The Simmons Partnership, INC (“TSP” or the “Firm”) has been in business since March 18, 2011. James Simmons is the firm’s owner. Mr. Simmons has been in the business of providing investment advice to clients for over 20 years. The Simmons Partnership, INC provides personalized financial planning and/or investment management services. Clients advised may include individuals, trusts, foundations, pensions and corporations. Investment Advisory Services and Financial Planning The Simmons Partnership, INC works with clients to provide investment management and financial planning services. In most cases, the client will supply to TSP information including income, investments, savings, insurance, age and many other items that are helpful to the firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, we will discuss your financial needs and goals with you and compare your current financial situation with the goals you state. Once these are compared, TSP will typically create a holistic investment program that includes a financial plan to help you meet your goals. The plan is intended to be a suggested blueprint of how to meet your goals. Not every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by you, it is very important that you accurately and completely communicate to us the information we need. Also, your personal life may change as your engagement with us progresses. It is very important that you continually update us with any changes so that if the updates require changes to your plan, we can make those changes. Otherwise, your plan may no longer be accurate. Once you have your financial plan, the decision is yours how to implement it. If you decide to implement your financial plan through TSP, you will become an asset management client. If you request, TSP may recommend the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from TSP. If you engage any professional recommended by TSP and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Asset Management TSP requires each client seeking investment management services to place at least $250,000 with us. We may waive this account minimum under certain circumstances, in our discretion. If you wish us to manage your investment accounts, we will ask you to provide us with investment guidelines, so that we can create asset allocations that meet your needs. These guidelines can be developed with our help, or you can create them yourself. Some examples of guidelines include your risk tolerance, or a maximum amount of assets to be held in non-U.S. investments, or a limit on the amount of stocks in your portfolio. Asset management services may be provided on either a “discretionary” or “non-discretionary” basis. When TSP is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive quarterly statements from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over trading in the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and TSP. When a client engages us to provide investment management services on a non-discretionary basis, we monitor the accounts in the same way as for discretionary services. The difference is that changes to your account will not be made until we have confirmed with you (either verbally or in writing) that our proposed change is acceptable to you. When recommending mutual funds that have multiple share classes, TSP will take into account the internal fees and expenses associated with each share class and select the most cost-effective share class that still meets the client’s needs and objectives and is available to the client. Retirement Plan Consulting Services The fiduciaries of self-directed retirement plans (which can include 401(k) plans) are required to, among other things, determine

a selection of investments from which the plan’s participants choose for their personal allocation in their individual participant account. TSP may provide assistance to plan sponsors in meeting this obligation through a consultative relationship including the selection of the plan investment options in accordance with the plan’s objectives, as well as the ongoing monitoring of those options to assist the plan sponsor in determining when changes to these options are needed. This advice is rendered on a non- discretionary basis, meaning the plan sponsor is free to accept or reject TSP’s recommendations. In addition, if requested by the plan sponsor, TSP may offer education to plan participants by providing educational workshops or seminars. TSP may also assist with the review of plan service providers. Wrap Program For some clients, TSP may include certain transactional costs in the client’s management fee. This arrangement is referred to a “Wrap Program”. For accounts in the Wrap Program, TSP pays a fee to Schwab Advisor Services based on the clients’ transaction costs. Fees included in the wrap fee include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark- downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than Schwab Advisor Services. Expenses for the management fees of third- party managers are also not included in the Wrap Program, and to the extent utilized, you will be responsible for such fees. Because TSP will be managing the assets of wrap fee program clients the same way as other non-wrap fee program clients, the use of external portfolio managers within the wrap program is expected to be limited. To the extent a third-party manager is utilized, the fees payable to such managers will not be included in the wrap program. Therefore, there is no difference between how TSP manages wrap free accounts and how TSP manages other accounts. Because of the nature of a wrap fee program, where wrap fees are not tied to an account’s frequency of trading and apply to generally all assets in the account, the wrap fee program client may pay more or less than if the client had compensated TSP outside of the wrap fee program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. Clients whose accounts will be rarely traded should. carefully consider whether the Wrap Program is appropriate. Clients are not required to participate in the Wrap Program. TSP receives a portion of the wrap fee for our services. While TSP recommends that most clients participate in the Wrap Program, not all clients participate. Examples of reasons a client may not participate include smaller account sizes or client preference. TSP does not engage other portfolio managers to manage assets within the wrap fee program. To the extent a third-party manager is utilized, the fees payable to such managers will not be included in the wrap program. TSP is the sole portfolio manager in the wrap program, which means that TSP receives a portion of the wrap fee for our services. Transaction fees are paid to various broker-dealers, mutual funds and ETFs. The remainder of the wrap fee is the management fee payable to TSP. As discussed more fully in the wrap brochure, the transaction fees paid to Schwab are based on a fixed rate that is based on the total amount of assets TSP clients have in custody with Schwab, where the rate drops as the amount of assets in custody increase. Accordingly, TSP does not receive greater compensation for placing or not placing trades. However, TSP does have an incentive to recommend Schwab to clients in order to reduce the fixed fee for transactions. TSP attempts to mitigate this conflict by requiring that the firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own, evaluating all aspects, including the wrap program asset-based transaction pricing when considering what broker-dealers to recommend. TSP will receive no additional compensation for offering the wrap fee program. Please see the separate Wrap Fee Brochure for a more complete description of the Wrap Program. Assets under Management As of December 29, 2024, TSP has 742 accounts and $154,349,434 assets under management. Of these totals, TSP manages 448 accounts and $112,699,239 on a discretionary basis and 294 accounts and $112,699,239 on a non-discretionary basis. Assets under Advisement As of December 29, 2024, through ongoing consulting and planning services, TSP has an additional $45,823,331 of assets under advisement. An asset under advisement means assets of our clients for which we provide recommendations but do not implement those recommendations.