Firm Description Riverwater Partners LLC (also known as "Riverwater Partners", "we", "us", "our") is a Wisconsin limited liability company which offers investment advisory services since 2016. Riverwater Partners provides investment management services to a wide variety of clients. Riverwater Partners is wholly owned by Laura Peck, Adam Peck, Matthew Drvaric, Gregory Wait, Nathan Fredrick and Cynthia Bohlen, with Laura Peck as majority owner. Riverwater Partners does not control any other firm nor engage in any other business. Riverwater Partners has a DBA, Riverwater BLUE (“Riverwater BLUE”) that provides investment advisory and consulting services primarily through the internet. The two entities share supervised persons and place of business. Riverwater Partners: Investment Management Services Wealth Management Services Our Wealth Management team develops and executes wealth management and financial plans for individuals and families. Our process begins by having clients complete an assessment of financial goals and objectives. We collaborate with clients to analyze their financial position and develop a comprehensive plan based on short- and long-term goals and personal risk tolerances. We offer customized investment portfolios tailored to our clients’ risk profiles and objectives, and regularly monitor progress. Services offered include quarterly performance reports, investment manager due diligence, ongoing management and maintenance of investments, cash flow management, portfolio rebalancing, and family wealth transfers. Asset Management Services Our Asset Management team actively manages three distinct separate account equity strategies; Riverwater Sustainable Value Strategy, Riverwater Micro Opportunities Strategy and Riverwater Equity Income Strategy. We apply a value-oriented approach to responsible investing using our disciplined research process, the Three Pillar Approach. Each strategy we manage are composed of focused portfolios that invest in 20-35 stocks. Institutional Investment Advisory Services We provide discretionary and non-discretionary investment advisory and consulting services to institutional clients, including endowments, foundations, non-profit organizations, and qualified retirement plan sponsors. Our advisory services begin with an analysis of our client’s financial position, current investment portfolio and policy, goals, cash flows, time horizon, restrictions, and overall objectives. We provide investment recommendations in line with the asset allocation strategy developed in collaboration with the client. We monitor and manage accounts on a continuous basis and provide quarterly performance measurement reports. We provide advice on a wide range of public and private investments. Riverwater Partners’ Institutional Advisory Team typically recommends third party advisors to manage either all or a portion of the client’s investment assets. Institutional advisory services include: design and implementation of custom asset allocation strategies, design of 401(k) investment menus, review or development of Investment Policy Statements, investment manager due diligence, performance measurement and reporting, cash flow management, board reporting, fiduciary fee benchmarking, 3(21) and 3(38) fiduciary services. Investments are not held by Riverwater Partners. Instead, all investments managed by Riverwater Partners are custodied at the brokerage firm through which transactions are placed. Additionally, Riverwater Partners provides model portfolios to third party advisors. Wrap Fee Program Riverwater participates in wrap programs for some clients. The client is charged a combined fee (referred to as a “wrap fee”) based upon a percentage of the market value of the account, which generally covers all services for:
• selection of program;
• the investment advisers’ fee to manage the client’s portfolio on a fully discretionary basis;
• brokerage commissions and, in some instances, dealer mark-ups or mark-downs for the execution of trades by the designated broker;
• acting as custodian for the assets in the client’s portfolio which also includes providing the client with trade confirmations and monthly statements;
• periodic evaluation and comparison of account performance; and
• continuing consultations on investment objectives. Riverwater receives a portion of this “wrap fee” for providing investment supervisory services. In some cases, Riverwater’s advisory fee is a separate fee. Riverwater BLUE: Investment Management Services Riverwater BLUE offers investment advisory services to clients through the Schwab Institutional Intelligent Portfolios (IIP) digital platform. Investing services are accessed and offered through Riverwater BLUE’s interactive website, www.riverwaterblue.com. Riverwater BLUE accounts are allocated among one of five model portfolios (hereinafter “Model Portfolios”). Riverwater BLUE designed

