R.M. Davis, Inc. (the Company) is an independent, SEC-registered investment advisor with offices located in Portland, Maine and Portsmouth, New Hampshire. The Company provides investment management, financial planning, and other wealth management services to its clients. The Company has been in business since 1978 and independently owned exclusively by Officers and employees for its entire existence. The current shareholders of the Company are Geoffrey Alexander, CEO; Brian Noyes, Chairman of the Board; Wendy Laidlaw, CFO; Mark Fernandez; Scot Draeger, President; Dean Walker, COO; John Doughty, CIO; Matthew McFarland; and Michael Wood. As of December 31, 2023, the Company managed $6,315,757,763 of client assets ($6,307,038,376 on a discretionary basis and $8,719,387 on a non-discretionary basis). The Company engages in no business or profession other than investment management and wealth management. The Company offers the following services to its clients:
• investment management services
• portfolio consulting services
• wealth management and financial planning services
• trustee and trust administration services
• personal affairs management services The last three of these services are only available to investment management clients of the Company. The Company’s standard management service generally diversifies assets in a client’s account(s) among individual common stocks and bonds, mutual funds and exchange-traded funds, and/or cash. Based on client input and goals, certain client accounts may be invested exclusively or primarily in fixed-income instruments, including, but not limited to individual bonds, mutual funds or exchange-traded funds holding fixed-income securities/bonds, as well as cash. Based on client input and goals, as well as the discretionary judgement of Client Advisors, certain client accounts may also exclusively or primarily invest in equity securities, with little or no allocation to fixed- income. In all circumstances, investment management fees are charged on all securities and cash positions, as the firm considers cash an asset class that is used actively, as needed. The Company also occasionally provides portfolio services to clients on a one-time or consulting basis. The Company and the client will agree on the details of such engagement orally or in a brief letter of understanding. The Company directs its investment management services to the individual needs and objectives of each of its clients, after consultation with the client regarding

that client’s goals and objectives, time horizon, and risk tolerance. Clients may impose certain types of restrictions on investing in certain securities or types of securities (see below, Investment Discretion). For example, occasionally, a client will request that we invest an account exclusively in equity securities of companies within a specific market capitalization range, or within certain market sectors. We maintain flexibility to tailor account management consistent with client interest and direction, while maintaining overall investment discretion. The Company offers clients wealth management and financial planning services and general guidance over a wide variety of subjects, including estate and gift planning, education funding, financial forecasting, insurance issues, retirement and Medicare-related planning, and tax-related matters. The Company does not serve as attorney, accountant, or insurance professional for any client but makes occasional observations, suggestions, and/or provides general insights regarding matters appropriate for clients to discuss with their unaffiliated attorneys, accountants, or insurance agents. Clients should consult their attorney(s) and/or accountant(s) on all legal and/or accounting/tax questions and should consult their insurance agent(s) on insurance decisions. The Company’s personal affairs management service assists clients in organizing and dealing with their personal household financial affairs, such as balancing checkbooks, reconciling bank statements, paying bills (or preparing checks to pay bills), organizing tax return materials to be provided to their accountants, and/or assistance resolving administrative issues with governmental and corporate entities. Company Officers also serve, in appropriate circumstances, as trustee (or co-trustee) of client trusts, including but not limited to revocable living trusts, testamentary trusts, charitable remainder trusts and irrevocable life insurance trusts. Separate and independent fees are charged for trustee services. Such trustee fees are in addition to investment management fees applied to the trust account. When an Officer of R.M. Davis serves as trustee for a trust, an unaffiliated co-trustee, trust grantor, and/or beneficiaries are independently responsible for selecting R.M. Davis as investment manager for such trusts. In other words, an Officer of R.M. Davis serving as trustee for a trust is not responsible for the trust’s appointment of an investment manager and has no role in comparison shopping for that appointment.