GARDE CAPITAL, INC.

Item 1: Cover Page ADV Part 2A of Form ADV Investment Adviser Brochure GARDE CAPITAL, INC. 1301 Fifth Avenue, Suite 3030 Seattle, WA 98101 206-552-7900 info@gardecapital.com http://www.gardecapital.com December 31, 2024 This Form ADV Part 2A Brochure provides information about the qualifications and business practices of Garde Capital, Inc. If you have any questions about the contents of this brochure, please contact us at 206-552-7900 or info@gardecapital.com. 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. Additional information about Garde Capital, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Garde Capital, Inc. is a registered investment advisor. Registration as an investment advisor does not imply any certain level of skill or training.  Item 2: Material Changes Garde Capital is required to advise clients and prospective clients of any material changes to or Firm Brochure (“Brochure”) since our last annual update. 2  Table of Contents (Item 3) Item 1: Cover Page ................................................................................................................................ 1 Item 2: Material Changes .................................................................................................................... 2 Item 4: Advisory Business .................................................................................................................. 5 Types of Advisory Services Portfolio Management .......................................................................................................................... 5 Financial Planning ................................................................................................................................... 5 Other Wealth Management Services ............................................................................................................................................ 5 Item 5: Fees and Compensation ....................................................................................................... 7 ..................................................................................................... 6 Compensation Methodology and Rates ................................................................................................ 7 Annualized Fees Assets Under Management ......................................................................................................................... 7 ................................................................................................................................................. 7 Hourly Fees........................................................................................................................................................ 8 Valuation of Publicly Traded Securities ................................................................................................ 8 How Clients Pay Advisory Fees ..................................................................................................................... 8 Other Types of Fees and Expenses Minimum Annual Advisory Fee ..................................................................................................................... 8 .......................................................................................................... 9 Commission-Based Compensation ETFs/Mutual Fund Fees ............................................................................................................................... 9 Item 6: Performance-Based Fees and Side-By-Side Management ..................................... 10 ...................................................................................................... 10 Item 7: Types of Clients ..................................................................................................................... 10 General Services Pension and Other Retirement Plans ............................................................................................................................................. 10 Methods of Analysis ................................................................................................. 10 Risks ...................................................................................................................................... 10 ...................................................................................................................................................................... 11 Asset Class Risk ............................................................................................................................................ 11 Management Risk ........................................................................................................................................ 11 Market Risk .................................................................................................................................................... 11 Item 9: Disciplinary Information ................................................................................................... 11 Passive Investment Risk ........................................................................................................................... 11 Item 10: Other Financial Industry Activities and Affiliations.............................................. 12 Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ................................................................................................................................................... 12 Code of Ethics ................................................................................................................................................... 12 3  Material Financial Interest and Personal Trading Item 12: Brokerage Practices ......................................................................................................... 