Advisory Business A. StateTrust Capital, LLC. (the “Firm”, “STC”, or the “investment advisor”) offers various levels of investment supervisory services. The Firm has been in business since the year 2000 and is 100% owned by StateTrust Group, LLC. B. During an initial interview, conducted at no charge to the client, the client’s needs, goals, liabilities, risk tolerance, and time horizon are determined. An appropriate allocation of assets in a portfolio mix of equities and fixed income is thereby established in conjunction with the client. The Firm’s services include (as required) helping the client in defining its investment objectives, formulate an investment policy for them, evaluate and recommend professional money managers, and as a final stage, design an asset allocation strategy for the client. C. Within each of the categories in the strategy, the accounts or funds are further segregated by pure styles, again depending on specific client conditions (e.g., large capitalization growth, small capitalization value, international large cap, etc.). In each of the chosen segregated styles, internal or external account money managers are chosen together with the client. In the cases of Asia Pacific, Asia, World, International, Equities-Growth, Equities-Core, Europe, Balance 50-50, Large Cap growth, Small Caps, and Fixed Income, StateTrust itself will manage directly some or all of the portfolios if directed to do so by the client. The client can impose

restrictions. D. The Firm currently uses a few subadvisors for its outside WRAP program of International equities. The Firm, through its custodian, has access to a number of external managers that could potentially be used. E. The Firm sponsors a wrap fee program. A “wrap fee” is an annual fee paid by the client that is intended to cover applicable services to the account, including investment advice and, will include one or more of the following: portfolio management, trade execution, clearing, settlements, custody (through AXOS Clearing, LLC, our custodian), administrative and account reporting services provided by STC, as well as investment advice and/or portfolio management services provided by a third-party adviser to the portfolio. To the extent that portfolio management or similar services are provided by third- party advisers, a portion of the wrap fee paid by the client will be paid to such advisers for their services – please refer to the section “Fees and Compensation” for additional details about these fees (also called advisory account fees). We generally manage accounts enrolled in wrap fee programs with the same level of care as non- wrap fee advisory accounts. Additional information about the program is covered by the ADV 2A Appendix 1 - WRAP brochure. F. The Firm currently manages client’s assets. Of these assets, as of December 31, 2023, $100,632,000.00 are managed in a discretionary basis and none of the assets are non-discretionary.