A. Description of the Advisory Firm TruNorth Capital Management (“TruNorth Capita”, the “Adviser”, or “we”) is a privately-owned company headquartered in Kalamazoo, Michigan. TruNorth Capital was founded in 2012 to provide investment management services primarily to high-net-worth families, individuals, corporations, and others. TruNorth Capital also provides investment management services to employer-sponsored retirement plans and in its capacity acts as a 3(38)-investment manager (as defined under the Employee Retirement Income Security Act of 1976 (“ERISA”)). The majority owners are Brian Mullally, John Schoolman, and Kevin Miller, who collectively bring decades of investment management experience creating client-centric, low-cost investment strategies. B. Types of Advisory Services TruNorth Capital is a fee only Registered Investment Adviser and is a fiduciary to each of its clients. As a such, TruNorth Capital upholds a duty of loyalty, fairness, and good faith towards each client and seeks to clearly disclose and mitigate potential conflicts of interest between the Adviser and its clients. TruNorth Capital and its personnel may recommend TruNorth Capital’s services and its investment adviser representatives in their individual capacities as investment managers and consultants. The term “fee only” means that TruNorth Capital and its investment adviser representatives will not accept commissions in connection with securities recommendations. Investment adviser representatives are those persons who are authorized to provide advice and manage accounts on behalf of the Adviser. TruNorth Capital is only compensated for advisory services via fees paid by its clients. TruNorth Capital is not a broker/dealer or custodian. Transactions in securities will be executed by an unaffiliated brokerage firm and investment accounts will be held by the client’s selected custodian. The Adviser recommends the services of Charles Schwab & Co., Inc. and clients establish their accounts directly with this service provider. Clients can expect to receive regular account statements directly from the custodian. Our services include investment management services and, if at the client’s request, retirement and financial planning services are provided to design optimal long-term savings and investment strategies, considering the client’s personalized financial needs, risk tolerance, assets, taxes, estate planning, income, background, and other factors. Planning services are initiated by the client throughout the engagement and there is no obligation to engage in these services. TruNorth Capital also regularly publishes newsletters and blogs to clients and non-clients that have freely subscribed to receive these publications. Services begin after TruNorth Capital and the client have executed the firm’s investment management agreement. TruNorth Capital provides discretionary investment management services, where clients give us the authority to buy and sell securities for their accounts according to our discretionary decisions and management in line with the client’s agreed upon investment strategy. TruNorth Capital does not provide non-discretionary financial advisory services. If requested by clients, retirement planning services can include collecting, organizing, and analyzing a client’s financial data to provide optimal wealth design through appropriate account structure (including taxable and non‐taxable accounts and 5 | P a g e strategies used within each) and income tax and estate tax strategies on the basis of the individual needs of the client. TruNorth Capital considers such factors as the size and source of the account, client’s identity and background, the client’s stated income and growth objectives, cash flow needs, income tax bracket, potential federal and state estate taxes, and the client’s relative risk aversion. The individual needs and situation of each client dictate whether both investment supervisory and retirement and financial planning services are utilized. Clients may choose to make self-directed securities transactions or hold self-directed assets, which are investments that are not reviewed and/or not recommended by TruNorth Capital. In such cases, TruNorth Capital has not passed on the suitability of said investments and while the Adviser may assist with executing client-directed implementation as a value-added service at the client’s request, TruNorth Capital will not manage these investments unless agreed in writing. While self-directed securities transactions and assets may be included in the portfolio reports provided to the Client by TruNorth Capital, self-directed assets are excluded from the Fees and Compensation owed to TruNorth Capital as so noted in Item 5. A. (Fee Schedule). Plan Management When an employer-sponsored retirement plan client engages TruNorth Capital to act as a fiduciary to the retirement plan pursuant to section 3(38) of ERISA, TruNorth Capital will develop a menu of investment options, to be provided to the retirement plan and therefore its participants. TruNorth Capital will monitor the investment options and will have the discretion to change the menu of investment options, pursuant to TruNorth Capital’s agreement with its retirement plan clients. C.

Client Tailored Services and Restrictions TruNorth Capital focuses on providing individualized services to its clients. TruNorth Capital and the client will share in a data gathering and discovery process in an effort to determine the client’s stated needs, goals, intentions, time horizons, risk tolerance and investment objectives, based upon information provided by the client. A client’s active participation is expected during the data-gathering process and the formulation of advice and recommendations. The client will complete a risk assessment and we will tailor the investment policy statement of the client to his/her specific investment strategy. Clients must understand that retirement and financial planning may not be fully considered due to the client’s current needs or due to the lack of information received, and/or disclosed by the client. Limitations on Individual Stocks: Generally, it is the philosophy of TruNorth Capital to not invest in individual stocks or equity securities. We do recommend exchange-traded funds (ETFs), which trade intra-day on exchanges similar to individual equities. However, we may agree to manage individual equity securities for new clients that have existing holdings. Limitations on Mutual Funds: TruNorth Capital does not generally invest in mutual funds other than no- load mutual funds, which may include lower cost institutional share classes from low-cost, no-load fund advisors. 6 | P a g e Limitation by Client: Clients may request reasonable restrictions on investing in certain types of securities, but TruNorth Capital reserves the right to cease management or to not accept a client relationship if the client restrictions would limit our ability to meet the client’s investment strategies. As an independent Investment Adviser, TruNorth Capital neither has nor do we offer proprietary products. For client accounts, we use maximum global diversification with targeted weighting to asset classes that offer the optimal blend of investments with a goal to increase returns and lower risk. We use low-cost, exchange-traded and mutual funds from providers to deliver performance. Kevin Miller (President and CEO) and Brian Mullally (Co-Founder and Relationship Manager) develop our investment management strategies. Retirement Plan Rollovers As previously noted in this Brochure, TruNorth Capital is a fiduciary to each client and the fiduciary duties apply to investment advice in connection with your retirement plan account or individual retirement account within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way the Adviser earns compensation (asset-based fees for managed accounts) creates some conflicts with your interests, Therefore, TruNorth Capital must operate under a special rule that requires us to act in your best interest and not put his interests ahead of yours. At the time of a rollover recommendation, TruNorth Capital will provide you with a written disclosure discussing the reasons the rollover is in your best interests. Also, under this special rule’s provisions, we must: * Meet a professional standard of care when making investment recommendations (give prudent advice). * Never put our financial interests ahead of yours when making recommendations (give loyal advice). * We must provide basic information about conflicts of interests and fees while avoiding misleading statements about these topics and investments * Follow policies and procedures designed to ensure that we give advice that is in your best interest. * Charge no more than is reasonable for our services 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). When TruNorth Capital recommends that a client roll their retirement plan assets from a retirement account into a new or existing account (e.g., rollover IRA) to be managed by TruNorth Capital, it serves as a fiduciary under ERISA and TruNorth Capital acknowledges that the recommendation creates a 7 | P a g e conflict of interest. The conflict of interest exists because TruNorth Capital will receive an investment management fee if the funds are rolled over and managed by the Adviser. Obviously, the conflict is eliminated if the recommendation is not accepted, or assets are managed by another adviser or the investor. TruNorth Capital’s clients are never under any obligation to roll over retirement plan assets to an account managed by TruNorth Capital. D. Wrap Fee Programs TruNorth Capital neither sponsors nor manages a wrap fee program. E. Assets Under Management As of December 31, 2023, the total number of client accounts is 852 and the amount of assets under management is $415,276,666. All assets are managed on a discretionary basis.