GLL offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to GLL rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with GLL setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). GLL has been in business as a registered investment adviser since August 31, 2018, and is owned by Asa Wesley Graves VII, John Douglas Light, Jeffrey Grant Lenhart and Ashley Philip Heatwole. As of the December 31, 2023, GLL had $1,086,150,779 in assets under management, of which $1,054,235,885 was managed on a discretionary basis and $31,914,894 was managed on a non-discretionary basis. While this brochure generally describes the business of GLL, certain sections also discuss the activities of its Supervised Persons, which refer to GLL’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on GLL’s behalf and are subject to GLL’s supervision or control. Financial Planning and Consulting Services ______________________________________________________________________________ GLL offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:  Business Planning  Cash Flow Forecasting  Trust and Estate Planning  Financial Reporting  Investment Consulting  Insurance Planning  Retirement Planning  Risk Management  Charitable Giving  Distribution Planning  Tax Planning  Manager Due Diligence These services are rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below) and not offered on a stand-alone basis. In performing these services, GLL is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. GLL recommends certain clients engage GLL for additional related services, or its Supervised Persons in their individual capacities as licensed insurance agent and or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for GLL to recommend that clients engage GLL or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by GLL under a financial planning or consulting engagement. Clients are advised that it remains the client’s responsibility to promptly notify GLL of any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating or revising GLL’s recommendations and/or services. Wealth Management Services ______________________________________________________________________________ GLL manages client investment portfolios on a discretionary or non-discretionary basis. In addition, GLL provides certain clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non- discretionary management of investment portfolios. GLL primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and options in accordance with their stated investment objectives. Where appropriate, GLL also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously

monitored or otherwise advised on by GLL unless specifically agreed upon. Clients can engage GLL to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, GLL directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. GLL tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. GLL consults with clients on an initial and ongoing basis to assess the client’s specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify GLL if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if GLL determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to GLL’s management efforts. Retirement Plan Consulting Services GLL provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:  Plan Design and Strategy  Plan Review and Evaluation  Executive Planning & Benefits  Investment Selection  Plan Fee and Cost Analysis  Plan Committee Consultation  Fiduciary and Compliance  Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by GLL as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of GLL’s fiduciary status, the specific services to be rendered and all direct and indirect compensation GLL reasonably expects under the engagement. Fiduciary Responsibility for Retirement Accounts ______________________________________________________________________________ When we provide investment advice to a client regarding a retirement plan account or individual retirement account, GLL is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way GLL makes money creates some conflicts with your interests, so we operate under a special rule that requires us to act in the best interest of the client and not put GLL’s interest ahead of the client’s interest. Under this special rule’s provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put GLL’s financial interests ahead of the client’s financial interests when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interests, fees and investments;  Follow policies and procedures designed to ensure that GLL gives advice that is in the best interest of the client;  Charge no more than is reasonable for services provided; and  Give the client basic information about conflicts of interest.