Description of Advisory Firm Piedmont Capital Management, LLC ("PCM" or the “firm”) is a North Carolina Limited Liability Company that was formed in 2010 and began operating in late-2011. PCM operates alongside Piedmont Trust Company (“PTC”), a state-chartered trust company organized in 2004. PTC provides PCM with certain administrative and support services relating to operational, technology and general office support pursuant to a written agreement. PCM is wholly owned by Piedmont Financial LLC (“PF”). PF is solely owned by Richardson Corporation. Since 1928, PTC and predecessor entities have served as the family office of the Richardson family. PCM was formed to offer additional investment advisory services to members of the founding family and to other compatible high net worth families. PCM benefits through its employees from over eight decades of experience providing sophisticated wealth management and customizes its advisory services to meet the needs of each client family. PCM seeks to thoroughly understand each client’s goals and objectives including certain restrictions clients may wish to place on the investment process, such as social or environmental restrictions. At the option of the client, PCM will develop a customized Investment Policy Statement. PCM will employ similar investment strategies to those implemented on behalf of PTC clients, including utilizing the services of third-party investment managers and consultants. Advisory Services Offered PCM provides investment management to its clients on a discretionary basis. PCM may implement its clients’ investment strategies via mutual funds, ETFs and other securities that are selected by PCM. For some clients, additional financial consulting and advice may be provided in conjunction with discretionary investment management. PCM manages some of its client assets in separately managed accounts. In general, pursuant to its standard investment management agreement, PCM will be authorized to exercise its best judgment in investing, reinvesting

and selling the cash and other securities in each separately managed account in its discretion, as well as through any of its outside managers. Piedmont Partners Fund PCM will also provide investment management services and related administrative services to the Piedmont Partners Fund, LLC, (the “Fund”) a North Carolina limited liability company. PCM manages the Fund on a discretionary basis in accordance with the terms and conditions of the offering and organizational documents of the Fund. PCM, its affiliates and its employees, are affiliated through ownership interest or otherwise with the Fund. Investments in the Fund are only suitable for certain qualified clients. Prior to investing, investors will receive a confidential private placement memorandum, which contains detailed information about the investment, risks, fees, service providers, conflicts of interest, as well as other information. The Fund will be managed in such a way as to meet the investment goals of the Fund, rather than the individual needs of any particular investor in the Fund. PCM and its employees will devote to the Fund as much time as PCM and the employees deem necessary and appropriate. Such activities may involve substantial time and resources of PCM and could be viewed as creating a conflict of interest in that the time and effort of PCM and our employees will not be devoted exclusively to providing services to the Fund or to our other clients, but will be allocated between providing services to the Fund and our other clients. The Fund is not required to register as an investment company under the Investment Company Act of 1940 in reliance upon an exemption available to such investment partnerships whose securities are not publicly offered as well as other restrictions. Assets Under Management As of December 31, 2023, PCM had approximately $371,318,825 in assets under discretionary management. Wrap Fee Programs PCM does not participate in, nor is it a sponsor of, any wrap or bundled fee program.