WESTFULLER ADVISORS, LLC

Item 1 – Cover Page FORM ADV: Uniform Application for Investment Adviser Registration PART 2A: Disclosure Brochure March 29, 2025 1185 Avenue of the Americas, 3rd Floor New York, NY 10036 www.westfulleradvisors.com This Client Brochure provides information about the qualifications and business practices of Westfuller Advisors, LLC (“Westfuller,” “our,” “we,” or “us”), a registered investment advisor. Registration does not imply a certain level of skill or training but only indicates that Westfuller has registered its business with the United States Securities and Exchange Commission (“SEC”). The information in this Client Brochure has not been approved or verified by the SEC or by any state securities authority. If you have any questions about the contents of this Client Brochure, please contact the Chief Administrative Officer at (212) 219-6198 or advisors@westfulleradvisors.com. Additional information about Westfuller is also available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov and on Westfuller’s website at www.westfulleradvisors.com. 1  Item 2 – Material Changes The following material changes have been made to Form ADV Part 2A since Westfuller’s last annual update of this disclosure statement issued on March 26, 2024: • Item 4 – Advisory Business: o Westfuller has entered into a joint venture with Bivium Capital Partners, LLC (“Bivium”), an SEC Registered Investment Advisor to provide non-profit institutional clients and family offices. Westfuller and Bivium (jointly “BWF”), provide tailored multi-asset class investment advisory services to BWF Clients through the use of third-party portfolio managers (“Independent Portfolio Managers”) . • Item 7 – Types of Clients o The investment minimum of institution clients has changed from $10 million to $20 million. o Language was added to reflect investment minimum of $50 million of BWF clients. • Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss o Additional disclosures have been added regarding the potential risk of loss. • Item 10 – Other Financial Activities and Affiliations: o Updates have been made to reflect the industry affiliations of Westfuller and Bivium as a result of the joint venture. • Item 12 – Brokerage Practices o Policy language regarding broker discretion, best execution, and directed brokerage related to BWF clients was included. • Item 17 – Voting Client Securities o Language was added to explain the proxy vote execution for BWF clients. 2  Item 3 - Table of Contents Item 1 – Cover Page 1 Item 2 – Material Changes 2 Item 3 - Table of Contents 3 Item 4 – Advisory Business 4 Item 5 – Fees and Compensation 11 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 14 Item 9 – Disciplinary Information 19 Item 10 – Other Financial Industry Activities and Affiliations 20 Item 11 – Code of Ethics 20 Item 12 – Brokerage Practices 22 Item 13 – Review of Accounts 25 Item 14 – Client Referrals and Other Compensation 25 Item 15 – Custody 26 Item 16 – Investment Discretion 26 Item 17 – Voting Client Securities 27 Item 18 – Financial Information 27 3  Item 4 – Advisory Business Introduction Westfuller is an SEC-registered investment advisor offering values-driven, comprehensive fee- based sustainable investment advisory and wealth management services since 2011. Westfuller is a privately held company based in New York City and organized as a limited liability corporation under the laws of the State of Delaware. Lola C. West and Ian Fuller are the principal owners of Westfuller, while a minority stake is held by Cambria Holdings, LLC. Additional information about Westfuller’s products, structure and management is provided on Part 1 of Westfuller’s Form ADV which is available online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. Client assets are held in separately managed accounts by a clearing broker-dealer that meets the criteria for a “qualified custodian” under the Investment Advisors Act of 1940 and provides custody, securities execution, clearance and administrative services. The investment advisory portfolio management program is made available through the following custodian channels: • • Accounts established directly with Fidelity Brokerage Services, LLC (“Fidelity”), a Fidelity Investments company and/or Bank of New York Mellon Pershing (“Pershing”). Fidelity and Pershing provide Westfuller with access to its institutional trading and custody services, which are typically not available to retail investors. Institutional Clients may also select the use of their own designated, qualified custodian such as Northern Trust, Bank of New York, US Bank, State Street, etc. Overview of Advisory Services Westfuller offers values-driven investment advisory and wealth management services to charitable institutions, foundations, endowments, family offices, ultra-high net worth individuals, high-net worth individuals, and businesses (each referred to as a “Client”). Investment advisory and wealth management services are more than investment management alone, as it can encompass all parts of an institution’s financial