the Model Portfolios and client accounts are managed by Riverwater BLUE investment adviser representatives. The Model Portfolios utilize mutual fund investments which consist of multiple asset classes. The Model Portfolios are as follows; 1.) Sustainable Income, 2.) Sustainable Income & Growth, 3.) Sustainable Growth & Income, 4.) Sustainable Growth and 5.) Sustainable Aggressive Growth. In order to determine a client’s appropriate Model Portfolio, clients provide information about themselves and their investment objectives exclusively through electronic means via an online questionnaire on the Schwab IIP website. The client answers questions about his or her assets, goals, risk aversion and time horizon and an algorithm is used to designate individual client accounts into the appropriate Model Portfolio. The algorithm is only used to designate individual client accounts into a predetermined Model Portfolio. The algorithm does not manage client accounts and the algorithm is not responsible for building the Model Portfolios. The algorithm is provided through the Schwab Institutional Intelligent Portfolios (IIP) digital platform. Schwab IIP does not act as an investment manager or adviser to client accounts, but rather acts as a technology service provider. The Model Portfolios were developed by Riverwater BLUE based on tenants of modern portfolio theory. Ongoing management of the Model Portfolios and client accounts is further based on modern portfolio theory. Modern portfolio theory seeks to maximize the expected return of a portfolio at a given level of risk. Advantages of modern portfolio theory include an investor’s ability to reduce the risk exposure of individual assets through diversification of historically low-correlated asset classes. Disadvantages include the assumptions that investors engage in rational behavior and that asset class correlations may change over time, especially during times of crisis. Funds comprising the Model Portfolios are limited to Sustainable, Responsible and Impact (SRI) investment funds. Further information regarding SRI investments may be found in Section 8.b. of this brochure. Using Schwab’s digital IIP platform, Clients can electronically enter into an advisory agreement with Riverwater BLUE and open a brokerage account with Charles Schwab Corporation (Schwab), an SEC registered broker dealer acting as the custodian of client accounts. Riverwater BLUE maintains discretion over client accounts and implements trade orders based on a client’s Model Portfolio (including, as applicable, any trade orders initiated by changes to the Model Portfolio made in Riverwater BLUE’s discretion). Clients should understand that the algorithm is entirely dependent on receiving accurate information from clients. If clients provide inaccurate information with regard to a client’s assets, goals, risk aversion and time horizon, or if a client fails to update promptly their information when it changes, it could materially impact the quality and applicability of the algorithm’s recommendations. Though the algorithm provides a recommendation based on information received from the client, the client is ultimately responsible for the selection of an appropriate Model Portfolio and for inputting changes to the client’s assets, goals, risk aversion and time horizon. However, Riverwater BLUE has the capability to override the algorithm Model Portfolio recommendations and will do so when in the client’s best interest. Any changes to the algorithm must be communicated to the client in writing. Clients may update their information on the adviser’s website, www.riverwaterblue.com. Information should be updated whenever there are changes to a client’s assets, goals, risk aversion and time horizon. Riverwater BLUE investment adviser representatives rebalance client accounts from time to time in the adviser’s sole discretion. The algorithm does not rebalance client accounts. Riverwater BLUE may change the specific mutual funds that comprise a Model Portfolio without notice to clients. The algorithm does not change the mutual funds which comprise a Model Portfolio. In the event a client provides Riverwater BLUE with information not ordinarily considered by the algorithm when a Model Portfolio is recommended (for example, liquidity needs) Riverwater BLUE may override the algorithm’s recommendation, subject to approval by the client. Riverwater BLUE also provides Financial Planning Services directly to clients for an additional fee. Client Tailored Relationships and Restrictions As a fiduciary, Riverwater Partners and Riverwater BLUE always act solely in your best interest. Your portfolio is allocated based on your investment objectives. Clients may impose reasonable restrictions on investing in certain securities or types of securities within a client’s allocated investment model. Assets under Management As of December 31, 2023, Riverwater Partners, including the DBA Riverwater BLUE had approximately $ $871,740,008 in total assets under management, of which $ $159,686,140 are discretionary and $ $712,053,868 are non-discretionary.