A. Firm Information Global Wealth Management, LLC (“GWM”) is a registered investment advisor with the United States Securities Exchange Commission and was organized as a limited liability company in the state of New Jersey in 2010. GWM is a successor of a continually operating registered investment advisor in Princeton NJ since 1983. Ram Kolluri, Chairman of GWM co–founded Individual Asset Planning Corporation in 1983 with offices in Princeton and Morristown NJ. The Princeton office was spun off into a separate corporation as GlobalValue Investors, Inc. in 1997 with Ram Kolluri as the sole stockholder of the company. GlobalValue Investors, Inc. name was changed to Global Investment Management, Inc. (“GIM”) in 2004. Global Investment Management, Inc. was acquired in 2008 by ICICI Securities Holdings Inc. a registered investment advisory firm – which in turn sold the business back to Ram Kolluri in 2010 – to be incorporated as GIM. Global Investment Management, LLC name was changed to Global Wealth Management, LLC (GWM) in February 2015. During 2017 Mr. Kolluri determined to sell a majority of his ownership stake, the result of which was that as of October 27, 2017 the GWM ownership became Martin Tuchman Revocable Trust: 85%, Ram Kolluri: 10%, Sripat Pandey: 5%. As of April 30, 2023, Ram Kolluri’s consultancy has ended, and he will no longer be a part of the operational team. A letter will be sent in early May to all existing clients to address the transition and as always, we welcome any comments or questions. B. Advisory Services Offered Investment Management Services GWM provides investment management services to high-net-worth individuals, family offices, pension plans, trusts, and foundations. GWM helps its individual Clients (hereinafter "Clients") to identify their objectives, risk tolerance, time horizon, and their preference for liquidity. With this information GWM helps its Clients develop a suitable written investment policy statement, taking the Client's stated preferences, their tax situation, and any other pertinent information into consideration. GWM invests its Client’s portfolios primarily in equity Exchange-Traded Funds (ETFs), Exchange Traded Notes (ETNs), Structured Notes, individual company securities, individual bonds, stock and bond mutual funds, and bond ETFs. GWM uses the ETFs and mutual funds to get the benefits of broad diversification in the U.S. and foreign markets at minimal cost to the Client. GWM primarily uses low-cost mutual funds and ETFs, but also uses individual securities and structured notes in situations where they are most appropriate for the individual Client. GWM does not guarantee the appreciation in value of such securities during the investment time horizon stated in the investment policy. Minimum account size for Investment Management Services is generally $500,000. Financial Planning Services GWM provides comprehensive financial planning as a part of its investment supervisory services. All new Client engagements include a comprehensive financial data gathering meeting either in person or via phone. This data is reviewed by Sripat Pandey as head of the Investment Policy Committee in the following areas: □ Income Tax Planning □ Cash Flow Planning □ Investment Planning □ Children's Education Planning □ Retirement Planning □ Estate Planning □ Risk Management & Insurance Planning GWM's initial financial planning recommendations may be either in oral or written form. The Client may choose to implement or reject the recommendations at any time. GWM offers to review the Client's financial condition from time to time as a part of its ongoing portfolio review meetings. Advanced Financial Planning Consultation Services Separately, GWM offers advanced financial planning consultation services such as investment supervision services to private family offices, business succession planning to closely held businesses, pension and retirement planning to small businesses and implementation of qualified pension plans on a negotiated fee basis. Pension planning services are offered in consultation with qualified attorneys, actuaries, and Third-Party Administrators, and employee education in connection with 401 (k) plans, etc. GWM does not prepare tax returns or render legal or tax opinion at any time in connection with offering the above-mentioned services. Clients are pro-actively encouraged by GWM to seek competent legal and tax advice where appropriate. GWM’s fee, in these circumstances is negotiated at the beginning the engagement and is fully always disclosed to the Client. Clients are separately responsible for all costs associated with obtaining legal and tax advice. In performing its services, we entrust that the Client will provide accurate information and GWM will not be obligated to verify any information received from the Client or from the Client’s other professionals. If requested by the Client, we may recommend the services of other professionals for purposes of implementing the plan. The Client is under no obligation to engage the services of any such recommended professional. GWM does not receive any compensation from these professionals for recommending their services. Clients are advised that it remains their responsibility to promptly notify GWM if there is ever any change in their financial situation during the financial planning process. It is the Client’s responsibility to notify us promptly of any material change to the information provided by the Client, including any change to any investment objectives, risk tolerance, investment time horizon, and any investment policies, guidelines or reasonable restrictions. We will honor Client restrictions unless those restrictions impair our ability to manage Client assets. Prior to rendering investment management services, GWM will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective(s). Pension Consulting Services GWM offers the following fiduciary pension consulting services to retirement plan sponsors (“Client”): 1. General plan design consulting. 