Aspetuck Financial Management’s RMP - Risk Managed Portfolio Program (also referred to as “ RMP Program”) is a service of Aspetuck Financial Management, LLC (“AFM”). AFM is a limited liability company organized in the state of Connecticut. Patrick T. Byrne, sole owner, founded AFM in July 2005. RMP Program RMP program provides clients with portfolio selection, portfolio construction, investment selection, and ongoing investment management on a discretionary basis. Aspetuck Financial Management, LLC has fiduciary responsibility for giving advice to retirement plans, solo 401(k)s, IRAs, and to all clients. Our portfolio management program seeks to actively manage your portfolio’s risks, pursue higher income, and return opportunities, by making appropriate adjustments in your portfolio as market conditions change. Generally, assets in the program are invested with a minimum investment horizon of three years. Often, equity investments are made with the intention of owning the investment for several years. AFM are not day traders but instead long-term strategic investors. Our expectation is that over longer periods of time, investors are more likely to be rewarded. However, longer holding periods do not assure investors of a profit. AFM’s investment management program is designed to achieve your goal over longer periods of time and is not seeking to beat the market. Instead, it seeks to produce positive returns on a more consistent basis than riskier streakier higher risks and return strategies. Of course, there can be no guarantee that Aspetuck Financial Management’s investment program will achieve your goal. Lastly, equities are long term investments. When treated that way they will provide growth in your account over meaningful time periods of greater than three years. Absolutely, missing best days in the market by being out and or panic selling after a correction, will lower your long-term returns and compromise goal achievement. Introduction to Program The RMP Program offers four portfolio strategies to choose from with different risk & reward characteristics. Your account is managed according to one of these four portfolio strategies: 1. Aggressive Emphasis on maximizing long-term capital appreciation. Portfolio strategy seeks to produce total returns that approximate Aggressive benchmark returns over a five-year period. Expect similar principal risk and fluctuation to popular World Equity Indexes and acceptable over the intended five-year investment horizon. Portfolio will invest predominantly in U.S. and Foreign equity investments, global fixed-income securities, and U.S. cash-equivalent investments. Generally, equity market exposure approximately ranges from 70- 85%. Aggressive diversified benchmark components: Barclays US Aggregate Bond Index 10%, B a r c l a y s Euro Aggregate Gov’t 10+ Yr. EUR 2.5%, Barclays Euro Aggregate Non-Gov’t EUR 2.5%, US Treasury Bills 0-3 Month 10%, DJ Global World Real Estate Index 5%, DJ UBS Commodity Index 5%, MSCI EAFE index 20%, MSCI EM Index 10%, S&P 500 Index 20.00%, Russell 2000 Index 15%. 2. Moderate The primary objective is capital appreciation. Income is a secondary consideration. Portfolio strategy seeks to produce total returns that approximate the Moderate diversified benchmark returns over a five- year period. Expect a moderately lower principal risk and fluctuation than popular World Equity Indexes and acceptable over the intended five-year investment horizon. Portfolio invests in global equities, global fixed-income, and domestic cash-equivalents investments. Generally, equity market exposure approximately ranges from 50-70%. Moderate benchmark components: Barclays Euro Aggregate Government 10+ Yr. EUR 5%, Barclays Euro Aggregate Non-Government EUR 5%, Barclays US Aggregate Bond Index 15%, BofAML US Treasury Bills 0-3 Months Index 15%, DJ Global World Real Estate index 5%, DJ UBS Commodity Index 5%, MSCI EAFE Index 14%, MSCI EM Index 6%, S&P 500 Index 20%, Russell 2000 Index 10%. 3. Conservative Primary objective is current income and capital appreciation is secondary. The portfolio strategy seeks to produce total returns that approximate the Conservative diversified benchmark over a five- year period. Expect a significantly lower principal risk and fluctuation than major World Equity Indexes and acceptable over the intended five-year investment horizon. Portfolio holds global equities, global fixed- income, and domestic cash-equivalents investments. Generally, equity market exposure approximately ranges from 35-50%. Conservative benchmark components: Barclays Euro Aggregate Gov’t 10+ Yr. EUR 5%, Barclays Euro Aggregate Non-Government EUR 5%, Barclays US Aggregate Bond Index 35%, BofAML US Treasury Bills 0-3 Months Index 15%, DJ Global World Real Estate Index 5%, DJ UBS Commodity Index 5%, MSCI EAFE Index 7%, MSCI EM Index 3%, S&P 500 Index 15%, Russell 2000 Index 5%. 4. Risk Averse Primary objective is current income, and stability of principal is secondary. Portfolio strategy seeks to produce total returns that approximate the Risk Averse diversified benchmark over five years. Expect lower principal risk and fluctuation and is acceptable over the intended five-year investment horizon. Portfolio will consist of a determined allocation among domestic cash-equivalents, global fixed-income securities, and global equity investments. Generally, equity market exposure approximately ranges from 20-35%. The Risk Averse benchmark components: Barclays Euro Aggregate Government 10+ Yr. T EUR Index 5%, Barclays Euro Aggregate Non-Gov’t EUR Index 5%, Barclays US Aggregate Bond Index 40%, BofAML US Treasury Bills 0- 3 Months Index 20%, DJ Global World Real Estate Index 5%, DJ UBS Commodity Index 5%, MSCI EAFE Index 3%, MSCI EM Index 2%, S&P 500 Index 10%, Russell 2000 