13 ..................................................................... 12 Factors Considered When Recommending a Custodian .................................................................. 13 Preferred Custodians ...................................................................................................................................... 13 How We Select Brokers/Custodians ................................................................................................... 13 Brokerage and Custody Costs ................................................................................................................. 14 Services That Generally Benefit Only Us ........................................................................................... 15 Brokerage for Client Referrals ............................................................................................................... 16 Directed Brokerage ..................................................................................................................................... 16 Aggregated Orders ...................................................................................................................................... 16 Item 13: Review of Accounts ........................................................................................................... 17 Trade Errors Policy ..................................................................................................................................... 17 Reviews Reports ................................................................................................................................................................ 17 Item 14: Client Referrals and Other Compensation ................................................................ 18 ................................................................................................................................................................. 17 Referral Relationships Item 15: Custody .................................................................................................................................. 18 ................................................................................................................................ 18 Item 16: Investment Discretion ..................................................................................................... 18 Item 17: Voting Client Securities ................................................................................................. 18 Proxy Voting Policy Item 18: Financial Information ...................................................................................................... 19 ........................................................................................................................................ 18 Privacy Policy ...................................................................................................................................... 20 4  Item 4: Advisory Business Garde Capital, Inc. is referred to in this document as “Garde Capital,” “the Company,” “us,” “we,” or “our.” In this document we refer to current and prospective clients of Garde Capital as “you”, “your”, or “client”. Garde Capital was created in 2009 and is substantially owned by its four principals: Jeffery Lippens, Marshal McReal, Richard Severs, and Thomas Owens. Types of Advisory Services We offer to provide investment advisory services to our clients on discretionary and non- discretionary bases. The advisory services include, among other things, providing advice regarding asset allocation and the selection of investments. Account management or supervision is guided by the stated objectives of the client. In addition, we consider a client’s risk profile and financial status prior to making any recommendations. The client may impose restrictions on investing in certain securities or types of securities. The client must clearly state these restrictions to us in writing. As of December 31, 2024, we had total assets under management of approximately $2,257,467,000. We manage approximately $2,246,638,000 of our clients’ assets on a discretionary basis and $10,829,000 on a non-discretionary basis. Portfolio Management We provide portfolio management services for our clients. Our investment philosophy combines the traditional, academic principles of modern portfolio theory with recent developments in the field of behavioral finance to help investors get the most from their investment assets. We strive to provide clients with exposure to a global portfolio of securities at a competitive cost, because value matters. Every portfolio is customized to Financial Planning meet the risk management needs of each of our clients. We provide financial planning and consulting services consistent with clients’ financial and tax status, risk profile, and return objectives. Some written plans may include a personal balance sheet and financial projections. Any reports, financial statement projections, and analyses are intended exclusively for client use in developing and implementing a client’s financial plan. In view of this limited purpose, the statements should not be considered complete financial statements. We will not audit, review, or compile financial statements, and accordingly we will not express an opinion or other form of assurance on them, including the reasonableness of assumptions and other data on which any prospective financial statements are based. It is likely that there will be material differences between projected and actual results because events vary, and circumstances frequently do not occur as expected. Our analyses will be highly dependent on certain economic assumptions about the future. Therefore, the client should establish familiarity with historical data regarding key assumptions such as inflation and investment rates of return, as well as an understanding of how significantly these assumptions affect the