BALDWIN WEALTH PARTNERS, LLC

Item 1: Cover Page Form ADV Part 2A Investment Adviser Brochure 204 Spring Street Marion, MA 02738 (508) 748-0800 www.baldwin-llc.com March 2025 This Brochure provides information about the qualifications and business practices of Baldwin Wealth Partners, LLC (“we,” “us,” “our”). If you have any questions about the contents of this Brochure, please contact Steven T. Dean, Chief Compliance Officer, at (508) 748-0800 or sdean@baldwin-LLC.com. Additional information about our Firm is also available at the SEC’s website, www.adviserinfo.sec.gov. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. We are a registered investment adviser. Please note that use of the term “registered investment advisor” and a description of the Firm and/or our employees as “registered” does not imply a certain level of skill or training. For more information on the qualifications of the Firm and our employees who advise you, we encourage you to review this Brochure and the Brochure Supplement(s).  Item 2: Summary of Material Changes In this Item of Baldwin Wealth Partners, LLC ’s (Baldwin Wealth Partners or the “Firm”, “we”, “us”, “ours”) Form ADV 2, the Firm is required to discuss any material changes that have been made to Form ADV since the last Annual Amendment. Material Changes since the Last Update Since the last Annual Amendment filing on March 26, 2024, the Firm has the following material change to report: • Effective August 2024, our legal name changed from Baldwin Brothers LLC to Baldwin Wealth Partners, LLC. Annual Update You will receive a summary of any material changes to our Form ADV brochure within 120 days of our fiscal year end. We may also provide updated disclosure information about material changes on a more frequent basis. Any summaries of changes will include the date of the last annual update of the ADV. Full Brochure Available Our Form ADV may be requested at any time, without charge by contacting Steven T. Dean, Chief Compliance Officer, at (508) 748-0800 or sdean@baldwin-LLC.com. Additional information about our Firm is also available at the SEC’s website, www.adviserinfo.sec.gov. The SEC’s website also provides information about any employees affiliated with the Firm who are registered as investment advisor representatives. 2  Item 3: Table of Contents Item 1: Cover Page ........................................................................................................................ 1 Item 2: Summary of Material Changes .......................................................................................... 2 Item 4: Advisory Business ............................................................................................................. 4 Item 5: Fees and Compensation .................................................................................................... 8 Item 6: Performance-Based Fees and Side-By-Side Management .............................................. 13 Item 7: Types of Clients ............................................................................................................... 14 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 15 Item 9: Disciplinary Information.................................................................................................. 20 Item 10: Other Financial Industry Activities and Affiliations ....................................................... 21 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 22 Item 12: Brokerage Practices ...................................................................................................... 24 Item 13: Review of Accounts ....................................................................................................... 26 Item 14: Client Referrals and Other Compensation .................................................................... 27 Item 15: Custody ......................................................................................................................... 28 Item 16: Investment Discretion ................................................................................................... 30 Item 17: Voting Client Securities ................................................................................................. 31 Item 18: Financial Information .................................................................................................... 33 3  Item 4: Advisory Business Firm Information Baldwin Wealth Partners, LLC (or the “Firm”, “we”, “us”, “ours”) was founded in 1974. For over 40 years we have been redefining the client experience through highly personalized attention, by crafting portfolios and strategies that reflect the individual point of reference of the people we work with. The results are investments that have true and meaningful impacts on our clients’ financial futures, the next generation, and the world around us. We are owned, both directly and indirectly, by members of the senior management team, including William H. Marvel, Taylor C. Baldwin, Andrew F. McIntire and Eric H. Strand. Description of Advisory Services: Our client base includes but is not limited to individuals, high-net-worth individuals, trusts, estates, charitable organizations, pension and profit-sharing plans, pooled investment vehicles, and corporations or other businesses. The majority of our business (approximately 85%) involves providing investment supervisory services for our clients. In addition, we provide investment advice to clients by monitoring accounts supervised elsewhere, and, in certain circumstances, through financial plans. Approximately 10% of the services we provide to our clients involve advice unrelated to securities. Financial Planning We offer financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. Clients understand that when they are engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. We meet with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. The financial plan may include both long and short-term considerations, depending upon the individual scenario. Upon completion a plan is presented to the client and the client is provided with recommendations that are deemed to be compatible with the client’s stated goals and objectives. An implementation schedule is reviewed with the client to determine which steps will be pursued, and with whom the steps may be accomplished. The client is under no obligation to utilize the Firm to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. 