A. Description of the Advisory Firm B. Types of Advisory Services Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. Pontera IWP uses a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Services Limited to Specific Types of Investments IWP generally limits its investment advice and/or money management to mutual funds, equities, bonds, ETFs, and REITs and may use other securities as well to help diversify a portfolio when applicable. Educational Seminars IWP provides educational retirement courses for a fee. These courses educate on the following topics: 1) Life Planning in Retirement 2) Financial Concerns 3) Investments (General) 4) Retirement

Income Sources, including Social Security 5) Health Care Planning 6) Estate Plan IWP offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs, which must be provided in writing by the client and would be documented by IWP either in the Investment Policy Statement or elsewhere in the client file. However, if the restrictions prevent IWP from properly servicing the client account, or if the restrictions would require IWP to deviate from its standard suite of services, IWP reserves the right to end the relationship.
C. Client Tailored Services and Client Imposed Restrictions A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. IWP does not participate in any wrap fee programs. IWP has the following assets under management: Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $172,030,440 $6,359,579 December 2023 Investment Supervisory Services Fees Total Assets Under Management Annual Fee Up to $500,000 2.15% $500,001 to $1,000,000 1.90% $1,000,001 to $2,500,000 1.75% Above $2,500,000 1.50% These fees are negotiable depending upon the needs of the client and complexity of the situation and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Lower fees for comparable services may be available from other sources. IWP uses the closing balance in the client’s account as of the last day of the monthly billing period for purposes of determining the market value of the assets upon which the advisory fee is based. Fees are paid monthly in arrears and therefore no refund policy is necessary. For contracts commenced or terminated mid-month, clients will be responsible for paying the prorated fees.
D. Wrap Fee Programs E. Amounts Under Management