Confluence was formed in December 2007 and registered as an investment adviser with the SEC in January 2008. Confluence was started by former investment management and investment banking professionals from A.G. Edwards & Sons and its investment management subsidiary, Gallatin Asset Management, Inc. The firm is 100% employee-owned, with Mark Keller and Brian Hansen as the principal owners. On April 30, 2018, Confluence acquired the assets of Gratry & Company, LLC, an international and global equity adviser. Confluence offers clients portfolio management services focused on an array of equity strategies, asset allocation strategies, balanced strategies, alternative, and sector strategies. Our clients include individuals (including high net worth individuals) and entities such as financial institutions (on behalf of their clients), corporations and corporate pension and profit-sharing plans, Taft- Hartley plans, other investment advisers (on behalf of their clients), charitable institutions, foundations, endowments, and registered investment companies. Confluence services are offered primarily through financial advisors (“Financial Advisors”) and the accounts are maintained with the client’s broker-dealer, bank, investment advisory firm, or other financial institution (“Financial Institution”). Financial Advisors work with clients to examine the client’s current financial situation and financial goals, to understand the risk tolerance and investment time horizon and to develop the overall financial plan/investment strategy for their clients. As part of the overall strategy, clients (or the Financial Advisor) utilize one or more Confluence strategies with respect to a portion of the client assets at the Financial Institution. In some instances, Confluence offers services directly to clients. Services provided by Confluence are limited to portfolio management and do not include financial planning, wealth management, accounting, retirement planning, legal, tax advice, or any other related or unrelated services. Confluence offers its services on either a “discretionary” or a “non-discretionary” basis. In a discretionary account (typically referred to as a separately managed account (“SMA”)), at the outset of the contractual relationship, Confluence is granted the authority by a client to determine the securities or other assets to purchase or sell in the account. This discretion will remain in effect unless revoked by the client or their Financial Advisor. Confluence will monitor the SMA and will purchase and sell securities and other assets in the account consistent with the investment strategy or strategies selected by the client or the Financial Advisor (on client’s behalf) as part of the overall investment plan (subject to any reasonable restrictions provided in writing to Confluence). In a non-discretionary account, Confluence makes recommendations to the Financial Advisor or Financial Institution concerning securities and other assets, but Confluence does not have the authority to implement such recommendations. Rather, the Financial Advisor or Financial Institution (on client’s behalf) has the sole authority to determine whether securities or other assets in the account are purchased or sold on the client’s behalf in accordance with Confluence recommendations and to determine the Financial Institution through which such transactions are implemented. Non-discretionary accounts also include those for which Confluence supervises the securities or other assets in the account, without any discretionary authority. As of December 31, 2023, Confluence managed or supervised an aggregate of approximately $12.3 billion of assets, of which $7.2 billion are assets under management held in discretionary accounts and $5.1 billion are assets under advisement. Confluence does not custody or take possession of client assets, and all such discretionary and non-discretionary assets are held with the Financial Institution or other qualified custodian (“Custodian”) selected by the client. When Confluence acts as an investment adviser, we are required to act in our clients’ best interests and not put our interests ahead of our clients. At the same time, the way we make money creates some conflicts of interest. Please refer to the following sections for a description of conflicts of interest: Item 5 – Fees and Compensation; Item 7 – Types of Clients; Item 10 – Other Financial Industry Activities and Affiliations; Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading; and Item 12 – Brokerage Practices. Additional information regarding conflicts and standards of conduct are included in the Confluence Client Relationship Summary, which is available on our website and available upon request. Confluence and its investment professionals manage assets for clients that are employee benefit plans or retirement accounts covered under the Employee Retirement Income Security Act

of 1974, as amended (“ERISA”). Confluence provides services as an ERISA “fiduciary” and the Internal Revenue Code (as applicable), which are laws governing retirement accounts. Confluence is a registered investment adviser under the Investment Advisers Act of 1940. Confluence provides a written description of the services to be provided for ERISA accounts. DISCRETIONARY ADVISORY SERVICES Confluence negotiates and enters into agreements to provide discretionary portfolio management and investment advisory services to clients. Confluence provides discretionary advisory services primarily through SMAs, which are offered through the client’s Financial Advisor or Financial Institution. In these instances, clients open an account with their Financial Advisor at the Financial Institution to select third-party investment advisory firms (such as Confluence) to manage all or a portion of the assets in the account. Confluence’s SMA arrangements can be “single contract,” in which Confluence enters into contract with the Financial Institution to provide discretionary advisory services to the clients of such Financial Institution, or can be “dual contract,” in which Confluence enters into a contract directly with the client to provide discretionary advisory services to the client; this contract is in addition to the client’s contractual agreement with such Financial Institution. Confluence manages investments for clients at various Financial Institutions. Confluence does not take possession of client assets, as all securities and monies are held by the Custodian of the client’s choice. Confluence offers SMAs utilizing various investment strategies, and SMAs within a particular investment strategy generally hold the same securities at the similar percentage of assets in the strategy (depending on when the account is funded). Clients can impose reasonable restrictions on investing in certain securities or industry sectors and other limitations on our investment discretion as mutually agreed upon. Confluence’s discretionary investment strategies are offered by Financial Institutions as part of unified managed account (“UMA”) programs at the Financial Institutions. In a UMA program, the client holds in a single account a wide variety of investments and investment strategies, including individual securities, mutual funds, exchange-traded funds, and other assets. As described more fully below, Confluence’s discretionary investment strategies typically are offered by Financial Institutions as part of wrap account (“Wrap Account”) programs at the Financial Institutions. Wrap Account Programs Confluence participates as an investment adviser providing portfolio management and investment advisory services to clients of Wrap Accounts sponsored by respective Financial Institutions. Confluence’s portfolio management and investment advisory services to the clients in Wrap Account programs are similar to its discretionary advisory services provided to its other clients. Confluence manages the SMAs in a Wrap Account in accordance with the guidelines provided to us by the program sponsor. In single contract Wrap Accounts, the program sponsor is responsible for the client relationship, client servicing, reporting, and billing. Clients in a Wrap Account are charged a bundled fee by the Financial Institution sponsoring the program (“Sponsor”), typically based on a percentage of the market value of the assets in the Wrap Account and is not based directly on the execution of transactions in a client’s account. The bundled fee generally covers charges for custody services, brokerage commissions, investment management, and other services as negotiated between the client and the Sponsor. Clients who participate in a Wrap Account should be aware that services similar to those provided as a participant in a Wrap Account may be available at a lower cost elsewhere separately or on an unbundled basis. Out of the bundled fee, the Sponsor pays Confluence a quarterly fee for providing portfolio management and investment advisory services with respect to that portion of the client’s assets over which Confluence has been delegated discretionary authority. However, for dual contract Wrap Accounts, Confluence’s fee may be paid directly by the client. Our fee is based on a percentage of the market value of the assets in the SMA for which we provide portfolio management and investment advisory services. For additional information regarding fees, please see Item 5 of this Brochure, titled Fees and Compensation. Because the bundled fee in Wrap Accounts typically includes charges for brokerage services, Sponsors and their clients generally expect Confluence to place trade orders through the Sponsor. If we execute trades for a Wrap Account with broker-dealers other than the Sponsor, the client will likely be subject to additional commissions, trade-away fees, and other charges assessed by the Sponsors. For information regarding directed brokerage accounts, please see