4  Investment Management We provide investment advisory services to clients on both a discretionary and non- discretionary basis. We have discretionary authority over the accounts of our investment advisory clients. In some cases, we meet informally with the client from time to time to discuss specific investment goals and strategies. While these discussions do not result in formal restrictions on our discretionary authority, they provide guidance for our investment decision-making processes. We also offer advice on equity securities, including exchange-listed securities, securities traded over the counter, and securities of foreign issuers. We provide advice on warrants, corporate debt securities, commercial paper, municipal securities, mutual fund shares, United States government securities, option contracts on securities, and futures contracts on intangibles. Advice is also provided on interests in partnerships that invest in real estate, oil and gas, venture capital and leveraged buyout funds. In addition, we occasionally create pooled investment vehicles to invest third-party (including clients’) funds or to invest in other investment funds, or directly in early and expansion stage private companies as well as funds that employ a specific investment strategy or invests in issuers which meet certain criteria. The Firm also serves as the investment adviser to these privately offered pooled investment vehicles. These pooled investment vehicles are available only to persons who are “accredited investors” under the Securities Act of 1933, or, in the case of some of the funds, “qualified purchasers” under the Investment Company Act of 1940, as amended. These pooled investment vehicles are not made available to the general public and are not registered investment companies. The Firm’s pooled investment vehicles include: (a) those formed to meet a high minimum investment requirement for a third-party venture capital or other investment fund (“Single Investment Funds”) and (b) those formed to engage in a particular investment strategy holding securities from a variety of issuers (“Strategic Funds”). These types of pooled investment vehicles are described below. Single Investment Funds Our Single Investment Funds pool certain clients’ investments to meet a minimum investment requirement in a single fund. Withdrawals from the Single Investment Funds are subject to the redemption and withdrawal restrictions in the underlying fund. Single Investment Funds are typically organized as limited liability partnerships with us serving as the Management Agent. Sub-Advisers In certain circumstances, we may recommend the services of a sub-adviser for clients who choose to invest in a fixed income strategy. The terms, compensation, and conditions under which the sub-adviser is engaged are fully discussed with the client prior to implementing the strategy. 5  In addition, we may also recommend the services of sub-advisers for some of their private funds and a limited number of retail clients. Tailored Relationships We tailor advisory services to the individual needs of the client. Clients may impose restrictions on investing in certain securities or types of securities. All limitations and restrictions placed on accounts must be presented to us in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. 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. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client: • To render impartial advice; • To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives; • To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead; • To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations; • Disclose any material conflict of interest in writing; and • Treat clients fairly and equitably. Regulations prohibit us from: • Employing any device, scheme, or artifice to defraud a client; • Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client; • Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or • Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when 6  conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. We do not sponsor, manage or participate in a Wrap Fee Program. Client Assets As of December 31, 2024, we managed $2,505,407,484 in client assets; $2,501,195,395 managed on a discretionary basis; and $4,212,089 on a non-discretionary basis. 7  Item 5: Fees and Compensation Compensation – Financial Planning We do not charge for Financial Planning. Compensation – Investment Management Services Investment Management fees are charged quarterly, both in advance and in arrears, based on a percentage of the client assets under management. A majority of clients are covered by the following annual fee schedule: Assets Under Management First $2,000,000 Next $3,000,000 Next $5,000,000 Over $10,000,000 Annual Fee 1.25% 1.00% 0.75% 0.60% Securities that are not publicly traded are valued at cost unless otherwise agreed with the client. In some special circumstances, we will negotiate the fees to be charged for account management and advisory services. Certain clients may be charged on a different fee schedule under legacy contracts. In addition to the fees described above, the Firm provides account monitoring services, without any advisory or management services, for a flat fee. Fees range from $600/month to $1,500/month. A reduced fee is made available for charities and certain accounts for which only minimal services are rendered. Smaller accounts, such as Individual Retirement Accounts (“IRAs”) and children's trusts, are generally placed in brokerage accounts with Pershing Advisor Solutions LLC (“Pershing”), Fidelity Investments (“Fidelity”), Charles Schwab (“Schwab”) and invested in a variety of mutual funds, as appropriate. We charge a fee of one percent (1%) annually for selecting and monitoring these investments, which is paid in addition to any fee that may be imposed by the individual fund into which a client’s funds may be invested. This fee is payable annually in arrears or at such time the client terminates its advisory agreement with us with respect to the account, prorated based on the number of months in which the Firm maintained the account. For a small number of clients, we provide bookkeeping services and share check signing privileges with these clients on their individual bank accounts so that we may pay certain expenses of these clients. These services are provided for a fixed monthly fee negotiated with the client. Fees range from $300/month to $2,000/month. Finally, we occasionally provide consulting services for a fixed fee. Fees range from $1,000/month 8  to $10,000/month. These fees are negotiated on a case-by-case basis. All fixed fees are charged quarterly in arrears. Compensation - Partnerships Where we provide services as the Management Agent for Single Investment Funds, the Firm receives fees equal to 1% to 1.5% of the fund’s capital commitments. Also, each client who invests in a Single