KKM Financial LLC (“KKM”) is a Delaware limited liability company which provides investment management and consulting services to a wide variety of clients. KKM began offering advisory services in August 2012. KKM is 91.5% owned by Killir Kapital Management, LLC Jeffrey J. Kilburg, along with an 8% ownership by Daniel Deming and a 0.5% ownership by Matt Franz. KKM does not control any other firm. As of February 29, 2024, KKM has approximately $333,352,649 under management. Of that $333,352,649 approximately $225,635,142 are discretionary assets and $107,717,507 are non- discretionary assets. Additionally, as of February 29, 2024, KKM has approximately $140,983,450 assets under advisement. The investment management services of KKM are described in detail below. Investment Management Services - KKM as Manager KKM offers clients portfolio management and reporting services by means of its Investment Management Services program. This program provides clients with investment analysis, investment recommendations, monthly or quarterly statements reflecting holdings and transactions, quarterly statements, and ongoing account monitoring services for a portfolio which may include stocks, bonds, mutual funds, exchange- traded funds, options, private placements, and convertible securities. KKM will exercise discretionary trading authority while providing services. This means that KKM Representatives will have authority to purchase and sell securities of their choice in the amounts and at the times they believe it is suitable for a client’s account to do so. KKM will also have the authority to hire and fire third party managers to manage all or a portion of client’s assets. The initial investment recommendations are based on the financial information gathered from each client including net worth, risk tolerance, financial goals and objectives, investment restrictions and overall financial conditions. Based on this information, the client is provided with investment recommendations designed to provide an appropriate asset mix consistent with the client’s objectives. The client’s portfolio and its performance are monitored by the client’s Representative in light of the client’s stated goals and objectives. The frequency of these reviews is determined by the Representative. KKM Representatives meet with the client on an as needed basis to discuss the portfolio and other aspects of the service. Clients should be aware that commissions will be charged for transactions by the brokerage firm processing the transactions. Investments are not held by KKM. Instead, all investments managed by KKM are held at the brokerage firm ("Custodian") through which transactions are placed. KKM does not assure or guarantee the results of its Investment Management Services; thus, losses can occur from following KKM’s advice pertaining to any investment or investment approach, including using conservative investment strategies. All advisory services are tailored specifically to the individual needs of the clients as described within each service above. Clients may impose restrictions on investment in certain securities or types of securities. KKM does not participate in any wrap fee program where the fee for our services is combined with the fee or commissions that a client’s brokerage firm charges for transaction execution services. It is KKM's policy when placing aggregated client orders of securities simultaneously for more than one client (called “block trades”) to allocate such orders and opportunities in a fair and equitable manner. When the Firm places block trades or must allocate limited investment opportunities among its clients, important issues arise concerning the equitable distribution of such securities. Block trades may result in lower commissions and better prices for clients than if the Firm placed multiple single orders. Block trades may also provide the KKM with operational efficiencies. KKM may utilize brokerage platform for trade execution that may aggregate sale and purchase orders (in a best execution manner) of securities held in the account with similar orders being made simultaneously for other accounts managed by KKM, if, in our judgment, such aggregation results in an overall economic benefit to the account based on an evaluation that the account is benefited by relatively better purchase or sale prices, potentially lower commission expenses, and beneficial timing of transactions, or a combination of such factors. This particularly pertains to separately managed account clients who custody their assets at Interactive Brokers. Investment Management Services - using Third Party Managers KKM can provide investment management services which involve supervision of the account on a regular basis. In establishing an Investment Management Account, KKM's Investment Adviser Representative (“IAR”) gathers information from each new client to determine the investment objectives and risk tolerance of the client. Once the investment objectives and risk tolerance have been determined, KKM will provide the client

with investment advice, which includes an analysis of current investments and recommendations of other appropriate investments, or a recommendation to use the services of a third- party manager. Investment Management services are provided on a discretionary basis as authorized by the client through the execution of the Investment Management Agreement. With discretionary services, KKM and its IARs may buy, sell or exchange securities, hire and terminate third-party investment managers, and open and terminate custodial accounts without obtaining specific consent from the client prior to each transaction. Third-party managers also have discretionary authority to buy and sell at will. KKM will typically use only third-party managers it is familiar with, thus will not perform a manager search before recommending third-party managers. For KKM and third-party managers to make appropriate investment decisions, it is important that the client provide accurate and complete responses to the questions asked by the IARs, as well as inform the IARs of changes to the client's investment objectives, personal circumstances and other factors that may impact management decisions for the account. IARs of KKM will, on at least an annual basis, contact each client to determine whether there have been objective changes or new restrictions on the management of the Investment Management portfolio. However, it remains the responsibility of each client to inform KKM of any material change. KKM does not guarantee the results of investment management advice it gives or the advice given and actions taken by third-party portfolio managers. Thus, losses can occur by using KKM's services. Investment Management Services – KKM Model Delivery KKM retains the ability to offer model portfolios to external investment platforms (TAMPs) by means of its Investment Management Services. This program has the ability to deliver model portfolios to external investment platforms. TAMPs typically transact or execute the model portfolios. However, there are select platforms in which KKM provides execution in addition to the model delivery. KKM makes model portfolios available through third-party platforms where KKM does not enter into an advisory agreement with the investor. Please note, this program is limited to certain third-party platforms and is separate from KKM’s other services described herein. Consulting Services Consulting Services provided by KKM vary by the objectives and financial circumstances of each client. The specific services provided are determined at contract signing and described in the Consulting Services Agreement. Services begin by the client’s KKM Representative performing an analysis of the client's existing assets, insurance, taxes, investment objectives, investments and other related matters. After this information-gathering step is completed, KKM's Representative then confers with the client to provide KKM's recommendations. Advice about investments is generally limited to stocks, bonds, mutual funds, exchange-traded funds, variable life and annuity contracts, and government-issued securities and use of other investment managers. Other topics regarding, for example, insurance, taxes, estate planning, and other matters are addressed in the scope requested by the client. For clients who have a large or highly-diversified securities portfolio or who need extensive financial, estate, tax or insurance advice, KKM may prepare written recommendations which assist the clients in arriving at an investment and insurance mix designed to achieve their investment objectives. The scope of the report is determined in advance between the client and KKM. Clients decide which investment recommendations to accept and implement. Clients are also free to select any brokerage, insurance or other product provider to purchase (or sell) the investments, insurance, or other products discussed with KKM. KKM does not guarantee results, and losses can occur from receiving Consulting Services. All Consulting Services advice is based on information provided by the client. It is the client's responsibility to be certain that KKM has current and accurate information. Investment Advice Specific to Retirement Account Rollovers When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries 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 some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care (give prudent advice);
• Never put our financial interests ahead of our clients (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice in client’s best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about our conflicts of interest.