results of our analyses. We may counsel clients as to 5  the consistency of their assumptions with relevant historical data, but we will not express any assurance as to the accuracy or reasonableness of the client’s specific data and assumptions. The client is ultimately responsible for the assumptions and personal data upon which our procedures and projections are based. The financial plan assumptions and reports are primarily a tool to alert the client to certain possibilities. The reports are not intended to nor do they provide any guarantee about future events including the client’s investment returns. Other Wealth Management Services For some clients, we provide other services that may include consultation on a broader range of issues that are important in the optimization of the overall financial health of the client. Examples of these types of financial services include but are not limited to review and performance reporting on non-managed assets, insurance planning, ongoing coordination with tax advisors or estate planning attorneys, budgetary planning, real estate planning, and other personal or business planning services. These services fall outside the scope of our standard investment management services and may require a separate engagement letter with the client. Types of Investments Used We typically create diversified investment portfolios using Exchange Traded Funds (ETFs) but will consider other types of investments owned by the client when we create and manage an investment portfolio such as individual stocks, individual bonds, and open-end mutual funds. Alternative investments such as hedge funds, fund of funds, commodity trading strategies, and other similar strategies may be used from time to time for select clients. In some, but not all cases, we may use options or futures contracts on securities in a client’s managed portfolio. Options and futures strategies are not used in all client portfolios. The use of options and futures strategies is not always successful at increasing return or reducing losses. The use of options and/or futures adds risk and cost to the portfolio. Options and futures strategies can diminish account performance. Important Information for Retirement Investors When we recommend that you rollover retirement assets or transfer existing retirement assets (such as a 401(k) or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional revenue when we manage more assets. In making the recommendation, however, we do so only after determining that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory recommendations and discretionary asset management services, as described in the advisory agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be described in the advisory agreement. 6  Item 5: Fees and Compensation Compensation Methodology and Rates Assets Under Management Most clients are charged for our asset management services based on a percentage of the assets being managed. Portfolio Management clients are subject to this fee arrangement. Clients may receive financial planning services as part of the portfolio management process and, as such, would not be charged an extra fee for planning. In some cases, we may offer financial planning services to clients for whom we do not manage a portfolio. In those instances, the client may be subject to the hourly fees described below. The following table represents our standard fee schedule for investment supervisory services. A client’s specific annual fee arrangement will be described in the written Investment Advisory Agreement entered into between Garde Capital and the client. The investment supervisory fees we charge are negotiable at our sole discretion based on the work required to manage the relationship, the total assets under management, the tenure of the relationship, and whether the account is related to other accounts we manage. All clients do not pay the same fees. Some clients may pay more and some clients may pay less than the fee schedule below, but this is our standard fee schedule. To $1,000,000 $2,000,000 $5,000,000 $10,000,000 $25,000,000 $50,000,000 Annualized Fees From $0 $1,000,001 $2,000,001 $5,000,001 $10,000,001 $25,000,001 $50,000,001 and up Per Year 0.95% 0.90% 0.90% 0.80% 0.60% 0.50% 0.40% The annual fee for our services is billed quarterly in advance based on the value of the account at the end of the previous quarter. If the management agreement does not span the entire quarterly billing period, the fee will be prorated based on the number of days the account is open during the billing period. The client’s qualified account custodian will send statements, at least quarterly, showing all disbursements for the account, including the amount of the investment supervisory fee, if deducted directly from the account. It is the shared responsibility of Garde Capital and the client to verify the accuracy of the fee calculation as the qualified custodian will not determine whether or not the fee has been properly calculated. Either party may terminate the Investment Advisory Agreement by providing written notice. Upon receipt of the client’s termination notice, we will cease providing advisory services. Any fees collected in advance of services being performed will be returned to the client on a pro rata basis. 