A. Firm Information High Pines Wealth Management, LLC (“High Pines” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a limited liability company (“LLC”) under the laws of the Commonwealth of Massachusetts. High Pines was founded in March 2017 and is primarily owned by James M. Gibbons. This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by High Pines. Information regarding Mr. Gibbons is included in his Form ADV 2B Brochure Supplement, which is included with this Disclosure Brochure. B. Advisory Services Offered High Pines offers wealth management services to individuals, high-net-worth individuals, trusts, estates, businesses, foundations, and endowments. (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith toward each Client and seeks to mitigate potential conflicts of interest. High Pines’ fiduciary commitment 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 High Pines may provide Clients with wealth management services, which generally include a broad range of comprehensive financial planning services in connection with discretionary and non-discretionary management of investment portfolios, pursuant to an investment advisory agreement. The investment management and financial planning services are described below. Investment Management Services – The Advisor offers investment management services either as a component of wealth management or pursuant to a standalone investment management agreement. High Pines provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. High Pines works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. After that initial meeting identifying the Client's goals, risk tolerance, and financial situation, High Pines will design a portfolio strategy utilizing one or more of the investment strategies outlined in Item 8. High Pines evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. High Pines may recommend, on occasion, redistributing investment allocations to diversify the portfolio. High Pines may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. High Pines may recommend 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 Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will High Pines 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 the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. 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 the 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 account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases 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. Financial Planning Services – The Advisor offers financial planning as a component of its wealth management services. 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, estate planning, personal savings, education savings, risk planning, insurance planning, 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, and establish education savings and/or charitable giving programs. High Pines may also refer Clients to an accountant, attorney, or other specialists as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. 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, 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 them through the Advisor. C. Client Account Management Prior to engaging High Pines to provide wealth management services, each Client is required to enter into a wealth management or investment advisory agreement with the Advisor that defines the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – High Pines, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives. ● Asset Allocation – High Pines 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 – High Pines will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – High Pines will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs High Pines does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by High Pines. E. Assets Under Management As of December 31, 20232, High Pines manages $130,429,325 in Client assets, $123,965,725 of which are managed on a discretionary basis and $6,463,600 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.