The McMillan Office, Inc. was founded in the early 1880’s. Until 2011, the McMillan Office operated as a Family Office, providing numerous services to family members and clients. In 2011, with the passage of the Dodd – Frank Reform Act, it was determined that the McMillan Office, Inc. should register with the Security Exchange Commission as an investment advisor. Michael Backman is President and 100% owner of the Company. On October 1, 2012, J.D. Martin & Company, (100% owned by Michael Backman) a registered investment advisory firm, merged into the McMillan Office, Inc. The McMillan Office, Inc. provides investment supervisory services primarily to individual investors, trusts and estates. The McMillan Office also provides investment supervisory service to charitable and nonprofit organizations, pensions, profit sharing plans, retirement accounts and state and municipal entities. Our fees for these services are generally based on a percentage of assets under management. On rare occasions, additional charges may be applicable if extraordinary services are requested or required. Clients using our services will open a mutually agreed upon brokerage account and often a checking account with that broker. Brokers will be selected on the basis of the level of service provided, which includes: availability of effective institutional research materials, availability of security analysts for consultation and related factors. On stock transactions, the Firm’s general practice is to trade with the custodial broker with their individual commission rates (including miscellaneous fees). The reasonableness of brokerage commissions will be judged on the basis of the above factors, the size and complexity of the individual transaction and the total volume of business transacted through each broker. Fixed income securities are normally bought and sold on a net basis. Trades are executed with the best available source for delivery against payment. The receipt of research materials would include economic analysis, company and industry research studies, statistical publications, security ratings, graphs changes of economic activity, etc. Access to individual security analysts by telephone and in meetings is also one of the services considered. Although individual Clients can choose any custodial broker, most of our Clients do not have a broker preference. In this instance, we mutually discuss and determine the custodial broker. The Company may pay a broker a brokerage commission in excess of that which another broker might have charged for effecting the same transactions, in recognition of the value of (a) brokerage or (b) research services provided by the broker, and (c) individual customer service. To achieve economy of scale, the Company sometimes engages in bunch stock trading with a particular custodial broker, where more than one account is open. All participating Clients will receive the same average price per share and the same discounted commission (miscellaneous fees not included). If there is a partial fill order, the share allocation amount will be pro-rated accordingly per participants. If a Client has chosen his own custodial broker where no other McMillan Office, Inc. custodial account is open, that

Client will not be able to participate in aggregate stock trading and may forego possible commission discounts. Research services provided by brokers through whom the Company effects security transactions may be used in servicing all the Company’s accounts and not all such services may be used in connection with the accounts which paid commissions to the broker providing such services. The McMillan Office, Inc. has full or limited trading authorization with the broker to buy, sell, hold, redeem, and otherwise trade mutual funds, stocks, bonds, and other securities subject to instructions provided by the Client. The institutional broker will provide monthly statements to the Client and hard copies and electronic data to the McMillan Office, Inc. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are exclusive of, and in addition to, the McMillan Office, Inc. investment management fee. The "investment supervisory services" for individuals includes a determination of the needs and objectives of each individual in order to provide investment management or recommendations appropriate to the particular circumstances. Factors such as age, risk tolerance, net worth, family make-up, dependents, obligations and the potential need for principal or income affect the investment policy guidelines with the option of full discretion or via recommending any portfolio changes to the Client for approval. In either case, the Client is advised of all transactions affecting their portfolio. Cash statements and lists of assets from the McMillan Office with market values are provided quarterly or monthly if the Client wishes. Tax information worksheets are provided annually. Fees are based on the market value of an account on a quarterly basis. The "investment supervisory services" for Clients other than individuals includes complete investment management of a portfolio on either a full discretionary or recommendation basis. The investment and reinvestment of the fund involves continual supervision of the individual securities making up the portfolio as well as periodic review of the overall diversification and balance of the portfolio. Cash statements detailing transactions and a list of securities reflecting both costs and market values are provided at least quarterly. Historically, the McMillan Office has always provided bill paying services to Clients. Checking accounts on behalf of our clients are associated with an institutional broker, who is also the custodian for the majority of the assets under management and who is under the jurisdiction of the Financial Industry Regulatory Authority (FINRA), Department of Labor (DOL) and Securities and Exchange Commission (SEC). The McMillan Office, Inc. has a long-standing relationship with an individual client consultant who was compensated prior to the merger of JD Martin & Company. The consultant is paid at a nominal fixed monthly rate to act as a liaison between the McMillan Office and the Trustees of a local municipal Police and Fire Retirement Account. Duties include the following: attend Trustee meetings, represent the McMillan Office with respect to matters relating to the retirement account and advise the McMillan Office of discussions from Trustee meetings.