Firm Description G&S Capital LLC (“G&S”) was founded in 2005 and became registered as an investment advisor in 2014. Justin L. Soucie is the sole owner. Types of Advisory Services The client can engage G&S to provide discretionary investment advisory services to individuals, families, businesses, and retirement plans (see below). Before engaging G&S to provide investment advisory services, clients are required to enter into an agreement with G&S setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fees that a client will incur (see fee schedule at Item 5 below). To the extent specifically requested by an individual client, G&S will generally provide financial planning and consulting services. In the event that the client requires extraordinary planning or consultation services G&S may determine to charge a client for such additional services pursuant to a stand-alone written agreement (see Limitations below). G&S provides investment advisory services specific to the needs of each client. Before providing investment advisory services, G&S will ascertain the client’s investment objective(s). G&S will then allocate (or recommend that the client allocate) the portfolio consistent with the designated investment objective(s). ASSET MANAGEMENT G&S offers discretionary direct asset management services to advisory clients. G&S will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The client will authorize G&S discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. ASSETS HELD AWAY G&S offers discretionary or non-discretionary asset management service to individuals with respect to assets held in retirement plan accounts and/or variable annuities. G&S will work with individuals on determining their individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, and asset allocation are based on the above factors. The accounts will be monitored on a quarterly basis. ERISA PLAN SERVICES G&S may be engaged to provide investment advisory services to ERISA retirement plans, whereby G&S shall manage Plan assets consistent with the investment objective designated by the Plan sponsor. In such engagements, G&S will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). G&S will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and G&S. G&S may also provide investment advisory services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between G&S and the plan. For such engagements, G&S shall assist the Plan with the selection of an investment platform from which Plan participants shall make their respective investment choices, and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision- making process. Limited Scope ERISA 3(21) Fiduciary. G&S typically acts as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non- discretionary basis. As an investment advisor G&S has a fiduciary duty to act in the best interest of the client. The plan sponsor still ultimately has responsibility for the decisions made in their plan, though using G&S can help the plan sponsor delegate liability by following a diligent process. The plan sponsor can select from a menu of fiduciary and non-fiduciary services to be provided by G&S, which are detailed further below. 1. Fiduciary Services can include:  Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options.  Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.  Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. 2. Non-fiduciary Services can include:  Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands G&S’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, G&S is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. G&S will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.  Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.  Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees.  Meet with Client on a periodic basis to discuss the reports and the investment recommendations. G&S may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between G&S and Client. 3. G&S has no responsibility to provide services related to the following types of assets (“Excluded Assets”): 1. Employer securities; 2. Real estate (except for real estate funds or publicly traded REITs); 3. Stock brokerage accounts or mutual fund windows; 4. Participant loans; 5. Non-publicly traded partnership interests; 6. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or 7. Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to G&S under this arrangement. 3(38) Investment Manager. G&S can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. G&S would then retain primary responsibility for the selection, monitoring and replacement of the plan’s investment options. The menu of fiduciary and non-fiduciary services offered are described below. 1. Fiduciary Services can include:  G&S has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.  Creation of specific asset allocation models that G&S manages on a discretionary basis, which Plan participants may choose in managing their individual retirement account.  Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.  Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.  Provide discretionary investment advice to the Client with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services can include:  Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands G&S’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, G&S is not providing fiduciary advice as defined by ERISA to the Plan participants. G&S will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.  Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees.  Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.  Meet with Client on a periodic basis to discuss the reports and the investment recommendations. G&S may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between G&S and Client. 3. G&S has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Employer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or mutual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or g. Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to G&S under this arrangement. FINANCIAL PLANNING AND CONSULTING To the extent requested by a client, G&S may determine to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.). For clients receiving Asset Management services from G&S, such financial planning and/or consulting services will typically be included as part of the Asset Management service offering. However, in the event that the client requires extraordinary planning or consultation services, or if the client requests standalone financial planning and/or consulting services, G&S may determine to charge the client for such additional services pursuant to a stand-alone written agreement. In such instances, the client will compensate G&S on an hourly fee basis described in detail under “Fees and Compensation” section of this brochure. Services include but are not limited to a thorough review of all applicable topics including Wills, Estate Plan/Trusts, Investments, Taxes, and Insurance. If a conflict of interest exists between the interests of the investment advisor and the interests of the client, the client is under no obligation to act upon the investment advisor’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through G&S. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. It remains the client’s responsibility to promptly notify G&S if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising G&S’s previous recommendations and/or services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, G&S will generally provide financial planning and related consulting services regarding non-investment related matters, such