operations and a person’s financial life. We provide our Clients with a variety of financial advisory services to assist them in managing the entirety of their financial and organizational affairs with purpose. This includes, among other things, mission-aligned investment management, investment policy design and implementation, organizational financial forecasting, sustainability and impact assessments, etc. We also provide support to our Clients with respect to philanthropic, estate planning, spending and reserve policies, etc. by working closely with our Client’s other professional advisors. We will recommend the services of other professionals for services outside our area of expertise, if needed. Our investment advisory and investment management services are primarily focused on managing a Client’s investable assets. We make investment recommendations, analyze portfolios, and research investment opportunities suitable for our Clients. The fee for this service is generally based on assets under management. Other services such as financial planning and consulting may or may not be included in this fee. We offer a defined amount of additional planning services at tiered fee levels dependent upon the amount of assets under management. If Clients need additional planning services, we offer such services through a fixed or hourly fee arrangement which are approved in advance by our Clients and can be negotiated. 4  Westfuller defines sustainable and impact investing as investments made into investment funds, investment managers, and companies with the intention to generate positive social and environmental impact alongside financial return. We seek out investment funds and investment managers that incorporate sustainability analysis and/or Sustainable, Responsible, Impact-focused (“SRI”) criteria into their investment philosophy to identify impact and sustainable investments. We believe these funds and managers gain additional insight into potential business risks and opportunities by incorporating SRI criteria. Funds and managers that focus on sustainable investing seek to invest in companies with practices, products, and/or services which may mitigate risks through their evaluation of externalities (e.g., greenhouse gas emissions, mining pollution, unfair employment practices, and lax corporate governance). We believe that funds and managers utilizing SRI and sustainability analysis are able to identify companies with quality management teams and are positioned to perform better than their peers over the long term. We work with our Clients to understand their financial assets, financial goals and objectives, and sustainability objectives using interviews and client questionnaires. Understanding a Client’s portfolio funding requirements, risk tolerance, and impact objectives provides us with the necessary information to construct a portfolio to meet short to medium term liquidity requirements and long-term growth goals. We allocate funds that are needed for short to medium-term distribution requirements to a spending allocation that is invested in cash equivalents and short to medium-term high-quality bonds and bond funds. Long-term growth assets are allocated based on identifying the appropriate risk model for a Client. We strive to allocate the Client’s assets across a globally diversified, multi-asset class portfolio. As appropriate, Westfuller allocates assets among investment funds (including mutual funds, exchange-traded funds (“ETFs”), and private funds (including, without limitation, private equity funds, real estate funds, and fund-of-funds) and third-party investment managers (including separate account managers, subadvisors, and third-party asset management platforms). Occasionally, Westfuller will also make direct investments with companies and other issuers, including, without limitation, private placement investments in community impact notes. We then select one or more investments for each of the asset classes in their appropriate risk model. For foundations and endowments, we may follow a Client’s existing IPS, or where appropriate, we will develop a mission-aligned investment policy statement (“IPS”). We facilitate discussions among multiple family members, members of Boards of Directors, and organizational stakeholders to draft an IPS that outlines an organization’s purpose and values, investment time horizon, return objectives, income and liquidity needs, investment restrictions, and sustainability objectives. If a Client has an IPS before engaging us, we will review the Client’s current IPS and make recommendations, as needed. Our relationship with a new Client starts with a one-on-one consultation. We will typically conduct one or more meetings with the Client (in person if possible, otherwise via telephone and/or video conference) in order to fully understand the Client's goals and values. We interview each Client, complete a profile questionnaire, and produce a financial plan to formally document specific needs, concerns and priorities. We evaluate factors such as values, current income