A. Description of the Advisory Firm GreenShields Capital (hereinafter “GSCL”) is a Limited Liability Company organized in the state of California. The firm was formed in 2016 and the principal owner is Brent Alex Greenshields. B. Types of Advisory Services Portfolio Management Services GSCL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GSCL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring GSCL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GSCL will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. GSCL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GSCL’s economic, investment or other financial interests. To meet its fiduciary obligations, GSCL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GSCL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is GSCL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. GSCL may also provide some limited Financial Planning services to ongoing Portfolio Management clients on a case-by-case basis. There would be no additional charge for this limited Financial Planning service. ERISA 3(21) Investment Advisor and 3(38) Investment Management Services For employer-sponsored retirement plans with participant-directed investments, GreenShields Capital LLC (GSCL) also doing business as Greenshields Plan Advisory Services (GPAS) provides its advisory services as an investment advisor as defined under Section 3(21) and as an investment manager as defined under Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(21) investment advisor, the plan sponsor and GPAS share fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Investment Advisor Agreement between GPAS and the plan sponsor. GPAS provides the following services to the plan sponsor: - Screen investments and make recommendations. - Monitor the investments and suggests replacement investments when appropriate. - Provide a quarterly monitoring report. - Assist the plan sponsor in developing an IPS. When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of all fiduciary responsibility for the investment decisions made by GPAS. GPAS is a discretionary investment manager in accordance with the terms of a separate ERISA 3(38) Investment Management Agreement between GPAS and the plan sponsor. GPAS provides the following services to the plan sponsor: - Select the investments. - Monitor the investments and replace investments when appropriate. - Provide a quarterly monitoring report. - Develop a customized IPS. GPAS’s goal in identifying the plan’s investment options is to provide a range of options that will enable plan participants to invest

according to varying risk tolerances, savings time horizons or other financial goals. The plan's investment options may consist of ETFs, CITs, mutual funds, model portfolios, or other similar investment funds. The investment funds from which GPAS will select from will be those that are available on the plan record-keeper’s investment platform. GPAS will prepare an IPS for the plan. The purpose of the IPS is to provide guidelines for making investment-related decisions in a prudent manner. It outlines the underlying philosophies and processes for the selection, evaluation, monitoring, and, if necessary, replacement of the investment options offered by the plan. GPAS will perform on-going monitoring of the investment options within the plan. The ongoing monitoring of investments is a regular and disciplined process. Monitoring confirms that the criteria remain satisfied and that an investment option continues to be appropriate. The process of monitoring investment performance relative to specified guidelines will be consistently applied. Selection of Other Advisers GSCL may direct clients to third-party investment advisers. Before selecting other advisers for clients, GSCL will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where GSCL is recommending the adviser to clients. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. 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);
• Avoid misleading statements about conflicts of interest, fees, 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; and
• Give you basic information about conflicts of interest. Services Limited to Specific Types of Investments GSCL generally limits its investment advice to mutual funds, equities, ETFs and treasury inflation protected/inflation linked bonds, although GSCL primarily recommends mutual funds to a majority of its clients. GSCL may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions GSCL offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GSCL from properly servicing the client account, or if the restrictions would require GSCL to deviate from its standard suite of services, GSCL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. GSCL does not participate in any wrap fee programs. E. Assets Under Management GSCL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $145,117,573 $0.00 December 2022