Investment Fund is required to pay a one-time administrative fee of $500 upon entry. Where we provide services as Manager for the Strategic Funds, the Firm is paid a management fee equal to 1.5% of the Fund’s assets, calculated and paid quarterly in advance. New investments in the Strategic Funds may be made quarterly or semi-annually, depending on the Fund, and investors may be redeemed quarterly provided they give proper advance notice to us. We have the right to delay a redemption if it would be detrimental to the Fund. Compensation - Sub-advisory Fees In the cases where we recommend the services of a sub-advisor for clients investing in a fixed income strategy, there is an additional fee charged by the sub-advisor based upon the following fee schedule: 0.175% per year for assets up to $5,000,000 0.150% per year for assets over $5,000,000 Sub-advisory fees are charged based on quarter-end values in arrears. All sub-advisory fees charged are separate and distinct from any advisory fees charged by the Firm. Fee Payment Options As indicated in our advisory agreement with clients, there are two options to pay for our services: • Direct debiting: At the inception of the relationship and each quarter thereafter, we will notify the custodian of the amount of the fee due and payable to us through our fee schedule and contract. The custodian does not validate or check our fee, but it does validate the account information on which the fee is based. They will “deduct” the fee from the client account(s) or, if the client has more than one account with us, from the account the client has designated to pay our advisory fees. o Each month, the client will receive a statement directly from the custodian showing all transactions, positions, and credits/debits into or from the account; the statements after the quarter end will reflect these transactions, including the advisory fee paid to us. o We distribute quarterly reports to clients for each account under management. This report includes a description of assets held, on both a market value and cost basis, by category. The report also includes calculations of the total portfolio 9  value and yield. • Pay-by-check: At the inception of a client account and each month thereafter, we will issue an invoice for our services for payment by check or wire transfer within 30 days of the date of invoice. Cash Balances Some of your assets may be held as cash and remain uninvested. Holding a portion of your assets in cash and cash alternatives, i.e., money market fund shares, may be based on your desire to have an allocation to cash as an asset class, to support a phased market entrance strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to pay fees or to provide for asset protection during periods of volatile market conditions. Your cash and cash equivalents will be subject to our investment advisory fees unless otherwise agreed upon. You may experience negative performance on the cash portion of your portfolio if the investment advisory fees charged are higher than the returns you receive from your cash. Retirement Plan Rollover Recommendations As part of our investment advisory services to our clients, we may recommend that clients roll assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge the client an asset-based fee as set forth in the advisory agreement the client executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to the client (i.e., receipt of additional fee-based compensation). Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the rollover, clients are under no obligation to have the assets in an IRA advised on by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in our clients’ best interests and not put our interests ahead of our clients’. Under this special rule’s provisions, we must: • meet a professional standard of care when making investment recommendations (give prudent advice); • never put our financial interests ahead of our clients’ when making recommendations (give loyal advice); • avoid misleading statements about conflicts of interest, fees, and investments; • follow policies and procedures designed to ensure that we give advice that is in our clients’ best interests; • charge no more than a reasonable fee for our services; and 10  • give clients basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, clients should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in the employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide clients with an explanation of the advantages and disadvantages of both account types and document the basis for our belief that the rollover transaction we recommend is in your best interests. Additional Fees and Expenses As noted above, in certain circumstances, fees, account minimums and payment terms are negotiable depending on client’s unique situation – such as the size of the aggregate related party portfolio size, family holdings, low-cost basis securities, or certain passively advised investments and pre-existing relationships with clients. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, the application of experience and knowledge of the client’s situation. Advisory fees payable to us do not include all the fees you will pay when we purchase or sell securities for your account(s). The following list of fees or expenses are what you pay directly to third parties, whether a security is being purchased, sold, or held in your account(s) under our management. Fees charged are by the broker-dealer/custodian. We do not receive, directly or indirectly, any of these fees charged to you. They are paid to your broker, custodian or the mutual fund or other investment you hold. The fees include: • Brokerage commissions; • Transaction fees; • Exchange fees; • SEC fees; • Advisory fees and administrative fees charged by Mutual Funds (“MF”) and Exchange Traded Funds (“ETFs”); • Advisory fees charged by sub-advisers (if any are used for your account); • Custodial fees; 11  • Deferred sales charges (on MF or annuities); • Odd-Lot differentials; • Deferred sales charges (charged by MFs); • Transfer taxes; • Wire transfer and electronic fund processing fees; • Commissions or mark-ups/mark-downs on security transactions; and • Other fees that may be incurred. In addition, we do not have or employ any employee at all that receives (directly or indirectly) any compensation from the sale of securities or investments that are purchased or sold for your account or to which we provide consulting expertise/services. 