Firm History and Ownership Washington Trust Advisors, Inc., (hereinafter the “Adviser”, the “Firm” or “WTA”) is an investment adviser registered with the U.S. Securities and Exchange Commission (the “SEC”) with its principal place of business located in Wellesley, Massachusetts and a second office location in New Haven, Connecticut. The Adviser offers wealth management and holistic financial planning services and has been registered with the SEC since 1983. The Adviser is a wholly owned subsidiary of The Washington Trust Company, of Westerly (“Washington Trust”) and operates under Washington Trust Wealth Management®. Washington Trust is a wholly owned subsidiary of Washington Trust Bancorp, Inc., the bank holding company. Washington Trust Wealth Management® is a registered trademark of The Washington Trust Company, which has licensed its use to its parent, affiliates, and subsidiaries, including Washington Trust Advisors, Inc. Investment Management Services The Adviser offers wealth management/financial planning services; individual portfolio management; model portfolios; independent third-party money manager selection programs; and portfolio management for institutional and high-net- worth clients. The Adviser offers clients a selection of separately managed accounts (managed by other advisers), mutual funds, exchange-traded funds (“ETFs”), fixed income, stocks, among other services noted below. Note for international clients: This information is required by law and is not a promotion of the Adviser’s products and services. Further, not all products are available to non-U.S. Residents. Wealth Management and Financial Planning Services The Adviser through its Team of Wealth Management Professionals provide financial advice in the form of a financial plan designed to address the client's financial and life goals, and the plan typically includes strategies to help meet those goals. To develop a plan, the Adviser assesses a client’s current financial status, tax status, future goals, life goals, investment objectives and risk tolerance, typically by analyzing the client’s balance sheet, income statement, insurance coverage, wills and trusts, estate and income taxes, company benefit plans, and other relevant materials. The Adviser tailors each financial plan to the client’s individual needs and objectives. In that process, a client may impose reasonable restrictions on investing in certain securities or types of securities. Individual Portfolio Management Customized / Tailored Portfolios The Adviser provides tailored discretionary asset management services to client’s accounts held at client- selected brokers and other custodians. Prior to entering into an agreement with a client, the Adviser discusses with the client its investment objective, risk tolerance, financial condition, investment restrictions, time horizon, liquidity needs and other factors that may apply to the portfolio of assets that the Adviser is expected to manage. The scope of the Adviser’s authority, the client’s investment objectives and restrictions, as well as the strategy that the Adviser is expected to employ in managing the assets, as well as the Adviser’s fees for performing its investment management services, are memorialized in the investment management agreement between the client and the Adviser. The Adviser has entered into an agreement with a broker to create certain individual bond portfolios for select clients. Such accounts may also invest in fixed income ETFs. Clients may impose reasonable restrictions on the Adviser’s authority to invest client assets in certain securities, certain types of securities, or certain industry sectors. Further, clients have the option to hire The Washington Trust Company, the Adviser’s parent company, to serve in the capacity as a Fiduciary (Corporate Trustee) over their personal or family Trusts. The Adviser’s investment recommendations may include advice regarding the following types of securities noted in the chart below. The Adviser, however, is generally not limited to the types of securities and other financial instruments that it may employ in managing client assets or providing recommendations, except as agreed with the client. In an investment advisory account, we may limit available investments based on factors such as your risk tolerance, net worth, age, investment objectives and experience. Mutual Fund Shares United States Governmental Securities Exchange Traded Funds (“ETFs”) Corporate Debt Securities (other than commercial paper) Fixed Income Securities (investment and non- investment grade) Options Contracts on Securities Individual Stocks (domestic and foreign) and Preferred Stocks Private Placements for Accredited Investors and Qualified Purchasers Model Portfolios & Individual Equity Strategies Nationwide Advisory Solutions (formerly referred to as Jefferson National Life Monument Advisor Annuity) (“Monument Advisor Model Portfolios”) The Adviser offers portfolio management services to clients in connection with the selection and monitoring of a model portfolio. Each model portfolio is held in a separate Monument Advisor Variable Annuity which represents an allocation to a selection of sub-accounts that are designed to mimic mutual funds with different allocations among equity, fixed income, hybrid, and alternative strategies. In addition, a selection of sub-accounts can be custom designed for an individual client under certain circumstances. Individual Equity Strategy (“Focused Thematic Growth Strategy”) The Adviser offers individual equity security investment portfolio management services using a focused thematic investment approach – The Focused Thematic Growth Strategy. The Strategy is designed to produce long-term growth of capital and income by investing in a diversified, actively managed portfolio of common stocks. As such, the Strategy is suitable only for investors with longer time horizons who can withstand a high degree of principal volatility. The Adviser will manage these accounts in accordance with the Strategy on a discretionary basis only. For clients or prospective clients interested in this service, the Adviser will seek to determine the client’s or prospective client’s investment goals and objectives to assess the suitability of the Focused Thematic Growth Strategy to the client's financial circumstances. Once invested through the Focused Thematic Growth Strategy, and to ensure the client's account continues