7  Hourly Fees Garde Capital may perform services for clients where the fee is based on an hourly rate. The rate per hour depends upon the level of complexity of the service and experience and expertise of the personnel used to do the work. This negotiable rate would normally not exceed $400 per hour. The tasks and services to be performed are described in an engagement letter that is signed by the client and Garde Capital that also includes the hourly rate, an estimate of time to complete the project, and the procedure for refund or partial billing if the engagement is terminated before completion. Flat Fees In addition to the asset management and financial planning services outlined above, we may provide other financial services as described in Item 4. In these cases, we may charge a flat fee to compensate Garde Capital for the work that comes with these enhanced services. The flat fee will be priced based on the scope of work for each client relationship. This fee will typically be charged in addition to the fees for investment management services noted above. Depending on the amount of the flat fee, the total fees as a percentage of assets under management may be higher than that shown in our schedule above. Valuation of Publicly Traded Securities Publicly traded securities in client account(s) managed by us are held at the custodian that we recommend but is ultimately chosen by the client. We use the securities valuation provided by the independent qualified custodian for reporting and billing purposes. The third-party vendor we use for client reporting and fee billing uses period-ending custodial values as well as data concerning accrued dividends and interest for the period to determine the actual value upon which clients will be billed. The account custodian generally does not include accrued dividends on the statement, which may lead to a difference between the values shown by the custodian and the values used by our billing vendor. We provide clients with an internally-produced fee statement in addition to the statement provided directly by the custodian, to permit review of the amounts billed and the valuation used. We encourage clients to carefully compare the statements received from Garde Capital and the statements received from the custodian and to contact us with any questions regarding the billing value. Publicly traded securities are usually valued by the custodian as of the end of business on the last trading day of the calendar quarter. How Clients Pay Advisory Fees Fees are generally deducted directly from the client’s account. The client must provide the qualified account custodian with written authorization to have fees deducted from the client’s account and paid to Garde Capital. Minimum Annual Advisory Fee All households that are being charged an asset-based fee are subject to a minimum annual advisory fee of $15,000 for the combined accounts in a billing household. This minimum annual fee is intended to compensate Garde Capital for the total cost of financial planning and investment management involved in a client relationship. The minimum fee may be negotiable 8  at our sole discretion. Based on the fee schedule above, because of the minimum fee we charge, households with less than approximately $1,600,000 in assets may pay a higher fee than that shown in our schedule. Other Types of Fees and Expenses In addition to the investment advisory fees paid to Garde Capital, the client will pay transaction fees (commissions) on certain securities to the custodian or broker-dealer executing securities transactions and charges for special services elected by the client or Garde Capital. Garde Capital does not receive compensation that results from these or any transaction fees. These fees may include: returned check fees international security transfer fees • periodic distribution fees • electronic fund and wire transfer fees • certificate delivery fees • reorganization fees • account transfer fees (outbound) • • • overnight mail and check fees • Rule 144 transfer fees • transfer agent fees • interest on margin This list is not meant to be exhaustive. Any fee on a special service incurred by the client will be fully disclosed. Please refer to Item 12 of this document for an explanation of our brokerage practices. ETFs/Mutual Fund Fees All fees paid to Garde Capital for investment advisory services are separate and distinct from the fees and expenses charged by ETFs and/or mutual funds to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in an ETF or mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which funds are most appropriate to each client's financial condition and objectives. Accordingly, clients should review both our fees and the fees charged by the funds to fully understand the total amount of fees to be paid and to thereby evaluate the advisory services being provided. Private Fund Fees In some cases, we may recommend that a client invest in a private fund that has its own annual fee structure which may include a performance-based fee. In those cases, the investor will bear 9  the cost of those fund fees, and Garde Capital will not participate in any fee sharing from the fund provider. These assets will simply be included in the total assets under management for a given household for the purposes of calculating our annual advisory fee. Commission-Based Compensation Our investment advisor representatives do NOT receive any commission-based compensation while providing investment advisory services to the client. Item 6: Performance-Based Fees and Side-By-Side Management Garde Capital does NOT charge fees that are based upon a share of capital gains or capital appreciation of client assets and this Item is not applicable to our firm. We provide investment advisory services to many clients. Not all clients receive the same investment advice, nor do they pay the same fee. We strive to act in the best interests of each of our clients at all times. Item 7: Types of Clients General Services We provide advisory services to a variety of types of clients including individuals and families, trusts, charitable organizations, individual pension plan accounts, and retirement plan trustees. Pension and Other Retirement Plans We provide advisory services to pension plans and other institutional clients. These services may include recommendations to the plan which are then approved by the pension plan sponsor. In some cases we will serve as a discretionary advisor to the plan. As part of our pension plan services we also provide employee education to plan participants. This education is consistent with Modern Portfolio Theory. Clients are encouraged to ask their pension plan sponsor what services Garde Capital is providing the plan. