Founded by its president, managing member and principal owner, James E. Bickley, GWM provides financial counseling and consulting, investment management and wealth management services to its clients. At GWM, a keen awareness exists that the firm must limit the services available so it may provide the focus necessary to address specific areas of need for clients’ financial strategies. It is with this mission in mind that GWM offers advisory services that are tailored to realize goals for accumulation of wealth and its preservation. Accordingly, the firm intentionally offers a limited scope of services so it may concentrate directly on the client’s need rather than a corporate need for expansiveness. Gibraltar was established in March 2003. Prior to engaging GWM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with the firm setting forth the terms and conditions under which GWM renders its services (collectively the “Agreement”). When a copy of this Brochure Document and the Brochure Supplement for the client’s investment adviser representative is not provided to the client at least 48 hours prior to signing the contract(s), client has five business days from the time at which they receive the Disclosure Brochure in which to cancel the contract, without penalty. GWM provides continuous investment advisory services to clients on a discretionary or non‐ discretionary basis and as of December 31, 2023, provided services for clients with a cumulative total of $150,274,806 in assets under management, of which $123,389,453 were managed on a non‐discretionary basis and $26,885,353 were managed on a discretionary basis. In addition, GWM advises on additional assets of $85,177,214 bringing GWM’s total assets under management/advisement to $235,452,020. When engaged by clients on a discretionary basis, GWM may, with the authorization of the client, trade any securities or rebalance any client’s portfolio without the client’s explicit direction and/or consent. GWM may also assist clients in the selection of an appropriate qualified money manager who will provide discretionary investment management services to a client. The firm does not have the discretion to hire or fire these independent managers without client consent. For this reason, assets managed by these independent asset managers do not meet the regulatory definition of assets under management by the firm and are, therefore, only included in the total assets under management/advisement referenced above. This Disclosure Brochure describes the business of GWM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of GWM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees or any other person who provides investment advice on GWM’s behalf and is subject to GWM’s supervision or control. Financial Consulting and Investment Consulting Services GWM may provide its clients with a broad range of comprehensive financial consulting and investment consulting services. These services include retirement, education, insurance, estate planning, asset and liability review, investments and tax and cash flow needs of the client. These services may be provided on a standalone basis or may be provided as part of the firm’s overall wealth management program (as set forth below). The services generally consist of the following, but may include other services as requested by the client: Financial Consulting
• Implementation of the firm’s wealth management system.
• Review of clients’ overall financial situation, including a written report of recommendations covering cash flow, tax planning, investment planning, estate planning and risk management.
• Preparation of a written Estate Planning Summary and recommendations.
• Preparation of a written Retirement Planning Report and recommendations.
• Preparation or update to a client’s existing financial plan. Investment Consulting
• An initial review and assessment of the past results of investment management services applied to investment portfolios.
• Recommendation of potential investment managers based on refinement of client’s investment objectives/needs.
• Ongoing monitoring and assessment of third-party adviser’s results relative to market indices and industry peers.
• Participation in client meetings with third-party investment manager representatives.
• Preparation of a written Asset Allocation Report and recommendation(s).
