A. Description of Advisory Firm Maple Capital Management, Inc. (MCM) is a corporation formed on July 1, 2004 in the state of Vermont that registered as an Investment Adviser Firm with the SEC in 2004. Ramsey A. Luhr, President, is a managing partner and majority owner of the firm. The firm maintains an employee ownership program which allows key employees to take an economic position in the company. The firm currently has over ten participants in this program and expects to add more in the future. B. Types of Advisory Services General Description of Primary Advisory Services MCM provides portfolio management and investment consulting services. Accounts are established with a qualified custodian by the client, who grants MCM the authority to make trades in each account. MCM primarily uses individual stocks and bonds when constructing client portfolios. It is our belief that the use of individual securities gives investors better control over their tax situation, better risk control in their accounts, and the potential for improved returns. The securities purchased for client accounts are selected by our research analysts and follow internal company guidelines. Mutual funds and/or exchange traded funds (ETFs) may generally be used for smaller accounts and for those sectors of the investment market for which MCM does not have an internal research capacity to follow. Mutual funds and ETFs are selected after a thorough analysis by the Asset Allocation, and Mutual Fund Research teams under the supervision of the investment committee. MCM has the ability to integrate and delegate the investment of client assets to a sub-advisor in lieu of using mutual funds and/or ETFs for asset class diversification. Promotion Program MCM partners with other unaffiliated third-party investment advisers (“promoters”) to provide services under a promotion arrangement. Clients will enter into an investment advisory agreement with MCM which allows for information sharing with the unaffiliated third-party investment adviser. The unaffiliated third-party investment adviser will assist you in the selection of a suitable investment portfolio and asset allocation strategy that will be used by MCM to properly allocate your assets in the investment portfolio. MCM will serve as the primary investment manager for your investment portfolios. The unaffiliated third- party investment adviser, in their role as promoter, will provide initial and ongoing education concerning the asset allocation strategy selected. The unaffiliated third-party investment adviser is available to answer questions you may have regarding your account and act as your relationship manager between you and MCM. The unaffiliated third-party investment adviser will periodically meet with you to discuss changes in your investment objectives and risk tolerance, and current asset allocations within each portfolio. Information from these meetings will be shared with MCM to facilitate MCM’s ongoing management of your accounts. MCM periodically changes the relative allocations among securities in the portfolios. MCM will take discretionary authority to determine the securities to be purchased and sold for you. MCM pays a portion of the advisory fee received from the client to the promoter. Form ADV 5 March 31, 2024 Joint Advisory Program MCM partners with other unaffiliated third-party investment advisers, pursuant to a separate agreement, to provide services under a joint advisory structure. Clients will enter into an agreement jointly with MCM and the unaffiliated third-party investment adviser. The unaffiliated third-party investment adviser will serve as your primary financial advisor and assist you in the selection of a suitable investment portfolio and asset allocation strategy that will be used by MCM to properly allocate your assets in the investment portfolio. MCM will serve primarily as investment manager for your investment portfolios. The unaffiliated third-party investment adviser will provide initial and ongoing education concerning the asset allocation strategy selected. The unaffiliated third-party investment adviser is available to answer questions you may have regarding your account and act as your relationship manager between you and MCM. The unaffiliated third-party investment adviser will periodically meet with you to discuss changes in your investment objectives and risk tolerance, and current asset allocations within each portfolio. Information from these meetings will be shared with MCM to facilitate MCM’s ongoing management of your accounts. MCM periodically changes the relative allocations among securities in the portfolios. MCM will take discretionary authority to determine the securities to be purchased and sold for you. Socially Responsible Investing Limitations Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by MCM), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Cash Positions Cash positions (money markets, etc.) are included as part of assets under management for purposes of calculating MCM’s advisory fee. At any specific point in time, MCM may maintain higher cash balances based upon perceived or anticipated client needs, market conditions/events

(there being no guarantee that such anticipated market conditions/events will occur). Cash may also build up as a residual to our investment process if suitable replacement investments cannot be found when securities are sold. This may result in significant cash balances being held. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, MCM’s advisory fee could exceed the interest paid by the client’s money market fund. Administrative Services Provided by Third Parties MCM has contracted with several third-party vendors to support various functions related to the administrative tasks of managing client accounts. Some of the services provided by these vendors include data reconciliation, performance reporting, voting client proxies, and trading client accounts. Due to these arrangements, some of these third parties have limited access to client account information. More information about these arrangements can be found in MCM’s Privacy Notice. Form ADV 6 March 31, 2024 Class Action Litigation Services Unless the client directs otherwise in writing, MCM has retained the services of Chicago Clearing Corporation (referred to as “CCC”) to file all eligible class action lawsuits on behalf of the client. CCC researches, files, monitors, and expedites the distribution of class action settlements. When a claim is settled and payments are awarded to MCM clients, it may be necessary to share client information, such as name and account number, with CCC in connection with this service. In exchange for managing class action filings, CCC earns a fee based on a flat percentage of all claims it collects on behalf of MCM’s clients. This fee is collected and retained by CCC out of the claims paid by the claim administrator. The client may opt out the service if they wish to file their own class action lawsuits by contacting MCM’s Chief Compliance Officer. ERISA Accounts MCM is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (“ERISA”). As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, MCM may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset MCM advisory fees. Portfolio Activity MCM has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, MCM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when MCM determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations In performing its services, MCM shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify MCM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising MCM’s previous recommendations and/or services. Disclosure Statement A copy of MCM’s written Brochure and Client Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. C. Client-Tailored Advisory Services MCM gathers key information about its client’s needs and objectives before initiating trades in client Form ADV 7 March 31, 2024 accounts. When possible, MCM prepares a written investment policy statement (IPS). The IPS reflects MCM’s understanding of each client’s circumstances and explains the approach MCM will use when managing client assets. As part of our services, MCM may provide non-investment financial advice such as estate planning and tax planning to its clients. Neither MCM, nor any member of its staff, serve as an accountant or attorney and MCM’s services should not be construed to be the same. If requested by a client, MCM may recommend other professionals for non-investment financial advice. MCM does not warrant or otherwise attest to the quality of services provided by these outside professionals. Clients may engage these service providers at their discretion. Clients may engage MCM to manage their assets on a non-discretionary or “advisory” basis. Under such an arrangement, MCM cannot affect any transactions without first obtaining verbal consent from the client. In the event of market volatility, MCM will be unable to affect any trades/transactions for advisory clients until they are individually contacted. D. Wrap Fee Programs MCM does not participate in any wrap fee programs at this time. E. Assets Under Management (AUM) As of December 31, 2023, MCM managed approximately $1,723,412,484 in client assets. As of December 31, 2023, MCM had approximately $1,661,875,125 in assets under advisement. Currently, MCM’s assets under advisement include 401k plans, insurance general operating funds and foundations where MCM serves solely as a consultant and does not have investment discretion or the ability to execute trades directly in client accounts.