and expenses, assets, investment objectives, tolerance for risk, investment time horizon, tax situation, investment 5  preferences, family dynamics, and philanthropic and impact goals. Depending on the complexity of the Client’s financial affairs, we may also ask to meet with their attorney, accountant, or other advisors. Westfuller’s investment strategies seek to systematically incorporate and articulate sustainability into the investment advisory services offered. To implement our strategy, we seek to utilize SRI inclusionary and exclusionary metrics to measure an issuer’s or an Underlying Manager’s adherence to, or adoption of, sustainability. Our advisory solutions and recommendations are informed by thematic and impact measurement research from leading sources such as Yourstake, FFI Solutions, Factset, Bloomberg As You Sow, MSCI Sustainalytics, Morningstar ESG, and American Friends Service Committee. Westfuller accepts new Clients who have a minimum initial balance of $3 million of total assets under management for individuals and families, and $20 million of total assets under management for institutions (non-profits, foundations, etc.). In addition to these advisory services, Westfuller has entered into a joint venture with Bivium Capital Partners, LLC (“Bivium”), an SEC Registered Investment Advisor to provide non-profit institutional clients and family offices with an initial minimum balance above $50,000,000 of assets under management, investment advisory and Outsourced Chief Investment Officer (“OCIO”) solutions. Westfuller and Bivium (jointly “BWF”), through the joint venture, develop tailored Investment Policy Statements (“IPS”) and provide comprehensive multi-asset class investment advisory services to BWF Clients through the use of third-party portfolio managers (“Independent Portfolio Managers”) . The IPS is the primary tool used by BWF to work with the Client in the selection, implementation, and oversight of mission-aligned OCIO solutions. Portfolios are monitored and adjusted by BWF throughout the duration of the client relationship. Advanced Financial Planning and Consulting Services Westfuller provides a wide range of comprehensive financial planning services, pursuant to a written client engagement letter. Topics that are addressed include SRI investing, asset allocation, portfolio diversification, management of risk, executive compensation, family dynamics, legacy issues, philanthropic giving, retirement planning, education planning and other general economic and financial topics. Westfuller and the Client will discuss and agree upon the specific topics to be covered by the advanced financial plan. We will also provide or arrange for comprehensive wealth management services such as executive compensation analysis (including equity grant awards), retirement planning, estate and tax management guidance, planned and philanthropic giving, credit and lending solutions advisory as well as insurance consulting. A financial plan will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, we may recommend that the Client start or revise their investment program, commence or alter retirement savings, and establish education savings and/or charitable giving programs. Westfuller may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, we will provide a written summary of the Client’s financial situation that includes our observations and specific recommendations. For consulting or ad-hoc engagements, we may not provide a written summary. Plans or consultations are typically completed within six months 6  of contract date, assuming all information and documents requested by Westfuller has been provided promptly. When we provide stand-alone financial planning services, which is only done on a limited basis, such financial planning and consulting generally includes several meetings and/or steps: Implementing the recommendations • Establishing and defining the client-advisor relationship • Gathering client data including goals • Analyzing and evaluating the client’s current financial status • Developing and presenting recommendations and/or alternatives • • Monitoring the recommendations Westfuller offers the following financial planning and consulting services to individuals, families, and institutions: Advanced Financial Planning • Retirement accumulation planning • Retirement income planning • Education and college planning • Employer retirement planning (reviewing 401k or 403b asset allocations) • Employee benefits planning • Executive compensation planning (including equity grant analysis) • Budget and cash flow planning • Financial impact planning and scenario modeling of life events such as new job, divorce, inheritance, asset liquidation or purchase, and the birth/death of a family member Income tax planning assistance Insurance analysis • Record keeping and reporting across balance sheet assets and liabilities • • Financial education for family members • Family decision-making processes • Philanthropic goals (private and public foundations) • Estate planning • Multi-generational wealth