NWM is registered with the U.S. Securities and Exchange Commission (“SEC”) and makes counseling, including financial planning, investment management and retirement plan advisory services available to a wide variety of clients. NWM has been registered as an investment adviser since 2010. NWM is wholly owned by Northwest Financial Corp. Northwest Financial Corp. is owned by Dwight Conover and Cornelius B. Conover IV. NWM does not control any other firm. As of December 31, 2023, NWM managed $717,763,545 on a discretionary basis, $0 on a non-discretionary basis and advised on $85,667,950 of self-directed retirement account assets. NWM’s Investment Adviser Representatives, Wealth Advisors, and Personal Banking Specialists (herein NWM Representatives) begin each advisory service by carefully examining the client’s investment objectives and financial circumstances. During this stage, time is taken to educate clients about the various features of different types of NWM counseling or investment management services that would benefit the client. Clients are also informed about investment alternatives and investment risks to make them aware that attempting to attain a higher rate of return entails accepting higher levels of risk and the potential for loss. Once this initial evaluation is complete, NWM Representatives recommend one or more of the advisory services described below that will be provided in a manner aimed at achieving the Client’s investment or other objectives. Clients are free to contact their NWM Representative at any time. Wealth Management Services NWM offers clients portfolio management and reporting services by means of its Wealth Management Services program. Through the program, clients receive investment analysis, allocation recommendations, monthly or quarterly statements reflecting holdings and transactions, quarterly performance reports, and ongoing account monitoring services for a portfolio which may include stocks, bonds, mutual funds, exchange- traded funds, private placements, and convertible securities. NWM will exercise discretionary trading authority while providing these services. This means that NWM Representatives will have authority to purchase and sell any securities at their discretion in the amounts and at the times they deem suitable for a client’s account. NWM may also recommend the use of third-party investment managers to manage all, or a portion of the assets. Such managers will be granted limited discretionary trading authority. For more information regarding third-party investment managers, please see Item 10 - Other Financial Industry Activities and Affiliations. The initial asset allocation recommendations are based on the financial information gathered from each client at the onset of the relationship. This includes information on net worth, risk tolerance, financial goals and objectives, investment restrictions and overall financial conditions. Based on this information, the client is provided with investment recommendations designed to provide an appropriate asset mix consistent with the client’s objectives. The client’s portfolio and its performance are monitored by the client’s Representative considering the client’s stated goals, objectives and investment restrictions. The frequency of these reviews is determined by the Representative and will be at least annually. NWM Representatives meet with the client on an as needed basis to discuss the portfolio and other aspects of the service. NWM typically recommends that investment management clients use the custody and transaction services of Charles Schwab. Charles Schwab provides custody services, processes transaction orders for client accounts, prepares monthly or quarterly account activity statements, and facilitates the payment of advisory fees due to NWM and any retained third-party managers. Clients should be aware that Representatives may make different recommendations and effect different trades with respect to the same securities and insurance to different advisory clients. While these costs may not be better than the commissions or execution available if the client used another brokerage firm, NWM Believes that the overall level of services and support provided to the client by recommended custodians and broker-dealers outweighs the potentially lower costs that may be available from other brokerage services providers. As a general rule, NWM believes that investing is best suited to those who believe in a long-term buy-and-hold policy. Therefore, clients should not expect frequent investment changes in the portfolio. However, as a result of monitoring the account, portfolio modifications may be advisable and made accordingly. Brokerage commissions will be charged for transactions by the brokerage firm processing the transactions. Selection of Independent Managers NWM may retain third-party investment advisers to manage a portion of the clients’ assets. Pursuant to the terms of the investment advisory agreement, NWM will have the discretion to hire and terminate these third- party advisers. NWM will provide independent managers objective and background information about the client at account inception, and thereafter as changes to such information is provided to NWM by a client. Pursuant to its discretionary authority granted by the client in the Investment Advisory Agreement, NWM may retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Fixed Income Investment Policy Statement. The fixed income manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The fixed income manager will obtain NWM’s consent prior to the sale of any client securities. Additionally, NWM may allocate a portion of a portfolio to an independent third-party investment advisor (“Independent Manager”) for separate account management based upon individual client circumstances and objectives, including, but not limited to, client account size and tax circumstances. Pursuant to the terms of the investment advisory agreement, NWM shall have the discretion to appoint and terminate these third- party advisers. The specific terms and conditions under which a client engages an Independent Manager may also be set forth in a separate written agreement with the designated Independent Manager. However, not all Independent Managers require a separate advisory agreement with the designated Independent Manager. Disclosure of the use of an Independent Manager and their additional fees will be provided to clients. Independent Managers utilized by NWM include BSP, Dimensional Funds Advisors and Parametric. Counseling and Financial Planning Services

