Gavin J Stellpflug

We charge an asset management fee to manage your investments, which is a percentage of your total investments managed by us, calculated based on the percentage of your managed investments' value as of the average daily balance in your accounts. A schedule of fees is included in the firm's Form ADV, Part 2A (Item 5), which can be found here: https://adviserinfo.sec.gov/firm/summary/269866. The asset management fee is prorated by quarter and is paid per quarter in arrears in four quarterly increments. We generally negotiate fixed rate management fees for certain ultra-high-net-worth clients on a case-by-case basis. Although we believe that our asset management fee is competitive, you should be aware that lower fees for comparable services may be available from other investment advisers. Depending on your investments, you may also pay other third-party fees, including brokerage, custodian, performance and account maintenance fees, fees related to mutual funds and ETFs, as applicable. Because our asset management fee increases as we manage more of your investments, we may be incentivized to encourage you to add more investments for us to manage on your behalf. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. More specific information regarding fees is available in Item 5 of our Form ADV, Part 2A, which may be found here: https://adviserinfo.sec.gov/firm/summary/269866. The asset management fee is prorated by quarter and is paid per quarter in arrears in four quarterly increments. We generally negotiate fixed-rate management fees for certain ultra-high-net-worth clients on a case-by-case basis. Although we believe that our asset management fee is competitive, you should be aware that lower fees for comparable services may be available from other investment advisers. Depending on your investments, you may also pay other thirdparty fees, including brokerage, custodian, performance and account maintenance fees, fees related to mutual funds and ETFs, as applicable. Because our asset management fee increases as we manage more of your investments, we may be incentivized to encourage you to add more investments for us to manage on your behalf. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. More specific information regarding fees is available in Item 5 of our Form ADV, Part 2A, which may be found here: https://adviserinfo.sec.gov/firm/summary/269866.

When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means:

We have minority owners that are also our clients. As a result, we may be perceived to favor these owners, all of whom are ultra-highnet-worth clients, in providing investment opportunities that would not be available to other clients. These owners, by virtue of their investment experience, sophistication, risk tolerance, and substantial net worth, can and do invest in certain investments that would not be suitable for all but a few of our clients.

In addition, when suitable and appropriate, we recommend that our clients invest in investments that are managed by our affiliates, Palladius Capital Management, LLC (“Palladius”) and Oakhurst Capital Management ("OCM" or collectively "Affiliates"). Our Affiliates, while sharing common ownership, are separate and independent firms and charge fees that are in addition to our asset management fee. We may be incentivized to recommend that you invest in Affiliates-managed investments in order to receive these additional fees. In certain cases, we reduce our asset management fee or have negotiated a reduction of our Affiliates-related fees to mitigate these incentives. In all cases, we disclose these conflicts in detail and monitor and evaluate the performance of these Affiliates-managed investments consistent with our fiduciary duty to you. Nonetheless, you may find other comparable investments with lower fees from unaffiliated third parties.

For additional information concerning all of our material conflicts of interest in managing your investments, please refer to Items 6, 8, 11 and 12 of Part 2A of our Form ADV, which can be found here: https://adviserinfo.sec.gov/firm/summary/269866.

Our advisors are either employees or partners of our firm. Your advisor typically receives a portion of the asset management fee as compensation for his or her services to you. Partners are further compensated by sharing in our firm's overall profits, which are derived largely from the asset management fee charged to you and our other clients. Your advisor may also be compensated by sharing in a portion of any fees relating to consulting services provided to you.