Shearwater Capital, LLC (hereafter referred to as Shearwater Capital) provides investment management advice, comprehensive financial planning and investment supervisory services for individuals and families, high net worth individuals, qualified retirement plans, and trusts. Shearwater Capital was founded in 1999 by Jeffrey Brown and Eric Malden, who serve as the company’s only principal owners. The Chief Compliance Officer is Jared Meese. The company takes a scientific approach to investing with an emphasis on broad global diversification, tax efficiency and low fees. We believe that investing should involve a long-term view and that stock selection and market timing generally do not add reliable risk-adjusted returns. Returns are sought through broadly diversified portfolios of domestic and international securities whose performance is based predominantly on passive asset class exposure. Our eligible security selection focuses primarily on mutual funds and exchange-traded funds with reasonable expenses and low turnover. The asset allocation strategy for each account is tailored to meet each client’s unique financial needs. An Investment Policy Statement (IPS) is prepared/tailored for each client, whether an individual, family or organization. The IPS includes relevant background information about the client, including the client’s investment objectives, risk tolerance, investment time horizon, and unique financial circumstances. The IPS also describes an asset allocation model designed to meet these investment goals, while taking into consideration

the client’s personal characteristics and financial circumstances. The IPS is reviewed at least annually to determine if the client’s situation has changed and whether the asset allocation strategy should be changed. The IPS can also be reviewed, and modified if necessary, any time at the client’s request. Clients may impose restrictions on investing in certain securities or types of securities. When appropriate, Shearwater Capital works with new clients to develop a plan to transition from a client's existing portfolio to the desired portfolio. An Investment Management Agreement, signed by the client and a firm representative, provides Shearwater Capital with the authority to make trades on the client’s behalf. As of February 2023, about 99.5% of the firm’s clients, representing $278,452,274 dollars in assets under management, prefer to have Shearwater Capital manage their accounts according to the asset allocation strategy specified in the IPS, without direct input from the client prior to each trade. The remaining 0.5% of clients, representing $1,311,549 million dollars in assets under management, prefer to take an active role in the investment process, ranging from discussing the investment options before trades are placed to specifying which securities to buy or sell. Shearwater Capital is not an accounting firm or law firm and does not provide legal or accounting advice. Clients should seek the services of an accounting firm or law firm when necessary. Shearwater Capital, LLC 5 Form ADV Part 2A Disclosure Brochure