Golden Eagle Capital Advisors, Inc. (“the Adviser”) has been in business since 2014. Maurizio Manzati is President, Chief Compliance Officer and 89.962% voting rights Shareholder. Maria Bravin is Director and Deputy Chief Compliance Officer. Both partners has more than 30 years of experience in financial and management consultancies. On June 15, 2023, Golden Eagle Capital Advisors completed the acquisition of all of the equity interests in Golden Eagle Securities, Inc. (“GES”). GES is an SEC registered and FINRA member Broker-Dealer incorporated in Florida. Discretionary Managed Portfolios Golden Eagle Capital Advisors offers a number of Asset Management Programs. These Asset Management Programs are managed to meet the stated objective of the Program. When clients choose an Asset Management Program, they will authorize Golden Eagle Capital Advisors and its assigned Asset Manager to make discretionary asset allocation decisions in their accounts based on the discipline and risk level of the program(s) chosen. Each Asset Manager appointed by Golden Eagle Capital Advisors offers a unique discipline of investing. Based on a preliminary Profile questionnaire completed by clients, our Advisory Representative will make a recommendation to them as to the Asset Manager, Program and risk level appropriate for them. Although the ultimate responsibility as to the management of their accounts remains with Golden Eagle Capital Advisors, Golden Eagle Capital Advisors relies on the expertise and management disciplines of its Asset Managers to manage each Program portfolio to the stated discipline and risk level. Golden Eagle Capital Advisors, however, retains the authority to modify any allocation instructions received by an Asset Manager. If an Asset Manager or Program ceases to be available or is removed from Golden Eagle Capital Advisors' offerings, Golden Eagle Capital Advisors will notify clients in writing, in advance, and if we do not hear back from them, we will move their assets within that Program to a new Asset Management Program with a commensurate level of risk. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk Loss, for a description of the primary investment strategies utilized by the Investment Management and Research Team. Golden Eagle Capital Advisors provides investment advice primarily on such investments as mutual funds, ETF’s, stocks, bonds and options. Non-Discretionary Managed Portfolios The ability to customize clients portfolio is available on GECA investment advisory platforms, for an advisory fee charged on all assets in the account, (the Asset Management Fee). Our Advisory Representative will provide one-on-one professional investment advice to help clients to choose the right investments, leaving the final investment decisions to them. Our Advisory Representative will work with clients to design a portfolio based on their investment objectives, tolerance for risk and any investment restrictions requested by them. The Adviser manages client's assets that are under custody at one of our various approved custodians and charges an annual fee (percentage of assets under management paid quarterly) for investment advice and services. ADV Part IIA 5 / 26 Rev. June 2023 Retirement Plan Consulting Program GECA offers consulting and advisory services for employer-sponsored retirement plans that are designed to assist plan sponsors of employee benefit plans (“Sponsors”). GECA may also assist Sponsors with enrollment and/or providing investment education to plan participants and beneficiaries. GECA provides these retirement plan services (“Retirement Plan Services”) through the GECA IARs and may charge

a fee for the Retirement Plan Services, as described in this Brochure and the Retirement Plan Consulting Agreement (“Agreement”). Retirement Plan Services include services that would be considered fiduciary services or non- fiduciary services under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), or comparable state laws, rules and regulations. In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of GECA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. In certain limited arrangements as agreed to in writing between a Sponsor and GECA, GECA may provide their retirement plan participants limited point-in-time advice which could also be deemed ERISA fiduciary advice. When delivering fiduciary services to a plan, GECA will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. When providing any fiduciary services to a retirement plan and/or plan Sponsor, GECA will solely be making recommendations to Sponsor and Sponsor retains full discretionary authority and control over assets of the plan. When providing any fiduciary services to a retirement plan participant in connection with Retirement Plan Services, GECA will solely be making recommendations to participant and participant retains full discretionary authority and control over asset of the participant’s account. Sponsor may engage GECA to perform the Retirement Plan Services by providing information about the plan, including the plan design, plan objectives, investment objectives, investment risk tolerance, demographics about plan participants, and third-party service providers, and by executing an Agreement. GECA will provide Sponsor a copy of this Brochure or a comparable brochure and the Agreement for review. The Agreement describes the terms of the arrangement between GECA and Sponsor, including a description of the Retirement Plan Services and the fees to be charged by GECA. By signing the Agreement, Sponsor represents that Sponsor has received sufficient information and determined that the Retirement Plan Services selected are: (i) necessary for the operation of the plan and (ii) reasonable and appropriate based upon the compensation to be paid for thenRetirement Plan Services. Sponsor must sign and submit the Agreement to GECA before GECA performs any Retirement Plan Services. A description of the Retirement Plan Services is as follows: ADV Part IIA 6 / 26 Rev. June 2023 Ø Vendor Analysis Ø Plan Participant Enrollment and Education Tracking Ø Investment Policy Statement (“IPS”) Design and Monitoring Ø Investment Management Ø Performance Reporting Ø Ongoing Investment Recommendation and Assistance Ø ERISA 404(c) Assistance Ø Benchmarking Services Other Fiduciary Services GECA offers fiduciary services under administrative agent role for non U.S. citizens or non U.S. resident aliens individuals and families, as well as estates, trusts, private foundations and other entities. These administrative activities are defined by common law, statutes, rules and regulations, or specifically by contracts, agreements or wills. The provision of these services are subject to a fiduciary standard of duty of care laid out in the US Investment Advisers Act of 1940, as amended by the "Dodd-Frank Act", related rules issued by the Securities and Exchange Commission and the U.S. prudent investor rule. Those services are provided only to GECA and its affiliates clients, former clients or person(s) to whom GECA or its shareholders are in business or personal long-term relationship with them.