to be managed in a manner fitting the client's financial circumstances, the Advisor will seek to maintain client suitability information in the client's file. As such, we request that clients notify us promptly of any material change to his/her financial circumstances. Third-Party Money Manager Programs The Adviser currently has legacy accounts for which the clients invest in Third-Party Money Manager Accounts (i.e., Separate Account Managers or “SAM”). The SAM selected by the Adviser have discretion to determine the underlying securities to be bought or sold within the account(s), subject to reasonable restrictions imposed by the client. The Custodian may have the discretion to replace the SAM within their Programs. Due to the nature of these programs, each of the chosen SAM is obligated to provide the client with a separate disclosure document outlining their services. These legacy accounts are custodied at Schwab and Morgan Stanley. Investment Advisory Services Individual Portfolio Advice The Adviser may on occasion provide non-discretionary asset advisory services to clients for the management of their assets. Prior to entering into an agreement with a client, the Adviser discusses with the client its investment objective, risk tolerance, financial condition, investment restrictions, and other factors that may apply to the pool of assets that the Adviser is expected to consider when making recommendations. The Adviser’s fees for performing its investment advisory services, are eventually memorialized in the investment advisory agreement between the client and the Adviser. Employee Benefit Plans The Adviser may on occasion offer plan sponsors and other fiduciaries to employee defined-contribution and defined-benefit plans advice on the management and/or the selection of plan and/or participant investment options under ERISA Section 3(21). In such event, the Adviser will be responsible for assisting plan fiduciaries in the identification of potential investment options, based on various factors, such as the size of the plan, the number of participants, and the nature of the participants. Among other things, the Adviser will help the plan fiduciary prepare a written investment policy statement for the plan. The Adviser will assist the plan fiduciary in monitoring and reviewing the performance of the investment options. From time to time, the Adviser may recommend to a plan fiduciary the addition of additional plan options, and the removal and replacement of plan options. Under this scenario, the ultimate decision rest with the plan fiduciary. In addition, the Adviser may manage the plan assets on a discretionary basis in accordance with the plan’s investment policy statement and will be a fiduciary to the plan under ERISA Section 3(38). These arrangements are separate and distinct from when the Adviser is providing advice on the underlying holdings of the plan and the plan fiduciary makes the final decisions on whether to add or remove the underlying holding as an investment option for plan participants. Other Investments and Other Services The Adviser may from time to time provide a client specialized investment manager or advisory services, other than as described above. In those cases, the scope of the services, as well as the fees the Adviser is to receive, are negotiated between the client and the Adviser. At no time will the Adviser accept or maintain custody of a client’s funds or securities, except for the limited authority outlined in Item 15 – Custody. All Client assets will be managed within their designated account(s) at the Custodian, pursuant to the Client investment advisory agreement, please see Item 12 – Brokerage Practices. Risks of Investment Investing in securities involves the risk of loss that clients should be prepared to bear. We manage the risks associated with the securities and Portfolios that we manage for our clients. The following are a few of the key types of risks: Equity Securities The value of the equity securities, including mutual funds and ETFs that invest primarily in traditional asset classes such as equities and fixed income, is subject to market risk, including changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities.
Debt and Other Fixed Income Securities Debt securities are subject to interest rate, market, and credit risk. Interest rate risk relates to changes in a security’s value as a result of changes in interest rates generally. Market risk relates to the changes in the risk or perceived risk of an issuer, country, or region. Credit risk relates to the ability of the issuer to make payments of principal and interest. The values of income securities may be affected by changes in the credit rating or financial condition of the issuing entities.
Risk of Loss of Investment No guarantee or representation is made that the Adviser’s strategy for managing a client’s account, or its recommendations will be successful or that a client’s investment objective(s) will be achieved. A client could experience a partial or total loss of its assets.
Alternative Strategies Certain hedging techniques, arbitrage strategies, distressed securities, options, long/short selling, and leverage employed by the mutual funds, ETFs, fixed income, or structured investments held inside of a client Portfolio will expose the portfolio(s) to additional volatility and risks. Short selling strategies employed by the particular investment involves the risk of potentially unlimited increase in the market value of the security sold short, which could result in potentially unlimited loss for the funds.
Cybersecurity Networks and systems could be subject to breach and client data may be exposed. We maintain a Written Information Security Program and Information Response Plan. In conjunction with our Parent Company’s Information Assurance and Technology Team we conduct periodic risk assessments of information security controls and practices.
For other risks that may be associated with your account, please contact your Wealth Advisor or Portfolio Manager. Assets Under Management As of December 31, 2023, the Adviser managed $1,886,752,472 of client assets on a discretionary basis and $22,194,788 on a non-discretionary basis for a total of $1,908,947,260 in assets under management. Clients may request more current information at any time by contacting the Adviser.