Index 5%. Index Definitions: S&P 500 Index is composed of 500 largest U.S. companies by market capitalization. These widely held stocks often used as a proxy for the U.S. equity market. The Russell 2000 Index measures the performance of the small-cap segment of the U.S. equity universe. It includes approximately 2000 of the smallest securities based on a combination of their market cap and current index membership. Barclays U.S. Aggregate Bond Index is composed of U.S. securities in Treasury, Government-Related, Corporate, and Securitized sectors that are of investment-grade quality or better, have at least one year to maturity and have an outstanding par value of at least $250 million. Barclays Emerging Market Bond Index includes fixed and floating rate USD-denominated debt from emerging markets in the following regions: Americas, Europe, Middle East, Africa, and Asia. DJ Global World Real Estate Total Return US Dollar. Global Real Estate Index is designed to represent general trends in eligible real estate equities worldwide. MSCI EAFE Index is a free float-adjusted market capitalization weighted index designed to measure the developed markets’ equity performance, excluding the U.S. & Canada, for 21 countries. MSCI Emerging Markets Index is a free float-adjusted market capitalization index that measures emerging market equity performance of 22 countries. MSCI All Country World Index, which is a free-float-weighted index of large- and mid-cap companies in nearly all equity markets around the world, including developed and emerging. BofAML US Treasury Bills 0-3 Month Total Return US dollar is comprised of a Treasury Bills that mature in three months that are rolled over into new issues. DJ UBS Commodity Index, Total Return, U.S. Dollar, is composed of commodities traded on U.S. exchanges, except for aluminum, nickel, and zinc, which trade on the London Metal Exchange. Barclays Euro Aggregate Gov’t 10+ Year, total return, euro denominated, aims to track the performance of the European Government Bond with maturities of 10 years plus, as closely as possible. The index offers exposure to Euro denominated investment grade government bonds issued by EMU member states with an original term of 10 years or greater. Barclays Euro Aggregate Non-Gov’t total return, euro denominated, index tracks the fixed-rate, investment-grade euro-denominated corporate bond market. The index includes publicly issued securities from industrial, utility, and financial companies that meet specified maturity, liquidity, and quality requirements. Investment Adviser Services and Responsibilities Investment advisory services involve a review of current investment holdings, preparing a personal Investment Policy Statement (“IPS”) that addresses a client’s portfolio objective, risk tolerance, income needs, liquidity requirements, investment horizon, tax implications, and financial circumstances. The client’s IPS determines which portfolio strategy is suitable, what investments are suitable, and how the account will be managed (for growth, for income & growth, etc.). Ultimately, it is the client’s decision to invest in any RMP portfolio. AFM is responsible for managing client accounts on a discretionary basis, executing transactions to manage client accounts. AFM is not responsible for performance of discretionary accounts where client is instructing the Investment Adviser on trades in an account or securities clients wants in account that are contrary to AFM recommendation. Summary of Services □ Portfolio Analysis and Recommendation

- Our IPM - Improving Portfolio Management™ Service reviews your current portfolio for ways to improve its construction and performance. Our recommendations seek to manage overall portfolio risks, enhance your portfolio's income, and return opportunities over time. The service assists with the selection of a suitable portfolio based on many factors. □ Establishment of an Investment Policy Statement - creation of your own Investment Policy Statement (IPS). Your IPS determines a suitable portfolio strategy and guides us on how to manage your assets according to your objective, needs, and circumstances. Investment Policy Statement is reviewed during optional account review or can be updated by client as their circumstances change and or risk preference. □ Dedicated Experienced Investment Adviser - to provide ongoing investment advice, ancillary retirement planning services, as well as caring responsive service. Above all else, AFM believe you will benefit most by having a long-term relationship with a trusted Investment Advisor who is familiar with your circumstances, needs, and goals. □ Ongoing Account Management and Investment Supervision of Model Securities – seeks to factor in global economic and market conditions, investment fundamentals, tax law changes, and your goals. □ Account Review – clients may request an account review either by telephone or in person. Although, AFM are available anytime during business hours to speak to you. □ Web Based Account Information – balance, positions, transactions, and cost basis information. □ Reporting - Monthly brokerage account statement, Morningstar Client Account Growth Chart Net Investment report (account performance), Morningstar quarterly billing invoice, and Brokerage firm realized gains/losses report, and year-end tax statements. □ Market and Portfolio Updates – e-mail communications, newsletter, events. □ Plan-To-Enjoy Life® Lifecycle Financial Planning Services– Our planning services recommend strategies that help a client with tax management, college planning, retirement planning, estate planning, small business retirement plan selection. Recommended planning strategies are executed through appropriate professionals such as a tax accountant, estate attorney, etc.