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis In order to help manage risk, a portfolio must be properly diversified at all times. As modern portfolio theory would dictate, this means not simply owning a large number of stocks and bonds, but spreading investment assets over many different types of stocks and bonds each of which may behave differently in response to varying economic and market conditions. By building a portfolio where we invest in asset classes that are not perfectly correlated with one another we strive to create a more optimized portfolio that can help minimize risk for a given level of return or maximize return for a given level of risk. At Garde Capital, we work to develop an asset allocation that is appropriate for each client given their specific return requirements and volatility constraints. We then implement that portfolio using efficient vehicles that give us exposure to each asset class and security type. The vehicles that we prefer to use are called exchange traded funds (ETFs). For an average fund expense ratio of approximately 0.08%, we 10  can build a global portfolio of stocks, bonds, and commodities that we believe provides an adequate level of diversification specific to each client. Risks Investing is not without risk and involves the risk of loss of principal which the client should be prepared to bear. We use several strategies to try to reduce risk, including diversifying a portfolio across multiple asset classes and monitoring the portfolio and the markets for changes in fundamentals. Despite these strategies, historical evidence clearly shows that every asset class has experienced severe declines in value—sometimes sustained over many years— throughout several periods of time in history. In addition, each of our strategies to minimize risk may not achieve that goal as the benefits of diversification decline if asset classes become more correlated. As with any investment, a client could lose all or part of their investments managed by Garde Capital, and their account performance could trail that of other investments. Asset Class Risk Securities in client portfolio(s) or in underlying investments such as mutual funds or ETFs may underperform in comparison to the general securities markets or other asset classes. Management Risk The performance of a client’s account is subject to the risk that Garde Capital’s investment management strategy may not produce the intended results. Market Risk A client’s account could lose money over short periods due to short-term market movements and over longer periods during market downturns. The value of a security may decline due to company specific issues, general market conditions, economic trends, or events that are not specifically related to the issuer of the security or to factors that affect a particular industry or industries. During a general downturn in the securities markets, multiple asset classes may be negatively affected. Passive Investment Risk Garde Capital may use a passive investment strategy that is not actively managed where we do not attempt to take defensive positions in declining markets. Item 9: Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. We have no information to disclose applicable to this Item. 11  Item 10: Other Financial Industry Activities and Affiliations Garde Capital does not have any material business affiliations within the financial services industry. Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Code of Ethics We have adopted a code of ethics (Code) for the purpose of instructing our personnel in their ethical obligations and to provide rules for their personal securities transactions. Garde Capital and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. The Code covers a range of topics that may include: general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code, review, and enforcement processes. We will provide a copy of the Code to any client or prospective client upon request. Material Financial Interest and Personal Trading From time to time the interests of the principals and employees of Garde Capital may coincide with those of our clients. Securities may be bought, held, or sold by a principal or employee of Garde Capital that is also recommended to or held by a client. If potential insider information is inadvertently provided or learned by a principal or employee, it is our policy to strictly prohibit its use. It is the policy of Garde Capital to permit the firm, its employees, and investment advisor representatives (“IARs”) to buy, sell, and hold the same securities that the IARs also recommend to clients. It is acknowledged and understood that Garde Capital performs investment services for various clients with varying investment goals, risk profiles, and time horizons. As such, the investment advice offered to one client may differ from the advice offered to other clients and investments made by our IARs. We don’t have an obligation to recommend for purchase or sale a security that Garde Capital, our principals, affiliates, employees, or IARs may purchase, sell, or hold. When a decision is made to liquidate a security from all applicable accounts, priority will always be given to client orders before those of a related or associated person, such as an IAR, to Garde Capital. In some cases the trades of the clients and advisory personnel will be combined in a single block trade, and all trades will receive the average price. Garde Capital has procedures for dealing with insider trading, employee-related accounts, “front running,” and other issues that may present a potential conflict when buy/sell recommendations are made. These procedures include reviewing 12  employee security transactions and holdings to eliminate, to the extent possible, the adverse effects of potential conflicts of interest on clients. Item 12: Brokerage