A. Waldron Private Wealth, LLC (the “Registrant”) is a limited liability company, initially formed as a limited partnership in 2004 in the Commonwealth of Pennsylvania, as the result of an entity conversion. The Registrant became registered as an Investment Adviser in October 2004. The Registrant is principally owned by the Waldron 2008 Family Trust, with John Waldron, the Registrant’s Managing Member, as Trustee. As a registered investment adviser subject to Section 206 of the Advisers Act, the Registrant acts as a fiduciary related to the conduct of its advisory services. As such, the Registrant has obligations imposed by the federal and state securities laws. For example, clients have certain rights that cannot be waived or limited by contract. Nothing in the Registrant’s Wealth Management and Planning Agreement should be interpreted as a limitation of the firm’s obligations under federal and state securities laws or as a waiver of any unwaivable rights that each client possesses. As a fiduciary, the Registrant must act in the best interest of its clients guided by the core duties of loyalty and care. In plain English, the duty of care means that the Registrant must provide advice that’s in clients’ best interest, seek the best possible execution of transactions and monitor clients’ investments over the course of their relationship with the Registrant. The duty of loyalty hinges on the Registrant making full and fair disclosure of any conflicts of interest so that clients can make an informed decision about whether to pay the Registrant to be their investment adviser. The rest of this document is designed to describe the firm’s policies and practices for adhering to the duty of care and the duty of loyalty. B. INVESTMENT MANAGEMENT SERVICES The Registrant provides discretionary and/or non-discretionary investment management services to clients on a fee basis. The Registrant’s annual investment management fee shall vary (up to 1.50% of the total assets placed under the Registrant’s management/advisement) and shall be based upon various objective and subjective factors. See also Fee Differential discussion below. INVESTMENT CONSULTING/MONITORING Registrant provides non-discretionary portfolio review/monitoring services on a stand- alone basis relative to those client assets that are not part of the investment assets subject to the Registrant’s investment management services discussed above. The terms and conditions of such an engagement may be set forth in our existing Wealth Management and Planning Agreement. These additional client investment assets are generally investment assets that are managed directly by the client or by other investment professionals engaged by the client. The Registrant’s portfolio review service is limited to periodic review of information pertaining to these assets as may be provided to the Registrant by the client, the other investment professional(s), and/or the account custodian, and does not include discretionary investment advisory services. Regardless of whether the Registrant provides the portfolio review/monitoring services as part of the Wealth Management and Planning Agreement services or on a stand-alone basis, the client (and/or the investment professionals engaged by the client with respect to such assets), and not the Registrant, shall be exclusively responsible for the investment performance of these assets. WEALTH PLANNING AND CONSULTING SERVICES The Registrant provides financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Wealth Management and Planning Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes, including certain of the Registrant’s representatives, in their individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Registrant’s previous recommendations and/or services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Registrant may provide financial planning and related consulting services. Neither the Registrant nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. The Registrant does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with the Registrant, if desired. Furthermore, although the Registrant may provide recommendations regarding non- investment related matters, such as estate planning, tax planning and insurance, the Registrant does not serve as a law firm, accounting firm, or insurance agency, and no portion of Registrant’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, the Registrant does not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.), including representatives of Registrant in their separate individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Family Dynamics, Governance, and Wealth Counseling Service. The Registrant offers Family Dynamics, Governance and Wealth Counseling services to its clients on a separate fee basis generally ranging from $5,000 to $50,000 on a project basis (depending upon the level and scope of the service(s) required and the professional(s) rendering the services), on hourly rate basis of $500, or for a monthly retainer of approximately $5,000. The Registrant shall provide this service in conjunction with the Registrant’s engagement of an unaffiliated industry professional. The terms and conditions, including the scope of the consulting service and corresponding fee, shall be set forth in writing between the Registrant and the client. Independent Managers/Sub-Advisers. The Registrant may also allocate a portion of client assets by and/or among certain independent investment manager(s) (the “Independent Manager(s)”), consistent with the stated investment objectives of the client. The Registrant may also engage sub-advisers to assist it with the management of the fixed income portfolios for a limited number of client accounts. The Registrant shall continue to render advisory services to the client relative to the ongoing monitoring and reviewing of account performance, for which Registrant shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Manager(s) or allocated to the sub-advisers. Factors which the Registrant shall consider in allocating client assets among Independent Manager(s) and/or sub-advisers include the client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s) and/or sub-adviser, together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets, are exclusive of, and in addition to, Registrant’s investment advisory fee set forth above. Unaffiliated Private Investment Funds. Registrant may provide investment advice regarding unaffiliated private investment funds. Registrant, on a non-discretionary basis, may also recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Registrant’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Registrant calculating its investment advisory fee. Registrant’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation In the event that Registrant references private investment funds owned by the client on any supplemental account reports prepared by Registrant, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If no subsequent valuation post-purchase is provided by the Fund Sponsor, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date), or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than original purchase price. The client’s advisory fee shall be based upon reflected fund value(s). The Registrant’s Chief Compliance Officer, Mary Keegan, remains available to address any questions regarding this conflict of interest. Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a non-discretionary investment advisory basis must be willing to accept that Registrant cannot affect any account transactions without obtaining prior consent to such transaction(s) from the client. Therefore, in the event that Registrant would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, the Registrant will be unable to affect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by Registrant independent of engaging Registrant as an investment advisor. However, if a prospective client determines to do so, they will not receive the Registrant’s initial and ongoing investment advisory services. In addition to Registrant’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses).

