Item 5 Performance-Based Fees and Side-by-Side Management .................................................4 Item 6 Types of Clients ..............................................................................................................5 Item 7 Methods of Analysis, Investment Strategies and Risk of Loss ...........................................6 Item 8 Disciplinary Information .................................................................................................7 Item 9 Other Financial Industry Activities and Affiliations ..........................................................8 Item 10 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......9 Item 11 Brokerage Practices .................................................................................................... 10 Item 12 Review of Accounts .................................................................................................... 11 Item 13 Client Referrals and Other Compensation .................................................................... 12 Item 14 Custody ...................................................................................................................... 13 Item 15 Investment Discretion ................................................................................................. 14 Item 16 Voting Client Securities ............................................................................................... 15 Item 17 Financial Information ................................................................................................. 16 ITEM 2 MATERIAL CHANGES We respectfully report that Dr. C. Russell de Burlo, Jr., founder of The de Burlo Group, Inc., passed away on February 24, 2024, at the age of ninety-nine. However, there are no material changes with respect to the Firm’s continuity of leadership, since Mr. Michael E. Shade has served in the capacity of President of the Firm since 2020, and continues to serve in that capacity. ITEM 3 ADVISORY BUSINESS The de Burlo Group, Inc. (the “Firm”) is an investment management company investing assets for organizations and individuals. Each client's account is separately invested. The de Burlo Group, Inc. is majority owned by the family of C. Russell de Burlo, Jr., and Michael E. Shade, President of the Firm. The de Burlo Group, Inc. operates out of an office in Boston's financial district. The Firm began as a single proprietorship and converted to an S Corporation in 1987. In 2004, the Firm was acquired by Ipswich Capital Investment Corp., a wholly owned

subsidiary of First National Bank of Ipswich in Ipswich, Massachusetts. In March 2010, the Firm was repurchased by C. Russell de Burlo, Jr. We provide personalized investment management on a discretionary basis to a broad range of individual and institutional clients with the objective of meeting clients' long term goals. We have extensive experience managing assets for non-profit organizations, Commonwealth of Massachusetts’ municipal pension funds, and portfolios for individuals. The Firm may provide investment management services through a consultancy arrangement. Many individual and non-profit clients have selected us to manage socially responsible portfolios. The types of securities in which we invest our clients’ assets include equities, bonds, and cash equivalents. Occasionally, we will use an ETF (exchange traded fund) to provide diversification in a specific market such as emerging economies. From time to time, we may also invest clients’ assets in warrants, preferred stocks, certificates of deposit, options, limited partnerships, and mutual funds. Occasions for doing this may arise at either the request of the client or at the discretion of The de Burlo Group, Inc. in instances where we recognize an opportunity that we believe fits the needs of a particular client or clients. The Firm tailors its advisory services to the individual needs of clients, which are based on in-depth discussions with clients to understand their objectives, finances, cash flow needs, risk comfort levels and tax status. We construct individual portfolios designed to meet each client's criteria. The de Burlo Group, Inc. complies with client imposed restrictions on investments in certain securities or types of securities such as tobacco, fossil fuel, gambling, alcohol defense products, or other security types. The Firm does not participate in wrap fee programs. The Firm’s total assets under management as of December 31, 2023, were $942,593,000. A. The Firm’s fees are generally based on the market value of assets under management as shown on the table below; however fees are negotiable. MARKET VALUE OF ASSETS ANNUAL FEE Up to $1 million in assets 1.00% Increments over $1 million up to $2 million 0.85% Increments over $2 million 0.75% Non-profit organizations Negotiable Municipal retirement systems Negotiable Occasionally, the Firm provides investment advisory services based on an hourly rate or at a negotiable one- time fee for a specific project or task rather than for on-going services. Clients may choose to be billed for their management fees or to have management fees deducted from their portfolios. In order to have fees deducted, the client must authorize his or her custodian to deduct fees, and The de Burlo Group, Inc. sends the client a copy of the bill presented to the custodian. All fees are billed in arrears. Generally, our largest clients are billed monthly at a rate of one-twelfth of the annual rate. The remaining clients are billed quarterly at one quarter of the annual rate. No fees are paid in advance. In addition to our advisory fees, clients using a bank custodian pay custody fees to the custodian by having them deducted from the portfolio. Clients using a broker as custodian pay an annual administrative fee to the broker. Clients also pay brokerage and transaction costs (commissions to the broker executing a transaction and SEC transaction fees where applicable). Mutual funds and exchange traded funds (ETFs) charge expenses in addition to our management fees. Please refer to item 11 below for more information about our brokerage practices.