Practices Factors Considered When Recommending a Custodian Garde Capital does not maintain custody of assets that we manage, although we may be deemed to have custody of assets if we are given authority to withdraw assets from a client’s account (see Item 15 – Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. Preferred Custodians We frequently recommend that our clients use low cost custodians such as Charles Schwab & Co., Inc. (“Schwab”), Member SIPC or Fidelity Brokerage Services, LLC (“Fidelity”) , Member SIPC. We are independently owned and operated and are not affiliated with Schwab or Fidelity. Each custodian will hold client assets in a brokerage account and buy and sell securities when we instruct them to. While we may recommend that clients use them as custodian/broker, the client will decide whether to do so and will open their account with the custodian by entering into an account agreement directly with them. We do not open the account for the client, although we may help them do so. Even though an account is maintained at the custodian, we can still use other brokers to execute trades for our client accounts as described below (see “Brokerage and Custody Costs”). Other Custodians Ultimately, the choice of custodian is entirely up to the client. Garde Capital will make every effort to accommodate the choice of custodian and provide a full range of investment advisory services. How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for client accounts) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange- traded funds, etc.) • Availability of investment research and tools that help us make investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, 13  other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, and stability • Prior service to us and our other clients • Availability of other products and services that benefit us Brokerage and Custody Costs Schwab and Fidelity generally do not charge clients separate fees for custody services but are compensated by charging you commissions or other fees on trades that it executes or that settle into your account. They are also compensated by earning interest on the uninvested cash in the custodian’s cash program, on any margin balance maintained in those accounts, and from other ancillary services. Most trades no longer incur commissions or transaction fees, though there are exceptions. Your custodian discloses its fees and costs to clients, and we take those costs into account when executing transactions on your behalf. They will charge you a flat dollar amount as “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab or Fidelity account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab or Fidelity execute most trades for your account. Certain mutual funds and ETFs are also made available for no transaction fee. As a result many confirmations show “no commission” for a particular transaction. Typically, the custodian (but not Garde Capital) earns additional remuneration from such services as recordkeeping, administration, and platform fees, for the funds and ETFs on their no-transaction fee lists. This additional revenue to the custodian will tend to increase the internal expenses of the fund or ETF. Garde Capital selects investments based on our assessment of a number of factors, including liquidity, asset exposure, reasonable fees, effective management, and low execution cost. Where we choose a no-transaction fee fund or ETF, it is because it has met our criteria in all applicable categories. Products and Services Available to Garde Capital from Schwab & Fidelity Schwab and Fidelity provide us with access to their institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to retail customers. They also make available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Their support services generally are available on an unsolicited basis (we don’t have to request them) and at no charge to us as long as our clients collectively maintain a specified amount of assets in accounts that we manage. If our clients collectively have less than that specified amount of assets at one of the custodians, they may charge us quarterly service fees. 14  Services That Benefit Clients The custodians’ institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through the custodians include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The services described in this paragraph generally benefit clients and their accounts. Services That Do Not Directly Benefit Clients The custodians also make available to us other products and services that benefit us but do not directly benefit clients or their accounts. These products and services assist us in managing and administering our clients’ accounts. They include investment research from the custodians and from third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at the custodians. In addition to investment research, the custodians also make available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us Schwab and Fidelity also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers The custodians may provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services to us. They may also discount or waive their fees for some of these services or pay all or a part of a third party’s fees. The custodians may also provide us with other benefits, such as occasional business entertainment of our personnel. The availability of these services from Schwab and Fidelity benefits us because we do not have to produce or purchase them. We don’t have to pay for these services so long as our clients collectively keep a specified amount of assets in accounts at the custodians. Beyond that, these services are not contingent upon us committing any specific amount of business to them in 15  trading commissions or assets in custody. The asset minimum may give us an incentive to recommend that a client maintains their account with Schwab or Fidelity, based on our interest in receiving services