In designing a project or comprehensive financial plan, regardless of the complexity, Representatives will:  Interview the client, analyze the client’s financial needs and assist the client in developing realistic goals and objectives based on information provided by the client. The Representative may also clarify planning problems and outline strategies designed to meet the client’s goals. A client may retain NWM to perform a single nonrecurring project, such as basic investment research or specific investment advice, retirement planning or insurance analysis, or a comprehensive plan covering these and other financial subjects. A client may also engage a Representative for projects that may require annual or more frequent reviews if more complex long-term planning is needed.  Prepare an initial written project or comprehensive plan in the scope requested by a client based on the information gathered during the client interview and needs evaluation. This plan may include establishing a clear set of objectives, an outline of resources, a written investment policy statement, an asset allocation model, strategy recommendations, retirement, estate, education, or insurance planning, product recommendations, and steps to take for implementing advice provided.  Help the client implement the plan, including purchasing and/or selling securities and/or insurance products.  Review the plan periodically in the scope and frequency agreed upon with the client. The Representative may also, as needed, recommend changes to the client’s investment portfolio or Plan, either in writing or verbally. Changes in the client’s financial condition, personal circumstances, goals, or general economic conditions may trigger changes in the plan. To the extent material changes have occurred to a client’s circumstances or goals, or to the extent a client requests a new project, the client will be asked to sign a new Service Agreement. The client may initiate contact with the client’s Representative as often as needed and the Representative will schedule conferences as needed, usually no less than annually. All planning is based on information provided by the client. It is the client’s responsibility to be certain NWM has current and accurate information for the initial plan and it is the client’s responsibility to inform the Representative of material changes affecting the investments and planning strategies implemented. Retirement Plan Advisory Services NWM may enter into agreements with employers that provide qualified retirement plans (“Plans”) with various advisory services in a 3(21) fiduciary capacity. NWM will act in a 3(21) fiduciary capacity and typically provides the following services: 1. Provide investment advice to the Employer at a Plan Level. 2. Deliver a report at least annually to the Plan which includes a review of the Plan’s Investment Policy Statement, including assessing the following: a. The criteria for selecting money managers and the due diligence procedures that the Plan followed in selecting its money managers and/or mutual funds; b. The basis for asset mix and rebalancing limits; c. The performance measurement criteria; d. Monitoring procedures of money managers and other investment-related venders; e. Composition and relevancy of quarterly performance reports; f. Composition of custodial reports; and g. Termination procedures for money managers. 3. Review of providers (custodians and recordkeeping) available to the Plan including: a. The capabilities of various providers; b. The performance record of various providers; c. The scope of investment choices at various providers; and d. The cost of various providers. 4. Review of the Plan’s overall investment activities for possible conflicts of interests or prohibited transactions by the fiduciary, money managers and/or consultants. 5. Advise Plan about mutual funds and other investment alternatives that are consistent with the investment categories allowable under the Plan; 6. Meet with representatives of Plan, at intervals mutually acceptable to Plan and NWM, to discuss the Plan's investment performance and investment selections; 7. Monitor investments in the Plan’s accounts with account custodians (each, an "Account”) and change investment selections as NWM deems appropriate. Client hereby grants NWM limited discretionary authority and appoints NWM as agent and attorney-in-fact with respect to each Account. Pursuant to such authorization, NWM may, in its sole discretion and at Plan’s risk, open brokerage and custodial accounts and accounts with third-party investment managers, purchase, sell, exchange, convert and otherwise trade in the securities and other investments in an Account on such markets, at such prices and at such commission as NWM believes to be in the best interest of the Account. NWM shall also have authority to arrange for delivery and payment in connection with transactions for each Account, and act on behalf of Client and in all other matters necessary or incidental to the handling of the Account. This authorization does not grant NWM or any third-party manager permission to take delivery or possession of Plan’s funds or securities except for fees due NWM; 8. Prepare written performance and other reports in the scope and at the times mutually agreed upon between Plan and NWM; 9. Conduct informational/educational group meetings with Plan participants at initial installation of the Plan, and periodically thereafter in the scope and frequency mutually agreed upon between Client and NWM regarding: a. General investment concepts; b. Investment objectives and performance of selected investments; and c. Investment allocations and strategies available to meet various investment objectives; 10. Provide individual counseling to Plan participants in the scope and at the times mutually agreed upon between Client and NWM. Such counseling shall not include specific investment recommendations to any participant For certain retirement plans, NWM mainly works in coordination and support with other retirement plan platforms (collectively “platforms”). Retirement plan clients will engage both NWM and platforms. Platforms will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. All advice provided by NWM and NWM Representatives is based upon the reliability of the information provided to NWM by the Plan and its participants. Either the client or NWM may at any time request an audit of the Plan by an independent certified public accountant, the fee for such audit will be paid by the party making the audit request.