A. Van Strum & Towne is an independent investment advisory firm wholly owned by its two principals and portfolio managers, James L. Collins, CFA and Barbara A. Wright, CFA. The firm was founded in 1927. Our income is derived solely from professional fees for managing assets. We are registered with the Securities and Exchange Commission under the Investment Advisors Act of 1940 and are members of the Investment Advisor Association. Van Strum & Towne requires that all principals have a college degree and comprehensive knowledge of investments, banking, and finance. In addition, any associated persons involved in determining investment strategy or giving investment advice to clients must pass the Series 65: Uniform Investment Adviser Law Examination. Both of the firm’s principals have college degrees, have passed the Series 65 Uniform Investment Adviser Law Examination and are CFA Charterholders. The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential established in 1962 and awarded by the CFA Institute which is the largest global association of investment professionals. To earn the CFA charter, candidates must:
• Pass three sequential, six-hour examinations
• Have at least four years of qualified professional investment experience
• Become members of the CFA Institute
• Commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. The three levels of the CFA Program test proficiency within a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA Charterholders to:
• Place their clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters B. Most of our clients are high net-worth individuals. We also manage accounts for individuals, trusts, foundations, charities, IRAs, 401(k) plans, partnerships, and pension and profit-sharing plans. We do not manage wrap accounts. Accounts under management are both discretionary and non-discretionary. The size

of our firm gives us the flexibility to act on investment opportunities in a timely manner and provides our portfolio managers the time and resources needed to work closely with clients. Our firm's portfolio managers work collaboratively to determine investment strategy, asset-mix guidelines, and maintain an approved list of securities. Our portfolio management responsibilities focus on achieving client objectives and controlling portfolio risk. We do this by selecting equity investments in companies that we believe will achieve success over the long term. We also emphasize bond investments in entities that we deem to be of high quality. We do not provide investment advice for derivative instruments, structured securities or private funds. Our investment process is characterized by low portfolio turnover though we are organized to act quickly when conditions warrant. Services provided to clients may include: - Retirement plan analysis - Financial planning - Asset allocation - Investment Policy Analysis - Ongoing portfolio review - Other investment or financial asset review C. Our first objective in working with a new client is to understand fully a client's unique financial profile, investment objectives and specific requirements. This understanding enables us to work closely with clients to develop an investment strategy that defines realistic investment objectives, designed to meet client-specific needs. We establish the asset-mix in an effort to achieve realistic, long-term investment objectives. This iterative process, which requires ongoing communication with clients, enables us to position client portfolios to benefit from long-term growth in the investment markets. Clients may impose restrictions on investing in specific securities, companies, or industries. We rely on our clients to update us about changes in their investment circumstances or risk tolerance that may impact their portfolio asset mix decision or liquidity requirements. We encourage frequent contact with clients and their tax, legal and other professional advisors. We provide our clients with written quarterly portfolio appraisal reports as well as year-end capital transaction reports. We have the capability to tailor our reports and their frequency to meet client requirements. D. Van Strum & Towne does not participate in wrap fee programs. E. As of December 31, 2022, our firm managed approximately $348 million on behalf of 99 clients, with $311 million in discretionary assets and $37 million in non-discretionary assets.