Background: Girard Advisory Services, LLC (“Girard” or “Advisor’) was founded as an Investment Advisor Firm in 1995 under the name Girard Partners, Ltd. In 2014, Girard's owner became Univest Bank and Trust Co. which is a wholly owned subsidiary of Univest Financial Corporation, a public reporting company listed on NASDAQ as UVSP. Beginning in 2019, the Advisor changed its name from Girard Partners, Ltd. to Girard Advisory Services, LLC and its statutory entity structure to a limited liability company. Girard is a fee only registered investment advisor that specializes in providing wealth management solutions such as investment management, financial planning, retirement planning and related services to individuals, trusts, estates, charitable organizations, pension and profit sharing plans and business entities. Investment Advisory Services: When providing investment advisory services to a client, Advisor will meet with a client or prospective client and review various aspects of their financial situation including, but not limited to, their stated financial needs, objectives and goals, risk tolerance, time horizon, income needs, existing investments and resources. Advisor will then use this information to make recommendations to the client and create and manage a portfolio designed to each client’s individual circumstances. Advisor will provide investment advisory services to clients pursuant to an Investment Advisory Agreement between Advisor and the client which establishes the terms and conditions of the engagement. Advisor utilizes an array of domestic and international equities, taxable and non-taxable fixed income investments, cash and cash equivalents in its portfolio construction. Advisor often implements its strategy by investing client assets in and among mutual funds, exchange traded funds, stocks, bonds and, when applicable, independent advisors (see additional details below regarding Independent Advisors). Advisor may also provide investment management services for a client’s annuity products and their underlying sub-account and index offerings. Advisor emphasizes asset allocation when creating investment strategies and portfolio construction. Portfolio weighting between various investment types and different market sectors will be determined by each client’s individual needs, investment objectives and goals. Clients may impose reasonable restrictions on the management of their account, including the ability to instruct Advisor in writing not to purchase certain investments or securities. Advisor offers an investment management solution designed to provide a customized asset allocation, investment management, and portfolio rebalancing platform utilizing mutual funds and exchange traded funds to clients who may not otherwise meet the required minimum account size of a traditional wealth management client of the Advisor. Independent Advisors: Girard may allocate a portion of a client’s investment assets to unaffiliated independent investment advisors and/or sub-advisors (“Independent Advisor”) in accordance with the client’s designated investment objective(s). In those situations, the Independent Advisor will have responsibility for the ongoing investment management decisions related to the client assets allocated to them. Girard will continue to provide investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Girard will generally consider the following factors when determining whether to allocate funds to an Independent Advisor: The Independent Advisor’s management style, performance, reputation, financial strength, reporting, pricing, and research. Girard will also consider the client’s investment objective and portfolio construction and how the services of the Independent Advisor will complement the client’s portfolio. The client will be provided a copy of the Independent Advisor’s Disclosure Brochure(s) as required and may be subject to the terms and conditions of a separate agreement between the client and the Independent Advisor if required by the Independent Advisor. Clients may impose reasonable restrictions on the management of their account, including the ability to instruct Advisor in writing not to purchase certain investments or securities. Financial Planning Services: Advisor provides financial planning services to clients regarding investment and non-investment related matters on a stand-alone separate fee basis. Financial planning services may include, but not be limited to, personal, retirement, estate, insurance, education, business and tax planning and cash flow analysis. Financial planning services are provided pursuant to a Financial Planning Agreement between Advisor and a client which establishes the terms and conditions of the engagement. The Financial Planning Agreement is separate from the Investment Advisory Agreement that Advisor may have with a client for investment management services. When providing financial planning services and corresponding recommendations to a client, Girard does not act in the capacity of a law firm or accounting firm, and no portion of its services should be construed as legal or accounting advice or services. Due to this fact, Girard does not prepare legal documents such as trust, wills or estate planning documents or tax related documents such as tax returns. It is the client’s responsibility to promptly notify Advisor of any changes in their financial situation, goals, investment objectives and risk profile for the purpose of Advisor updating the client’s financial

