A. Time in business, ownership Hartford Financial Management, Inc. has been in business since 1989. Mr. R. Dario Quiros is the firm’s principal and owner. B. A summary of our advisory business We work closely with our clients or their authorized representatives to structure and develop investment programs that are individually suited to the client’s stated investment goals and risk preferences.
• For our “family” or individual clients, we typically apply a comprehensive and ongoing financial- planning-style of approach. This means that we gather information and confer with the client to understand broader financial needs and lifestyle goals for both the near and the long-term future. Using a written interview or other means, we gather data on the client’s assets, sources of income, anticipated expenses, goals, and anticipated life events. To develop the actual financial plan, we: Do an in-depth review of the current financial position: > Financial and life style assets > Income, expenses, and cash flow > Debt analysis > Risk analysis and insurance status > Estate planning status and issues Do financial & statistical analyses: > Modeling of assets, liabilities and cash flow > Projecting cash flows and asset values > Statistical analysis under varying market conditions Do “What If…” scenario analyses: > Investment scenarios and adjustments > Life style issues and changes Structure and implement the investment plan: > Plan objectives > Investment assumptions > Asset allocations > Investment guidelines & limiting parameters. We conduct on-going management of the relationship and the portfolio: > Quarterly reports > Annual meeting & financial review > Incorporate lifestyle changes > Measure progress relative to plan > Consult on other issues that might impact the plan > Adjust holdings of individual investments and securities > Adjust market sector allocations and holdings > Adjust asset allocations to maintain investment plan allocations > Dynamically manage and hedge investments as market conditions warrant
• For pension / profit sharing plan clients, services vary with the assignment. For company retirement plans, we offer investment management, investment policy creation, investment menu design, QDIA selection, total cost analysis, performance monitoring, plan benchmarking, and vendor search and evaluation. As applicable, our services will be designed to comply with ERISA regulations.
• For family businesses, services vary with the assignment. We offer investment management, as well as consultation via planning analysis including assessment of assets and opportunities and overall financial and/or business circumstances or considerations.
• For foundations or endowments, we offer investment management, spending formula analysis, investment policy review, board member communication & education, and investment review & reporting.
• For institutional clients such as banks or credit unions, services vary with the assignment. We offer investment portfolio management, balance sheet management, interest rate risk management, capital planning, and director education among other services as needed. We supervise client portfolios on an ongoing basis by monitoring daily developments in the markets and our clients’ changing circumstances, and by providing quarterly reviews of accounts for conformity with specified guidelines on a rolling basis. Those specified guidelines are spelled out in the investment advisory contract in combination with an investment policy statement--the “IPS”—unless a client declines the preparation of an IPS. We assist in arranging for custody of clients' securities and funds with third party vendors when requested or work with a client’s existing custodians and representatives. We provide performance results on an annual basis or more frequently as required. A Note on Retirement Assets: HFM sometimes gives advice to investors on whether to transfer/roll retirement assets to a different account. That advice could result in greater HFM compensation. As a fiduciary under ERISA (Employee Retirement Income Security Act) specifically with respect to retirement assets, HFM must follow procedures to seek to mitigate such conflicts of interest. HFM must evaluate with the investor whether the change is

in the investor’s best interest. Code of Ethics: (See also Item 11) As an investment adviser, Hartford Financial Management, Inc. has a written Code of Ethics which sets forth standards of conduct expected of its personnel. Investment advisers are fiduciaries and as such have the responsibility to render professional, continuous, and unbiased investment advice. Fiduciaries owe their clients a duty of honesty, good faith, and fair dealing, and must act at all times in the client's best interests and must avoid or disclose conflicts of interest. Our Code of Ethics emphasizes and implements these fundamental principles. It addresses, among other things, personal trading, gifts, the prohibition against the use of inside information, and other situations where there is a possibility for conflicts of interest. A copy of this Code of Ethics is available upon request. C. Tailoring of services and programs We tailor our services and programs to the individual needs of the client, including but not limited to attention to appropriateness and the client's stated risk tolerance. We manage, sell, exchange, invest and otherwise deal with clients' assets in such a way that in our sole and absolute discretion appears to further any and all stated investment objectives. We apply our discretion in the investment advisory relationship in keeping with our firm’s role as a fiduciary. In limited circumstances, a client may arrange in writing to limit that discretion, or to pose restrictions on investing in certain securities or types of securities. An example would be an individual client subject to employer blackout periods where he or she is not permitted by his or her employer to trade in the employer’s company stock at certain times. In general, however, we urge the client to avoid limits on discretion because it can lead to our inability to address time-sensitive matters during market events or when the client is unavailable. Understanding that changes in a client’s circumstances or goals certainly require feedback, flexibility, reassessment, and adjustment of plans or strategies, limiting our discretion can also open the door to undesirable ad-hoc investment decision-making by the client, difficulty addressing broader allocation, diversification, or income goals, or to excessive drift away from stated goals and plans, among other issues. Limits on discretion are the more typical structure only in our institutional client relationships where we are working with the institution’s management professionals. We offer customized investment programs, typically using direct investment in individual securities, including but not limited to:
• Stocks (equity securities)
• Fixed income securities such as bonds (municipal, government, corporate, etc.) and for certain of our clients for whom it would be appropriate, asset-backed and mortgaged-backed securities, among others
• Money market funds
• Exchange-traded funds and mutual funds when appropriate to serve liquidity or other purposes, such as when exposure to a certain aspect of the markets is desired using a limited allocation of assets and when direct investment in individual securities is not practical or cost-effective. When we begin management of a client portfolio that already contains these types of investments, we evaluate their current and ongoing value to the overall client plan. We look at a number of measures, including but not limited to their expense ratios, performance, fund management style, effect on diversification, volatility, etc. We also can work with separate accounts managers programs. Also, in the course of assisting a client with financial planning questions, we can help identify the potential beneficial role of a type of insurance product for a client and help analyze some alternatives. D. Wrap fee programs - Not applicable We do NOT participate in wrap fee programs. E. Assets managed on a discretionary basis. See also this Item 4, C, above. Hartford Financial Management, Inc. manages some clients on a discretionary basis, and some on a non-discretionary basis. See also Item 4, C, above for more discussion of “discretionary” management of assets. As of 12/31/2022 this was the breakdown: Assets managed on a discretionary basis: $ 711,638,355. Assets managed on a non-discretionary basis: $ 4,082,238.