A) History and Ownership Harbor Advisory Corporation (“Harbor” and also doing business as “Harbor Advisory”), an SEC registered investment adviser located in Portsmouth, New Hampshire, has been providing personalized investment management services to individuals, families, foundations, trusts, estates, charitable organizations, pensions and profit-sharing plans, and corporations since 1972. Harbor is completely employee owned. Its owners are Weld R. Butler, John J. De Gan, and Daniel R. Zibinskas. B) Advisory Services Offered Harbor offers discretionary investment management of equity, balanced, and fixed income portfolios. Investment management clients can expect Harbor to offer advice on retirement planning, estate planning, educational funding, insurance issues, debt management, and tax planning as they relate to portfolios. Harbor does not practice law nor do we prepare tax returns. Harbor actively coordinates with tax, legal and other professional advisors on behalf of its clients. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or

the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C) Individualized Investment Management Harbor renders portfolio management services by working with each client to develop an individualized asset allocation plan based on each client’s risk profile and individual needs, including the extent and nature of the client’s assets, tax and estate needs, and other considerations. Portfolios are designed to fulfill specific objectives of individual clients and may or may not resemble portfolios of other clients depending on each client’s risk profile, tax profile or other individual requirements. Clients who wish to impose restrictions on investing in certain securities or types of securities (due to specific philosophical or ideological objections to certain companies or industries or otherwise) can instruct their portfolio manager to avoid or eliminate these investments from their portfolio. D) Wrap Fee Programs Harbor DOES NOT participate in wrap fee programs. E) Discretionary Investment Management As of December 31, 2023, Harbor managed $402,797,487.62 in client assets, $402,144.674.90 of w h i c h a r e m a n a g e d on a discretionary basis and $652,812.72 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.