Advisory Business: The Bollard Group, established in 1995 and located in Boston, Massachusetts, is a multi-family office that provides investment advising; bookkeeping and other accounting services; income tax advising and tax return preparation; financial and estate planning services; and other wealth management and business advising services to its clients. Our clients primarily include high net worth individuals, trusts, charitable foundations and client family-centric companies. Spinnaker Capital LLC (“Spinnaker Capital”), established in 2000 and located in Boston, offers private funds (hereafter “Spinnaker Funds”) to certain eligible clients to invest in one or more of the following alternative investments: private equity, venture capital, hedge funds and real estate investments. Spinnaker Capital LLC is an affiliate of The Bollard Group and sponsors certain private funds. Spinnaker Capital LLC, as well as the other managing members of the related private funds, are relying on The Bollard Group’s registration with the SEC as an investment adviser. References to the “Firm” shall include The Bollard Group, Spinnaker Capital and the other relying advisers described in this Brochure. Firm Ownership: The Bollard Group is wholly owned by members of its senior management team and is controlled by Anastasios Parafestas (the “Principal”). At present, there are no outside ownership interests of the Firm. Spinnaker Capital and each of the managing members of the Spinnaker Funds are wholly-owned by the Principal. Advisory Services Offered: We provide both discretionary and non-discretionary investment advisory

and portfolio management services to individuals, trusts, charitable foundations and companies. In providing these services we tailor our advisory services to the individual needs of our clients. For each client, we formulate an investment objective, direct and manage the investment and reinvestment of the assets of the portfolio and provide portfolio performance and other reporting to the client. The core of our investment advisory and portfolio management services includes the design and implementation of equity portfolios, fixed income portfolios and highly liquid cash equivalent positions to meet our clients’ individual needs. As part of our service, we allow clients to instruct us in writing, if they wish to impose restrictions on investing in certain securities or types of securities. Where appropriate for the client, we offer access to alternative investments and through our related person, Spinnaker Capital, an opportunity to invest in the Spinnaker Funds. These types of investments involve additional risk and they will only be recommended when consistent with the client’s stated investment objectives, tolerance for risk, suitability and liquidity. Please see Items 5 and 10 for additional information regarding the Spinnaker Funds and the types of fees associated with an investment in a Spinnaker Fund. At present, we do not provide portfolio management services in any wrap fee programs. Assets Under Management: As of December 31, 2023, the Firm had $5,662,841,000 in total assets under management. Of this amount, $5,540,235,000 is managed on a discretionary basis and $122,606,000 is managed on a non-discretionary basis.