Wharton Business Group, LLC (the “Registrant”) is a limited liability company formed on September 23, 2009 in the State of Delaware. The Registrant became registered as an Investment Adviser Firm in November 2009. The Registrant is directly owned by Alera Group Inc. A. As discussed below, the Registrant offers to its clients (individuals, high net worth individuals, pension and profit sharing plans, 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 The client can determine to engage the Registrant to provide discretionary and/or non- discretionary investment advisory services on a fee basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management, generally between negotiable and 1.00%. Registrant's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the Registrant), the Registrant may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. RETIREMENT PLAN CONSULTING SERVICES Registrant provides retirement consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (hereafter the “Company”) in meeting their management and fiduciary obligations to the plan under the Employee Retirement Income Securities Act (“ERISA”). Retirement consulting services will consist of general or specific advice, and may include any one or all of the following: 1. Strategic Planning and Investment Policy Development/Review. Meet with the Company and/or the named fiduciary or their fiduciary delegate to assist them in developing an investment policy statement (hereafter the “IPS”). Alternatively, if the plan has an existing investment policy statement, Registrant will review the existing IPS and assist the Company, named fiduciary and/or their fiduciary delegate to determine whether the plan is performing consistent with the IPS and/or whether the IPS needs to be revised, based on an analysis of the plan’s liquidity requirements, performance goals and risk tolerance levels of the plan using information provided by the Company; 2. Plan Review. Conduct a review of the plan design and advise the named fiduciary whether the plan is operating in accordance with plan documents and applicable provisions of ERISA; and review named fiduciary's compliance with fiduciary responsibilities, including compliance with requirements for self-directed plans (if applicable) under ERISA Section 404(c); 3. Plan Fee and Cost Review. Conduct an annual review fees and costs charged to plan by other service providers to assist named fiduciary to determine reasonableness of fees and costs paid by plan; 4. Third Party Service Provider Liaison. Act as liaison for the plan and the named fiduciary when dealing with the trustee, custodian, plan actuary and other third party service providers to plan; 5. Assessment of Investments. Conduct a periodic review of fund expenses, investment performance, and style drift for mutual funds offered by the plan to participants, comparing them with other funds in the same asset category using Morningstar data from Principia and MPI Stylus; provide suggestions to the named fiduciary from time to time as deemed warranted by the IAR for alternative mutual fund options for the plan to make available to its participants (which decision shall remain the sole and exclusive decision of the named fiduciary and/or their fiduciary delegate); 6. Participant Education and Communication. Coordinate and/or conduct investment education and enrollment meetings for plan participants as determined by the Company. The Company may also engage Registrant to provide the following additional services, for separate compensation: 1. Executive Benefits. Review, design and implementation for nonqualified plans/deferred compensation. 2. Plan Conversion. Assist with conversion to alternate vendors, including preparation of Request for Proposal (“RFP”) from prospective new vendors, and review and comparison of responses to RFP. 3. Merger and Acquisition Assistance. Perform merger and acquisition due diligence review of pension plan documents and investments for possible merger or termination of duplicate plans. 4. Compliance Correction. Assist with corrective actions as necessary to comply with applicable laws and regulations. 5. Coordination with Other Advisers. Interact with outside advisors, or tax, legal and accounting counsel as necessary. Registrant and the Company will determine in advance the scope of services to be performed and the fees for all requested services. Prior to engaging Registrant to provide pension consulting services, the Company will be required to enter into an Investment Advisory Agreement with Registrant setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee paying arrangements. In performing the contracted services, Registrant shall not be required to verify the accuracy or consistency of any information received from the Company. All client accounts are regulated under ERISA. Registrant will provide pension consulting services to the Company as described above. In providing pension consulting services, Registrant and the Company agree that Registrant will serve in a fiduciary capacity with respect to certain of the services provided, and as referenced in the Investment Advisory Agreement. However, the Company is free to seek independent advice about the appropriateness of any recommendations made by Registrant. Although allowable under certain circumstances, Registrant, will not render advice to utilize any affiliated mutual funds and will not act as broker of record or directly receive any commissions or mutual fund 12b-1 fees from investments of the plan assets. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent requested by a client, the Registrant may determine to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Registrant 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 Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes, including the Registrant’s representatives in their individual capacities as licensed insurance agents. (See disclosure at Item 10.C). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If the client engages any such

recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by the client, Registrant may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Registrant does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Registrant does not prepare estate planning documents or tax returns. To the extent requested by a client, Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.), including representatives of Registrant in their separate individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant and/or its representatives. Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note-Conflict of Interest: The recommendation by Registrant’s representative that a client purchase an insurance commission product through Registrant’s representative in his/her separate and individual capacity as an insurance agent, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any insurance commission products through such a representative. Clients are reminded that they may purchase insurance products recommended by Registrant through other, non- affiliated insurance agencies. Registrant’s Chief Compliance Officer, B.J. Webster, Jr., remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Retirement Rollovers-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 the Registrant recommends that a client roll over their retirement plan assets into an account to be managed by the Registrant, such a recommendation creates a conflict of interest. Registrant will earn new (or increase its current) compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant. The Registrant’s Chief Compliance Officer, B.J. Webster, Jr., 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. ERISA / IRC Fiduciary Acknowledgment. If the client is: (i) a retirement plan (“Plan”) organized under ERISA; (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take a distribution; (iii) the beneficial owner of an IRA acting on behalf of the IRA; or (iv) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code: then the Registrant represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by the Registrant or its representatives or with respect to any investment recommendations regarding an ERISA Plan or participant or beneficiary account Please Note: Cash Positions. 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), the Registrant may maintain cash positions for defensive purposes. All cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating the Registrant’s advisory fee. ANY QUESTIONS: The Registrant’s Chief Compliance Officer, B.J. Webster, Jr., remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a non- discretionary investment advisory basis must be willing to accept that Registrant cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Registrant would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, the Registrant will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2 of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. B. The Registrant shall provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, an investment adviser representative will discuss with each client, their particular investment objective(s). The Registrant shall allocate each client’s investment assets consistent with their designated investment objective(s). Clients may, at anytime, impose restrictions, in writing, on the Registrant’s services. C. The Registrant does not participate in a wrap fee program. D. As of March 26, 2024, the Registrant had $3,333,268,060 in assets under management on a discretionary basis and $319,111,872 in assets under management on a non- discretionary basis.