• Tax management strategies seek to defer and or reduce current income taxes.
• Estate planning and strategies seek to reduce estate taxes, income taxes, and distribute assets according to your wishes using a Trust(s) or appropriate account registrations.
• Retirement strategies include retirement income needs analysis, retirement income strategies, and retirement plan choices.
• Educational cost analysis and college savings strategies. Clients receive ancillary planning services at no charge, upon request. Aspetuck Financial Management does not offer legal, insurance, or accounting advice to our clients. However, AFM may from time to time discuss or recommend financial strategies, products, and services which have tax and or legal implications. Clients are urged to consult with their own legal and tax adviser with respect to their specific situations, and to act on their tax, insurance, and or legal advice. Adviser Services Under ERISA 3(38) Investment Manager Client/Plan Sponsor may also hire the services of Adviser for the purpose of hiring an investment manager” under ERISA Section 3(38) and participate in the RMP Program. The adviser will use an independent Custodian, Third Party Administrator/Record Keeper services for portfolio management technology, custodial services, record keeping, and administration. Client/Plan Sponsor is provided with a variety of investment-related services. A description of the services to be provided and the parties providing same is set forth in the Services section. Adviser acknowledges Its co-fiduciary status to Plan Sponsor. Adviser will manage Client/Plan Sponsor's assets through the Risk Managed Portfolio Program (Program). The adviser will have full discretionary authority and control to make the actual investment decisions. Adviser shall exercise discretion regarding the selection of Plan investments. The manager may select, monitor, remove and replace the investment options offered under the plan, subject to the terms of the plan documents and its investment policy statement. Adviser will help plan participants with investment education, set asset allocation and define investment risk. Adviser will assist in the education of the participants in the Plan about general investing principles. And the investment alternatives available under the Plan. Adviser will assist in the group enrollment meetings to explain retirement plan participation, savings and investing for eligible employees. Adviser agrees to perform the functions outlined in the Plan Sponsor’s Investment Policy Statement and comply with ERISA 401(k) plan rules. As a fiduciary under the Plan, Adviser will assist Plan Sponsor with the following:
• Create, maintain, update, and execute Plan Investment Policy Statement.
• Ensure that the Plan offers sufficient asset classes with different and distinct risk/return profiles, so each participant can prudently diversify his/her account.
• Manage the assets under its supervision in accordance with the guidelines and objectives outlined in Agreement, and Investment Policy Statement.
• Operating Plan Sponsor’s Investment Management Committee (Committee).
• Exercise full investment discretion with regards to buying and selling investments in model portfolios.
• Annual review of model performance, investment option performance, and annual costs of plan.
• Communicate to the Committee all significant changes pertaining to the assets it manages or the investment management firm itself. Changes in ownership, organizational structure, and financial condition.
• Make available to the participants appropriate educational materials and opportunities within the parameters of applicable U.S. Department of Labor guidance. Third Party Plan Administrator will also make available educational materials for Plan Sponsor and participant.
• Adviser will provide ancillary financial/retirement planning services on an ad hoc basis.
• Use, with respect to the Plan, the same care, skill, prudence, and due diligence under the circumstances then prevailing that experienced investment professionals acting in a like capacity and fully familiar with such matters would use in like activities for like retirement plans with like aims in accordance and compliance with ERISA and all applicable laws, rules, and regulations.
• Avoid prohibited transactions and conflicts of interest. Abide by PTE 2020 20 rule. Written acknowledgement of fiduciary status under the PTE. The Plan Sponsor will retain a financial intermediary to serve as custodian. The assets of the Plan will be held in trust. The Custodian is responsible for the safekeeping of the Plan’s assets and maintaining records. All duties and responsibilities of the Custodian shall be identified and agreed to in a separate Custodial agreement. The duties and responsibilities of the Administrator & Recordkeeper shall be identified and agreed to in a separate Plan services agreement by the Plan Sponsor. Administrator/Record Keeper Adviser will provide quarterly Plan Participant account statements with investments held, transaction activity, and account performance. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS AFM offers the same suite of services to all 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/ may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent AFM from properly servicing the client account, or if the restrictions would require AFM to deviate from its standard suite of services, AFM reserves the right to end the relationship. Advisory services are tailored to individual needs of client by placing them into a suitable portfolio strategy that supports their goals, need for income and or growth, liquidity, and circumstances. Underlying investments are supportive of portfolio strategy. For example, a client that needs current income would own fixed-income securities and dividend paying securities. A suitable portfolio model is the Conservative strategy model. Clients may impose restrictions on investing in certain securities or types of securities. And may request that certain securities or types of securities be purchased for account. They may even request minimum cash-equivalent amounts (liquidity) for their account(s). Client accounts can be customized or managed by one of our suitable portfolio strategies. WRAP FEE PROGRAM A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. AFM does not participate in any wrap fee programs. ASSETS UNDER MANAGEMENT As of December 31, 2023, AFM had $ 126,453,710 in discretionary assets under management and $0 in non- discretionary assets under management.