that benefit our business rather than based on the client’s interest in receiving the best value in custody services and the most favorable execution of client transactions. This is a potential conflict of interest. We believe, however, that our selection of low-cost platforms such as Schwab or Fidelity as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of their services (see “How We Select Brokers/Custodians”) and not their services that benefit only us. We do not believe that recommending that our clients collectively maintain a minimum amount of assets at a certain custodian in order to avoid paying a quarterly service fee presents a material conflict of interest. Brokerage for Client Referrals We do not use, recommend, or direct activity to brokers in exchange for client referrals. Directed Brokerage If a client directs Garde Capital to execute securities transactions at a broker-dealer other than one we use for our other clients, the client will forgo any benefit from savings on execution costs that we may have obtained through our negotiation of volume discounts or batched orders. In directing the use of a particular broker-dealer, it should be understood that we will not have authority to negotiate commissions or obtain volume discounts, and best execution may not be achieved. A client may incur higher commissions, other transactions costs, greater spreads, or receive less favorable net prices, on transactions for their account than would otherwise be the case had they used a broker-dealer we prefer. Aggregated Orders When we decide to purchase or sell a specific security for multiple clients at the same time, we will consider aggregating, or combining the orders. This procedure will result in a single average price for all client transactions in the aggregated order. The account custodian charges for each transaction as if it were placed individually. We generally trade in liquid securities and partial allocations are not a concern under normal market conditions. However, should we not receive the full amount of the requested, or if multiple executions are required, the following apply: • • If the full amount we requested is not obtained (and we determine to stop trading), we will pro-rate the purchased shares equally across all participating accounts. However, if employee transactions are included in the block and only a partial fill is completed, employee transactions are excluded (per our Code) until all client trades are completed. If multiple fills occur to complete the full block, then all purchases are averaged to price and each participating client receives their full allocation at that average price. 16  Trade Errors Policy From time to time we may make an error in submitting a trade order on a client’s behalf. When this occurs, we may place a correcting trade with the broker-dealer which has custody of the client’s account. The goal of this transaction will be to restore the account to the intended status at no cost to the client, and neither a gain nor loss due to the correcting trade will remain in the account. Best Execution As indicated above, we typically require that clients open brokerage/custodial accounts at one of two custodians, Schwab or Fidelity. We are not compensated directly for recommending custodians to clients, though we may receive indirect economic benefits from those custodians as outlined above. The criteria for recommending a custodian include reasonableness of commissions and other costs of trading, ability to facilitate trades, securities lending needs, access to client records, computer trading support and other operational considerations. These factors will be reviewed from time to time to ensure that the best interests of our clients are upheld. In seeking “best execution” for clients, the key factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, considering the full range of services, including execution capability, technological processes used for submitted trades and other valuation services. Item 13: Review of Accounts Reviews Our advisory associates perform reviews of all investment advisory accounts no less than quarterly. Accounts are reviewed for consistency with the investment strategy and performance. Reviews may be triggered by changes in a client’s personal, tax, or financial status. Macroeconomic and company-specific events may also trigger reviews. Financial plans are reviewed only upon request unless a client retains us to update the plan on a continous basis. Reports We do not routinely send reports to all of our clients. However, we are able to provide our clients with a range of reports detailing the status and performance of their accounts. The delivery and frequency of such reports is based on client preference and can be provided on a monthly, quarterly, semi-annual, or annual basis. Additionally, these reports can be made available on request, particularly during portfolio reviews or when specific information is required. Reports will be delivered to clients electronically via email, through an online portal (if applicable), or via traditional mail, based on client preference. 