• Preparation of a written analysis of clients’ current investment portfolio and recommendations for change where appropriate. In performing its services, GWM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such third-party information. The client retains absolute discretion over all implementation decisions and is free to accept or reject any of GWM’s recommendations. Clients are advised that it remains their responsibility to promptly notify GWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the firm’s previous recommendations and/or services. Relative Strength Advisory Services The Relative Strength Advisory Service is a service offered by GWM. All client assets are held in the client’s name at a custodian of the client’s choosing or in a separate account by means of an association with a company sponsored plan or account. No assets are held or will be held by GWM. GWM will provide advice regarding the mutual funds or exchange-traded funds (ETFs) offered to the individual client through the client’s 401(k) or retirement plan. In some instances, GWM may provide assistance to the client in developing or refining a menu of fund or ETF alternatives. The advice and guidance provided by GWM is based upon results from an individual matrix created and maintained for each client and/or plan. The fund or ETF choices within the plan are compared to one another and those with the best Relative Strength measurements, as determined using the point & figure charts, are then provided as investment recommendations

as determined by the model selected by the client. Each quarter GWM will communicate to the client the funds or ETFs in which investments are to be made. Depending on which Fund/ETF Model (3 Fund Model or 3- ETF Model; 4 Fund Model or 4-ETF Model; or 5 Fund Model or 5-ETF Model) is selected for use by the client, it will be the client’s responsibility to equally invest in the top 3, 4 or 5 Fund or ETF Model on the recommended listing. By way of example, with the 3 Fund Model or 3-ETF Model, 34% of the allocation would be invested in the first fund/ETF choice and 33% invested in the remaining second and third choices. All menu options are evaluated not less than quarterly for purposes of providing guidance on fund or ETF changes and re-balancing. Increased transaction costs may be incurred for mutual fund and ETF models that are re-balanced more frequently. A more frequent re-balancing schedule may or may not improve model performance when factoring in the increased cost of transactions incurred. Investment Management and Wealth Management Services (Discretionary and Non- Discretionary) In addition to earning fees for consulting to personal and retirement investment accounts, GWM extends additional services to clients who are in need of special supervision of their financial assets and personal business matters through its offering of wealth management services. These services may include the financial counseling and consulting services described above as well as the non-discretionary management of investment portfolios. To implement a client’s plan and as detailed further in Item 8, GWM may allocate clients’ investment management assets among Independent Managers (defined below). The Independent Managers may utilize a variety of investments including, but not limited to, exchange-traded funds (“ETFs”), individual stocks, fixed income securities and mutual funds in accordance with the client’s investment objectives. GWM may also exercise discretionary authority over a client's account and implement trades for such clients itself through its relationship with a Financial Institution, as defined below. GWM tailors its advisory services to the individual needs of clients. The firm consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. GWM ensures that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. GWM is committed to know their clients and to understand and be aware of changes in circumstances that may require a realignment of investment parameters and priorities. Although the firm does not implement a standardized investment policy statement (“IPS”) for clients, it will work with clients to prepare an IPS or with Independent Managers who may prepare an IPS for the client, as n e e d e d . Clients may impose reasonable restrictions or mandates on the management of their account if, in GWM’s sole discretion, the conditions would not materially impact the performance of a portfolio strategy or prove overly burdensome to GWM’s management efforts. Use of Independent Managers As mentioned above, for clients who require investment management services GWM may recommend that clients authorize the active discretionary management of their assets by independent investment managers (“Independent Managers”). The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between GWM or the client and the designated Independent Managers. GWM renders services to the client relative to the non- discretionary recommendation of Independent Managers. GWM monitors and reviews the account performance and the client’s investment objectives. GWM receives an annual advisory fee which may be based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending an Independent Manager for a client, GWM reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that GWM considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, GWM’s investment advisory fee set forth above. In addition to GWM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Inter-Active Advisory Services For clients wishing to increase their investment knowledge, Gibraltar offers an interactive investment service. Inter-Active investing allows for an in-depth and collaborative approach for clients to gain insight from Gibraltar’s advisors on investment ideas and strategies. Our professionals work with and support the active investor looking to make independent investment decisions. The focus is on detailed analyses and explanations of specific strategies clients may wish to discuss in order to make more informed decisions about their personal investments. Interactive investing provides customized guidance that is a valuable resource for our clients seeking a more dynamic relationship with a focus on learning and mentoring as they make investment decisions. Sub-Advisory Services GWM serves in the capacity as a sub-adviser under a sub-advisory agreement with a general partner and investment manager to a designated amount of a private fund. As such, GWM may be compensated by a fixed or a percentage management fee and a portion of a performance fee equal to a percentage of net profits/net gains of the sub-advised assets of the private fund in accordance with the Fund formation, management and offering documents.