planning • Coordination of outside professional • • Trustee administration service • Business succession planning. Consulting • Providing mission-related investing and impact investing education • Development of mission-related investing an impact investing guidelines and implementation plans IPS drafting, or review to address financial and mission/impact guidelines • • Providing operating reserve policy guidelines and drafting • Impact investment manager search and selection 7  • Miscellaneous consulting such as the selection of an accountant, trust and estate attorney, non-profit counsel, bookkeeper, or other family office services. Philanthropic Planning Westfuller assists Clients in determining guidelines for philanthropic spending; identify assets to gift as well as suitable charitable vehicles; and assist them in aligning their giving with their sustainability objectives. Westfuller may recommend the services of a philanthropic consultant and/or Donor Advised Fund (“DAF”). Clients are responsible for the fees and expenses associated with such philanthropic consultants and DAFs. Philanthropic contributions are managed on a client-by-client basis. Financial planning and consulting recommendations may pose a potential conflict for Westfuller. Clients are not obligated to implement any of our recommendations and, if the Client elects to act on any recommendation the Client is under no obligation to execute a transaction through Westfuller. Sustainable, Responsible, and Impact-Focused (SRI) Portfolio Management Westfuller provides SRI and values-driven wealth management, investment advice and portfolio management services on a continuing basis. We do not require Clients to grant Westfuller discretionary trading authority to participate in our investment management program. Prior to engaging Westfuller to provide portfolio management, each Client is required to enter into an advisory agreement that sets out the terms and conditions under which services will be provided. These services may include: • Establishing an Investment Policy Statement – Westfuller, with the Client’s participation, will develop a statement that summarizes the Client’s values, investment goals and objectives along with the broad strategies to be employed to meet the objectives. An Investment Policy Statement generally includes specific information on the Client’s stated SRI goals, financial goals, time horizon for achieving the goals, investment strategies, Client risk tolerance and any reasonable restrictions imposed by the Client. • Asset Allocation – Westfuller will develop a values-driven strategic asset allocation that is targeted to meet the investment objectives, Sustainability and Impact goals, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Westfuller will develop a values-driven portfolio for the Client that is intended to meet the stated objectives, SRI goals, and values of the Client. • SRI Investment Management and Supervision – Westfuller will provide sustainable, multi- asset class investment management and ongoing oversight of the Client’s portfolio and overall account. IRA Rollover Recommendations For purposes of complying with the U.S Department of Labor’s (“DOL”) Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, Westfuller is providing the following acknowledgment. When Westfuller provides investment advice to a Client regarding a Client’s retirement plan account or individual retirement account, Westfuller is a fiduciary 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. 8  Westfuller benefits financially from the rollover of Client assets from a retirement account to an account that Westfuller manages or provides investment advice, because the assets increase Westfuller’s assets under management and, in turn, Westfuller’s advisory fees. As a fiduciary, Westfuller only recommends a rollover when we believe it is in the Client’s best interest. Alternative Investments Westfuller also offers advice on alternative investments such as Community Impact Notes, venture capital, private equity, real estate and hedge funds. Westfuller may also advise on structured notes, the use of foreign exchange forward contracts and interest rate and equity derivatives. Alternative investments generally are speculative investments that are subject to a significant amount of risk. Hedge funds are complex investment vehicles that often engage in the use of leverage and other speculative investment practices, such as short sales, options, derivatives, futures and illiquid investments that may increase the risk of investment loss. Prospective investors must carefully review the risk- disclosure statement. This Client Brochure is not a solicitation, recommendation or invitation to invest in alternative investments and is intended solely to disclose the availability of alternative investments within our advisory program. Independent Portfolio Managers Upon Client request, Westfuller can introduce them to Independent Portfolio Managers that, based on our due diligence, we believe are suitable for the Client or recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Portfolio Managers”) for all or a portion of a Client’s investment portfolio. Clients can choose Westfuller to manage their account assets, retain an Independent Portfolio Manager, or choose both of these options. Independent Portfolio Managers work with each Client to identify their investment goals and objectives as well as risk tolerance in order to create a portfolio allocation. The manager will then construct a portfolio, consisting of stocks, bonds, options, exchange-traded funds and mutual funds to achieve the Client’s investment goals. The Independent Portfolio Manager may also recommend alternative investments as necessary to meet the needs of its Clients. The Independent Portfolio Manager may also require the Client to authorize them to effect transactions without prior consultation with the Client. In instances where an Independent Portfolio Manager is used, the Client will be required to authorize and enter into a tri-party advisory agreement with Westfuller and the Independent Portfolio Manager that defines the terms of the investment management and related services. Westfuller will assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into a tri-party agreement, will be provided with the Independent Portfolio Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). As a general matter, the factors Westfuller will use to evaluate an Independent Portfolio Manager include, but are not necessarily limited to: reputation, management strength and continuity, performance record, investment philosophy, client service, values-alignment, minimum dollar investment requirement and fees. We use these factors to determine whether the Independent Portfolio Manager is compatible with the Client’s investment objectives, risk tolerances, values and other client criteria. Supported by our advice and guidance, the Client makes all Independent Portfolio Manager selection decisions. We encourage Clients to review the public disclosures available with respect to any Independent Portfolio Manager we may propose for more information on their investment advisory services and brokerage policies. 9  Westfuller will conduct continuing due diligence with regard to the Independent Portfolio Managers may recommend consistent with our oversight responsibilities. We will be responsible for screening, retaining, monitoring and will, where necessary, recommend replacement of the Independent Portfolio Managers for investment decisions regarding their respective portion of the Client’s account assets. The methods of implementing investment strategies vary from Client to Client. Clients opting to engage an Independent Portfolio Manager will be provided with a list of managers we deem appropriate for that particular Client. Westfuller does not accept compensation from, or pay compensation to, any managers. BWF OCIO BWF partners with Independent Portfolio Managers to help them achieve the Client’s strategic objectives by serving as their OCIO. BWF provides a bespoke investment policy that focuses on Clients’ immediate and long-term needs. In its capacity as an OCIO, BWF will help clients build out an Investment Policy Statement (IPS) to guide their investment philosophy and target portfolios. The IPS includes such items as Diversity, Equity Inclusion (DEI), Environmental, Social, and Governance (ESG), liquidity goals, performance expectations, and portfolio diversification. The IPS is customized for each Client based on the mentioned, and other goals as outlined by the Client. Additionally, BWF will perform due diligence on Independent Portfolio Managers before funding and on an on-going basis. Westfuller’s Total Assets Under Management As of December 31, 2024, Westfuller approximately manages the following assets: Assets Under Management (AUM) Discretionary Non-Discretionary Total Assets under Management Assets $1,508,389,276 $626,973,779 $2,135,363,056 Westfuller’s Assets Under Advisement Westfuller participates in consulting relationships with a number of clients where Westfuller provides Investment Policy Statements, asset allocation study, liquidity needs assessment and investment models to clients. In these instances, Westfuller’s primary responsibilities are to create a non-client specific, representative model portfolio based on a specified investment strategy and to communicate periodic model changes to the client. Clients have sole discretion with respect to implementing a model, in whole or in part. As of December 31, 2024, Westfuller approximately advises on the following assets: Total Assets under Advisement (AUA) $601,000,000 10  Total Assets Under Management / Assets Under Advisement Total AUM/AUA $2,736,363,056 Item 5 – Fees and Compensation Sustainable and Values-Driven Portfolio Management Westfuller Client advisory agreements set out the specific manner in which we are compensated for portfolio management services. Clients can elect to pay either a fixed fee or an asset-based fee. All fees are subject to negotiation and may differ from Client to Client, based on a number of factors. Pursuant