Advisory Business Founded in 1993, Breckinridge Capital Advisors, Inc. is an investment advisor with a mission to provide the highest caliber of investment management. Our investment management services are offered through separate accounts, which are often customized by clients. Reflecting our commitment to ESG and sustainability, Breckinridge is a Massachusetts Benefit Corporation and a certified B Corp (https://bcorporation.net/). We believe these designations help us to align our goals to create positive, long‐term impact for our clients, employees, and the communities in which we live, work and invest. Breckinridge is independently owned by its former and current employees and members of the board. Peter Coffin, the firm’s founder is the firm’s majority owner. As of December 31, 2023, Breckinridge managed over $47.8 billion in assets on behalf of 17,848 clients. Our Clients Breckinridge manages portfolios for a wide variety of clients, ranging from high net worth individuals to mutual funds sponsored by unaffiliated parties. Clients commonly access our services through intermediaries such as other investment advisors, consultants and wrap fee programs. These programs, advisors and consultants (collectively, Intermediaries) are not affiliated with Breckinridge. Some clients are directly sourced from institutions. Intermediaries are expected to conduct their own due diligence of our firm. Each Intermediary will offer all or some of Breckinridge’s investment strategies to their clients. Client Relationship Structures For wrap fee programs, we enter into advisory agreements with the sponsors, not with the underlying clients. Some advisors have entered into an advisory agreement with Breckinridge, while others require Breckinridge to enter into agreements with the underlying client directly. Regardless of the agreement arrangements, the Intermediary, not the underlying client, remain Breckinridge’s primary point of contact for any underlying client communications, including changes to account guidelines and restrictions. Therefore, throughout this Brochure, our reference to clients generally includes Intermediaries. Underlying clients who access our services directly usually appoint an authorized party to act on their behalf. Any such arrangements

are specified in either the investment management agreement or separate written documentation. Limitations to Client Information When underlying clients access our services through an Intermediary , we will not be provided with sufficient information from the Intermediary to perform a suitability assessment of our services for their accounts. We rely on the Intermediaries who, within their fiduciary duty, must determine whether Breckinridge and Breckinridge’s services are in the client’s best interests. This includes any assessment of whether a particular wrap free program is appropriate for the underlying client. Technology and Information Security Since Breckinridge’s founding, we have always pushed ourselves to innovate technologically. We believe innovation allows us to better serve our clients. This has led us to develop proprietary technology and techniques that have enabled us to manage portfolios, analyze issuers, and implement customizations for our clients. We also rely on third‐party systems and data to operate and service client accounts on a daily basis. As a result, our firm and these third‐party providers process, store and transmit large amounts of electronic information about our clients and their accounts, including transactions and holdings. The dependence on technology and systems makes us and our service providers susceptible to cybersecurity risks that include loss of client information or assets, privacy breaches and identity theft, loss of confidential company information, and disruption of business. These types of events can be caused by unintentional failures or deliberate attacks. Breckinridge has policies and procedures that address information security, privacy, identity theft, business continuity and third‐party service providers. These policies are reviewed regularly and revised as necessary to reflect changes in our business, the way we process, store and transmit electronic information, or other matters. A copy of Breckinridge’s information security policies and privacy notice are available upon request by contacting our compliance team at 617‐443‐0779 or by emailing [email protected]. In addition, our privacy notice is available on our website (https://www.breckinridge.com/privacy‐ notice/).