12  Item 6: Performance-Based Fees and Side-By-Side Management “Performance-based fees” are fees based on the capital gains or capital appreciation in an account. We do not charge performance-based fees. “Side-by-side management” refers to the practice of managing both accounts that are charged a performance-based fee and accounts that are charged other types of fees, such as asset-based fees and hourly fees. Because we do not charge performance-based fees, we do not engage in side-by-side management. Our advisory fee compensation is charged only as disclosed above (Item 5). 13  Item 7: Types of Clients Types of Clients We provide our services to a number of types of clients: Individuals, including high net worth individuals • • Trusts, estates, and charitable organizations • Pension and Profit-sharing plans • Pooled investment vehicles • Corporations or other business Account Minimums We generally require a minimum dollar value of assets under management of $1,000,000 for starting or maintaining an account. Under special circumstances, we accept portfolios with a dollar value of assets of less than $1,000,000. We may group certain related client accounts for purposes of achieving the minimum account size. 14  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Investment Framework Background At Baldwin Wealth Partners (BWP) we have provided investment services for families and private foundations since the 1970s. Those services include customized investment policy development, asset allocation, equity portfolio management, investment strategy implementation, and ongoing review, all guided by our clients’ long-term investment goals. Our mission is to help clients simplify their investment strategies in an increasingly complex world and provide advice on a range of investments, spanning internal strategies, external funds, and private investments. Our high-touch relationship with our clients allows us to craft tailored investment programs to meet client needs while responding to the challenges of a constantly changing and dynamic investing world. However, we do manage guideline strategic asset allocation models, which serve as a starting point for client portfolio construction for most clients. Our investment process combines both a top-down approach and fundamental bottom-up due diligence. Our top-down macro perspective is formed through a rigorous and continual study of global markets, industries, sectors, and societal trends by a team of highly experienced investment professionals. In forming these perspectives, we use a wide variety of resources including research from economists, bank research teams, financial newspapers and magazines, annual reports and prospectuses, as well as insight from investment managers with whom we partner. Asset Allocation At BWP, we construct portfolios using five core asset classes: • Equities – Equities are used in client portfolios seeking capital appreciation as part of their investment objective. The asset class includes Domestic, International Developed Market, and Emerging Market stocks. • Fixed Income - Fixed income is used in client portfolios seeking income as a part of their investment objective. It acts as ballast to clients’ equity portfolios while generating current income. That asset class includes investment-grade taxable bonds, tax-advantaged municipal bonds, Treasuries, Treasury Inflation Protected Securities (TIPS), and higher yielding non-core credit. • Alternatives – Alternatives can serve as diversifiers and potential return drivers. Clients’ alternatives exposure can include allocations to private credit, hedge funds, private equity, venture capital, and other uncorrelated strategies. • Real Assets – Real Assets can drive returns, generate current income, and seeks to protect portfolios against inflation. Clients’ real asset exposure can include allocations to Real Estate 15  Investment Trusts (REITs), private real estate, listed infrastructure, private infrastructure, and commodities, including precious metals. • Cash – Cash and enhanced cash allocations such as short-term Treasury Bill holdings can generate current income, provide liquidity, and preserve optionality through the business cycle. Clients’ allocations across asset classes are driven by client goals, client risk profiles and asset class risk, return, and diversification characteristics. We believe creating balanced portfolios that are diversified across those asset classes can drive returns and mitigate risk through the business cycle. We maintain a family of guideline asset allocation models reflecting our approach to balancing exposure across those asset classes. However, individual client portfolios can deviate from those guideline asset allocation weights, for reasons including client needs, client instructions, client risk profiles, and considerations of assets held outside of BWP. BWP Core Equity Strategy Construction At BWP, we manage the core large cap US individual equity allocation of clients’ portfolios in house through our Baldwin Core Equity Strategy model. That is used in most asset allocation strategies seeking capital appreciation. The Baldwin Core Equity Strategy is a moderately concentrated 30-50 name equity model and seeks to maintain portfolio turnover below 30% annually. Relatedly, we take a tax aware approach to turnover management, and work to minimize clients’ realized capital gains where applicable. However, turnover may exceed our targets when market conditions or tax considerations warrant it. Individual client equity portfolios can deviate from our strategy weights, for reasons including client needs, client instructions, client risk profiles, and considerations of assets held outside of BWP. Our Core Equity Strategy is driven by bottom-up fundamental research. BWP Core Equity Strategy Security Selection Within the BWP Core Equity Strategy, we seek to generate risk adjusted returns by buying great businesses for good prices, with intention of holding them for the long run. We evaluate prospective equity investments against four pillars of our fundamental equity research process which include growth, quality, value, and ESG criteria as outlined below: Growth: We look for companies with track records of through cycle free cash flow per share growth, and companies serving growing end markets. That can involve identifying companies 16  we believe are positioned to benefit from thematic growth opportunities and structural tailwinds. Quality: We focus on companies with strong returns on invested capital and the ability to reinvest capital at potential attractive rates long term. We favor companies we believe are leaders in their industries, companies which are positioned for long-term profitability, companies with strong management teams, companies with shareholder friendly capital allocation practices and companies with sound balance sheets. Value: We seek stocks that trade at a discount to