Smithbridge Asset Management, Inc, (“Smithbridge”) established in January,1997, is an independent investment advisor registered with the Securities and Exchange Commission (SEC) based in Chadds Ford, Pennsylvania. As an SEC registered advisor, Smithbridge is subject to a fiduciary standard in our relationship with clients. This means that we are obligated to put the interests of our clients first and that investment decisions must be in our client’s best interest. Smithbridge has been registered with the SEC since 1997. The firm is organized as a Sub-chapter S corporation formed under the laws of the State of Delaware. Jonathan F. Kolle, CFA® and Shawn R. Keane, CFP® are the principal shareholders. Our primary focus is providing financial planning and managing investments for individuals, trusts, estates, charitable organizations, profit sharing and pension plans and endowment funds. Smithbridge is committed to disciplined investment management, financial planning, and personalized service. We manage each client’s account individually, according to the client’s particular goals and guidelines. Client portfolios may include individual stocks, bonds, real estate investment trusts (REITS), mutual funds, master limited partnerships (MLPs), certificates of deposit (CD’s) and exchange traded funds (ETFs). As of December 31, 2023, we managed a total of $613,003,476 in client assets of which $595,854,050 were discretionary assets and $17,149,426 were nondiscretionary assets. Financial Planning Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is the consideration of all questions, information, and analysis as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The client always has the right to decide whether to act upon our recommendations. If the client elects to act on any of the recommendations, the client always has the right to affect the transactions through anyone of their choosing. In general, the financial plan may a d d r e s s any of the following areas of concern. The client and advisor will work together to select the specific areas to cover.
• Business Planning: We provide consulting services for clients who currently operate their own businesses, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals.
• Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. 5 | P a g e
• College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations for savings strategies are included, and, if needed, we will review your financial picture in relation to financial aid eligibility or assess the best way to contribute to plans for children or grandchildren (if appropriate).
• Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals.
• Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request.
• Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal.
• Insurance: We will review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile.
• Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure.
• Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, with focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original

projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years.
• Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significantly adverse effect on your financial picture, such as premature death, disability, property and casualty losses, or the need for long‐term care 6 | P a g e planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self‐insuring”).
• Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state, or local tax laws and rates that may affect your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Portfolio Management Individual Portfolio Management Smithbridge is an investment advisor that utilizes individual stocks, bonds, real estate investment trusts (REITS), mutual funds, master limited partnerships (MLPs), certificates of deposit (CD’s) and exchange traded funds (ETFs). We believe in mitigating risk through diversified portfolios of high-quality securities and carefully considered asset allocation for each client. In managing equities, discipline and continuity are key concepts. The same process of equity evaluation is always used, and that process is heavily influenced by fundamental factors. The investment process for equity portfolios concentrates on large capitalization stocks primarily of U.S. corporations. These companies tend to have global business models and long operating track records. Shares of foreign companies listed on U.S. exchanges (ADRs) are also used and may be up to 25% of the portfolio. Smithbridge may also include actively managed mutual funds in the portfolio if it serves the client’s interest. Individual bonds and bond ETFs are utilized, with various maturities and usually relatively short average duration. Bonds of investment grade are emphasized. Depending on the tax status of the client or type of account, municipal bonds may be utilized. ETFs are used for further diversifying the portfolios and exposure to additional asset classes. Comprehensive ETF portfolios are used to provide extensive diversification for clients who do not need or want individual stocks or bonds. Multiple combinations of equity and fixed income ETFs are used to match the client’s risk tolerance and liquidity needs with the expected performance of the portfolio. We work with individual clients to determine their proper risk tolerance and asset allocation. Smithbridge manages taxable client portfolio in a tax efficient manner. Clients may impose restrictions on investments in specific securities and types of securities. Each client has an individualized written investment goals and guidelines statement that is reviewed annually. We encourage personal meetings with clients at least once a year. 7 | P a g e MODEL PORTFOLIO MANAGEMENT Our firm also provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to invest in a specific strategy using a defined investment style to mirror the investment strategies offered to clients in individual investment accounts. These model portfolio management services are offered through unaffiliated brokerage or advisor- based investment platforms under separate contract in which Smithbridge Asset Management participates. Unaffiliated Investment Consultants and Financial Advisors use these platforms to offer the model portfolios provided by Smithbridge Asset Management and other investment managers to their clients. These consultants and advisors tailor the selection of the model portfolios through personal discussions with the client in which the client's goals and objectives are established. The consultant or advisor determines if the model portfolio is suitable to the client's circumstances, and once they determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account at the individual account level. Clients retain individual ownership of all securities. MUTUAL FUND PORTFOLIO MANAGEMENT Smithbridge Asset Management also provides investment services to Manor Investment Funds (the "Mutual Funds"), a series of mutual funds registered under the Investment Company Act of 1940. Smithbridge Asset Management serves as the investment manager to the Mutual Fund, and continuously manages the fund assets based on the investment goals and objectives as outlined in the Mutual Fund's prospectus. Interested investors should refer to the Mutual Fund's prospectus and Statement of Additional Information ("SAI") for important information regarding objectives, investments, time-horizon, risks, fees, and additional disclosures. These documents are available on-line at www.manorfunds.com. Prior to making any investment in the funds, investors and prospective investors should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment in the Mutual Funds.