2. Assist the Client and its fiduciaries to meet their fiduciary responsibilities as investment fiduciaries pursuant to the Employee Retirement Income Security Act ("ERISA"). 3. Assist the Client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and the objectives of the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. 4. Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404 (c) and the regulations there under. 5. Provide non – discretionary investment advice to the Client about asset classes and investment alternatives available for the plan in accordance with the plan policies and objectives. Client shall have the final decision-making authority regarding the initial selection, removal and addition of the investment options. 6. Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. 7. Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 8. Provide non – discretionary investment advice to the Client with respect to the selection of a Qualified Default Investment Alternative (QDIA) for the participants that are automatically enrolled in the Plan or who otherwise fail to make an investment election. The Client retains the sole responsibility to provide all notices to the participants required under ERISA 404 (c) (5). 9. All retirement plan consulting services shall follow the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). Under such appointments, GWM acknowledges that we are a fiduciary within the meaning of Section 3(21) of ERISA. 10. The educational support and investment workshops will NOT provide individual Plan participants with individualized tailored investment advice or individualized, tailored asset allocation recommendations. GWM will not serve in the capacity of a “fiduciary advisor” as so defined under the Pension Protection Act of 2006. 11. GWM does not provide services generally provided by a record keeper, or a third-party administrator or an actuary to a qualified retirement plan. Services provided to a Client will be specified in an agreement and we will disclose to the client any change to the information in the agreement required to be disclosed by our firm under ERISA

Regulation Section 2550.408b-2(c)(1)(iv). 12. GWM will perform the Fiduciary Services in accordance with the prudent man rule set forth in ERISA Section 404 (a) (1) (B). GWM offers the following non–fiduciary pension consulting services to retirement plan sponsors (“Client”): 1. Assist in the education of the participants in the plan about general principle of retirement planning, savings and investing towards retirement, concepts asset allocation among various asset classes, controlling emotions and withstanding capital markets volatility, and understanding the investment alternatives that are available under the plan. Client understands that Adviser’s assistance in participant retirement planning and investment education shall be consistent with and within the scope of (d) (i.e., the definition of investment education) of the Department of Labor Interpretive Bulletin 96-1. Investment Education shall include the following four types of information: a. Information about the terms of the plan and the benefits of participating in the plan. b. General information about retirement planning and general principles of investments c. General information about the “target date” funds and aged based mapping to the funds (as Qualified Default Investment Alternatives as part of 404 (c) compliance) that are offered by the plan. d. Explanation relating to educational tools that a participant can use to determine risk tolerance, perform gap analysis, and other similar interactive investment (computer or web based) materials. 2. Assist in the group enrollment meetings designed to increase retirement plan participation among employees and retirement planning and investment understanding by the employees. 3. Perform analysis of the fees and expenses associated with the investments and the service providers. 4. Perform provider searches and analysis of services provided by bundled providers, record keepers and other service providers. 5. Adviser will perform the Non – Fiduciary Services and shall not be liable for any liabilities and claims arising there under unless caused by Adviser’s intentional misconduct or gross negligence. Client acknowledges that: 1. It has retained, and will exercise, final decision – making authority and responsibility for the implementation of any recommendations or advice rendered to the Client by GWM. 2. In performing the Non – Fiduciary duties, GWM is not acting as a fiduciary of the Plan as defined in ERISA. 3. In performing both Non – Fiduciary and Fiduciary Services, GWM does not act as, nor has GWM agreed to assume the duties of, a trustee or the Plan Administrator, as defined under ERISA, and GWM has no discretion over the investment of Plan assets or to interpret the Plan documents, to determine eligibility or participation under the Plan, or to take any other action with respect to the management, administration or any other aspect of the plan. 4. GWM does not provide legal or tax advice. 