our estimate of intrinsic value. We can use a range of valuation metrics including price/earnings (P/E), enterprise value/EBITDA, and price / free cash flow (P/FCF) ratios to estimate firms’ intrinsic value. We also value names based on sum-of-the-parts analysis or discounted cash flow analysis when appropriate. ESG Integration: We look for companies which take a proactive approach to managing their environmental risks, companies which perform well across key social impact metrics like workplace safety, and companies with good governance practices including strong board oversight. We may also favor companies with exposure to sustainability themes. The ESG pillar involves evaluating company performance across dimensions that can include: ▪ Environmental Impact - Policies, targets, and operational performance related to energy use, water use, waste generation, and other relevant environmental impact metrics. ▪ Social Impact - Social impact policies, targets, and operating performance relating to workplace safety, supply chain integrity, employee satisfaction, and customer satisfaction. ▪ Governance Practices - Strong board oversight and independence, strong executive performance, and aligned executive compensation. ▪ Thematic Exposure - Exposure to sustainability themes which can include energy transition investment and better-for-you products. ▪ ESG Risk Management - Historic controversies, company specific ESG risks, and company specific regulatory risks. We believe that companies which demonstrate leadership across these dimensions are well-positioned for operational resiliency and sustainable, long-term value creation. Manager Selection 17  At BWP, we generally take a manager of managers’ approach to asset classes outside of large- cap US equities and/or for those clients in legacy portfolio models. This manager of manager approach uses external managers through various investment vehicles which may include but is not limited to the use of Mutual Funds, ETFs, Third-Party Managers, and Separately Managed Accounts in our portfolios. Additionally, we allocate to large-cap US equity funds for some clients, where portfolio size or other considerations warrant it. When allocating to external managers, we seek to identify and partner with experienced teams with clear investment frameworks, attractive historical performance, and competitive fees. Our manager research process centers around five Ps: People, Process, Philosophy, Performance, and Price. We leverage external research partners to source new managers and support our manager research process. ESG is also one of the pillars of our manager selection process for clients seeking a more ESG focused portfolio. Along with evaluating managers’ people, process, historic performance, and fees, our selection process may also incorporate ESG factors and reviewing manager performance across dimensions that can include: • Investment Process – Whether managers incorporate ESG analysis and risk management into their investment research process. • Thematic Opportunities – Whether managers are positioned to benefit from sustainability themes. E.g., Energy transition investment, better-for-you products, supply chain resiliency. • ESG Risk Management – Identifying historic controversies, regulatory actions, or manager specific ESG risks. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Although we manage assets in a manner consistent with your investment objectives and risk tolerance, there can be no guarantee that our efforts will be successful. You should be prepared to bear the following risk of loss: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to • tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar next year will not buy as 18  much as a dollar today, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • False or Misleading Information: We rely on information obtained from sources believed to be reliable to make investment decisions. No guarantee can be made that these sources are indeed reliable. • Cybersecurity Risk: A breach in cyber security refers to both intentional and unintentional events that may cause an account to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause an account to incur regulatory penalties, reputational damage, and additional compliance costs associated with corrective measures, and/or financial loss. • Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. • Custodial Risk: This risk is the probability that a party to a transaction will be unable or unwilling to fulfill its contractual obligations either due to technological errors, control failures, malfeasance, or potential regulatory liabilities. 19  Item 9: Disciplinary Information We are required to disclose all pertinent facts regarding any legal, regulatory or disciplinary events that would be material to your evaluation of the Firm or the integrity of our management. There have never been any legal, regulatory or disciplinary actions against the Firm or our management persons. 20  Item 10: Other Financial Industry Activities and Affiliations Financial Industry Activities – Broker-Dealers We are not registered as a broker-dealer, and none of its management persons are registered representatives of a broker-dealer. We are not registered and do not have an application pending as a securities broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor. Accountant or Accounting Firm Certain of our employees are separately licensed as Certified Public Accountants but do not practice in any capacity outside the Firm. Lawyer or Law Firm Certain of our employees are separately licensed as attorneys but do not practice in any capacity outside the Firm. Insurance Company or Agency Certain of our Investment Advisor Representatives may be licensed insurance agents or brokers and may be appointed with several insurance companies. They may earn separate compensation for transactions implemented through various insurance companies. This activity and related compensation are conducted outside of their capacity at the Firm. Clients are not obligated to use any company for insurance product purchases and may work with any insurance agent they choose. Insurance compensation will be separate and distinct from our investment advisory fees. Other Investment Advisors As noted in Item 4, we may recommend or select other investment advisors for its clients. We do not receive compensation for these recommendations. 