Firm Information and Advisory Service The business activities of Shuttleworth & Company (hereafter “SCO”) consist of providing investment advisory services. David L. Shuttleworth, founded SCO in March 1999. Erin M. Maynard, Matthew R. Freiburger and David L. Shuttleworth are all shareholders in the firm. SCO renders continuous management of accounts and provides advice to clients as to investment of funds based on an individual client’s needs and suitability. SCO utilizes a balanced long-term investment strategy. Therefore, suitable clients include individuals (including trusts and estates), pension funds, charitable organizations, and other entities with established funds that have long time horizons. Established goals and objectives serve as guidelines that portfolio managers of Shuttleworth & Company use for investment management decisions. Advisory services are performed in general on a discretionary basis. No client account participates in a wrap-fee program. SCO has under its management the following assets as of December 31, 2023: Discretionary $137,851,883 Non-Discretionary $0 Retirement Plan Rollover Recommendations - When SCO provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to an IRA or make a distribution from the retirement plan account, we acknowledge that SCO is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way SCO makes money creates conflicts with your interests, so SCO operates under a special rule that requires SCO to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, SCO must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice).
• Never put the financial interests of SCO ahead of you when making recommendations (e.g., give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that SCO gives advice that is in your best interest.
• Charge no more than is reasonable for the services of SCO; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by SCO, please know that SCO and our

investment advisor representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by SCO. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by SCO. Thus, our investment advisor representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have adopted an impartial conduct standard to manage this conflict of interest whereby our investment advisor representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in SCO receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by SCO and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of SCO or our affiliated personnel. SCO will generally require that anyone whose functions or duties relate to providing investment advice possess a CFA, ChFC, or CPA designation, Series licensing, and/or experience judged by SCO’s management to be comparable to the above. Management Services for Held Away Accounts SCO offers an additional service directly to clients that have accounts held away from SCO where SCO has discretion and may use a third-party platform to facilitate the management of held away accounts. SCO regularly reviews the available investment options in these accounts, monitors them, rebalances, and implements our strategies in the same way we do other accounts, though using different tools as necessary.