Description of Advisory Services Alden Investment Advisors is a Delaware LLC and is fully owned by Alden Partners, LLC., a Pennsylvania LLC. We began operations in October 2021. As of December 31, 2022, we had $290,949,395 in assets under management. We provide a variety of financial advisory services, including the discretionary management of client accounts, retirement plans and non-discretionary asset management services. We focus on providing a customized allocation for each client using custom portfolio strategies as well as offerings from other RIAs, mutual funds and private investment funds. In some cases, we may recommend third party money managers who have an expertise in a particular investment strategy. Prior to introducing any Pennsylvania clients to another investment advisor, we will be responsible for determining if we are properly licensed, notice filed, or exempt from registration with the Pennsylvania Department of Banking and Securities. We also offer customized asset allocation and portfolio management strategies to individual clients. Alden specializes in evaluating, designing, and implementing retirement programs and executive benefits packages for small and mid-sized companies. Using information such as corporate objectives, industry specific data, competitive dynamics, and budgetary considerations, Alden assists employers to design retirement packages to attract, retain, and motivate employees. Alden may act as a fiduciary to retirement and benefit plans and will have clients that include non- profit entities such as hospitals, churches, schools, credit unions, endowments and others. Asset Management Services The investment management services that we provide to individuals involves determining the risk/return profile of the client, as well as their goals and objectives, then selecting the appropriate strategy. Clients are free to impose restrictions or limitations on our selection of investments in certain securities, or types of securities. Our recommendations are based on information that you provide to us regarding your financial needs, retirement and financial goals, investment objectives, net worth, time horizon, risk profile, tax situation, and liquidity needs. We generally manage individual client accounts on a fully discretionary basis, which allows us to change your portfolio allocation as we deem prudent without your prior authorization. However, you may choose to have your account managed on a non-discretionary basis. If you choose a non-discretionary account, we will need to discuss any changes to your account before repositioning your assets, which may delay our ability to reallocate your assets in response to market conditions. Alden Investment Advisors provides its clients and IARs with access to Alden COVE. Alden COVE is a wealth and investment management pla�orm delivered by Alden Capital Management. As such, Alden Investment Advisors and Alden Capital Management have engaged in a co-advisory rela�onship to provide Alden COVE and its relevant investment, trading and middle/back-office services. Clients of Alden COVE have their accounts billed at the regular Alden Capital Management fee schedule. Alden Capital Management deducts the fees on a monthly or quarterly basis, retains a por�on of that fee (that was pre-nego�ated with the firm and/or IAR during onboarding and pla�orm setup), and distributes the remaining amount to Alden Investment Advisors. AIA then provides the IAR with their por�on of the fee. Alden COVE u�lizes the Amplify Pla�orm as its technology provider and sub-advisor, as well as Pontera for management of held-away accounts. Clients will have access to a broad array of ins�tu�onal asset managers through Alden COVE. Please see addi�onal informa�on below: Alden COVE Pla�orm Alden Capital Management provides IARs and RIAs with access to its Alden COVE pla�orm (“Alden COVE”). Alden COVE offers these IARs/RIAs access to a broad array of ins�tu�onal asset managers, and the ability to construct unified managed accounts (UMAs) including strategies from these asset managers, and advisor-directed strategies. By u�lizing Alden COVE, advisors can service their clients more efficiently. Before onboarding a client to the Alden COVE pla�orm, advisors obtain informa�on about their financial circumstances, investment objec�ves, financial goals, risk tolerance, investment �me horizon and liquidity needs. This will generate a risk score which allows the advisor to appropriately manage the client account. The client’s risk score will be easily accessible to the advisor, as well as their current por�olio’s risk score, as an addi�onal tool to ensure the client’s profile is managed appropriately. Alden requires that at least annually, the client is contacted to determine whether there have been any changes to any of the above items which may impact their risk tolerance, investment objec�ve, or other. Clients of the Alden COVE pla�orm are subject to Alden Capital Management’s regular fee schedule. Alden bills one client fee and compensates the individual advisor on a schedule nego�ated at the �me of advisor onboarding. The client will see one line-item bill for this fee on their custodial statement. Alden will directly compensate any technology pla�orm or integra�on partner from its remaining fee. Addi�onal fees may be charged by ins�tu�onal asset managers and/or sub-advisors. These fees will be charged separately, outside and above, the agreed upon client fee between Alden and the client. These fees are not distributed to Alden. There may also be custodial fees charged to individual clients that are no different to

other Alden accounts managed at those custodians. Pla�orm Services With Alden COVE, advisors and/or clients may receive assistance with:
• Client account opening (including paperwork review, custodial review/liaison, tracking funding and pla�orm setup) and servicing (such as standing/periodic instruc�on setup, contribu�ons, distribu�ons, RMD calcula�ons, and more).
