GHP Investment Advisors, Inc. (hereinafter “GHPIA” or “we”) is a SEC‐registered investment adviser with its principal place of business located in Colorado. GHPIA began conducting business in 1995. Listed below are the firmʹs principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).  Brian Jay Friedman, President GHPIA offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES (ʺISSʺ) INDIVIDUAL PORTFOLIO MANAGEMENT GHPIA provides Investment Supervisory Services that consist of the management of investment accounts for clients on a discretionary and non‐discretionary basis. We manage these accounts based on client‐specified guidelines and objectives. Typically, GHPIA prepares a financial plan (see the “Financial Planning” section below for details) for an investment management client before we begin managing the client’s assets. Through the financial planning process, we may seek to determine the client’s time horizons, risk tolerance, liquidity needs, suitability and other factors. We typically use the information provided by the financial plan to help us create and manage the client’s investment portfolio. If an investment management client chooses to not receive a financial plan, GHPIA may seek to determine the client’s time horizons, risk tolerance, liquidity needs, suitability and other factors through an alternative data‐gathering process. We typically use the information gathered through this alternative process to help us create and manage the client’s investment portfolio. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker‐dealer or insurance company, and generally include advice regarding the following securities:  Exchange‐listed securities  Securities traded over‐the‐counter  Foreign issuers  Warrants  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Variable life insurance  Variable annuities  Mutual fund shares  United States governmental securities  Options contracts on securities  Investment Partnerships: GHP International Reform and Development Fund, L.P. or Israel Investment Fund, L.P. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with our reasonable assessment of the clientʹs stated investment objectives, tolerance for risk, liquidity and suitability. GHP International Reform and Development Fund, L.P. GHPIA is the general partner of the GHP International Reform and Development Fund, L.P. (the “IRDF”). The IRDF is a Delaware limited partnership under the Delaware Revised Uniform Limited Partnership Act, as amended. The IRDF is structured to rely on an exclusion from the definition of an “investment company” under the Investment Company Act of 1940, as amended, and, therefore, is not registered with the SEC as an investment company. The partnershipʹs objective is long‐term capital growth through investments in a portfolio of, among other things, publicly traded foreign and domestic securities. GHPIA may recommend the IRDF to certain clients, but only as a piece of a diversified portfolio and only upon an assessment of the client’s investment objectives, tolerance for risk, liquidity and suitability. Clients and prospective clients should refer to the IRDF’s “Private Placement Memorandum” for details regarding the IRDF and the risks related to investing in the IRDF. The sale of the IRDF is limited to investors who are accredited investors. Israel Investment Fund, L.P. GHPIA is the majority owner and managing member of Israel Investment Advisors, LLC. Israel Investment Advisors, LLC is the general partner of the Israel Investment Fund, L.P. (the “IIF”). The IIF is a Delaware limited partnership under the Delaware Revised Uniform Limited Partnership Act, as amended. The IIF is structured to rely on an exclusion from the definition of an “investment company” under the Investment Company Act of 1940, as amended, and, therefore, is not registered with the SEC as an investment company. The partnershipʹs objective is long‐term capital growth through investments in a portfolio of, among other things, publicly traded Israeli securities. GHPIA is the investment manager for the IIF, and GHPIA may recommend the IIF to certain clients, but only as a piece of a diversified portfolio and only upon an assessment of the client’s investment objectives, tolerance for risk, liquidity and suitability. Clients and prospective clients should refer to the IIF’s “Private Placement Memorandum” for details regarding the IIF and the risks related to investing in the IIF. The sale of the IIF is limited to investors who are accredited investors. FINANCIAL PLANNING GHPIA provides comprehensive Financial Planning Services by performing a thorough evaluation

of a client’s current and future financial condition. Prior to engaging us to prepare a financial plan, we define the scope of the relationship between the financial planning client and GHPIA in a written engagement letter, which includes the fee for the plan. The fee for the financial plan will not exceed the cost quoted within the engagement letter. We typically begin the financial planning process with the Information Gathering Meeting. In this meeting, we review a questionnaire completed by the client to obtain information about assets and liabilities, income and expenses, risk tolerance and life goals. Using this information, we typically create financial statements to provide a snapshot of the client’s financial position and asset allocation. We use Net Worth and Cash Flow statements to prepare a long‐ term financial forecast using various assumptions such as inflation, rates of return, earnings growth, etc. We then have a Report Back Meeting with our client and use these models to advise them on any modifications that we deem appropriate to achieve their financial goals in all or some of following areas:  Retirement Planning  Education Planning  Risk Management  Income Tax Planning  Estate Planning  Investment Management Implementation of any recommendations outlined in the financial plan is entirely at the client’s discretion. However, should the client choose to implement our recommendations, we suggest that they work closely with their attorney, accountant, insurance agent and/or investment adviser as required. We may also coordinate with these professionals on the client’s behalf. Financial planning recommendations are not limited to proprietary products or services offered by one specific investment adviser, broker‐dealer or insurance company. GHPIA does not receive commissions or referral fees for recommending a product or service. Financial planning clients may choose to engage GHPIA for investment management services but are not obligated to do so. PENSION ADVISORY SERVICES We also provide several advisory services separately or in combination with our investment supervisory and investment management services described above. While the primary clients for these services are pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Advisory Services are comprised of several distinct services. Clients may choose to use any or all of these services. Selection of Investment Vehicles: We assist plan sponsors in determining appropriate asset allocation and portfolio diversification options. We then review various mutual funds (both index and managed) to determine which investments are appropriate for the plan. The number of investments to be recommended is determined by the client. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (ʹʹself‐directed plansʹʹ), we may also provide periodic educational support and investment workshops designed for the plan participants. The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on only isolated areas of concern such as business planning or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker‐ dealer or insurance company. TAX PREPARATION SERVICES GHPIA is the sole owner of GHP Family Office. GHP Family Office may offer tax preparation services to a limited number of GHPIA clients. Tax engagements are entered into under a separate agreement with GHP Family Office for separate and additional compensation unrelated to asset management services. No GHPIA asset management client is obligated to use the tax preparation services of GHP Family Office. PUBLICATION OF PERIODICALS GHPIA publishes a quarterly newsletter providing general information on various financial topics including, but not limited to, estate and retirement planning, market trends, etc. GHPIA may also publish additional newsletters from time to time covering current market trends, economic conditions, etc. No specific investment recommendations are provided in these newsletters and the information provided does not purport to meet the objectives or needs of any individual. These newsletters are distributed free of charge to our advisory clients and prospective clients. AMOUNT OF MANAGED ASSETS As of 12/31/2022 we were actively managing approximately $1,922,308,576 of clientsʹ assets on a discretionary basis plus $62,385,793 of clientsʹ assets on a non‐discretionary basis.