Description of Services and Fees Signet Investment Advisory Group, Inc. is a registered investment adviser based in Providence, Rhode Island. We are organized as a corporation, under the laws of the State of Rhode Island. We have been providing investment advisory services since 2003. Roberta Capuano is our firm's principal owner. We offer investment counseling services and specialize in the management of individual, corporate, trust, and estate accounts, as well as charitable organizations, pension and profit sharing plans.
The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Signet Investment Advisory Group, Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this Brochure.
As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Our primary business is to provide discretionary portfolio management to our clients. Pursuant to a grant of discretionary authority, subject to any written guidelines or restrictions you may set, we will perform various functions, at your expense, without further approval from you. We recognize that you have individual needs that require a customized investment strategy; therefore, we work with you to develop a clear understanding of your financial situation, risk limitations, and growth expectations. Understanding an individual's total financial picture enables us to develop an investment strategy, with realistic goals, for those funds entrusted to our management. Once the client-counselor relationship is established, we provide full time management of your assets. We encourage periodic review, as well as frequent informal communication, striving to continually be accessible to our clients.
When we establish a counseling relationship with you, your adviser will work with you to determine your investment objectives and constraints. Constraints include time horizon, liquidity and current income requirement, risk tolerance, financial profile, expected contributions and withdrawals, and rate of return expectations. Once these parameters are defined, we will manage your assets accordingly. Our annual fee for portfolio management services is billed quarterly in arrears based on the market value of the assets in your account at the end of each calendar quarter. If the agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client.
On an annualized basis, our fees, which are subject to negotiation, are based on the following fee schedule: Assets Under Management Annualized Fee* First $1,000,0001.00% Over $1,000,0000.60% **If we serve as trustee/co-trustee, fees may be higher, not to exceed 2% At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee.
4 Generally, we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you monthly. These account statements will show all transactions from your account. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. In limited situations we will invoice you for payment of our advisory fee. As such, payment must be received by us within 30 days. You may direct us in writing that certain securities be unsupervised

and, as a result, those assets are deducted from the billable account value for fee purposes. Either party may terminate the engagement by providing advance notice to the other party. Fees will be assessed pro rata in the event the agreement is terminated at any time other than the last day of a calendar quarter. Refunds of advisory fees are not applicable as our fees are payable in arrears.
We offer investment counseling and asset management as described above to employee benefit plans ("Plan") and/or to the participants of such plans ("Participants"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). Our compensation for these services is described above and also in the service agreement. In providing services to the Plan and Participants, our status is that of an investment adviser registered under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are as a discretionary fiduciary of the plan as defined in Section 3(38) under ERISA. Types of Investments We offer advice on equity securities, corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual funds, U.S. Government securities, money market funds, REITS and Exchange Traded Funds (ETFs). Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: 5
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Assets Under Management As of December 31, 2023, we provide continuous management services for $309,161,872 in client assets on a discretionary basis.