as tax planning, insurance, etc. G&S will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions may occur based upon assets under management, special projects, etc. for which G&S may charge a separate fee). G&S does not serve as an attorney, accountant or insurance agent, and no portion of our services should be construed as legal, accounting or insurance services. Accordingly, G&S does not prepare estate planning documents or tax returns, nor does it sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non- investment implementation purposes (i.e., attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from G&S and/or its representatives. If the client engages any professional, recommended or otherwise, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged professional(s), and not G&S, shall be responsible for the quality and competence of the services provided. Variable Products/Retirement Plans. G&S also may render investment advisory services to clients relative to: (1) a variable investment product that they may own, and/or (2) their individual employer-sponsored retirement plans. In so doing, G&S directs the allocation of client assets among the various investment alternatives (generally mutually funds) that comprise the variable life/annuity product or the retirement plan. The client assets shall be maintained at either the specific insurance company that issued the variable annuity product which is owned by the client, or at the custodian designated by the sponsor of the client’s retirement plan. In the event that G&S is requested to provide advisory services with respect to a variable investment product and/or retirement plan sponsored by the client’s employer, G&S’s advice is limited to the investment alternatives provided by the variable product and/or retirement plan sponsor. Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If G&S recommends that a client roll over their retirement plan assets into an account to be managed by G&S, such a recommendation creates a conflict of interest if G&S will earn new (or increase its current) compensation as a result of the rollover. If G&S provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), G&S is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by G&S, whether it is from an employer’s plan or an existing IRA. Authorized Agents. In an attempt to enhance services to its clients, G&S has entered into an arrangement with an unaffiliated registered investment adviser (TKG Advisors, LLC d/b/a Kotys Wealth Professionals; CRD: 168156) (“Kotys”) for the provision of certain back-office services. Pursuant to this arrangement, certain representatives of Kotys have executed documents to become authorized agents of G&S. This arrangement gives such Kotys representatives the ability to implement trades on behalf of G&S, at G&S’s direction. Per the terms of this arrangement, no representative of Kotys is entitled to make any investment decisions or trades on behalf of any G&S client without prior instruction from an appropriate G&S representative. Cash Positions. G&S continues to treat cash as an asset class. As such, unless determined to the contrary by G&S, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating G&S’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), G&S may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, G&S’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion G&S shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless G&S reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a G&S actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any G&S unmanaged accounts. Independent Managers. G&S may allocate a portion of the client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets, including, to the extent applicable, proxy voting responsibility. G&S shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that G&S shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note. The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, G&S’s investment advisory fee disclosed at Item 5 below. Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by G&S independent of engaging G&S as an investment advisor. However, if a prospective client determines to do so, he/she will not receive G&S’ initial and ongoing investment advisory services. Portfolio Activity. G&S has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, G&S will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when G&S determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by G&S will be profitable or equal any specific performance level(s). eMoney Advisor Platform. G&S may provide its clients with access to one or more online account aggregation platforms (the “Platforms”). The Platforms allow a client to view their complete asset allocation, including those assets that G&S does not manage (the “Excluded Assets”). G&S does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, G&S shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not G&S, shall be exclusively responsible for such investment performance. The client may choose to engage G&S to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between G&S and the client. In addition to the foregoing, the Platform hosted by eMoney Advisor (“eMoney”) also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by G&S. Finally, G&S shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without G&S’s assistance or oversight. Client Obligations. In performing our services, G&S shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify G&S if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that G&S and its third- party service providers use to provide services to G&S clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in G&S’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and G&S are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although G&S has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that G&S does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by G&S) will be profitable or equal any specific performance level(s). Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent. Wrap Fee Programs G&S does not sponsor any wrap fee programs. Client Assets under Management As of December 31, 2023 G&S has approximately $338,004,600 in discretionary assets under management.