to specific client authorization, Westfuller shall instruct the account custodian to directly debit our fees from the Client’s account. Some legacy Westfuller and BWF Clients may be on a different fee schedule, which can result in fees that are different than those disclosed below. Westfuller and BWF may negotiate a lesser investment management fee based upon certain criteria such as anticipated future additional assets, related accounts, family members’ accounts, account composition, dollar amount of assets in excess of investment minimums, pro bono activities, etc. Investment managers may have minimum fee or portfolio size requirements that differ from the below. Institutional Clients: Asset-based Fee The asset-based fee is generally paid quarterly, in arrears based upon the prior quarter-end statement value of the account as computed by the account custodian, according to the following fee schedules: Assets under Management First $5,000,000 $5,000,001 - $10,000,000 $10,000,001 - $25,000,000 $25,000,001 - $50,000,000 $50,000,001 - $75,000,000 $75,000,001 - $100,000,000 $100,000,001 - $500,000,000 $500,000,001 - $1,000,000,000 Above $1,000,000,001 Annual Fee 1.00% 0.85% 0.70% 0.65% 0.60%* 0.55%* 0.50%* 0.45%* 0.25%* * - An administration fee of 20bps for BWF clients is added to legacy investments that cannot be managed by BWF on discretionary basis. Non-Institutional Clients: Asset-based Fee 11  The asset-based fee is generally paid monthly, in arrears based upon the prior month-end statement value of the account as computed by the account custodian, according to the following fee schedules: Assets under Management First $1,000,000 $1,000,001 - $3,000,000 $3,000,001 - $5,000,000 $5,000,001 - $10,000,000 $10,000,001 - $25,000,000 $25,000,001 - $50,000,000 $50,000,001 - $75,000,000 $75,000,000 - $100,000,000 Above $100,000,000 Annual Fee 1.75% 1.00% 0.90% 0.85% 0.80% 0.75% 0.70% 0.65% 0.60% Fixed Fee At the Client’s request, we will negotiate an annual fixed fee (based on our standard hourly rates of $375-$550 and other factors including the amount of work involved, the assets placed under management and the appropriate degree of attention needed to manage the account). The fixed fee is paid on a prearranged cadence (i.e., monthly or quarterly), in arrears, in equal installments over the course of a year. Fees for related entities and individuals are negotiable. Independent Portfolio Managers Fees charged by Independent Portfolio Managers are negotiated directly between the Client and the manager and are separate from the advisory fees charged by Westfuller and BWF. We will make every effort to negotiate a suitable discounted fee for Westfuller and BWF services in such cases. As noted in Item 4, Westfuller and BWF may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Portfolio Managers. To eliminate any conflict of interest, Westfuller and BWF do not earn any compensation from an Independent Portfolio Manager. Westfuller and BWF will only earn its investment advisory fee as described above. Independent Portfolio Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Portfolio Manager. The terms of such fee arrangements are included in the Independent Portfolio Manager’s disclosure brochure and applicable contract[s] with the Independent Portfolio Manager. The total blended fee, including Westfuller and BWF’s fee and the Independent Portfolio Manager’s fee will not exceed 2% annually, with the exception that alternative assets may be as high as 2.75% (private equity, hedge funds, real estate, etc.). Financial Planning Financial planning services are offered as an additional service to Westfuller Clients and are provided on fixed fee basis based on assets under management. Clients with assets under management below $1,000,000 are charged $7,500 and Clients with a range of assets under management between $1,000,001 to $4,999,999 are charged $5,000 for financial planning 12  services. There is no charge for these services for Clients with assets under management over $4,999,999. All fees are reviewed with the Client beforehand. All fees are subject to negotiation and may differ from Client to Client, based on a number of factors. A deposit of 50% for financial planning services fees are due and payable at the execution of the client agreement with balance due upon completion of the financial plan. Other Fees and Charges These can include, but are not limited to, fees charged by the account custodian for margin interest, currency exchange, dealer markups or markdowns, electronic fund transfer, and other miscellaneous fees and taxes on brokerage accounts and securities transactions. Directed Brokerage Westfuller Clients wishing to utilize a broker dealer other than Fidelity and/or Pershing will incur charges in addition to our advisory fee. These can include, but are not limited to, brokerage commissions, dealer markups or markdowns, margin interest, exchange fees, and miscellaneous fees and taxes. Please see Item 12 - Brokerage Practices, for more information. Termination Fees Westfuller’s services can be terminated