engages Pettinga to perform non-discretionary investment advisory services is required to enter into an investment advisory agreement. Pettinga’s non-discretionary advisory services for participant-directed plans include assisting the ERISA Plan Client in selecting a broad range of investment options consistent with ERISA Section 404(c), assisting the ERISA Plan Client in making decisions about the selection, retention, removal and/or addition of investment options, and if the ERISA Plan Client has determined that the plan should have a QDIA for participants who fail to make an investment election, assisting in the selection of the investment that will serve as the QDIA. Pettinga also provides asset allocation services that enable participants to allocate the money in their plan account among the plan’s designated investment alternatives. The asset allocation service is not an investment itself, but instead a service to help participants decide how to invest their plan account. ERISA Plan Non-Fiduciary Services: Pettinga’s non-fiduciary services to ERISA Plan Clients include assisting in group enrollment meetings, educating plan participants about general investment principles and in the case of participant-directed plans, educating participants about the investment options available under the plan. Retirement Account Clients/Potential for Conflict of Interest: Pettinga is a fiduciary under ERISA with respect to investment management services and investment advice provided to ERISA Plan Clients, including ERISA plan participants. Pettinga is also a fiduciary under Section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to ERISA Plan Clients, ERISA plan participants, individual retirement accounts (“IRAs”) and IRA owners. As such, Pettinga is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption. No client is under any obligation to roll over ERISA plan or IRA assets to an account advised or managed by Pettinga. Unwaivable Rights As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Client Obligations Each client retains the responsibility to promptly notify Pettinga if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, and/or revising the Firm’s previous recommendations or services. When performing requested services, Pettinga will not be required to verify any information received from the client or from the client’s other professionals. The Firm is expressly authorized to rely on such information. No Legal or Accounting Advice While employees of Pettinga may be licensed attorneys or accountants, the Firm does not provide any legal or accounting advice. Clients should seek the counsel of a qualified attorney and/or accountant when necessary.