plan and related recommendations. Retirement Plan Investment Advice and Consulting: Advisor provides investment advice and consulting services to Plan Sponsors of ERISA retirement plans on either a discretionary or non-discretionary basis as agreed upon by Advisor and the Plan Sponsor pursuant to an Investment Advisory Services Agreement entered into between Advisor and the Plan sponsor. Advisor assists the Plan Sponsor with the analysis, selection, and monitoring of investment options made available to plan participants. Advisor may also assist the Plan Sponsor with creating an investment policy statement, the selection of a product sponsor’s program or third-party platform and providing eligible plan participants with education and enrollment related to the plan. The Plan Sponsor’s Investment Policy Statement will enumerate any specific exclusions, restrictions or special considerations for the investment options made available under the plan. Retirement Plan Participant Advice: Advisor offers investment advisory services to participants in employer sponsored tax exempt retirement plans (Plan). Participants will authorize Advisor to manage their assets in the plan on a discretionary basis, including both participant and employer contributions over which participant has investment decision making responsibility and consisting of the securities/investment opportunities made available by the plan sponsor. The participant’s individual investment strategy is tailored to their specific needs and goals as discussed and determined between Advisor and the participant and may include some or all of the securities made available by the plan sponsor. Once the appropriate portfolio has been determined, it will be monitored by Advisor and reallocated or rebalanced as deemed necessary. Participants maintain the ability to impose reasonable restrictions on the management of their account, including the ability to instruct Advisor in writing not to purchase certain investments or securities. At no time will Advisor act as custodian of the Plan or have direct access to the Plan’s funds and/or securities. If participant’s retirement plan account is closed for any reason, this causes Advisor’s services related to the account to terminate as of the date of closing. Upon termination, participant will have the exclusive responsibility to monitor the securities in their account, and Advisor will have no further obligation to act or provide investment services with respect to those assets. Retirement Plan Rollovers: Retirement plan rollovers include moving assets from one employer sponsored retirement plan, such as a 401(k), to a new employer’s retirement plan, an employer sponsored plan to an individual retirement account (IRA) and an IRA to another IRA. If Advisor recommends that a client roll over their retirement plan assets into an account to be managed by Advisor, this recommendation creates a conflict of interest if Advisor will earn new (or increase its current) compensation as a result of the rollover. Clients should be aware that such compensation would likely be higher than those they would pay through the plan, and there can be additional costs and expenses, such as custodial fees and account fees. Under current regulatory standards, if Advisor provides a recommendation regarding whether a client should engage in a rollover, Advisor is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Advisor. Securities Backed Line of Credit (SBLOC): Advisor offers SBLOCs through its parent company Univest Bank and Trust Co. SBLOCs are loans whereby a client can borrow against the assets in their investment portfolio without having to liquidate the assets held in the account. These loans require monthly interest-only payments, and the loan remains outstanding until it is re-paid. SBLOCs are non-purpose loans, which means the loan proceeds can be used for almost anything except the proceeds may not be used to purchase or trade securities. A SBLOC provides a client with the opportunity to avoid potential capital gains taxes because securities do not need to be liquidated in order to access to funds. A client may also be able to continue to receive the benefits of their holdings such as dividends, interest and appreciation. However, SBLOCs have risks and downsides. For example, if the value of the securities pledged as collateral decrease, a client may need to add funds to their account or their positions could be liquidated. Advisor does not receive compensation from SBLOCs. However, recommending a SBLOC to a client presents a conflict of interest because Advisor’s parent company will receive an economic benefit from providing a SBLOC to a client. Additionally, Advisor has a financial incentive to recommend a SBLOC because Advisor will continue to receive investment advisory fees on assets in a client’s account which would otherwise be reduced if a client liquidated some of their assets to meet their borrowing needs. Advisor consults with a client to evaluate whether a SBLOC is in their best interest and does not receive additional compensation for recommending a SBLOC which helps mitigate Advisor’s conflicts of interest. At December 31, 2022, Girard had discretionary assets under management of $1,602,049,872.00; Non-discretionary assets under management of $477,848,668.00; and total assets under management of $2,079,898,540.00.