Description of Firm We are a registered investment advisory firm that is wholly owned by Lair Hill Partners, Inc. DBA ZUNA Holdings (“ZUNA Holdings”), an Oregon Corporation. Greg Koleno and Aalok Shah (who also serves as ZUNA’s Chief Compliance Officer) own more than 25% of Lair Hill Partners, Inc. ZUNA is managed by elected managers, who are also owners of ZUNA Holdings including Carrie Hepburn. Advisory Services Offered As a registered investment advisory firm, ZUNA offers a variety of services to both corporations and non- profits through a service model that promotes both innovation and collaboration among itself and its clients. In its service to both public and private entities, our diverse team of professionals provide the following services to defined contribution and defined benefit plans: Fiduciary Services to Retirement Plans ZUNA will serve as a fiduciary under the Employee Retirement Income Security Act (“ERISA”) Section 3(21)(A) to the retirement plan as it relates to selection, monitoring and replacement of the plan’s investment options, including the default investment option. We will either serve in a non-discretionary capacity, in which case we will make a recommendation to the client and the client will have the ultimate decision-making authority, or we will serve in a discretionary capacity under Section 3(38) of ERISA. If we are appointed to serve with discretion, we will make decisions about the plan’s investment options and report back to the client. Our investment services will be provided on a continuous basis to the plan. We can also build model portfolios available within the plan, if it is determined that model portfolios would be appropriate for the plan’s participants. In the event the plan determines that certain features are necessary and appropriate to implement for its employees, we can assist with reviewing such features including managed accounts, which are generally offered through a third party (not through ZUNA). Non-Fiduciary Services to Retirement Plans In addition to the services that ZUNA provides to the plan in a fiduciary capacity, we are also available to provide several other services in a ministerial (or non-fiduciary) capacity. These services will assist the client in meeting its fiduciary responsibilities to be able to continue to offer the plan and meet its requirements under the current law and regulations. We offer the following services:
• Fiduciary governance support and documentation including preparation of meeting agendas for the plan’s fiduciaries, preparation of draft meeting minutes to document the meetings of the plan’s fiduciaries, and assistance with drafting and revising documents to reflect the processes of the plan fiduciaries including committee charter and investment policy statement.
• Fiduciary education for retirement plan fiduciaries and staff to include information related to fiduciary responsibilities under ERISA and ever-changing regulatory and legislative changes.
• Review of plan rules/provisions and assistance complying with the existing provisions. When changes to the plan are contemplated, ZUNA will assist the plan’s fiduciaries

with understanding the implications of contemplated (or required) plan changes.
• Coordination of communications and oversight of third-party service providers (for example, third party administrators, recordkeepers, auditors) to assist with plan administration.
• Fee benchmarking for recordkeeper(s) and contract negotiation assistance to assist the plan’s fiduciaries in paying no more than reasonable fees as required under the regulations.
• Coordination of requests for proposals for service providers (for example, third party administrators, recordkeepers, payroll providers, auditors) to assist the plan in selection (or maintaining) a service provider that meets the needs of the organization while charging no more than reasonable fees through a competitive and objective bidding process.
• Implementation of a new service provider (for example, third party administrators, recordkeepers, payroll providers) by facilitating contract reviews, timelines, data transfer, and employee communications, as required.
• Review and implementation of procedures for monitoring missing participants and small sum distribution providers (as necessary).
• Support to the retirement plan(s) during mergers and/or acquisitions including assistance with decisions to terminate or maintain and acquired company’s plan and assistance communicating with impacted participants. Fiduciary and Non-Fiduciary Services to Participants in Retirement Plans While many of our services are aimed at assisting the company (and its fiduciaries) in meeting their obligations under the law, we also provide services directly to employees (also known as participants). We provide services to participants in both a fiduciary capacity under ERISA Section 3(21) as well as in a non-fiduciary capacity. In a fiduciary capacity, ZUNA provides participants with the opportunity to meet one-on-one with a licensed financial professional in which investment advice will be provided to help employees meet their financial goals. This investment advice is non-discretionary in nature, meaning that ZUNA’s financial professionals may make recommendations to the employee but it is up to the employee to implement the recommendation. The engagement with these employees is not continuous and ongoing but may still be deemed to be investment advice in some instances. Where we provide financial planning services, we will disclose the terms of the engagement, including specific services, fees and payment, in a written agreement with the client. We will also provide the following non-fiduciary services to employees:
• Group sessions via the web or in-person in which employees will have access to a variety of topics of interest including social security, general financial education, and more.
• Phone and email support for plan inquiries.
• Access to a wellness program and monitoring of effectiveness delivered through online resources. Assets Under Management As of December 31, 2022, we have regulatory assets under management of approximately $206,683,184 of which$196,459,459 is managed with discretion and $10,233,725 is managed without discretion.