Firm Description Howland Capital Management LLC was founded as Blackstone Management Corporation in 1967. The name of the firm was changed to Howland Capital Management, Inc. in 1994. In 2012, the firm was restructured under the same ownership and management and is now Howland Capital Management LLC. Howland Capital Management LLC (HCM) provides personalized, confidential investment management to various types of clients and invests in publicly and privately traded securities. HCM generally provides investment advice to:  individuals and families  revocable and irrevocable trusts  retirement and pension accounts  custodian accounts and education trusts  foundations and charitable organizations  endowments for non‐profits  estates The investment advice provided by HCM is variable depending on the needs, objectives and other preferences of the client. Advice is provided through consultation with the client and can include:  determination of financial objectives  investment management  cash flow management  tax planning  insurance review  education funding  retirement planning  estate planning  identification of financial problems  charitable planning  ESG investing Client accounts are managed on a separate account basis. The initial meeting with a prospective client or client family is an exploratory interview to determine the extent to which investment management may be beneficial. Once a prospective client signs an Investment Advisory Agreement and becomes a client, the account opening process begins. As part of the account opening process, the manager develops an in‐depth knowledge of the client’s financial situation, which is reflected in the Investment Policy Statement (IPS). HCM is strictly a fee‐only investment advisory firm. The firm is not affiliated with entities that sell financial products or securities. HCM employs the services of National Advisors Trust Company, FSB (NATCo) to act as the qualified custodian for most HCM clients. NATCo is based in Kansas City, MO. HCM also provides tax consultation and tax return preparation to its clients for a separate fee. Principal Owners Weston Howland III and Charles E. Clapp III are the majority members, holding 54% of the outstanding stock, each with approximately 50%. Types of Advisory Services HCM provides investment advisory services, also known as asset management services. HCM frequently furnishes advice to clients on matters not involving securities, such as financial planning, taxation, and trusts, including estate planning. As of December 31, 2022, HCM managed $2,585,963,800 on a discretionary basis. Tailored Relationships The goals and objectives of each client are documented in HCM’s client relationship management system. Investment Policy Statements are created to reflect the client’s stated goals and objectives. The Investment Policy Statement also drives the investment program, which takes into account a client’s tax situation, risk tolerance, time horizon, estate plan, security and asset preferences and other items relevant to their goals and objectives. Types of Agreements The following agreements define typical client relationships: Investment Advisory Agreement ‐ HCM provides investment management services to all of its clients. The scope of the work and fee structure are provided to the client prior to the start of the relationship and are described in the Investment Advisory Agreement. The Investment Advisory Agreement covers such areas as the development of an investment program, custody and fees, reports to clients and client confidentiality. The client’s financial affairs are reviewed, including those of their children if requested. Realistic and measurable goals are determined and objectives are set to reach those goals. As goals and objectives change over time, recommendations are made and implemented on an ongoing basis. HCM cannot transfer an Investment Advisory Agreement without client consent. Please refer to Item 5 of this brochure for applicable fee schedules. Tax Engagement Letter ‐ Tax consultation and preparation work are performed separately and billed on an hourly basis. HCM has the right to terminate any of the aforementioned agreements at any time by notifying the client in writing.

Similarly, a client has the right to terminate an Advisory Agreement by notifying HCM in writing. Please refer to Termination of Agreement below regarding the billing procedure for the final fee. Asset Management Assets are invested primarily in:  Cash Liquidity Program  Equities (stocks) ‐ domestic and international  Mutual funds (open & closed ended), exchange‐traded funds  Treasury, agency, municipal, and corporate bonds  Private equity and private pooled investments For mutual funds, HCM is generally able to buy institutional class shares that charge lower fees. Mutual fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. HCM does not receive any compensation, in any form, from fund companies. Stocks and bonds are purchased or sold through a group of broker dealers chosen by the firm based on the quality of their research and their ability to deliver best execution trades. The brokerage firms used receive commission on the stocks and bonds traded. This commission is passed on to the client and is included in the total price the client pays for the stock or bond. HCM also manages private equity and private pooled investments. Please refer to Item 8 for more information on these private investments. Valuation of Securities Publicly Traded Securities ‐ HCM has a valuation policy that defines how the value of securities held in HCM’s client accounts is determined. Equities listed on any stock exchange, mutual funds, index funds and exchange traded funds are valued daily. Bonds are valued on a daily, weekly, or monthly basis, depending on the type. Pooled Investments (HCM Venture Funds) – HCM relies on the capital account valuation provided in the quarterly reports published by the underlying funds held in the pool. In general, these funds follow valuation guidelines in FASB No. 157, that have become universal for most venture capital funds. Valuation of these funds is ongoing. All documentation is held in either electronic or paper form, and in some cases both. Private Equity Chosen by HCM – In the small number of cases where HCM makes a direct private investment on behalf of a client, it lists the value of the security at cost until there is a significant event that warrants a change in price. A significant event is generally defined as a major deviation from the business plan or a financing where an independent third party values the company. In the event that HCM is unable to substantiate an updated price, it continues to value the asset at cost. In some cases where a third party cannot be relied upon to value a private equity investment, HCM will determine the price itself using company metrics and a methodology specific to the company and its industry. It evaluates these special cases individually. In situations where the asset is not feed and only held by a few clients, HCM may not calculate a price. Private Equity Chosen by Clients – Under certain circumstances, HCM may hold private equities selected by a client in their accounts. In these situations, HCM typically receives valuation updates directly from the company. Termination of Agreement A client is able to terminate an Advisory Agreement by notifying HCM. As of the notification date, the Advisory Agreement will cease to be discretionary and will instead be non‐discretionary. This means that HCM will continue to monitor the account associated with the Agreement and will not make any changes to the account (aside from raising cash to pay final fees) without the client’s approval. If the manager believes changes to the account are warranted due to extreme circumstances pertaining to a security and/or the markets, they will seek client approval in writing before proceeding. In addition, the client can instruct the manager to make changes in their account in writing. Final account fees will be collected on the day the assets are transferred from the current custodian to the new custodian. The account will be billed only up to that date. A client is able to withdraw, in whole or in part, any assets held in the account by providing notice to HCM and NATCo, subject to reasonable delays necessary to obtain the transfer of securities or to convert assets into cash for subsequent transfer.