Baldwin Brothers was founded in 1974. For over 40 years we have been redefining the client experience through highly personalized attention, by crafting portfolios and strategies that reflect the individual point of reference of the people we work with. The results are investments that have true and meaningful impacts on our clients’ financial futures, the next generation, and the world around us. Baldwin Brothers is owned, both directly and indirectly, by members of the senior management team, including William Marvel, Taylor Baldwin, Andrew McIntire and Eric Strand. Description of Advisory Services: Our client base consists of individuals, high net worth individuals, trusts, estates, charitable organizations, pension and profit-sharing plans, pooled investment vehicles, business development companies, an investment adviser firm, and a variety of business entities. The majority of our business (approximately 85%) involves providing investment supervisory services for our clients. In addition, we provide investment advice to clients by monitoring accounts supervised elsewhere, and, in certain circumstances, through financial plans. Approximately 10% of the services we provide to our clients involve advice unrelated to securities. Financial Planning We offer financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. Clients understand that when are engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. We meet with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. The financial plan may include both long and short-term considerations, depending upon the individual scenario. Upon completion a plan is presented to the client and the client is provided with recommendations that are deemed to be compatible with the client’s stated goals and objectives. An implementation schedule is reviewed with the client to determine which steps will be pursued, and with whom the steps may be accomplished. The client is under no obligation to utilize the Firm to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Investment Management Baldwin Brothers provides investment advisory services to clients on both a discretionary and non-discretionary basis. Baldwin Brothers has discretionary authority over the accounts of our investment advisory clients. In some cases, Baldwin Brothers meets informally with the client from time to time to discuss specific investment goals and strategies. While these discussions do not result in formal restrictions on our discretionary authority, they provide guidance for our investment decision- making processes. Baldwin Brothers also offers advice on equity securities, including exchange-listed securities, securities traded over the counter, and securities of foreign issuers. We provide advice on warrants, corporate debt securities, commercial paper, municipal securities, mutual fund shares, United States government securities, option contracts on securities, and futures contracts on intangibles. Advice is also provided on interests in partnerships that invest in real estate, oil and gas, venture capital and leveraged buyout funds. In addition, Baldwin Brothers occasionally creates pooled investment vehicles to invest third- party (including clients’) funds or to invest in other investment funds, or directly in early and expansion stage private companies as well as funds that employ a specific investment strategy or invests in issuers which meet certain criteria. Baldwin Brothers also serves as the investment advisor to these privately offered pooled investment vehicles. These pooled investment vehicles are available only to persons who

are “accredited investors” under the Securities Act of 1933, or, in the case of some of the funds, “qualified purchasers” under the Investment Company Act of 1940, as amended. These pooled investment vehicles are not made available to the general public and are not registered investment companies. Baldwin Brothers’ pooled investment vehicles include: (a) those formed to meet a high minimum investment requirement for a third-party venture capital or other investment fund (“Single Investment Funds”) and (b) those formed to engage in a particular investment strategy holding securities from a variety of issuers (“Strategic Funds”). These types of pooled investment vehicles are described below. Single Investment Funds Our Single Investment Funds pool certain clients’ investments to meet a minimum investment requirement in a single fund. Withdrawals from the Single Investment Funds are subject to the redemption and withdrawal restrictions in the underlying fund. Single Investment Funds are typically organized as limited liability partnerships with Baldwin Brothers serving as the Management Agent. Sub-Advisors In certain circumstances, Baldwin Brothers may recommend the services of a sub-advisor for clients who choose to invest in a fixed income strategy. The terms, compensation, and conditions under which the sub-advisor is engaged are fully discussed with the client prior to implementing the strategy. In addition, Baldwin Brothers may also recommend the services of sub-advisors for some of their private funds and a limited number of retail clients. Tailored Relationships Baldwin Brothers tailors advisory services to the individual needs of the client. Clients may impose restrictions on investing in certain securities or types of securities. All limitations and restrictions placed on accounts must be presented to Baldwin Brothers in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs Baldwin Brother does not participate in a Wrap Fee Program. Client Assets As of December 31, 2023, Baldwin Brothers’ assets under management were $2,281,166,083; $2,209,616,933 is managed on a discretionary basis; and $71,549,149 is managed on a non- discretionary basis.