Interval Funds. When consistent with a client’s investment objectives, Registrant may allocate investment assets to “interval funds.” Investment companies structured as “interval funds” are generally designed for long-term investors that do not require daily liquidity. Shares in interval funds typically do not trade on the secondary market. Instead, their shares are subject to periodic redemption offers by the fund at a price based on net asset value. Accordingly, interval funds are subject to liquidity constraints. Interval funds investing in securities of companies with smaller market capitalizations, derivatives, or securities with substantial market and/or credit risk tend to have the greatest exposure to liquidity risk. Generally, the interval funds Registrant recommends offer liquidity during a one-to-two-week period, on a quarterly basis, during which a client can redeem previously purchased shares. Given the lack of secondary market, the infrequent nature of the offers to buy back shares, and liquidity gates (or re-purchase limits during the quarterly liquidity windows), you should consider the shares of interval funds to be illiquid. Registrant’s clients are under no obligation to use interval funds and may restrict the Registrants use of interval funds accordingly. Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Retirement Investors. The Registrant is a fiduciary under Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and under the Internal Revenue Code (“IRC”) with respect to investment management services and investment advice provided to ERISA plan clients (“Plan Sponsor”) including ERISA plan participants, IRAs and IRA owners (collectively “Retirement Investors”). The way that the Registrant makes money creates a conflict of interest so the Registrant must operate under a special rule that requires the firm to act in clients’ best interest and not put the firm’s interests ahead of its clients. As such, the Registrant is subject to specific duties and obligations under ERISA and IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a Prohibited Transaction Exemption (“PTE”). The Registrant has chosen to rely on the PTE (2020-02) as provided by the Department of Labor. Retirement Plan Rollovers. When the Registrant recommends a rollover of Retirement Assets into an IRA or Roth IRA, the firm believes that the “value add” that can be provided with respect to those assets (described herein), justifies any increased costs related to the management of the Retirement Assets. Like any other advice provided by the Registrant, a rollover recommendation is based on the individual client’s needs and circumstances, including the risks and potential rewards associated with that recommendation. It should be noted; however, that a conflict of interest arises when the Registrant recommends to clients that they roll over their Retirement Assets into an IRA or Roth IRA that is managed by the Registrant. By recommending that a client roll over retirement plan assets to an IRA, even if there are no costs associated with the IRA rollover itself, the Registrant is entitled to earn investment management fees on the IRA account. Investing in a managed IRA with any investment adviser, including the Registrant, will typically be more expensive than investing through your retirement plan. Opening a new IRA as a brokerage account will also result in additional charges such as commission charges and fees charged by the underlying investments (i.e., equity, fixed income, mutual fund, ETF, etc.). Custodial and trading fees also apply. See Item 5: Fees and Compensation. In contrast, leaving assets in a retirement plan or rolling the assets to a plan sponsored by a new employer will likely result in little or no compensation to the Registrant. Therefore, the Registrant has an incentive to encourage investors to rollover retirement plan assets into an IRA managed by the Registrant. Investors considering rolling over assets from a qualified employer-sponsored retirement plan to an IRA should review and consider the advantages and disadvantages. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover retirement plan assets to an IRA; or (4) Cash out the retirement plan assets and pay the required taxes on the distribution. At a minimum, Retirement Investors must consider the factors regarding the fees and expenses, available investment options, management and/or advisory services to be provided, availability of penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and the ability to place transactions in employer stock. the Registrant encourages clients to discuss their options and review the above-listed considerations with an accountant, third- party administrator, investment advisor to their Employer Plan (if available), or legal counsel. If a client chooses to move forward with a rollover of Retirement Assets into an account managed by the Registrant, that client must acknowledge the conflicts described above before any such rollover. Account Data Aggregation / Reporting Services. Registrant, in conjunction with the services provided by ByAllAccounts, Inc., eMoney, and Black Diamond may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by Registrant (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not Registrant, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, Registrant’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if Registrant is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), Registrant does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If Registrant were asked to make a recommendation as to any Excluded Assets, the client is under no obligation to accept the recommendation, and Registrant shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Registrant provide investment management services for the Excluded Assets, the client may engage the Registrant to do so pursuant to the terms and conditions of the Wealth Management and Planning Agreement between Registrant and the client. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG” considerations into the investment due diligence process. There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin, the Registrant, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, the Registrant will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. The Registrant does not recommend or advocate the purchase of, or investment in, cryptocurrencies. The Registrant considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Cash Positions. Registrant treats cash as an asset class. As such, unless determined to the contrary by the Registrant, all cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of Registrant’s written disclosure statement and Client Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the execution of the Wealth Management and Planning Agreement. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. Registrant does not offer a wrap fee program for its investment advisory services. E. As of December 31, 2023, the Registrant had $3,925,133,315 in assets under management on a discretionary basis, and $ $140,831,862 on a non-discretionary basis for a total of $4,065,965,177.