Wilbanks, Smith & Thomas Asset Management, LLC was founded in 1990 and is located at 150 West Main Street, Suite 1700, Norfolk, Virginia 23510. WST is privately owned by its principals. All operational and investment decisions are made by the firm’s principals. We are one of the oldest and largest independent investment advisors in Southeastern Virginia. WST’s Investment Committee has a combined experience of over 150 years in the investment management industry. WST provides investment services for individuals, pension and profit sharing plans, corporations, Taft Hartley organizations, municipalities, bank trust departments, trust companies, insurance companies, foundations and endowments. In addition, WST offers advisory services through a platform of investment strategies that focus on improving risk-adjusted return through rules-based, risk-managed investment frameworks that rely on complex quantitative modeling and are executed primarily through Exchange Traded Funds (ETFs) and in some cases mutual funds. WST Capital Management (“WSTCM”), a division of WST, oversees quantitative research and manages these rules-based strategies. Our website (www.wstcm.com) focuses solely on the strategies and solutions offered by the WSTCM division. Depending upon the particular investment objectives and risk tolerance of a client, WST may utilize one or more or all of the strategies in an effort to achieve the client’s investment objectives and, depending upon what we may consider adverse market conditions, we may, in our discretion, fully invest a client’s assets in this service in money market funds, gold funds or investment grade fixed income funds as a defensive strategy. These strategies involve various levels of risk. First, we may not be successful in implementing the strategy thus resulting in investment losses and, second, the particular strategy may not work as planned with the potential for missing out on beneficial movements in price due to an error in timing. The long-term objective of each WST Capital Management strategy is to achieve risk-adjusted returns that exceed those of comparable buy-and-hold strategies, primarily by reducing the experience of volatility that affects markets. Certain strategies incorporate various sub-strategies that generate buy/ sell signals based on a range of factors that comprise trends we believe are correlated

to asset class performance. The models are designed to issue signals based on each strategy and attempts to limit losses during declining markets and to participate in rising markets. The strategies shift investments among money market funds and multiple asset classes through investments in actively managed and/or passive equity and fixed income mutual funds or exchange traded funds. Portfolio allocations may be rebalanced at WST's discretion. Each of the WST Capital Management strategies have varying degrees of investment risk that are unique to that particular strategy as disclosed to clients via the WST Capital Management marketing presentations. Wilbanks, Smith & Thomas Asset Management, LLC acts as general partner and investment adviser to private funds. Other expenses may be incurred by the private funds and its limited partners such as the costs of buying and selling securities, audits, compliance and other administrative fees. Some of our employees and principals may also be investors in these entities. This may present a conflict of interest which we address by full and fair disclosure to our clients. Retirement Rollovers Conflict of Interest: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest; and
• Charge no more than is reasonable for our services. The principal owners of WST are Wayne Wilbanks, who is President, Thomas Investment Properties, LLC. The amount of client assets we manage as of December 31, 2023, is $190,845,217 on a discretionary basis.