5. Investments are subject to various market, political, currency, economic, and business risks and may not always be profitable; and further that GWM does not and cannot guarantee financial or investment results. 6. GWM may perform other services for other clients (such as Personal Choice Retirement Accounts or PCRA for participants in the plan under a separate investment advisory agreement with GWM at their choice) or other selections on a fully disclosed basis, (i) may charge a different fee for its PCRA clients, and that GWM (ii) may give advice and take action that is different from the plan investment selections etc. 7. GWM may, by reason of performing services for other clients, acquire confidential information. Client acknowledges and agrees that GWM is unable to divulge to the Client or any other party, or act upon, any such confidential information with respect to its performance under this agreement. 8. GWM is entitled to rely upon all the information provided to GWM, whether financial or otherwise, from reputable third parties or by client, Client representatives or third – party services providers to the Client, the Plan, or GWM without independent verification. Client agrees to promptly notify GWM in writing of any material changes in the financial and other information provided to GWM and to promptly provide any such additional information as may be requested by GWM. 9. GWM will not be responsible for voting proxies of the mutual funds held by the Plan (or it’s Trust). The responsibility for voting proxies of investments held by the plan or its trust remain with the Client (or, if applicable, with the plan participants). For All Advisory Services Offered: GWM is entitled to rely upon all the information provided to GWM, whether financial or otherwise, from reputable third parties or by client, Client representatives or third – party services providers to the Client, the Plan, or GWM without independent verification. Client agrees to promptly notify GWM in writing of any material changes in the financial and other information provided to GWM and to promptly provide any such additional information as may be requested by GWM. IRA Rollover Considerations and Recommendations We comply with the Department of Labor (“DOL”) Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable. Our firm is providing the following additional acknowledgment: When we provide investment advice to individuals regarding a retirement plan account or individual retirement account, we are deemed a fiduciary 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 potential conflicts with your interest. Therefore, we operate under a special rule which requires the us to act in a client’s best interest and not put our interest ahead of the client. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put the Adviser’s financial interests ahead of a client when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure advice given is in the client’s best interest;
• Charge no more than is reasonable for services; and
• Provide basic information about conflicts of interest. We benefit financially from the rollover of a client’s assets from a retirement account to an account managed by the Firm. This is a primary conflict of interest because when we provide investment advice, the assets increase the Firm assets under management and, in turn, advisory fees. To meet the fiduciary responsibility we only recommend a rollover when it is deemed in the client’s best interest. C. Client Account Management When providing Investment Management Services, GWM will work with each Client to determine and understand their unique circumstances, including their: □ Financial objectives □ Risk tolerance □ Time horizon □ Liquidity preferences □ Tax situation We then develop a suitable written investment policy statement that reflects these circumstances and guides us in designing a customized investment strategy for each Client. Clients may request that certain restrictions be placed on their portfolio. We will typically honor these requests (and include them in the Client’s Investment Advisory Agreement) so long as these restrictions do not impede our ability to effectively manage their portfolio. With these strategic guidelines in place, we determine an appropriate asset allocation for the Client and construct a portfolio utilizing: □ US and international equity (stock) Exchange-Traded Funds (ETFs) □ Bond ETF’s □ Stock and bond mutual funds □ Money Market Funds □ Individual company stocks □ Individual fixed income securities (bonds) □ Structured Notes GWM primarily employs ETFs and mutual funds so that our clients are able to benefit from broad diversification in the U.S. and foreign markets at minimal cost. We also use individual securities (like stocks or bonds) in circumstances where they offer a better match with the objectives we are seeking to achieve. Client accounts and investment selection is overseen by the Investment Committee. The Investment Committee is comprised of GWM senior staff members. The Investment Committee meets periodically to review current GWM investments, potential investments as well as deciding on general investment guidelines. D. Wrap Fee Programs We do not participate in any wrap fee programs. E. Assets Under Management As of December 31, 2022, GWM manages the following assets: Discretionary Assets $217,671,051 Non-Discretionary Assets $30,343,233 Total $248,014,284