Bryn Mawr Capital Management, LLC (“BMCM”) (formerly named WSFS Capital Management, LLC d/b/a West Capital Management) was formed in 2016 to offer a variety of investment advisory services, including financial planning and investment management. It is a wholly-owned subsidiary of WSFS Financial Corporation (“WSFS”). WSFS is a publicly-held bank holding company. BMCM provides financial planning, consulting, and investment management services. The firm works with its clients to develop a wealth plan that is customized to the clients’ goals and investment objectives. Prior to engaging BMCM to provide investment advisory services, the client is required to enter into a written agreement with BMCM setting forth the terms and conditions under which BMCM renders its services (the “Agreement”). In addition, BMCM serves as sub-adviser, providing investment management services to certain accounts at WSFS Bank’s Wealth division and other unaffiliated trust companies and/or SEC registered investment advisers. BMCM manages these accounts in accordance with the investment policy statement provided to BMCM by WSFS Bank, other trust companies and/or registered investment advisers. As of the close of business on December 31, 2023, BMCM had regulatory assets under management of $3,035,760,870of which $2,908,146,729were managed on a discretionary basis and $127,614,141 were managed on a non-discretionary basis. In addition, BMCM had assets under advisement totaling $360,524,594. Co-Advisory Relationship with WSFS Bank On January 25, 2019, we entered into a co-advisory relationship with our affiliate, WSFS Bank, under which WSFS Bank can recommend that a prospective advisory client enter into a tri-party investment advisory agreement between WSFS Bank, us and the client. In this arrangement, WSFS Bank provides certain non-discretionary advisory and other services to the co-advised client, and BMCM provides ongoing discretionary advisory services to the client. More specifically, WSFS Bank conducts an assessment of a prospective client’s needs to determine whether professional money management services are appropriate for clients, and whether BMCM would be an appropriate adviser for prospective advisory clients. At the onset of the relationship, the potential co-advised client will receive and sign a disclosure statement. The disclosure statement describes the terms of compensation WSFS Bank will receive, acknowledges the receipt and review of BMCM’s Form ADV Part 2A, 2B, and Form CRS and acknowledges the receipt and review of BMCM’s and WSFS’s privacy policy. WSFS Bank is required to complete an assessment of each co-advised client. In addition, each co-advised client is required to enter into a tri- party Investment Advisory Agreement with WSFS Bank and BMCM. Under this agreement, BMCM is responsible for investing and reinvesting the client’s assets, on a discretionary basis. Co-advised clients are permitted to impose reasonable restrictions on the management of their advisory accounts. In addition, co-advised clients are responsible for informing BMCM when changes occur in a client’s personal or financial circumstances that may have a bearing on the manner in which assets are invested. WSFS Bank is responsible for attempting to contact co-advised clients to discuss a client’s satisfaction with, and the suitability of, the services provided by us within 90 days from acceptance of the Investment Advisory Agreement and relevant disclosures and at least annually thereafter. Investment Management Services Clients can engage BMCM to manage all or a portion of their assets on a discretionary or non- discretionary basis. As part of these services, BMCM provides its clients with certain financial planning or consulting services based on the clients’ needs. These financial planning and consulting services typically include services such as estate planning, retirement planning, investments, education, and cash flow needs of the client. As detailed in Item 8, the firm allocates clients’ investment management assets among Independent Managers (as defined below) and various investment strategies in accordance with the investment objectives of the client. However, BMCM can provide advice about any type of investment held in clients' portfolios. If appropriate, BMCM may recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, and/or pooled investment vehicles when consistent with the clients’ investment objectives. BMCM utilizes various alternative platform providers, when appropriate, to assist in the selection of privately offered securities (please see Item 8 for more detail). BMCM tailors its advisory services to the individual needs of clients. As detailed in Item 8, BMCM consults with clients initially and on an ongoing basis to develop an investment policy statement which determines risk tolerance, time horizon and other factors that may impact the clients’ investment needs. BMCM ensures that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. Clients are advised to notify BMCM promptly if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon BMCM’s management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in BMCM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Discretionary Participant Account Management As part of our Investment Management services, we utilize a third-party platform to facilitate the discretionary management of held away assets such as defined contribution plan participant accounts. Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize losses during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Use of Independent Managers As mentioned above, BMCM determines if it is appropriate for clients to authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between BMCM and the client under which BMCM is authorized to designate Independent Manager(s). BMCM provides the service of selecting Independent Managers. BMCM also monitors and reviews the account performance and the client’s investment objectives. In addition to BMCM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than BMCM. In such instances, BMCM will likely alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Financial Planning Through the financial planning process, we work with our clients to determine their short-term and long- term goals. We recognize that each client has unique circumstances, so our team provides tailored financial planning ideas and strategies. Our focus encompasses various aspects of the client’s financial well-being, including estate planning, income tax management, charitable giving, cash flow, wealth transfer, and family legacy objectives. If you choose to utilize our financial planning services, we will conduct a meeting to gather information about your financial circumstances and objectives. We may use financial planning software to analyze your current financial position and define your long-term goals and objectives, both financial and non- financial. From there, we will develop shorter-term, targeted objectives to support your overall financial strategy. To ensure a coordinated effort toward achieving your stated goals, our team may collaborate with your other advisors, such as CPAs, enrolled agents, estate planning attorneys, and insurance brokers. We believe in providing you with a holistic view of your financial situation, whether it's through specific goal- oriented reports, general investment and planning recommendations, guidance on outside assets, or periodic updates. Our financial planning services may include: 1. Reviewing and clarifying your financial goals. 2. Assessing your overall financial position, including cash flow, balance sheet, investment strategy, risk management, and estate planning. 3. Developing a unique plan for each goal you have, whether it's related to personal or business real estate, education, retirement, charitable giving, estate planning, business succession, or other personal goals. 4. Creating a goal-oriented investment plan in consultation with

