A. Steigerwald, Gordon & Koch Inc. (“SGK”) is a Virginia corporation formed on June 17, 1996. SGK became registered as an investment adviser in June 1996. John S. Steigerwald is SGK’s principal owner. SGK’s officers are John S. Steigerwald, Chief Executive Officer; Jeffrey A. Gordon, President; Darren A. Koch, Vice President; and Karen Showalter, Secretary/Treasurer. B. As discussed below, SGK offers to its clients (generally: individuals, high net worth individuals, business entities, trusts, estates and charitable organizations, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES Clients can engage SGK to provide discretionary investment advisory services on a fee- only basis. SGK’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under SGK’s management. Before engaging SGK to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with SGK setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. SGK’s annual investment advisory fee compensates for investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. While SGK believes that it is important for the client to address financial planning issues on an ongoing basis, SGK’s fee, as set forth at Item 5 below, will remain the same regardless of whether the client determines to address those issues with SGK. If SGK determines in its sole discretion that the client requires extraordinary planning and/or consultation services, SGK may seek to charge for those services under the terms and conditions of a stand-alone Financial Planning and Consulting Agreement. Before SGK provides such investment advisory services, an investment adviser representative will coordinate with each client to develop their investment objectives. Then, SGK will allocate client investment assets consistent with the designated investment objectives. Once allocated, SGK provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may execute account transactions based on those reviews or other triggering events. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent requested by a client, SGK may determine to provide financial planning and/or related consulting services regarding matters such as tax and estate planning, insurance, etc. on a stand-alone basis per the terms and conditions of a separate written agreement and fee, the fee for which shall generally be based upon the individual providing the service and the scope of the services to be provided. Prior to engaging SGK to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with SGK setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to SGK commencing services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, SGK may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. as part of the investment advisory engagement or according to the terms and conditions of a stand-alone Financial Planning and Consulting Agreement. SGK does not serve as an attorney, accountant, or insurance agency, and no portion of its services should be construed as legal, accounting, or insurance implementation services. Accordingly, SGK does not prepare estate planning documents, tax returns or sell insurance products. Unless specifically agreed in writing, neither SGK nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with SGK, if desired. SGK’s financial planning and consulting services are completed upon communicating its recommendations to the client. Upon client request, SGK may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional, who shall be solely responsible for the quality and competency of the services they provide. If the client engages any unaffiliated recommended professional, and a dispute arises related to the engagement, the client should seek recourse exclusively from and against the engaged professional. Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If SGK recommends that a client roll over their retirement plan assets into an account to be managed by SGK, such a recommendation creates a conflict of interest if SGK will earn new (or increase its current) compensation an advisory fee on the rolled over assets. Whether SGK provides a recommendation as to whether a client should engage in a rollover or not, SGK is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over plan assets to an IRA managed by SGK or to engage SGK to monitor and/or manage the account while maintained at the client’s employer’s plan or an existing IRA. SGK’s Chief Compliance Officer, John Steigerwald, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Portfolio Activity. SGK has a fiduciary duty to provide services consistent with the client’s best interest. SGK will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when SGK determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by SGK will be profitable or equal any specific performance level(s). Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of SGK. Generally, with potential exceptions, SGK does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by SGK will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by SGK) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client for which SGK does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which SGK does not maintain custodian access and/or trading authority. Corresponding Services/Fees. When agreed to by SGK, SGK shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by SGK; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Cash Positions. SGK continues to treat cash as an asset class. As such, unless determined to the contrary by SGK, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating SGK’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), SGK may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, SGK’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Account custodians generally require

that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, SGK shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless SGK reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. ANY QUESTIONS: SGK’s Chief Compliance Officer, John Steigerwald, remains available to address any questions that a client or prospective client may have regarding the above. ESG: We don’t have or recommend a strategy: Please Note: Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by SGK), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. SGK does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, SGK shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, SGK, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, SGK will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: SGK does not recommend or advocate the purchase of, or investment in, cryptocurrencies. SGK considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Client Obligations. In performing its services, SGK will not be required to verify any information received from the client or from other designated professionals who provide services to the client, and SGK is expressly authorized to rely thereon. Clients maintain responsibility to promptly notify SGK if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising SGK’s previous recommendations or services. Reporting Services. SGK can also provide, for a separate fee (delete if no additional fee), account reporting services, which can incorporate client investment assets that are not part of the assets that SGK manages (the “Excluded Assets”). Unless agreed to otherwise, the client and/or his/her/its other advisors that maintain trading authority, and not SGK, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, SGK does not provide investment management, monitoring or implementation services for the Excluded Assets. If SGK is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and SGK shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage SGK to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between SGK and the client.
• emoney. In the event that SGK provides the client with access to an unaffiliated vendor’s website such as emoney (change if a different vendor), and the site provides access to information and/or concepts, including financial planning, the client, should not, in any manner whatsoever, infer that such access is a substitute for services provided by SGK. Rather, if the client utilizes any such content, the client does so separate and independent of SGK. Cybersecurity Risk. The information technology systems and networks that SGK and its third-party service providers use to provide services to SGK’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in SGK’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and SGK are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although SGK has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that SGK does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by SGK) will be profitable or equal any specific performance level(s). Disclosure Statement. A copy of SGK’s written Brochure as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. Availability Exchange Traded Funds. SGK utilizes exchange traded funds for certain client portfolios. In addition to SGK’s investment advisory fee described below, clients will also incur, relative to exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, SGK generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker- dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on individual equity transactions [including ETFs], others do). These fees/charges are in addition to SGK’s investment advisory fee at Item 5 below. SGK does not receive any portion of these fees/charges. C. SGK provides investment advisory services specifically tailored to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, SGK will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on SGK’s services. D. SGK does not participate in a wrap fee program. E. As of December 31, 2023, SGK had $1,050,589,563 in assets under management on a discretionary basis.