21  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics As required by regulation (and because it is good business), we have adopted a Code of Ethics that governs a number of potential conflicts of interest we have when providing our advisory services to you. This Code of Ethics is designed to ensure we meet our fiduciary obligation to you, our client (or prospective client) and to drive home a culture of compliance within our Firm. An additional benefit of our Code is to detect and prevent violations of securities laws, including our obligations we owe to you. Our Code includes the following: • Requirements related to the confidentiality of your information and investments; • Prohibitions on: Insider trading (if we are in possession of material, non-public information); o o Rumor mongering; and o The acceptance of gifts and entertainment that exceed our policy standards; • Reporting of gifts and business entertainment; • Pre-clearance of employee and securities transactions; • Reporting (on an on-going and quarterly basis) all personal securities transactions (what we call “reportable securities” as mandated by regulation); and, Our Code does not prohibit personal trading by employees (or our Firm). As you may imagine, as a professional investment adviser, we follow our own advice. As a result, we may purchase or sell the same or similar securities (or securities that are suitable for an employee or related account but not suitable for any client, including you) at the same time that we place transactions for your account and the accounts of our other clients. Our employees must acknowledge the terms of the Code at least annually, and any employee not in compliance with the Code may be subject to termination. We will provide a copy of our Code upon request. From time to time, we may recommend that certain clients participate in a partnership or partnerships for which the Firm or one of its principals acts as general partner or management agent or in which any of the foregoing has an interest. These partnerships are formed to aggregate client contributions and thereby meet high minimum investment requirements for third-party investment funds, to invest in early or development stage issuers, or to take advantage of a particular investment strategy. The Firm, one of its principals or a wholly owned subsidiary of the Firm, serves as the management agent of such partnerships and receives a management fee for its services. We recommend participation in these partnerships only after a thorough review of a 22  client's complete financial condition. The offering memoranda for each partnership fully discloses our financial interest in the partnership, as well as any interest of the Firm’s principals in the partnership. Participation or Interest in Client Transactions – Financial Interest and Principal/Agency Cross It is our policy that the Firm will not affect any principal or agency cross securities transactions for client accounts. We will also not cross trades between client accounts. 23  Item 12: Brokerage Practices Research and Other Soft Dollar Benefits We do not receive formal soft dollar benefits other than execution from broker-dealers in connection with client securities transactions. See disclosure below in “Brokerage – Other Economic Benefits.” Brokerage for Client Referrals We do not receive client referrals from broker-dealers. Directed Brokerage We do not receive client referrals from any brokers and therefore does not factor that in when recommending or selecting brokers for clients. As noted below, we permit clients to direct brokerage. However, if a client directs us to use a specific broker, they are reminded that we will most likely not have the authority or ability to negotiate commission rates and therefore the client may pay higher commission fees. Brokerage Securities transactions for accounts managed by us are executed by brokers whom we consider to be well established and financially sound. The Firm maintains ongoing brokerage business relationships with Pershing, Schwab and Fidelity as well as other national and regional brokerage firms. We will generally recommend that clients use Pershing, Schwab or Fidelity and its affiliates for brokerage services, although we also permit clients to direct us to use brokers other than those three. When you direct us to use a certain broker, we can’t ensure that you will receive best execution of the trades for which we send to the broker you choose. Except as described above with respect to our relationship with Pershing, Schwab and Fidelity, the criteria utilized in our selection of brokers are as follows: • commissions charged for effecting securities transactions • the experience and skill of the firm's securities traders • the financial responsibility, administrative efficiency and breadth of services rendered • the value, in our opinion, of research services and products provided with respect to the transaction to be executed and with respect to our overall perspective on the securities markets Our primary objective is to receive the best realized net price for any transaction, taking into consideration the commission charged and the broker's execution capability. However, within that framework, we wish to compensate brokers for research services and products they provide that enable us to provide additional benefits to our clients and to better discharge our overall investment management responsibilities. 24  The research products and services provided by brokers include computer software that monitors and analyzes securities and prices, and computerized and hard-copy news and analysis services. To the extent that any of these products or services serve functions that are not related to the making of investment decisions (e.g., portfolio software used for administrative purposes), we make a good faith effort to allocate the cost of the product or services according to its use and pay for non-research functions with our own funds. As a result, from time to time, clients may pay commissions higher than those obtainable from other brokers in return for research services and products and the custodial services described below. We find it difficult to allocate research fairly to specific accounts, and therefore the benefits received by each client on each account may not be commensurate with the broker commissions generated by the account. Brokerage – Other Economic Benefits We may have the opportunity to receive traditional “non-cash benefits” from broker-dealers such as customized statements; receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk servicing advisors exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client portfolios; ability to have investment advisory fees deducted directly from client portfolios; access to an electronic communication network for client order entry and portfolio information; access to mutual funds which generally require significantly high minimum initial investments or those that are otherwise only