• Asset management strategy or strategies such as investment manager introduc�ons, investment strategy recommenda�ons, assistance crea�ng models and/or UMAs at the advisor-level or for individual clients on a case-by-case basis, through consulta�ons with Alden’s investment team.
• Technology services such as a mul�-custodial trade order management system (TOMS) and customized client portals for ongoing performance repor�ng. Use of Technology Pla�orm and Sub-Advisor Alden COVE sits on top of the Amplify Pla�orm and leverages its services as a technology provider. This allows Alden to focus primarily on helping advisors and clients with the investment management and middle/back-office services outlined above. Amplify Pla�orm provides Alden COVE with a technology chassis, back-office opera�onal support services such as administra�ve, trading and repor�ng services as well as access to independent third-party managers. Alden has executed a pla�orm agreement which allows it, as a pla�orm member, to receive the back-office services outlined above on a sub-advisory basis. This allows advisors using Alden COVE to allocate all or a por�on of their underlying client’s assets among the different ins�tu�onal asset managers available through the pla�orm on a discre�onary basis. Each client has a direct contractual rela�onship with Alden for access to Alden COVE pla�orm, which allows both Alden and Amplify Pla�orm to renders its services to the client. Alden engages unaffiliated investment advisors to service its advisors and client accounts as sub-advisors. These sub-advisors will perform discre�onary investment management services and shall manage, invest and reinvest the underlying client assets designated by the advisor. As such, selected manager(s) shall be authorized, without prior consulta�on to the advisor or client, to buy, sell, trade or allocate the underlying client’s assets in accordance with the underlying client’s investment objec�ves and to deliver instruc�ons in furtherance of this responsibility to the underlying client’s broker-dealer or custodian. Advisors retain responsibility for their underlying client rela�onships, including the ini�al and ongoing suitability determina�on, and shall also retain the responsibility for implemen�ng client investment recommenda�ons in accordance with their fiduciary duty to the client. Advisors are responsible for obtaining and furnishing informa�on pertaining to asset management strategy selec�on and underlying client account guidelines along with any reasonable account restric�ons. In a typical advisor rela�onship with Alden COVE, Alden will compensate Amplify Pla�orm directly from its remaining fee. Management of Held-Away Accounts Alden COVE helps advisors and clients to expand their breadth of service by receiving professional discre�onary management on held-away accounts/assets such as defined contribu�on plan par�cipant accounts. Alden leverages a technology pla�orm, Pontera to do so. Pontera allows Alden and its affiliated advisors through Alden COVE to avoid being considered to have custody of client funds as they do not have direct access to client log-in creden�als to effect trades. Alden has integrated Pontera into its Alden COVE pla�orm and may receive compensa�on for this integra�on as well as similar investment management, technology and client services outlined above. A link is provided to clients allowing them to connect accounts to Pontera. Once client accounts are connected, the advisor will review the current account alloca�ons. When deemed necessary and based on informa�on also gathered during the Alden COVE client account onboarding, the advisor will rebalance the account, considering client investment goals and risk tolerance, and in any change in alloca�ons will consider current economic condi�ons and market trends. This holis�c approach allows advisors to expand their professional management for clients. The goal of this addi�onal integra�on is to improve account performance over �me, minimize loss during difficult market, manage internal fees that harm account performance, and factor in all client accounts to create an appropriate asset alloca�on and por�olio, regardless of where the account is currently held. It is the advisor’s responsibility to review the account(s) at least quarterly and make alloca�on change they deem necessary. Clients using the Pontera integra�on of Alden COVE will also be subject to Alden Capital Management’s regular fee schedule. Alden bills one client fee and compensates the individual advisor on a schedule nego�ated at the �me of advisor onboarding. Alden will compensate Pontera directly from its retained fee. Permi�ng access to a data feed, Pontera-based accounts will be linked into Alden COVE’s advisor pla�orm and client portals for op�mized unified managed household repor�ng, though it is the advisor’s responsibility to request this feed. Alden Capital Management Strategies Alden Capital Management has its own proprietary investment strategies available for clients on Alden COVE. Alden acknowledges a conflict exists when clients and/or their advisors select an Alden managed model for either all or part of a client’s por�olio.