Calvert Wealth Management, Inc. (hereafter, known as the "Company"), was established in September 1998. The principal owners of the firm are John T. Stone, Jr. and Kelly C. Sheahan. The Firm offers Portfolio Management, Wealth Planning, and Financial Consulting Services. Portfolio Management Services: The Company provides continuous advice to a client regarding investment of client funds based on the individual needs of the client. Through personal discussions in which client goals and objectives are established, the Company creates and manages a portfolio. The company will manage advisory accounts on a discretionary basis. Account supervision is guided by the stated objectives of the client (e.g., Capital Preservation, Income with Growth, Growth and Income, etc.) Portfolios are created consisting of one or more of the following: Money Markets, CDs, Bonds, Individual Equities, Exchange Traded Funds (ETFs), No-Load or Load Waived Mutual Funds, and other investment products consistent with the client's objectives. The Mutual Funds will be selected on the basis of any or all of the following criteria: The fund's performance history, the industry sector in which the fund invests, the track record of the fund's manager, the fund's investment objective, the fund's management style and philosophy, and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by each client's risk tolerance, and stated goals and objectives. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. When appropriate to the needs of the client, the Company may recommend the use of trading (Securities sold within 30 days). Because this investment strategy involves certain additional degrees of risk, it will only be recommended when consistent with the client's stated tolerance for risk. Institutional Wealth Management: The Company provides fiduciary and educational services to 401(k)s and other Employer Sponsored Retirement Plans. The primary objective/service of the Company to these plans is to align the goals and objectives of the Plan to those of the Employers and Employees. This service is provided through the organization of the Investment Committee, investment monitoring through the use of an Investment Policy Statement, and a high level of attention to employee education. Portfolios are created consisting of one or more of the following: Money Markets, CDs, Bonds, Individual Equities, Exchange Traded Funds (ETFs), No-Load or Load Waived Mutual Funds, and other investment products consistent with the client's objectives. The Mutual Funds will be selected on the basis of any or all of the following criteria, as detailed within the Investment Policy Statement: The fund's performance history, the industry sector in which the fund invests, the track record of the fund's manager, the fund's investment objective, the fund's management style and philosophy, and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by each client's risk tolerance, and stated goals and objectives. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. When appropriate to the needs of the client, the Company may recommend the use of trading (Securities sold within 30 days). Because this investment strategy involves certain additional degrees of risk, it will only be recommended when consistent with the client's stated tolerance for risk. Financial Planning Services: The Company offers Financial Planning Services which provide a comprehensive evaluation of a client's overall financial situation. This assessment is then utilized to develop an actionable plan to help the client reach their stated financial goals. Preliminary Meeting: The process starts with a preliminary meeting to explore the benefits and costs of preparing a Financial Plan. The initial meeting is offered at no cost or obligation. Plan Development: Once services are retained and the scope of the engagement has been agreed to, the company requests a variety of information concerning the client’s financial situation and objectives utilizing an interview process where client goals and plans are identified. It is at this meeting that the cost for the plan preparation is estimated, and the client signs the Financial Planning Agreement. Plan Analysis and Design: Information provided by the client is reviewed and analyzed. The Financial Plan is designed based on the client's objectives, interests, and family situation. The plan incorporates the company's evaluation on investments, taxes, insurance and risk management, estate planning, college planning, retirement, survivor needs, and senior care as each of these situations may apply to the client’s financial situation. After the Plan has been completed and checked, a presentation meeting is scheduled with the client. At this meeting the results of the evaluation, as well as recommended actions are presented to the client. The client is encouraged to take the plan home for further review and discussion. A follow up meeting is then scheduled for plan finalization. Plan Finalization: After the client has had the opportunity to review the plan document and associated recommendations, the Company schedules the plan finalization meeting to review and address any questions the client may have. At this meeting, the initial planning agreement comes to a close and payment is made for services rendered. Plan Implementation: Available under a separate agreement, the company coordinates the implementation of the Financial Plan, monitors the progress made on the recommended actions, and updates the plan as necessary. Consulting Services: For those situations in which the preparation of a Financial Plan would be inappropriate, the company provides financial consulting on an hourly basis. This limited consultation may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Legal Services: The company does not provide any legal services, but will coordinate with the Attorney of the client’s choice during the design and coordination of the Financial Plan. Any fees for legal services are billed directly by the provider and are not shared with the company. Tax Services: The company does not provide any tax services but will coordinate with the Accountant or CPA of the client’s choice during the design and coordination of the Wealth Plan. Any fees for tax services are billed directly by the provider and are not shared with the company. Management of Client Assets: As of December 31, 2023, CWM was managing $138,213,110 of client assets under management on a discretionary basis. CWM does not manage client assets on a non-discretionary basis. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, CWM shall generally provide financial planning and related consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. CWM does not serve as an attorney or accountant, and no portion of our services should be construed as same. Accordingly, CWM does not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.). You are under no obligation to engage the services of any such recommended professional, including certain CWM’s representatives, in their separate individual capacities as representatives of Comprehensive Asset Management and Servicing, Inc. (“Comprehensive”), an SEC registered and FINRA member broker-dealer, and as licensed insurance agents-see disclosure at Item 10 below. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation that we make. If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify CWM, in writing, if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising CWM’s previous recommendations and/or services. Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If CWM recommends that a client roll over their retirement plan assets into an account to be managed by CWM, such a recommendation creates a conflict of interest if CWM will earn new (or increase its current) compensation as a result of the rollover. If CWM provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), CWM is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by CWM, whether it is from an employer’s plan or an existing IRA. Use of Mutual and Exchange Traded Funds: CWM utilizes mutual funds and exchange traded funds for its client portfolios. In addition to CWM’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The mutual funds and exchange traded funds utilized by CWM are generally available directly to the public. Thus, a client can generally obtain the funds recommended and/or utilized by CWM independent of engaging CWM as an investment advisor. However, if a prospective client does so, then they will not receive CWM's initial and ongoing investment advisory services. Socially Responsible Investing Limitations: Socially Responsible Investing

involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by CWM), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. CWM does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, CWM shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Cash Positions: CWM continues to treat cash as an asset class. As such, unless determined to the contrary by CWM, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating CWM’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), CWM may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, CWM’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, CWM shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless CWM reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within a CWM actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any CWM unmanaged accounts. eMoney. In conjunction with the services provided by eMoney, CWM may also provide access to account aggregation services, which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets that we manage (the “Excluded Assets”). Unless otherwise agreed to in writing, the client and/or their other advisors that maintain trading authority, and not us, shall be exclusively responsible for the investment performance of the Excluded Assets. CWM does not provide investment management, monitoring or implementation services for the Excluded Assets. The client may engage CWM to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between CWM and the client. Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of CWM. Generally, with potential exceptions, CWM does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by CWM will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by CWM) will be profitable or equal any specific performance level(s). In addition, there may be other securities and/or accounts owned by the client for which CWM does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which CWM does not maintain custodian access and/or trading authority. Corresponding Services/Fees. When agreed to by CWM, CWM shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent; (3) shall generally consider these securities as part of the client’s overall asset allocation; (4) report on such securities/accounts as part of regular reports that may be provided by CWM; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by CWM), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. CWM does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, CWM shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Portfolio Activity. CWM has a fiduciary duty to provide services consistent with the client’s best interest. CWM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when CWM determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by CWM will be profitable or equal any specific performance level(s). Client Obligations. In performing our services, CWM shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify CWM, in writing, if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that CWM and its third-party service providers use to provide services to CWM’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in CWM’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and CWM are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although CWM has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that CWM does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by CWM) will be profitable or equal any specific performance level(s).