Cambridge Capital Management, LLC (hereinafter referred to as "CCM") has been in business since 1999. We are an investment adviser registered with the SEC. Our principal place of business is in O’Fallon, Illinois. We also hold client meetings by appointment only at a St. Louis, Missouri office. Nathaniel W. Klitzing is the Managing Member and sole owner of the Firm. As of December 31, 2022, CCM managed $242,276,665 in assets on a discretionary basis and $27,846,529 on a non-discretionary basis for a total of $270,123,194 in assets under management. Investment Management Services CCM is in the business of managing individually tailored investment portfolios. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. We manage advisory accounts on a discretionary basis. Meaning, for these accounts, we implement transactions without seeking prior client consent. When CCM is providing investment management services to an account held at a client’s employer sponsored retirement plan we exercise non-discretionary authority only. In these circumstances, we obtain consent of the client before conducting a transaction in the account. In the event that CCM’s investment management services include assets held at a client’s employer sponsored retirement plan, CCM’s management is limited to the scope of the plan’s selections and restrictions. For assets in these “Held Away Account(s)” CCM does not accept discretionary authority to effect transactions and will not have, nor will it accept, any authority to make or effect any disbursements or transfers of assets. The client is solely responsible for implementing CCM’s recommendations for assets in a Held Away Account. Account supervision is guided by the stated objectives of the client (i.e., Capital Preservation, Conservative, Conservative Growth, Moderate, Moderate Growth, Growth, Full Growth), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Financial Planning/Consulting Services We also provide general financial planning to you as part of our Investment Management service if requested. Normally this service is provided to investment management clients without any additional fees. The focus of financial planning is to assist the client in defining personal financial planning goals and objectives to be pursued in the areas of business planning, children’s education, retirement planning, estate planning, tax planning, and investments, and to supply an analysis and recommendations as to the actions and investment strategies necessary to attain these goals and objectives. The client is not obliged to follow recommendations made during the financial planning process, it is solely up to the client to implement any advice, strategy, or recommendation made in a financial plan. For individuals wishing to receive financial planning not a part of investment management the Firm may be engaged to provide a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of this service is that through the process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. This service is subject to a flat fee based upon the scope and complexity of the engagement. The fee will be disclosed in the agreement signed by the Client prior to the start of the engagement. Clients can also receive investment advice on a more limited basis. This may include advice on asset allocation to participants in self-directed retirement plans or an isolated area(s) of concern such as investment strategy, estate planning, retirement planning, or any other specific topic. Retirement Plan Consulting Services We offer services to both plan sponsors and participants of retirement benefit plans. Plan Design and Provider Consulting. We may assist with various aspects of the plan design. We evaluate bundled or unbundled retirement plan service providers, including record keepers, third party administrators, trustees, custodians, investment companies and legal and accounting professionals. Investment Services. We offer assistance in creating and establishing a plan’s asset allocation and in evaluating, and monitoring investment options. This may include reviewing appropriate investment options for the plan, asset classes and investment styles, evaluating and recommending investment managers, types and selection of investment options. We may also conduct periodic reviews of the plan’s investments to evaluate performance, risk characteristics and expenses and recommend changes where appropriate. Employee Education Services. We provide services to help plan participants choose an appropriate deferral rate and investment selection by holding enrollment meetings and providing online or printed educational materials to encourage participation and help employees choose appropriate deferral rates and investment elections. We may also work directly with plan participants to help them evaluate their retirement savings goals and implement appropriate contribution amounts and investments available in the plan. In the event a client contracts with CCM for one-on-one consulting services such as, providing education or information on plan options and benefits to plan participants, those services are consultative in nature and do not involve CCM implementing recommendations in individual participant accounts and are not fiduciary in nature. It is the responsibility of each participant

to implement changes in the participant’s individual accounts. We can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. Fiduciary Services. To assist plan sponsors in fulfilling their ERISA fiduciary responsibilities, we may compare a plan’s services, investments, features and fees against those of comparable plans in similar-sized organizations, provide educational resources to help plan sponsors understand and meet their fiduciary obligations and provide detailed listings and explanations of all fees paid by the plan and participants to service providers and identify appropriate opportunities for cost savings. The following services are considered fiduciary consulting services:
• Plan Design Consulting
• Investment Policy Statement Development and Refinement
• Asset Allocation
• Manager Evaluation and Selection
• Performance Monitoring and Reporting
• Qualified Default Investment Alternative Evaluation and Recommendation
• Investment Reviews
• Participant Advisory Services
• Model Portfolios CCM acknowledges that in performing the fiduciary consulting services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Advisor acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Advisor to be a fiduciary as a matter of law. However, in providing the fiduciary consulting services, Advisor (a) has no responsibility and does not (i) exercise any discretionary authority or discretionary control respecting management of the client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of the client’s retirement plan or (iii) have any discretionary authority or discretionary responsibility in the administration of the client’s retirement plan or the interpretation of retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets and (c) is not the “Administrator” of the client’s retirement plan as defined in ERISA. The following services are considered non-fiduciary services:
• Plan Provider Consulting
• Employee Enrollment Meetings
• Participant Education
• Plan Benchmarking
• Fiduciary Education
• Fee Reporting and Analysis All recommendations of investment options and portfolios are submitted to the client for ultimate approval or rejection. Therefore, it is always the client’s responsibility to make changes to the plan itself. CCM does not serve as administrator or trustee of the plan. CCM does not act as custodian for any client account or have access to client funds or securities (with the exception of some accounts having written authorization from the client to deduct our fees). In addition, we do not implement any transactions in a retirement plan or participant’s account. For retirement plan consulting services, the retirement plan or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. CCM will disclose to you, to the extent required by ERISA Regulation Section 2550.408b-2(c), any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). Services in General CCM hereby acknowledges that it is a "fiduciary" when the firm’s services are subject to the provisions of ERISA of 1974, as amended. When we provide investment advice to you 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. Our investment, financial planning and consulting recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. While we reserve the right to offer advice on any product that may be suitable for each client’s specific circumstances, needs, goals and objectives, our advice primarily involves the following instruments:
• Exchange-listed securities
• Exchange traded funds (ETFs)
• “No-load” or “load-waived” mutual funds
• Corporate debt securities Occasionally, we may also recommend or advise on investments in the following instruments:
• Certificates of deposit
• Municipal securities
• Commercial paper
• United States government securities
• Variable Annuities We tailor our investment management and consulting recommendations to the individual needs of each client. All such recommendations are tailored based on information gathered through client questionnaires, electronic communications, telephone and in-person discussions. We believe in dollar-cost averaging, which means spreading the purchase of securities over time to achieve the lowest average cost. Termination of Agreements Clients have five (5) business days from the date of signing an advisory agreement with CCM to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, the client may terminate an agreement by providing written notice to our principal place of business. Upon termination, any prepaid unearned fees are promptly refunded, and any earned, unpaid fees are due and payable. CCM will typically pro rate the investment management services fee from date of termination for the time remaining in the current quarter. CCM has a right to terminate any agreement upon reasonable notice to the client. Upon termination, any unearned prepaid fees will be promptly refunded to the client, and any earned unpaid fees are immediately due and payable.