by either party upon 30 day’s written notice in accordance with the Client’s advisory agreement. BWF’s services can be terminated by either party upon 60 day’s written notice in accordance with the Client’s advisory agreement upon termination, advisory fees will be pro-rated and, because such fees are assessed in arrears, no refund would be necessary. The Client is responsible to pay for services rendered through the termination date. Once the advisory agreement has been terminated, subsequent transactions executed by the account custodian for the Client account will be processed at the custodian’s prevailing brokerage rates. Additional Fees and Expenses As part of Westfuller and BWF’s investment advisory services, Westfuller may invest, or recommend that Clients invest, in mutual funds and exchange traded funds. The fees that you pay to Westfuller for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or ETFs (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. Clients may also incur transaction charges and/or brokerage fees, mutual fund fees, exchange traded fund fees, sub- adviser and third-party manager fees, hedge fund fees, and other private placement fees, and other transactions costs when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom the account transactions are executed. Westfuller does not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. Westfuller does not receive any fees from these mutual funds or closed- end funds pursuant to a fund’s Rule 12- b1 plan. Item 6 – Performance-Based Fees and Side-By-Side Management Westfuller does not charge or accept any fees based on a share of capital gains on, or capital appreciation of, the assets of a Client (i.e., performance fees). 13  Item 7 – Types of Clients Westfuller provides investment advisory services to ultra-high-net worth individuals, high-net worth individuals, charitable institutions, foundations, endowments, corporate pension and profit- sharing plans, and businesses. Westfuller accepts new Clients who have a minimum initial balance of $3 million of total assets under management for individuals and families and $20 million of total assets under management for institutions though the firm reserves the right to grant exceptions. Fees and investment minimums are subject to negotiation and may differ based on factors including the amount of assets, number of accounts, levels of contributions/distributions, and the number and range of supplemental advisory and client-related services provided. Client relationships are subject to a minimum annual advisory fee of $20,000. Accordingly, Clients whose household account balances are less than $3 million will pay advisory fees at an effective rate for portfolio management services that may not be appropriate for such accounts. BWF accept new Clients who have a minimum initial balance of $50 million of total assets under management for non-profit institutional clients and family offices. This amount may be waived by BWF on a case-by-case basis and typically if there is reasonable assurance the account will grow to $50 million or more. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Understanding our Client’s goals through a comprehensive financial planning process is a core principle of our investment philosophy. We work with our Clients to understand their income and liquidity needs as well as their long term financial and impact goals. An in-depth understanding of our Client’s income requirements is needed to ensure there is sufficient high-quality, low-volatility assets that can be accessed during any part of the market cycle. We determine the long-term goals for growth of investable assets to best meet the Client’s goals such as for retirement, family expenses, legacy gifting objectives, organizational spending, and organizational impact. After determining a Client’s needs and goals, Westfuller will recommend an asset allocation that consists of low-volatility assets to meet spending and distribution needs and risk assets to provide the opportunity for growth. Westfuller believes constructing an asset allocation that considers and plans for the volatility over a complete market cycle is the primary determinant of a portfolio’s risk and return characteristics. Broad diversification mitigates risk and increases the probability of meeting a Client’s long-term return objectives. Westfuller constructs global, multi-asset class portfolios that have both passive and active management, which can minimize costs and maximize the potential for portfolio return. Passive strategies are employed in the more efficient such as large cap global equity and core fixed income allocations. For less efficient asset classes, Westfuller seeks to employ active managers potentially able to outperform the appropriate benchmark, provide risk mitigation, or add positive environmental and/or social impacts. Westfuller has three model asset allocations representing a range of client needs for income and growth. Westfuller periodically rebalance portfolios to maintain target allocations. 