A. Description of the Advisory Firm Clockwise Capital LLC (hereinafter “ClockCap”), also d/b/a Clockwise Capital, is a Limited Liability Company organized in the State of Delaware. The firm became registered as an investment adviser in 2015. The principal owners are Garari Eli Mikel, & Ryan Jeffrey Guttridge. B. Types of Advisory Services Portfolio Management Services ClockCap evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. The firm bases its services on the individual goals, objectives, time horizon, and risk tolerance of each client. Depending on the needs of the client, ClockCap may create an Investment Policy Statement for the 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 • Risk tolerance ClockCap seeks to provide investment advices in accordance with the fiduciary duties owed to its accounts and without consideration of ClockCap’s economic, investment or other financial interests. ClockCap does directly invest the client’s portfolio. Clients should be aware that ClockCap offers to different investment strategies: its standard Professor Portfolios Strategy and its Clockwise Capital Strategy. The main investment difference is that the Clockwise Capital Strategy provides a more adaptive investment approach based on the market environment with the goal of providing positive market returns regardless of the market. Clockwise Capital Innovation ETF In January of 2022 ClockCap launched the Clockwise Capital Innovation ETF (“TIME”). This is the first opportunity for ClockCap to serve as an Investment Adviser to a Registered Investment Company. In addition, ClockCap will serve as the fund’s Subadviser. This fund is a diversified, actively managed exchange-traded fund (“ETF”) that will invest opportunistically in companies with distinct secular advantages. ClockCap balances the portfolio between next-gen companies and legacy enterprises that are adapting to the new paradigm at rates fundamentally undervalued by the market. Selection of Other Advisers ClockCap may direct clients to third-party investment advisers. Before selecting other advisers for clients, ClockCap will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where ClockCap is recommending the adviser to clients. Subadviser Services ClockCap may also act as a subadviser to advisers unaffiliated with ClockCap. These third-party advisers would outsource portfolio management services to ClockCap. This relationship will be memorialized in each contract between ClockCap and the third-party advisor. The advisors are Fiduciary Planning, LLC (CRD# 304104) and Legado Wealth Management LLC (CRD# 305263). Betterment Securities Betterment for Advisors is a digital wealth management platform generally serving independent investment advisory firms and advisors. Betterment LLC (“Betterment”), a registered investment advisor, serves as sub-advisor to Advisor’s clients (“Clients”). MTG LLC, dba Betterment Securities (“Betterment Securities”), a registered broker-dealer and member of FINRA and SIPC, serves as broker-dealer and custodian. The services provided by Betterment include: ● Goal-Based Investment Management: Betterment’s goal-based investment platform allows Advisors and Clients to identify multiple investment goals for each Client, each with specific portfolio allocations; ● Portfolio Construction Tools: Advisor and Advisor’s Clients have access to a set of Betterment constructed portfolio strategies, third-party model portfolio strategies, or, if applicable, Advisor constructed custom portfolio strategies (described below), each of which is comprised of low cost, index-tracking exchange-traded funds or mutual funds (the latter only for advisors who are approved to construct portfolios with Dimensional Fund Advisors mutual funds), and are able to customize the risk-level for each investment goal (collectively “traditional securities portfolios”); ● Automated

Investment Management Services: Betterment’s algorithms automate back- office tasks such as trading, portfolio management, and account rebalancing; ● Website and Mobile Application: Betterment’s website and mobile application provide a platform for account access and monitoring and delivery of account documentation and notices; and ● Advisor Dashboard: Advisors have access to a dashboard for purposes of monitoring and managing Client accounts. Certain Advisors offer to their Clients through Betterment’s platform custom portfolio strategies. If Advisor chooses to participate in this offering, Advisor may construct Custom Portfolios using Advisor's own investment methodologies, and Advisor’s Clients are able to use Betterment’s automated advice features, including automatic rebalancing, dividend reinvestment, tax loss harvesting, and asset location services. Advisor, and not Betterment, is responsible for managing any goal for which a Custom Portfolio is elected on the basis of a Client’s financial situation and investment objectives. Betterment will not evaluate whether any Custom Portfolio is suitable for any Client’s individual investment objectives, either at the time of election or on an ongoing basis. In addition, Advisor, and not Betterment, is responsible for disclosing to Advisor’s Clients any limitations to Betterment’s features caused by the election of a Custom Portfolio strategy. Betterment for Advisors offers several account types to Advisors and their Clients, such as taxable investing accounts, individual retirement accounts (IRAs), and cash management accounts (Cash Reserve). If Advisor’s Client also is employed by a company that utilizes Betterment’s 401(k) offering, Betterment at Work, Advisor may also manage Client’s Betterment 401(k) account if Client delegates investment management authority of their 401(k) to Advisor. Advisors can also view Clients’ Betterment checking account in their Advisor Dashboard, and Advisors can also view Clients’ health savings accounts (HSAs), if the Client has a Betterment HSA through their employer. Tailored Services and Investment Restrictions To use Betterment for Advisors’ services, Clients and/or their Advisors must inform Betterment of their financial situation and preferences through Betterment’s online application. To set up an investing account through the Betterment platform, Advisors and/or their Clients must select an investment goal, select a portfolio strategy (or follow the Advisor’s pre-set default portfolio strategy), and set an allocation (the risk level of the portfolio which corresponds to a ratio of stock to bonds), and may provide additional details about the Client’s investment objectives within Betterment’s interface. Guidance provided by Betterment is available in the online application, but Advisors are ultimately responsible for ensuring that Advisor’s Clients are placed in suitable investments. Advisors are also responsible for ensuring that the information they provide to Betterment about their Clients is accurate and up-to-date. Advisors can also restrict the securities purchased for Client accounts by electing Betterment’s Flexible portfolio strategy or Advisor’s Custom Portfolio strategy to choose their own asset classes and adjust allocation weights. Clients and/or their Advisors can influence Betterment’s discretionary management of their account by turning on or off several of Betterment automated portfolio management features. C. Client Tailored Services and Client Imposed Restrictions ClockCap 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 are not permitted to impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. 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. ClockCap does not participate in any wrap fee programs. E. Assets Under Management ClockCap has the following assets under management: Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $269,532,513 .00 $60,557,596 .00 December 2023