A. Firm Information Great Oak Capital Partners, LLC (“Great Oak” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the Commonwealth of Massachusetts. Great Oak was founded in June 2015 and is owned and operated by John R. Noonan III, CFP® (Principal and Chief Compliance Officer) and William R. Sylvia Jr., CFP® (Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Great Oak. B. Advisory Services Offered Great Oak offers investment advisory services to individuals, high net worth individuals, trusts, estates and retirement plans (each referred to as a “Client”). The Advisor acts as a fiduciary to its Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Great Oak’s fiduciary commitment to each Client is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Great Oak may provide Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. Financial planning services may also be offered on a stand-alone basis. Investment Management Services – Great Oak provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and financial planning services. Great Oak works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. Great Oak will then construct a portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Great Oak’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client. Great Oak will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client based on their meetings with the Advisor. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Great Oak evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Great Oak recommends, on occasion: redistributing investment allocations to diversify the portfolio; adding specific positions to increase asset class weightings; selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based Page 5 account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will Great Oak accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client wealth management agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services – Great Oak will typically provide a variety of financial planning services to Clients, either as a component of wealth management or pursuant to the terms and scope of a stand-alone financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings

and/or charitable giving programs. Great Oak may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, which would pose a conflict, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Great Oak provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services Great Oak also provides Communication and Education to the Plan Participants, pursuant to the terms of the Advisor’s agreement with each Plan Sponsor:
• Investment Education Page 6
• Periodic On-Site Advisor Visits with Staff for Account Updates and Reviews
• Periodic Plan Participant Group Education Opportunities These services are provided by Great Oak serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description Great Oak’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Sub-Advisory Management Services The Advisor may also act as a sub-adviser to unaffiliated third party investment advisors whereby such third parties engage Great Oak for the purpose of managing all, or a portion of, the unaffiliated advisor's client assets ("outside accounts"). The third party advisor will remain as the Primary Advisor for its client accounts. Under such arrangements, Great Oak provides discretionary asset management services, where the management services provided to the outside accounts are based upon established model portfolios or strategies which correlate to specific investment objectives and risk tolerance levels. The model portfolio allocations will be constructed and maintained to provide investment objective driven management services to investors. Great Oak will monitor the investments contained in the accounts in order to provide on-going supervision as to changes in the investments, and/or allocations of such investments, that are necessary to adhere to the desired investment objective. Subject to any written guidelines that the investor may provide, Great Oak will be granted discretion and authority to manage the outside accounts. Accordingly, the Advisor is authorized to perform various functions, at the investor's expense, without further approval from the investor. Such functions include the determination of the type and amount of securities to be purchased and/or sold. Great Oak provides continuous supervision and re- balancing of the outside account portfolios as changes in market conditions occur. The Primary Advisor will be responsible for determining initial and on-going suitability of any of our portfolios in which to place the investor's assets. Great Oak will manage the accounts in accordance with the chosen portfolio's stated objectives and will not be responsible for determining suitability of any chosen strategy/portfolio. C. Client Account Management Prior to engaging Great Oak to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Great Oak, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Great Oak will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Great Oak will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Great Oak will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Great Oak does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Great Oak. E. Assets Under Management As of December 31, 2023, Great Oak manages approximately $320,516,393 in Client Assets, $308,058,063 of which are managed on a discretionary basis and $12,458,330 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Page 7