Gaylan Abood founded Cambridge Advisors Inc. in 1990 as an independent, fee-only investment advisor. Cambridge Advisors Inc. has always been owned 100% by employees of the firm. Gaylan has since retired and the current owners of the firm are Lori Liffring, President and Chief Compliance Officer, who owns 50%; Michael Bridgman, Vice President, who owns 25%; and Justin Anderson, Vice President, who owns 25%. Cambridge Advisors Inc. provides investment management and financial planning services to clients. Investment management includes giving continuous investment advice or making and implementing investment decisions on a discretionary basis in client accounts. Having discretion on the account means that we do not need to ask for specific client consent before each buy or sell transaction. Our investment management services include financial planning services that do not always result in a written financial plan. At the request of the client, Cambridge Advisors will provide a written financial plan at no additional charge. Our portfolios are custom-tailored to each client’s individual needs, risk tolerance levels, and preferences and may include individual securities, mutual funds, and/or exchange traded funds. Portfolio managers talk with clients to learn about their situation and discuss what types of investments may be appropriate for them and guidelines for the management of the account. Clients may request that certain securities or types of securities (such as securities issued by tobacco or alcohol companies) not be held in their accounts. Cambridge Advisors offers stand-alone financial planning services as a separate service for those clients that do not need our investment management services or do not meet our minimum account value of $500,000. Our financial plans include advice and recommendations on the following topics: retirement planning, retirement income planning, legacy planning, asset allocation, life insurance analysis, cash flow analysis, and/or special goal planning. Cambridge Advisors Inc. also provides investment advisory services to retirement plans. Our retirement plan services include: A. Fiduciary Consulting Services
• Investment Policy Statement Preparation. Advisor will help Client develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. Cambridge Advisors Inc. Page 5 August 2023
• Non-Discretionary Investment Advice with Trading Authority. Advisor will provide Client with non-discretionary investment advice regarding the purchase or sale of securities of the Plan. Advisor will not have investment discretion to make decisions to buy or sell securities of the Plan. Client will be solely responsible for determining whether or not to buy or sell securities of the Plan. Client grants Advisor the power and authority to carry out these decisions by Client by giving instructions, on behalf of Client, to brokers and dealers and the qualified custodian(s) of the Plan for Advisor’s management of the designated retirement plan assets. Client authorizes Advisor to provide a copy of this Agreement to the qualified custodian or any broker or dealer, through which transactions will be implemented on behalf of Client, as evidence of Advisor’s authority under this Agreement.
• Investment Selection Services. Advisor will provide Client with non-discretionary investment advice about asset classes and recommendations of investment options consistent with ERISA section 404(c). The implementation of any Advisor’s advice will be solely the responsibility of Client.
• Investment Due Diligence Review. Advisor will provide client with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. Advisor will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and Advisor will make recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. Advisor will provide non-discretionary alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5).
• Model Portfolios. Advisor will recommend to the Plan model portfolios that invest in assets using the Plan’s Designated Investment Alternatives (“DIAs”), assist the Plan in monitoring the model portfolios and as necessary and prudent make recommendations to the Plan to change the allocations within the model portfolios using the existing DIAs. The model portfolios will be limited to the DIAs and not consider other investments. Plan will be responsible for determining whether or not to approve such recommended model portfolios and updates/changes to the model portfolio. Once the Plan has approved the model portfolios or subsequent changes to the model portfolio, the third-party service provider will be responsible for making the portfolio models available to the Plan participants. Each Plan participant will have the option to elect or not elect the model portfolios.
• Individualized Participant Advice. Upon request from Client, Advisor will provide one-on- one advice to Plan participants regarding their individual situations. B. Fiduciary Management Services
• Discretionary Management Services. Advisor will provide Client with continuous and ongoing supervision over the designated retirement plan assets, as specified in Exhibit A. Advisor will actively monitor the designated retirement plan assets and provide advice to Client regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. Client grants Advisor discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in the sole discretion of Advisor without first consulting with Client. Client also grants Advisor the Cambridge Advisors Inc. Page 6 August 2023 power and authority to carry out these decisions by giving instructions, on behalf of Client, to brokers and dealers and the qualified custodian(s) of the Plan for Advisor’s management of the designated retirement plan assets. Client authorizes Advisor to provide a copy of this Agreement to the qualified custodian or any broker or dealer, through which transactions will be implemented on behalf of Client, as evidence of Advisor’s authority under this Agreement. If Client has elected to utilize Advisor’s Discretionary Management Services, then Advisor will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to the management of the available investment options, and Advisor hereby acknowledges that it is a fiduciary with respect to its selection of investment options

available to Plan participants. C. Retirement Plan Rollover Recommendations When Cambridge Advisors Inc. provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Cambridge Advisors Inc. is a “fiduciary” 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. The way Cambridge Advisors Inc. makes money creates conflicts with your interests so Cambridge Advisors Inc. operates under a special rule that requires Cambridge Advisors Inc. to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Cambridge Advisors Inc. must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Cambridge Advisors Inc. ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Cambridge Advisors Inc. gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Cambridge Advisors Inc.; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Cambridge Advisors Inc., please know that Cambridge Advisors Inc. and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Cambridge Advisors Inc. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Cambridge Advisors Inc. Cambridge Advisors Inc. Page 7 August 2023 Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Cambridge Advisors Inc. receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Cambridge Advisors Inc. and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Cambridge Advisors Inc. or our affiliated personnel. D. Non-Fiduciary Services
• Participant Education. Advisor will be available upon request to provide education services to the Plan participants about general investment principles and the investment alternatives available under the Plan. Client understands that Adviser’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. Advisor shall assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. As of December 31, 2022, Cambridge Advisors managed $504,072,222 assets on a discretionary basis and $26,409,420 on a non-discretionary basis for a total of $530,481,642. Administrative Services Provided by Orion Advisors Services, LLC Cambridge Advisors has contracted with Orion Advisor Services, LLC (referred to as “Orion”) to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, client database maintenance, quarterly performance evaluations, and other functions related to the administrative tasks of managing client Cambridge Advisors Inc. Page 8 August 2023 accounts. Due to this arrangement, Orion will have access to client accounts, but Orion will not serve as an investment adviser to Cambridge Advisor clients. Clients will not incur additional fees with the firm’s use of Orion. You may see slight differences in the quarter-end market value of your account from your custodian’s statement as compared to the market value of your account from Orion, due to differences in the treatment of accrued interest posting, trade date versus settlement date, and other variables. Limits Advice to Certain Types of Investments Cambridge Advisors provides investment advice on the following types of investments:
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Unit Investment Trusts (UITs)
• Exchange Traded Securities
• Fixed Income
• Structured Products Although we generally provide advice on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings significantly as deemed appropriate based on your risk tolerance and our expectations of market behavior and analysis of chart formations. We may modify my investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.)