various advisors, considering tax implications, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable accounts, and trust accounts that require special attention. 5. Designing a risk management plan that aligns with your risk tolerance and includes strategies for risk avoidance, mitigation, and transfer. This plan also considers liquidity and explores various insurance options and potential company benefits. 6. Crafting and implementing an estate plan, in conjunction with your estate and/or corporate attorneys as tax advisors, to provide for you and/or your heirs in the event of incapacity or death. Once we have reviewed and analyzed the information you provide, we will present you with a written plan designed to help you achieve your stated financial goals. The financial plan is based on the information available at the time of presentation and the data you provide to us. If your financial situation, goals, objectives, or needs change, please inform us promptly. The financial plan will be reviewed in accordance with the terms of the Financial Planning Agreement. You are not obligated to act on any of our financial planning recommendations. If you choose to implement any of our recommendations, you are free to do so through any brokerage firm of your preference, and you are not obligated to use our other investment advisory services. Retirement Plan Fiduciary and Advisor Services BMCM provides qualified plan management and monitoring services for a fee, based on the size of the plan assets. The services include, but are not limited to, assisting with the Investment Policy Statement, providing a screened list of fund choices, providing asset allocation models, monitoring the fund selections on a quarterly basis, document fund monitoring process and educating employees. Implementation of the specific investment allocation for participants remains with each participant. As a result of the recent regulations promulgated by the Department of Labor, which interpret the Employee Retirement Income Security Act (ERISA), there are choices when it comes to the fiduciary responsibilities for managing your company’s retirement plan. It is crucial that plan sponsors and trustees have a good understanding of the different types of financial advisers who can service their retirement plan and provide protection for all plan participants. BMCM offers two different options for managing a company’s retirement plan: 1. 3(38) Fiduciary Investment Manager 2. 3(21) Fiduciary Investment Adviser There is a distinct difference between a 3(38)-fiduciary investment manager and a 3(21)-retirement plan fiduciary. BMCM can be hired in either capacity through our registered investment adviser (RIA) structure, so the arrangement chosen is dependent upon the type of relationship you desire. 3(38) Fiduciary Investment Management Services Under this arrangement, BMCM is appointed by the plan sponsor or trustee and accepts discretion over plan assets and assumes full responsibility for the fiduciary functions concerning decisions related to the plan investment selections. As a 3(38)-investment manager, BMCM has the responsibility and authority to select the investment options for the plan and decide if and when to make changes to the plan investments. If selected as a 3(38)-investment manager, our services are as follows: 1. Be responsible for the selection of plan investments 2. Have discretionary authority to determine the core investment options and qualified default investment alternatives under the plan; and 3. Provide asset allocation portfolios to participants reflecting a range of risk and potential return characteristics. These portfolios are updated by BMCM on a discretionary basis and traded accordingly. 3(21) Fiduciary Investment Advisory Services A 3(21)-retirement plan fiduciary adviser is appointed by the plan sponsor or trustee to act in a co-fiduciary capacity. Through the 3(21) arrangement the plan sponsor or trustee and 3(21) fiduciary adviser share responsibility and accountability for the investment decisions made at the plan level. When the plan sponsor is provided with investment recommendations from the 3(21) adviser, the plan sponsor can agree or disagree with the recommendation. Under this arrangement, the plan sponsor is legally responsible and liable for the decision of whether to implement that advice. If selected as a 3(21)-fiduciary adviser, our services are as follows: 1. Assist in the development and/or review of an investment policy statement (IPS) 2. Assist in the evaluation, selection, and monitoring of plan investments, core options, and qualified default investment alternatives, if applicable; 3. Provide periodic reports to the sponsor regarding the performance of investments and related fees, compared with applicable benchmarks and peer groups; and 4. Provide investment options to the plan sponsor. 5. Should investment changes occur in accordance with an Investment Policy Statement procedure, notices are sent to plan participants notifying them of the upcoming change by the plan administrator and the participant can go into their account and make investment changes, at any time. The plan sponsor remains responsible for selecting investments and investment options under the plan, and the participant shall remain responsible for making investment decisions regarding his/her accounts from among the options permitted under the plan. Plan Consulting Services We offer Plan Consulting services which may include, but is not limited to, Service Provider Liaison; Education Services to Plan Committee; Participant Enrollment; Plan Education; Plan Search Support/Vendor Analysis; Benchmarking Services; and Assistance Identifying Plan Fees. The specific services to be provided will be documented and agreed upon in the Plan Consulting Agreement. Disclosure Regarding Rollover Recommendations A client or prospect 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) rollover 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). Our firm may recommend an investor roll over plan assets to an IRA for which our firm provides investment advisory services. As a result, our firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our firm. Our firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations are also reviewed by our firm’s Chief Compliance Officer in a best effort to determine that the recommendation to a client was reasonable or that the client has determined to make the rollover after being provided ample information about their options. No client is under any obligation to roll over plan assets to an IRA advised by our firm or to engage our firm to monitor and/or advise on the account while maintained with the client's employer. Our firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding this disclosure. Acknowledgment of Fiduciary Status 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 interest 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.