Navigation Group (“the Adviser”) has been in business since 1998. Carlo A. Panaccione and Erik S. Davis are the principal owners. Assets Under Management As of December 31, 2023, the Adviser manages $644,159,328 on a discretionary basis. 1. Wealth Planning A. Wealth Planning When completing a comprehensive wealth plan, all or some of the following areas may be included: Financial Position The Adviser will work with clients to analyze their current net worth (assets and liabilities) and cash flow (income and expenses) and recommend specific courses of action to facilitate the funding of various financial goals and objectives. Investment Planning and Portfolio Analysis The Adviser will evaluate a client’s investment goals, concerns, risk profile and current portfolio holdings to assess if the strategies and goals are compatible. The Adviser will prepare an asset allocation analysis and create a strategy consistent with a client’s risk tolerance and incorporate the parameters and constraints that govern the management of their portfolio. The Adviser will manage the implementation of the strategy. Risk Management The Adviser will evaluate a client’s insurance needs, including life, disability and long-term care and will analyze the adequacy of their current insurance coverage. The Adviser will provide recommendations. The Adviser will provide recommendations designed to help a client’s insurance program minimize the financial risk to their assets and protect against insurable losses. Financial Independence The Adviser will use available data and assumptions to project the savings and investment amounts a client will need to achieve their retirement goals and maintain financial independence. The Adviser will analyze a client’s goals with respect to inflation and the assumed rates of return, and also assist with coordinating their savings plan, asset allocation and investment strategy. Executive Benefit and Retirement Plan Analysis The Adviser will analyze savings plans, stock options, restrictive stock agreements, retirement plans, payout alternatives and payout timing choices to develop strategies to potentially minimize tax consequences. The Adviser will harmonize a client’s employee benefits, overall asset allocation strategy and financial goals. Education Funding The Adviser will assist clients with determining how much is needed to provide funding for educational expenses. Income Tax Planning The Adviser will work with a client’s tax consultants to make recommendations that are designed to help achieve longer term goals while attempting to minimize federal and state tax liabilities. Estate Planning The Adviser will work with a client’s estate planning attorney to develop and implement a comprehensive estate plan to distribute assets according to their wishes, in the manner the client deems appropriate. The plan may address creating wills, revocable living trusts, irrevocable life insurance trusts, family limited partnerships, durable powers of attorney, health care powers of attorney and other estate planning techniques to meet the client’s objectives. This type of planning requires coordination with a client’s attorney to properly title assets and designate beneficiaries so that a client may benefit from actions that are allowable under estate tax law to minimize their estate tax liability. Family Meetings In an effort to help a client communicate their overall financial and estate planning wishes to their family a client may choose to have the Adviser help facilitate a “Family Wealth Meeting”. Wealth Planning Conflicts of Interest When multiple services are offered, there is an incentive for the Adviser offering wealth planning services to recommend products or services for which the Adviser, or a related party, may receive compensation. A conflict of interest is created whenever the Adviser or an associated person of the Adviser recommends products or services to a client for which the Adviser or an associated person receives compensation. However, wealth planning clients are under no obligation to act upon any recommendations of the Adviser or to execute any transactions through the Adviser if they decide to follow the recommendations. Wealth Plan Annual Review The Adviser will review and update a client’s wealth plan, financial goals,

the progress of the wealth plan and revisions to recommendations based upon a client’s financial situation. The annual review will provide a client with continued access to a personal web page. 2. Consulting Services Life Insurance Review The Adviser will evaluate existing life insurance policy or policies as part of the wealth planning process by performing the following tasks: 1. Obtain illustrations on current policies. 2. Shop the market for more effective and economical products. 3. Generate insurance policy comparisons if appropriate. 4. Work with a client to complete the application and medical underwriting processes and review the new policy or policies. Disability & Long-Term Care Review The Adviser will submit a quote request for disability and long-term care insurances as part of the wealth planning process. The Adviser will review the quotes with a client to determine the most appropriate policy terms and riders to protect their assets and meet their disability and long-term care needs. The Adviser will work with a client during the underwriting process to complete the application and fulfill the medical review requirements. The Adviser will deliver the policy and explain the coverage in detail. Estate Plan Annual Review The Adviser will review a client’s estate plan annually to make sure the plan continues to be consistent with the client’s intentions, takes advantage of available exemptions, and avoids the probate process when appropriate. Post-Mortem Services The Adviser will assist with post-death services which include, but are not limited to: preparing an asset inventory, determining the date of death asset valuations, determining alternate asset valuation dates, applying for applicable Taxpayer Identification Numbers (“TINs”), and assisting with paperwork to establish and fund a Family Trust account, Marital Trust account and/or Estate account. Family Financial Philosophy Process The Adviser will recommend an Advanced Discovery and Development meeting for a client with a net-worth that exceeds $10 million. The meeting should include all appropriate family members and be held before starting the wealth planning process. A Family Financial Philosophy is created during the meeting. It involves developing a mission statement and outlining a client’s vision, values and goals. The objective is to maximize a client’s investment in the planning process and help to clearly define what planning services may be appropriate. 3. Investment Management Services The Adviser provides investment management services to its clients on a discretionary basis. When the Adviser manages client assets on a discretionary basis, the Adviser executes securities transactions for clients without having to obtain specific client consent prior to each transaction. Discretionary authority is limited to investments within a client’s managed accounts. The Adviser provides investment management services that include, among other things, advice regarding asset allocation and the selection of investments, portfolio design, investment plan implementation and ongoing investment monitoring. The Adviser relies on the stated objectives of the client and considers the client’s risk profile and financial status prior to making any recommendations. 4. Advisory Referral Services The Adviser maintains referral agreements with third-party asset managers (other independent investment advisers). The Adviser gathers information about a client's financial and tax status and investment objectives in order to determine the client’s risk profile. Based on this analysis the Adviser assists the client in allocating assets among various third-party asset management programs. The Adviser receives compensation for introducing clients to these third-party asset managers and for certain ongoing services provided to clients. The Adviser may have an incentive to refer a client to these third-party asset managers. A conflict of interest is created whenever the Adviser or an associated person of the Adviser recommends products or services to a client for which the Adviser or an associated person receives compensation. All third-party asset managers to whom the Adviser refers a client are licensed as investment advisers by their resident states and any applicable jurisdictions or by the Securities and Exchange Commission.