OWNERSHIP/ADVISORY HISTORY Pinnacle Wealth Management Group, Inc. (“We”) is a Michigan Subchapter S Corporation. It was subsequently registered as a Michigan investment adviser in 2016. Daniel A. Cesta (“Mr. Cesta”) and Eddison C. Millington, II (“Mr. Millington”) are the owners of the firm. Additional information about Mr. Cesta and Mr. Millington can be found under Item 19. ADVISORY SERVICES OFFERED Pinnacle Wealth Management Group, Inc. provides personalized investment management services, generally on a discretionary basis. Before we enter into an advisor-client relationship, we may offer a complimentary general consultation to determine a prospective client’s needs and discuss services available that meet those needs. Only after a prospective client has had time to review our solutions/services can they determine whether a relationship might benefit them. Investment advisory services begin only after we and the client formalize the relationship with a properly executed agreement. Our advisory role. At the outset of each client relationship, Pinnacle Wealth Management Group, Inc. evaluates each client’s financial circumstances. We employ a comprehensive process that involves a thorough understanding of the client’s needs and objectives. FINANCIAL PLANNING We offer clients financial planning services to evaluate their financial situations, goals, including risk tolerance, and time horizon. Through a series of personal interviews and the use of questionnaires, the firm will collect pertinent data; identify goals, objectives, financial problems, and potential solutions. We will prepare and present specific recommendations and implement those recommendations, as agreed upon with the client. As a result of these actions, our advice may be provided on financial and cash management, risk management, estate planning, tax issues, retirement planning, educational funding, goal setting, or other needs as identified by the client and the firm. We may offer comprehensive planning services or the client may desire advice on certain planning components; the firm can tailor services as desired by the client. At the conclusion of the financial planning service, the firm will present the client with a written financial plan. PORTFOLIO MANAGEMENT We offer ongoing portfolio management services in a wrap fee program. The following is a summary of the program. For additional details please refer to our Appendix 1 – Wrap Fee Brochure. Our portfolio management services are based on the individual goals, objectives, time horizon, and risk tolerance of each client. At the outset of each relationship, we evaluate a client’s current investments with respect to their financial circumstances, risk tolerance levels and time horizon. With this information we create a customized portfolio. Our investment goal is to generate a personalized rate of return that moves the client towards their stated objectives. As you move through life’s stages, your needs, priorities, and economic environment will change and so too should your investment strategy. We will request discretionary authority from a client Pinnacle Wealth Management Group, Inc. Page 5 ADV Part 2A –3/26/2024 in order to select securities and execute transactions without permission from the client prior to each transaction. Pinnacle Wealth Management Group, Inc. bases its investment recommendations on a variety of factors including, but not limited to, performance risk, fees, tax efficiency of different investment strategies, as well as, client input and preferences regarding the strategies. During the initial review stage, which is the basis for developing an investment strategy and a wealth management plan, if desired, we set up several meetings between the relationship manager and client, and assess the following as part of the review:
• Return goals and expectations;
• Risk tolerance;
• Time horizon;
• Market outlook;
• Future planning needs. The client’s needs and objectives are documented in our client relationship management system. Clients may impose restrictions on investing in certain securities or types of securities. Based on the results of client discussions and the information provided by the client, we document the agreed upon investment strategy. In general, for some client accounts, Pinnacle Wealth Management Group, Inc. constructs client portfolios in accordance with our model strategies: Conservative, Balanced, Growth, or Income. Client portfolios are managed in accordance with the model strategy most appropriate to the client’s risk profile. All the

model strategies include some combination of equities, bonds, mutual funds, ETFs, alternative investments, and may potentially include other investment products. For other clients of Pinnacle Wealth Management Group, Inc., customized portfolios are utilized based upon the client’s needs and individual circumstances. PLATINUM PROGRAM For qualifying clients, we offer a platinum program that consists of family office services, which are designed to help clients organize their financial situations and plan for the successful transfer of wealth to the next generation in the most tax-advantageous manner. These services generally include financial planning in the following areas: Family Continuity, Estate Planning and Philanthropy – We coordinate estate and transfer planning, including trust preparation services, with outside attorneys and other professional advisors. Areas we address may include wealth preservation and distribution strategies, succession and philanthropic considerations, and entity administration and foundation management. As the client’s legal needs change, we coordinate ongoing meetings with the attorneys as needed. We annually review the client’s estate plan with the client. The attorneys’ fees are directly billed to and paid by Pinnacle Wealth Management Group, Inc. The client is not invoiced by the attorney. Pinnacle Wealth Management Group, Inc. Page 6 ADV Part 2A –3/26/2024 Ongoing Integrated Tax Assistance – Annually, we coordinate income tax planning and preparation with outside accountants. Additionally, we work with the accountants on a year around basis so they understand the client’s financial situation and goals. We assist with the preparation of any quarterly estimated taxes that may be due by the client. The accountants’ fees are directly billed to and paid by Pinnacle Wealth Management Group, Inc. The client is not invoiced by the accountant for this service. Business Consulting Services – We provide family business advisory consulting. This service may include annually coordinating the business tax returns along with annual reviews of income statements and balance sheets to look for savings and efficiencies. We also assist in structuring the transfer of the business from one generation to the next. Ongoing Financial Planning – Our firm provides broad-based financial planning designed to assist clients in developing a strategy for the successful management of income, assets and liabilities in meeting their financial goals and objectives. Areas addressed may include liability management, retirement planning, transactional planning and structure, tax minimization, and tax return preparation and representation. We meet with clients up to four times per year to review and update their financial plans. Cash Management, Record Keeping and Financial Reporting – Our firm may assist clients with the management of their financial affairs by providing cash flow planning and projections, document management, and ongoing bookkeeping services. We may also provide advice on debt structure and analysis. ASSET MONITORING SERVICE We offer an ongoing monitoring service for those assets held away from our management. These assets may include the client’s employer-sponsored retirement plan and/or the client’s investments held in personal brokerage accounts. For employer-sponsored retirement plans, Adviser will review employer-sponsored plan’s available investment options and make an asset allocation recommendation to the client. Similarly, for personal assets held away, Adviser will review the assets and propose an asset allocation. TAILORED SERVICES We tailor all our services to the client’s stated goals, needs and objectives. For our portfolio management service clients, we allow them to impose restrictions on investment in certain securities or types of securities. All restrictions must be presented to us in writing. WRAP PROGRAM We offer our portfolio management and platinum program services through a wrap fee program. Our wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than non-wrap accounts. Additional information about our model portfolios as a wrap program can be found in our Appendix 1 to the ADV Part 2A (i.e. Wrap Fee Program Brochure). Pinnacle Wealth Management Group, Inc. Page 7 ADV Part 2A –3/26/2024 CLIENT ASSETS MANAGED As of December 31, 2023, we manage $163,965,211 in client assets on a discretionary basis.