Ownership Warburton Capital Management, LLC (“Advisor” or “we”), a registered investment adviser since 2006, became an investment advisor registered with the State of Oklahoma in June 2012 and due to an increase in the assets managed by the firm we have to changed our primary regulatory authority to the U.S. Securities and Exchange Commission as of 2013. The firm is a limited liability company formed under the laws of the State of Oklahoma. The majority owners are Thomas K. Warburton and Blue Sky Bank. General Description of Primary Advisory Services We offer personalized investment advisory services including asset management and financial planning services (review and action services, newsletters). The following are brief descriptions of our primary services. A detailed description is provided in Item 5, Fees and Compensation, so that clients and prospective clients (“client” or “you”) can review the services and description of fees in a side-by-side manner. 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 and/or the Internal Revenue 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 interests 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. Asset Management We offer asset management services providing clients with continuous and on-going supervision over their accounts. This means that we will continuously monitor a client’s account and make trades in that account when necessary. Financial Planning We offer review and action services to clients also contracting for personalized wealth management services. We gather information and documentation to assess a client’s current financial situation, objectives and goals. Clients receive an oral and/or written action report that includes an analysis of the client’s assets and high-level action items to help them meet their objectives and goals. Pension Plan Consulting We offer pension consulting services to employee benefit plans based upon an analysis of the needs of the plan. These services may include an existing plan review, formation of the investment policy statement, asset allocation advice, investment performance monitoring, and/or communication and education

services where we assist the client in providing meaningful information regarding the retirement plan to its participants. However, we do not have discretion over the administration of the plan or the plan assets. Advice to plan participants is limited to general, impersonal advice. The scope of these services, the fees, and the terms of the agreement for these services are negotiated on a case-by-case basis with each client depending upon the on the complexity of the plan and the agreement with the client. The terms regarding payment of fees, termination, and refund will be clearly set forth in the agreement executed between our firm and the client. These accounts are regulated under the Employee Retirement Income Securities Act ("ERISA"). We provide consulting services to the client as described above. The client must make the ultimate decision as to retaining the services of such investment advisers as we recommend. The client is free to seek independent advice about the appropriateness of any recommended services for the plan. Limits Advice to Certain Types of Investments. We provide advice on the following types of investments:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States government securities
• Options contracts on securities and commodities
• Futures contracts on tangibles and intangibles
• Interests in partnerships investing in real estate and in oil and gas interests We reserve the right to offer advice on any investment product that is suitable for each client’s specific circumstances, needs, goals and objectives. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information. Tailor Advisor Services to Individual Needs of Clients Our services are always provided based on your specific needs. You are given the ability to impose restrictions on your accounts, including specific investment selections and sectors. However, we will not enter into an investment advisor relationship with a client whose investment objectives is considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Wrap-Fee Program versus Portfolio Management Program In traditional management programs, advisory services are provided for a fee but transaction services are billed separately on a per-transaction basis. In wrap-fee programs, advisory services and transaction services are provided for one fee. We do not act as a portfolio manager of or sponsor wrap fee programs. Client Assets Managed by Advisor The amount of client assets managed by us totaled $498.6 as of January 25, 2023. $497.7 million managed on a discretionary basis and $0.9 million on a non-discretionary basis.