A. Description of the Advisory Firm Stirlingshire RIA LLC (hereinafter “STIRLINGSHIRE”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in June 2023, and the principal owner is Stirlingshire Investments, Inc.. B. Types of Advisory Services Hybrid Robo-Advisory Portfolio Management Services STIRLINGSHIRE provides online “hybrid robo-advisory” portfolio management. This entails the use of algorithm-based portfolio management advice. These automated investment solutions are customized to each client and based on individual characteristics, such as the client’s age, risk tolerance, income, and current assets, among others. STIRLINGSHIRE’s investment advisory personnel oversee the algorithm. The approach is "hybrid" in that the portfolio management process relies upon both algorithms and portfolio management by the portfolio manager, each designed to be utilized across multiple clients. Clients are encouraged to update their account/questionnaire with any change in their objectives, risk tolerance, or other pertinent information, as that information factors into the portfolio’s composition. Services Limited to Specific Types of Investments STIRLINGSHIRE generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. STIRLINGSHIRE may use other securities as well to help diversify a portfolio when applicable. 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. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client 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. C. Client Tailored Services and Client Imposed Restrictions STIRLINGSHIRE provides online “hybrid robo-advisory” portfolio management. Client accounts are invested into a thematic portfolio, depending on the client’s individual objectives. Through the internet, the client interface is automated to the extent possible. The approach is "hybrid" in that the portfolio management process relies upon both algorithms and portfolio management by the portfolio manager, each designed to be utilized across multiple clients. The client’s investment profile dictates the portfolio strategies, which in turn may impose restrictions in investing in certain securities or types of securities. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. STIRLINGSHIRE does not participate in wrap fee programs. E. Assets Under Management STIRLINGSHIRE has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $0 August 2023