17  Item 14: Client Referrals and Other Compensation Referral Relationships We currently have written arrangements with outside entities that provide compensation for successful referrals of new clients. Our agreements with these entities provide that the introducing firm will receive a portion of the advisory fees that would otherwise be charged and fully retained by Garde Capital. The agreements require the other firm to make full disclosure of the arrangement to prospective clients in advance of the referral and to obtain client acknowledgement of the arrangement. Further, the arrangement does not result in clients paying fees higher than they would otherwise pay for a similar scope of work. As of 2022, Garde Capital has solicitation agreements in place with Berntson Porter & Company Wealth Management, LLC and BMMS Wealth Advisory, LLC. Item 15: Custody Clients authorize us to deduct periodic investment advisory fees directly from one or more of their accounts managed by us. These deductions from client accounts are shown on the periodic statements sent by the account custodian directly to the client. The client is encouraged to review these statements carefully and compare the amounts on the custodian statements with any fee statements we send, and the fee schedule outlined in their Investment Advisory Agreement. Garde Capital reports custody of some client assets solely because of signed Standing Letters of Authority (SLOAs) for money movement that are on file at the custodians for some client accounts. We are in compliance with the conditions set forth by the SEC relating to SLOAs and do not require a surprise exam of these assets. Item 16: Investment Discretion Clients grant Garde Capital a limited power of attorney to select, purchase, or sell securities without obtaining their specific consent within the account(s) they have under our management. The limited powers of attorney are granted in the written Investment Advisory Agreement entered into between the client and us. There are no restrictions upon the securities that may be purchased, sold, or held in an account unless the client provides these restrictions to us in writing. Item 17: Voting Client Securities We will vote proxies for securities held in the accounts that we manage. Proxy Voting Policy We have adopted a written policy regarding the voting of client proxies that is designed to ensure that we fulfill our fiduciary obligation to our clients to monitor corporate actions and 18  vote client proxies. The written policies are designed to address a wide range of common business and social issues often contained in proxy statements and how to vote them in the best interest of our clients. Items not specifically addressed in the policy will be dealt with on a case-by-case basis. If a material conflict of interest presents itself, we will notify the affected clients and/or refrain from voting the respective shares. We will vote proxies in a way that we believe will cause securities to increase the most or decline the least in value in order to maximize shareholder value. Consideration will be given to both the short and long-term implications of the proposal to be voted on when considering the optimal vote. Clients can obtain a copy of our proxy voting guidelines by contacting us directly. We can also provide information on how we voted on a specific proxy item on request. Requests should identify the security and the proxy item in writing to assure they are clearly understood and submitted to the following person: Scott Severs Chief Compliance Officer Garde Capital, Inc. 1301 Fifth Avenue, Suite 3030 Seattle, WA 98101 Item 18: Financial Information Garde Capital does not have any financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients. We do not require pre-payment of investment advisory fees of greater than $1200, nor do we require payment of fees more than six months in advance. 19  Privacy Policy WHAT DOES GARDE CAPITAL DO WITH YOUR PERSONAL INFORMATION? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you h o w we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Social Security number and financial information • Investment holdings and investment experience • Financial goals and financial history When you are no longer our customer, we continue to share your information as described in this notice. How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Garde Capital chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Garde Capital share? Can you limit this sharing? For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No For our marketing purposes— to offer our products and services to you Yes No For joint marketing with other financial companies No We don’t share For our affiliates’ everyday business purposes— information about your transactions and experiences No We don’t share For our affiliates’ everyday business purposes— information about your creditworthiness For nonaffiliates to market to you No We don’t share No We don’t share 20  Page 2 Who we are Who is providing this notice? Garde Capital, Inc. What we do How does Garde Capital protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also restrict access to your personal information to those individuals who need to know the information to provide services and/or products to you. How does Garde Capital collect my personal information? We collect your personal information, for example, when you • Open an account or deposit funds. • We prepare a financial plan for you. Why can’t I limit all sharing? Federal law gives you the right to limit only • sharing for affiliates’ everyday business purposes—information about your creditworthiness • affiliates from using your information to market to • you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law. Definitions Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. • We have no affiliates. Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. They may include: • Custodians, e.g., Charles Schwab, Inc or Fidelity • Performance Reporting providers such as Black Diamond 21  Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Other important information You may have privacy protections under applicable state laws, including those for California residents. To the extent the state laws apply, we will comply with them when we share information about you, and in some case may be limited by you. California Residents: The California Information Privacy Act provides additional protections to control whether we share some of your personal information. In accordance with California law, we will not share information we collect about California residents with outside companies, except as permitted by law, such as with the consent of the customer or to service a customer’s accounts. Questions? Please call 206-552-7900. 22