generally available to institutional investors; reporting features; receipt of industry communications; and perhaps discounts on business-related products. Broker-dealers may also provide general access to research and perhaps discounts on research products. Any research received is used for the benefit of all clients. We have no written or verbal arrangements whereby we receive soft dollars. While we endeavor at all times to put the interest of the clients first as part of its fiduciary duty, clients should be aware that the receipt of any additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. Trade Aggregation We may aggregate multiple clients’ purchase or sale orders for the same security in order to execute transactions in the most efficient manner. Purchases by our employees may also be aggregated with clients’ purchase orders for the same security. In these cases, we will attempt to allocate securities among its clients in a fair and unbiased manner. We will first make such allocations of the securities to its clients and in a manner that will not favor performance accounts over asset-based fee accounts or favor one class of clients over another. We will look at the investment goals and requirements of its clients involved in making such allocations. 25  Item 13: Review of Accounts Reviews We monitor client portfolios as part of an ongoing process, and regular account reviews are generally conducted on a quarterly basis. Reviews could also occur at the time of new deposits, material changes in the client’s financial information, changes in economic cycles, at our discretion or as often as the client directs. Reviews entail analyzing securities, sensitivity to overall markets, economic changes, investment results, asset allocation, etc., to ensure the investment strategy and expectations are structured to continue to meet the client’s objectives. These reviews are conducted by one of our Investment Advisor Representatives. Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of any changes. Reporting At least quarterly, the custodian provides clients with an account statement for each client account, which may include individual holdings, cost basis information, deposits and withdrawals, accrued income, dividends, and performance. We may also provide clients with periodic reports regarding their holdings, allocations, and performance. 26  Item 14: Client Referrals and Other Compensation Other Compensation We do not have any arrangements with third parties where we receive any economic benefit from providing investment advice or advisory services (other than as described in Item 12). Compensation – Client Referrals We have been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, accountants, employees, personal friends of employees, and other similar sources. We do not compensate referring parties for these referrals. For certain legacy referral arrangements (referrals to a third party) related to the acquisition of another investment advisory firm, the Firm receives referral compensation. The Firm does not currently make referrals for compensation. 27  Item 15: Custody Custody – Fee Debiting We are deemed to have custody of client assets shall be held in the custody of a bank, trust company or brokerage firm agreed upon by the client and us. The client may authorize us (in the client agreement) to debit fees directly from the client’s account at the custodian. The custodian is advised in writing of the limitation of our access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to the Firm. Custody – First Party Money Transfers Clients may provide us with written ongoing authorization to wire money between the client’s accounts held with the qualified custodian directly to an outside financial institution (i.e., a client’s bank account). A copy of this authorization is provided to the qualified custodian. The authorization includes the client’s name and account number(s) at the outside financial institution(s) as required. Custody – Third Party Money Transfers Clients may also provide us with a standing letter of authorization (or similar asset transfer authorization) which allows the Firm to disburse funds on behalf of clients to third parties. We ensure the following conditions are in place when deemed to have custody via third party money movement: 1. The client provides a Written Authorization to the custodian that includes all appropriate information as to how the transfer should be directed; 2. The Written Authorization includes instruction to direct transfers to the third party either on a specified schedule or from time to time; 3. Appropriate verification is performed by the custodian, along with a transfer of funds notice to the client promptly after each transfer; 4. The client may terminate or change the instruction to the custodian; 5. We have no authority or ability to designate or change any information about the third party contained in the instruction; 6. We maintain records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and 7. The custodian sends the client a written initial notice confirming the instruction and an annual written confirmation thereafter. Custody – Trusteeship/Check Signing/Bill Payments The Firm is deemed to have custody over certain of its client accounts because one or more of our “related persons” either serve as a trustee for the account or have power of attorney over the funds in the account. We (certain employees) have check writing authority over client accounts. These forms of custody are offered on a limited basis. A qualified custodian holds the funds for these clients, and they are subject to a surprise examination by an independent 28  accountant in accordance with the custody rules under the Investment Advisors Act. Custody – Pooled Investment Vehicles We or a “related person” (entity) acts as Managing Member or General Partner of pooled investment vehicles in which clients invest, and as a result, is deemed to have custody over those pooled investment vehicles. Each pooled investment vehicle is audited annually by an independent accountant in accordance with the custody rules under the Investment Advisors Act. Investors receive audited financial statements within 180 days after the end of each fund’s fiscal year as required. Custody – Account Statements All of our clients receive account statements from a qualified custodian at least on a quarterly basis. Clients are urged to carefully review such statements and compare such official custodial records to the reports that we provide. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients may notice occasional differences between the two statements, due to the fact that our reports all transactions based on trade date, whereas certain custodians report transactions based on settlement date. There are a few days between when a trade is placed (trade date) and when the trade settles (settlement date). Custodians may not list a transaction on a statement until settlement. We list all transactions on trade date. Therefore, there may be month-end transactions listed on our statement that are not reflected on the brokerage statement. For tax and other purposes, the custodial statement is the official records of your account(s) and assets. 29  Item 16: Investment Discretion We have discretionary authority to manage the accounts on behalf of some, but not all, of our clients. For those discretionary accounts, we receive discretionary authority from the client, through the investment advisory agreement, at the outset of an advisory relationship. With respect to these discretionary accounts, we retain full authority to determine securities to be bought or sold, the amount of securities to be bought and sold, the broker or dealer to be used, and the commission rates paid to such broker or dealer. While clients do not specify limits on this authority, we endeavor to maintain a balanced portfolio in each account and to follow an investment strategy for each account which has been discussed with and approved by the client. If we have not been given discretionary authority, we consult with the client prior to each trade. 30  Item 17: Voting Client Securities Proxy Voting Unless otherwise directed by a client or under a legacy contractual arrangement, we will assume responsibility for voting the proxies we receive from companies in which our clients have invested. Because a client’s interests in regard to a particular proxy may differ from those of ours or the individual investment advisor responsible for voting that proxy, we have adopted a Proxy Voting Policy to ensure that the interests of our clients are always put first. We vote proxies in accordance with the recommendations of management of the issuing company soliciting the proxy unless the portfolio manager for a client’s account determines that it is not in the best interest of the client to do so. In those cases, the portfolio manager will vote the proxy in the manner he or she determines is in the best interest of the client taking into account the client’s financial and non-financial goals, the status and history of the underlying investment, and the conditions of the market in which the issuing company operates. Clients can elect to vote proxies according to our ESG Proxy Voting Principles. In such cases, we have partnered with Glass Lewis to vote proxies based on their ESG Thematic Voting Policy. A client may request a copy of our complete Proxy Voting Policy and our Proxy Voting Record by contacting Steven T. Dean, Chief Compliance Officer. When Conflicts Occur. Conflicts can arise in a number of situations. Any of the following entities and individuals can be involved in a relationship that causes a conflict for a portfolio manager: • • • • • Baldwin Wealth Partners; the portfolio manager; any close family member of the portfolio manager; any trust for the benefit of any of the above; or any entity controlled (either directly or through any number of intermediaries) by any of the above. If a portfolio manager has the authority to vote a particular proxy on behalf of a client, and any of the above entities and individuals has a known and material personal or business relationship with the company issuing that proxy or any of that company’s officers, directors, employees, or holders of a substantial amount of its stock, a conflict may exist. Each of the following is an example of a potential conflict: • • Baldwin Wealth Partners provides services to the company issuing the proxy or one of its executive officers; a portfolio manager owns a substantial equity interest in the issuing company; 31  • • • a portfolio manager’s son is married to a director of the issuing company; a trust for the benefit of a portfolio manager’s grandchildren owns a substantial amount of stock in the issuing company; and a limited liability company run by a portfolio manager’s spouse does a significant amount of business with the issuing company. Although we have always voted, and will continue to vote, proxies in the best interests of our clients and without regard to what might or might not be beneficial for any other party, and in many instances no conflict will actually exist, it is important that there be no question of conflict. Therefore, all potential conflicts must be brought to the attention of someone other than the involved portfolio manager and the matter resolved in accordance with our policy. The two primary methods of resolution are as follows: 1. Internal Resolution. If the individual responsible for voting a particular proxy has a potential conflict, that portfolio manager must determine if any of our other advisors could vote the proxy without any chance of conflict. If so, the portfolio manager responsible for voting should inform the non-conflicted portfolio manager of the relevant circumstances under which the proxy is to be voted (including, but not limited to, the client’s financial goals, the status and history of the underlying investment, and the conditions of the market in which the issuing company operates), make a full disclosure of the responsible portfolio manager’s possible conflict, and have the non- conflicted advisor make the decision as to how to vote the proxy. 2. External Resolution. If either Baldwin Wealth Partners or any of our portfolio managers have a potential conflict of interest in regard to voting a particular proxy, there are three ways the proxy may be voted. The first, and most desirable, is to obtain instructions on how to vote the proxy from the client on whose behalf the proxy is to be voted (or that client’s legal representative). The second is to obtain consent from the client (or the legal representative) to vote the proxy after making a full disclosure of the portfolio manager’s possible conflict. If neither the client nor any of the client’s legal representatives is available, however, the third approach is to obtain guidance from any reputable proxy research and voting service (e.g., Institutional Shareholder Services) as to how to vote the proxy for the general benefit of the issuing company’s shareholders. 32  Item 18: Financial Information We are not required to provide clients with a balance sheet; we do not require prepayment of fees of both more than $1,200 per client and more than six months in advance. We have no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of any claim, bankruptcy, or other financially related proceeding. 33