History and Ownership WindRock Wealth Management (“WindRock”) was formed in 2012 to create a wealth management firm with an entrepreneurial-mindset to seize on unique investment opportunities fitting the macroeconomic backdrop. WindRock provides full portfolio advisory services including asset allocation and research on a wide variety of public and private investment opportunities. Brett Rentmeester is the sole owner and Principal at WindRock (“Principal”) through OceanRock LLC, an entity owned by the Principal. Brett is a veteran entrepreneur in the investment business. Formerly, Brett was a founding partner of Altair Advisers, an investment advisor in Chicago. Prior to that, Brett was a manager in Arthur Andersen’s Investment Advisory Services practice in Chicago. Types of Advisory Services WindRock offers the following investment offerings detailed below. FAMILY OFFICE SOLUTIONS WindRock’s Family Office Solutions serve families typically with more than $10 million of assets. We develop an intimate tie to the families we work with to understand their personal situation, goals and objectives, and motives for investing their money. We serve as our clients’ investment strategist, serving to invest and oversee their portfolio in a holistic manner coordinated with their other financial planning. We work closely with their other service providers (e.g. estate planner, CPA, private banker, family office etc.) to assist in coordinating their overall financial planning. We have found that most wealthy families struggle with coordinating the information flow amongst their team of advisors, often costing them real money and lost opportunity. Our process begins with an in-depth discussion with each client to formulate an appropriate investment portfolio. This culminates in the written formation of an investment policy statement, which serves as a blue-print for the investment strategy. WEALTH MANAGEMENT SERVICES WindRock’s Wealth Management Services are available typically starting at minimums of $500,000. We work with clients to determine their risk tolerance and then to match them appropriately to a portfolio representing our best thinking. We view the investment universe in four broad categories – Global Equities & Tactical Allocators, Global Bonds, Hard Assets and Unique Private Investments. Some clients engage us to advise them on their entire investment portfolio and other clients engage us to advise them on a specific silo of their investment portfolio, such as the Hard Asset and/or Unique Private Investment categories. Hard Assets generally include a mix of assets that are positioned benefit from inflation with major sub- categories including: precious metals (bullion and miners), diversified commodities (e.g. energy, metals, agriculture/farmland), foreign currencies and unique trades. The Unique Private Investment category includes private investments such as the investment opportunities through “Iridius” (e.g. Iridius Investment Advisors LLC, Iridius Real Estate Managers LLC, Iridius Capital LLC, Iridius Income Fund(s) & affiliates), “SCM” (Singularity Capital Advisors LLC, Singularity Capital Management LLC & affiliates), and “SC” (Singularity Capital LLC, Singularity Investment Managers LLC and affiliates), which are generally available to accredited investors. These private investments are more fully detailed on page 5 “Conflicts of Interest”. Clients who inform WindRock of their intentions or desire to diversify by including private investments in their portfolios and who also acknowledge they are aware of the formal relationship between the Principal and Iridius, SCM and SC, shall be notified of any Iridius, SCM or SC investment opportunities and shall have the right to participate or decline. WindRock clients who invest in Iridius, SCM, or SC opportunities pay a management and incentive fee (subject to performance) to SCM or SC, where the Principal is an owner. For clients that engage us to advise them on their overall portfolio, we formalize an investment policy statement consistent with the strategy chosen. We communicate with clients primarily through quarterly webcasts, discussions and meetings to discuss the strategies and our view of the investment environment. Once a documented strategy is agreed upon for either Family Office or Wealth Management Services, WindRock manages the portfolio within the confines of the agreed parameters and reports results to clients. Assets are invested with various investment managers, mutual funds, ETFs, derivatives and private investments. For assets that have pre-determined investment choices, such as a 401(k) Plan, WindRock will assist clients in finding appropriate investments that fit within the context of their overall asset allocation and investment plan. WindRock does not directly assist Wealth Management clients with financial planning services, but will connect clients with particular needs to third-party service providers in areas such as mortgage financing and lending, estate planning, certified public accountants, family office concierge services, and other financial services. These providers will be selected based on their services, reputation and fees. WindRock may receive referrals from these third-party providers that work with our clients as well as other third-party providers that don’t work with WindRock clients. WindRock is not responsible for the advice or actions of these third-party service providers. There is no obligation for clients to utilize any of these providers, but we believe we are providing valuable connections for clients that are seeking outside advisors. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent. Retirement Plan Services WindRock offers retirement plan services to retirement plan sponsors. For a corporate sponsor of a retirement plan, our retirement plan services may include one or more of the following services: Fiduciary Consulting Services WindRock provides the following fiduciary retirement plan consulting services:
• Non-Discretionary Investment Advice. WindRock will provide the retirement plan sponsor (“Sponsor”) with general, non-discretionary investment advice regarding assets classes and investment options, consistent with your plan’s investment policy statement.
• Investment Selection Services. WindRock will provide Sponsor with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. WindRock will provide Sponsor with periodic due diligence reviews of the plan’s reports, investment options and recommendations.
• Investment Monitoring. WindRock will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and WindRock will make recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. WindRock will provide you with non- discretionary investment advice to assist Sponsor with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c- 5(e)(4)(i), for participants who are automatically enrolled in the plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to Sponsor for their ultimate approval or rejection. The retirement plan Sponsor client who elects to implement any recommendations are providing WindRock with the power and authority to carry out these decisions by giving instructions, on Sponsor’s behalf, to brokers and dealers and the qualified custodian(s) of the plan for management of the designated retirement plan assets. Fiduciary Consulting Services are not

management services, and WindRock does not serve as administrator, plan fiduciary or trustee of the plan. WindRock 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). WindRock 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 Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non- discretionary investment advice only. WindRock will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause WindRock to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, WindRock (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of client’s retirement plan or the interpretation of client’s 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 without the express approval from the plan administrator. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances. Clients must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, WindRock will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All clients are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, WindRock cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. WindRock will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to Sponsor 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). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or plan administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learns of such error or omission. Retirement Plan Rollover Recommendations When WindRock provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that WindRock is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way WindRock makes money creates conflicts with your interests so WindRock operates under a special rule that requires WindRock to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, WindRock must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put the financial interests of WindRock ahead of you when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that WindRock gives advice that is in your best interest;
• Charge no more than is reasonable for the services of WindRock; and
• Give client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by WindRock, please know that WindRock and our investment adviser representatives have a conflict of interest. WindRock can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by WindRock. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by WindRock. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in WindRock receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by WindRock and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of WindRock or our affiliated personnel. Wrap Fee Programs Advisor does not participate in wrap fee programs. Client Assets under Management As of December 31, 2023, WindRock managed approximately $342,795,865 of client assets under management on a discretionary basis.