A. Description of the Advisory Firm B. Types of Advisory Services Retirement Rollovers – Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If The Foundry recommends that a client roll over their retirement plan assets into an account to be managed by The Foundry, such a recommendation creates a conflict of interest if The Foundry will earn new (or increase its current) compensation as a result of the rollover. If The Foundry provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), The Foundry is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by The Foundry, whether it is from an employer’s plan or an existing IRA. Custodian Charges – Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker- dealer/custodian for client accounts, The Foundry generally recommends that Charles Schwab & Co., Inc. serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. There can be no assurance that Schwab will not change their transaction fee pricing in the future. Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Cash Positions The Foundry continues to treat cash as an asset class. As such, unless determined to the contrary by The Foundry, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating The Foundry’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), The Foundry may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, The Foundry’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, The Foundry shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund available on the custodian’s platform, unless The Foundry reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, an indication from the client of a need for access to such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within The Foundry’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes or anticipated client withdrawals. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of The Foundry’s unmanaged accounts. Portfolio Activity The Foundry has a fiduciary duty to provide services consistent with the client’s best interest. The Foundry will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions or withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when The Foundry determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by The Foundry will be profitable or equal any specific performance level(s). Other Assets A client’s account(s) may hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of The Foundry. There may be other securities owned by the client for which The Foundry does not maintain custodian access and/or trading authority. Generally (with potential exceptions), The Foundry does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Despite these limitations, The Foundry: (1) upon client request, shall remain available to discuss these securities; (2) shall generally consider these securities as part of the client’s overall asset allocation; and (3) include the market value of all such securities for purposes of calculating its advisory fee. If/when liquidated, it should not be assumed that the replacement securities purchased by The Foundry will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by The Foundry) will be profitable or equal any specific performance level(s). Independent Managers The Foundry may allocate some or all of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”), including SEI Investment Management Corp., in accordance with the client’s designated investment objective(s). Typically, The Foundry will identify an appropriate strategy or portfolio (or a blend thereof) offered by the Independent Manager(s), and the Independent Manager(s) will then implement such strategy in the client account by allocating among other unaffiliated third-party managers. In such situations, the Independent Manager(s) will have day-to-day responsibility for the ongoing allocation between third party managers, and such third-party managers will have investment authority over the management of the allocated assets. The Foundry will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The factors The Foundry considers in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, The Foundry’s advisory fee as set forth in Item 5. Variable Annuity Sub-divisions The Foundry may render discretionary investment management services to clients relative to variable annuity products that they may own. In so doing, The Foundry directs the allocation of client assets among the various mutual fund sub-divisions which comprise the variable annuity product based upon the investment

objectives of the client. Such services are subject to The Foundry’s investment advisory fee as outlined in Item 5 below. Cybersecurity Risk The information technology systems and networks that The Foundry and its third-party service providers use to provide services to The Foundry’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in The Foundry’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and The Foundry are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although The Foundry has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that The Foundry does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. ERISA Plan and 401(k) Individual Engagements Trustee Directed Plans. The Foundry may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, The Foundry will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). The Foundry will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. Participant Directed Retirement Plans. The Foundry may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between The Foundry and the plan. For such engagements, The Foundry shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by The Foundry), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Client Retirement Plan Assets. If requested to do so, The Foundry shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, The Foundry shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. The Foundry’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. The Foundry will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify The Foundry of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by The Foundry to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of The Foundry calculating its advisory fee. Use of Mutual and Exchange Traded Funds The Foundry utilizes mutual funds and exchange traded funds for its client portfolios. In addition to The Foundry’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Non-Discretionary Service Limitations Clients that determine to engage The Foundry on a non-discretionary investment advisory basis must be willing to accept that The Foundry cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that The Foundry would like to make a transaction for a client’s account, and client is unavailable, The Foundry will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations In performing our services, The Foundry shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify The Foundry if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Foundry) will be profitable or equal any specific performance level(s). Disclosure Brochure A copy of The Foundry’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and The Foundry. The Foundry will customize a program for each individual client. As part of our client discovery process, we will get to know the client’s specific needs and requirements and develop a plan to be executed by The Foundry on behalf of the client. Financial needs and priorities will be identified and assessed. Preferences and any specific plan restrictions expressed by the client will also be noted. The Foundry will then begin analyzing plans and developing recommendations through our initial plan implementation and an iterative process of client review meetings. The investment adviser representatives of the Foundry strongly weigh the client's time horizon when considering appropriate allocations. For certain clients, we develop time- segmented portfolios allocations that are designed to match the dates at which portfolio distributions will be required. Goals-based investing can divide portfolio assets into sub- portfolios based on the specific goals identified by the client (e.g., college funding, new home fund, retirement funds). Each sub-portfolio can have its own unique risk profile. 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. The Foundry does not participate in any wrap fee programs. C. Customized Services and Client Imposed Restrictions D. Wrap Fee Programs As of December 1, 2023, The Foundry has $143,380,000 in assets under management on a discretionary basis, and $55,370,000 in assets under management on a non-discretionary basis, for a total of $198,750,000 in assets under management. Investment Advisory Fees The Foundry’s standard investment management fee schedule for investment advisory services only is as follows: 0.75% on the first $1,000,000 0.65% on the next $9,000,000 0.50% on all assets over $10,000,000 The Foundry’s investment management fee schedule to include financial planning services is as follows (a minimum annual fee of $5,000 will apply): 1.00% on the first $1,000,000 0.80% on the next $9,000,000 0.50% on all amounts over $10,000,000 The Foundry’s investment management fee schedule for 401(k) profit-sharing plans is as follows: 0.50% on the first $3,000,000 0.40% on the next $7,000,000 0.30% on all amounts over $10,000,000 The Foundry’s investment management fee schedule for SIMPLE IRA accounts is as follows: 0.50% on all plan assets Grandfathered Schedule Clients engaged with The Foundry prior to October 1, 2023 have been grandfathered under their current fee schedule as follows: 0.70% on the first $500,000 0.60% on the next $1,500,000 0.50% on the next $8,000,000 0.40% on all assets over $10,000,000 Custodian Charges – Additional Fees As discussed below at Item 12 below, when requested to recommend a broker- dealer/custodian for client accounts, The Foundry generally recommends that Schwab E. Assets Under Management