(a.) About Hamel Associates, Inc. Hamel Associates, Inc. is a wealth management firm established in 1990. It is headquartered in Chatham, NJ with an additional office in Webster Grove, MO. Hamel Associates, Inc. is committed to providing comprehensive fee-based wealth management services to high-net-worth individuals, both domestically and abroad. Hamel Associates, Inc. offers an assortment of investment management, financial planning, and tax preparation services. Hamel Associates, Inc. is a fiduciary to each of its clients. Pat Hamel, the president and founder of Hamel Associates, Inc., has over 30 years of experience assisting high net worth individuals manage their financial affairs. Prior to establishing Hamel Associates, Inc., Pat held senior positions in the personal financial planning groups of a money center bank and a Big 4 accounting firm. Pat holds an undergraduate degree in accounting and a master’s degree in taxation. (b.) About Advisory Services Hamel Associates, Inc. devotes a significant portion of its resources to providing advisory services to clients. Through investment management, Hamel Associates, Inc. develops investment portfolios for clients in order to meet their goals and objectives. Ordinarily, Hamel Associates Inc. creates portfolios that contain a mixture of stocks and bonds. These holdings may consist of direct holdings or securities held indirectly through mutual fund or exchange traded fund investments. From time to time, portfolios may contain investments in precious metals, commodities, and other

alternative investments. In the case of very high net worth individuals, Hamel Associates, Inc. may introduce various private equity, venture capital, and real estate deals to clients. Hamel Associates, Inc. may also review similar deals upon a client’s request. Hamel Associates, Inc. also provides financial planning services to certain clients, where the inclusion of such services is agreed to in advance. These services are designed to assist clients in other areas of personal finance such as income tax planning, cash management, investments, employee benefits, debt management, insurance, and estate planning. A client may terminate service at any time by providing written notice to Hamel Associates, Inc. (c.) Client-Oriented Advising At the commencement of an investment advisory relationship, Hamel Associates, Inc. develops a plan with the client in order to set parameters concerning how assets under management should be invested. This includes a determination of the appropriate allocation of assets between stocks, bonds, and other investment classes. The client may direct Hamel Associates, Inc. to refrain from investing in certain securities or types of securities. Hamel Associates, Inc. does not manage ESG portfolios and does not assist clients in the management of ESG portfolios. As of December 31, 2023, Hamel Associates, Inc. had assets under management of $489,339,727. Of this amount, approximately $434 million was managed on a discretionary basis and approximately $55 million was managed on a non- discretionary basis.