Item 5 - Additional Compensation ........................................................................................................19 Item 6 - Supervision ....................................................................................................................................19 Firm Description Madrone Investment Advisory, LLC (“Madrone”) was founded as a sole proprietorship by Michael Zaidlin in 2009 and became an LLC in 2011. Mr. Zaidlin is 100% owner and Chief Compliance Officer. Types of Advisory Services ASSET MANAGEMENT Madrone offers non-discretionary direct asset management services to advisory clients. What does non-discretionary mean? It means that Madrone will recommend specific securities to be bought or sold, as well as the amount, but will obtain the clients approval to purchase or sell such securities prior to executing any transactions in the client’s account. This approval is initially granted by the client when both Madrone and the client agree on, and sign, an initial proposed investment portfolio. After that, any further transactions must be further approved by the client as to the type and the dollar amount of security purchases. One of the primary reasons Madrone provides non-discretionary asset management is because it helps ensure that the client is not only educated and informed about their investments, but because it also provides an opportunity for more and better communication between the client and Madrone. In addition to investment recommendations, Madrone will provide clients with ongoing portfolio management services consistent with that client’s investment objectives, investment time horizons, and risk tolerance. Investment strategies and selection, asset allocation, portfolio monitoring and the overall investment program will be based on the those factors. All investment portfolios managed by Madrone are individually tailored for each client, taking into account, where feasible and where the client is forthcoming about such information, the Client’s existing positions in outside accounts that are neither managed nor advised upon by Madrone. Madrone primarily structures broadly diversified investment portfolios with passive exchange traded mutual funds and mutual funds which typically, though not always, have very low annual expense ratios, are market-cap weighted, tax-efficient, and/or evidence- based which are designed to provide investors with market returns. Please see Item 8 for a more detailed description of our investment philosophy and associated risks. Madrone does not provide clients with a formal comprehensive financial plan, which typically includes elements such as a net worth statement, cash flow analysis, a risk management plan, and other elements. However, Madrone can provide clients with limited information about certain aspects of financial planning that clients may find to be sufficient for their needs. Clients desiring a more formal comprehensive financial planning may choose to seek such services elsewhere. ERISA PLAN SERVICES Madrone provides services to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. ERISA 3(38) Investment Manager. Madrone can act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. Madrone

would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• Madrone has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. client understands the Madrone’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Madrone is not providing fiduciary advice as defined by ERISA to the Plan participants. Madrone will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Madrone may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Madrone and client. 3. Madrone has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent. Wrap Fee Programs Madrone does not sponsor any wrap fee programs. Client Assets under Management Madrone has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $8,347,000 $192,407,000 December 31, 2023