Firm Description Reflection Asset Management, LLC (hereinafter referred to as “RAM”, the “Adviser”, the “Firm” or “we”) is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). RAM was founded by Jason Britton, Chief Executive Officer, in January 2019 and began providing advisory services at the approval of its registration with the State of South Carolina in March of 2020. RAM is an asset management firm formed to prove that investing for financial return and positive social impact is not only possible, but the future of investing. Delivering competitive financial returns as well as social impact across asset classes, RAM seeks to demonstrate there can be profit with purpose. RAM’s flagship strategies are thematic US Equity portfolios leveraging a proprietary 400 factor model in order to evaluate the environmental, social, and governance performance of each company to uncover competitive advantage and value. In addition to the Large Cap and All Cap strategies, RAM offers portfolios dedicated to the themes of gender equality, sustainability, fossil fuel divestment, social justice, and religious based portfolios. As an emerging, employee-owned asset manager, RAM brings institutional investment experience and authenticity to the Environmental, Social and Governance (“ESG”) and impact investing industry. Investment Advisory Services RAM provides investment advisory services on a discretionary basis to individual investors and is the investment adviser to the Democratic Large Cap Core ETF and Sphere 500 Climate Fund, each a registered investment company organized under the Investment Company Act of 1940. Separately Managed Accounts RAM offers portfolio management

services on a discretionary basis. An investment advisory agreement is executed with each client. A client profile is created for individual and small business clients to determine the appropriate investment strategy. With discretionary accounts, the Firm will direct, in their sole discretion and without prior consultation with the client, the investment and reinvestment of assets, including securities and cash or cash equivalents, in the client’s account. The client’s financial circumstances, investment objectives, and any special instructions or limits that the client wishes the Firm to follow in managing the client account is outlined in the investment advisory agreement. Clients agree to notify RAM promptly of any significant changes to the information provided by the client in the investment advisory agreement or any other significant changes to their financial circumstances or investment objectives that might affect the way the client’s account should be managed. Clients also provide RAM with any additional information as the Adviser may request from time to time to assist the Adviser in managing the client account(s). WMNomics and other model accounts RAM provides investment advisory services on a discretionary basis to individual investors through model portfolios offered through Interactive Brokers. Model portfolios are comprised of individually selected US equities, and may include a fixed income mutual fund and/or international equity mutual fund. Consulting services RAM provides investment consulting services when requested. Assets Under Management The Adviser had $130,865,339 under discretionary management as of 3/28/24. The Adviser does not have non-discretionary assets under management.