14  Embedded in Westfuller’s investment philosophy is the belief that patient, long-term investing can lead to better long-term returns. Short-term and high-turnover approaches create incentives for companies that are focused on short term, unsustainable business strategies. Investment returns and risk are impacted by sustainability factors. Westfuller firmly believes that SRI factors are long-term determinants of a company’s performance, and companies that integrate sustainability into their business practices are competitively better positioned for the future. By integrating sustainability criteria into traditional asset allocation modeling over a long-term investment horizon, we believe superior portfolio construction can be achieved. BWF’s investment philosophy is rooted in the theory that investment opportunities are best sourced when casting a wide and inclusive net that ensures “best” is not synonymous with “large” or “well known” in the selection process. Research has shown that when included, both established as well as boutique Independent Portfolio Managers, can offer investors compelling investment opportunities, particularly in inefficient asset classes and sustainability-themed and impact strategies. BWF recognizes that a dynamic portfolio construction process can help minimize manager risk while maximizing investment returns. As such, BWF seeks to add value through Independent Portfolio Manager selection and portfolio construction, starting with a clear understanding of our clients’ objectives. In selecting Independent Portfolio Managers, BWF looks at the unique investment theses each firm deploys and whether its style and process are distinct or like other firms that BWF may have identified. Independent Portfolio Managers has on the aggregate portfolio’s BWF’s portfolio construction goal is to mitigate investment risk, including the business risks inherent in allocating to smaller, newer Independent Portfolio Managers. In constructing efficient portfolios, understanding how the underlying Independent Portfolio Managers interact is crucial. BWF typically assesses and quantifies the Client’s return and risk expectations and the desired benchmark for the portfolio. The team then engages in an iterative process of quantitative and qualitative assessments of proposed Independent Portfolio Managers combinations. BWF also uses a proprietary returns-based optimizer when assessing potential Independent Portfolio Managers combinations and allocations. Holdings-based factor exposures are also inputs. The optimizer is run to determine potential portfolio combinations that would satisfy a variety of constraints (e.g., maximizing information ratio, maximizing consistency, minimizing drawdowns). This collection of optimized portfolios provides the team with perspective around the impact each return potential characteristics. Our goal is to find unique sources of alpha. Our “performance first” culture identifies firms that share our performance mindset. We expect 70-80% of above-benchmark performance to come from Independent Portfolio Manager selection, with the remaining 20-30% derived from asset allocation, portfolio construction, and Independent Portfolio Managers weightings. BWF employs a systematic approach to identifying, conducting due diligence on, monitoring, and selecting Independent Portfolio Managers so that Clients get the benefit of active portfolio management, where appropriate. BWF relies on its quantitative tools to understand the investment risks being taken by each Independent Portfolio Manager; then, BWF’s due diligence process adds qualitative judgment to understand and evaluate each of those risks. 15  BWF’s due diligence and ongoing review process includes: screening its proprietary database for potential Independent Portfolio Managers; performance and attribution analysis (initial and ongoing); review of business viability (initial and ongoing); an initial questionnaire and two detailed requests for information (one focused on the investment strategy and philosophy of the firm; and one focused solely on the financial, compliance and operations of the Independent Portfolio Manager); conference calls to discuss firm operations and viability, investment style, performance, and firm compliance and operations; on-site visits for all Independent Portfolio Managers before funding; and periodic on-site visits of all funded Independent Portfolio Managers. In addition, many of the Independent Portfolio Managers travel to a BWF office site throughout the year, which provides opportunities for more frequent in person interaction. While BWF’s Investment Committee is responsible for leading the due diligence process and making Independent Portfolio Manager funding decisions, BWF also relies on its compliance team to provide insight into an Independent Portfolio Manager’s ability to manage and administer its compliance programs and overall operations (initial and ongoing). Lastly, quarterly conference calls are conducted by the investment team with all funded Independent Portfolio Managers. In constructing portfolios, BWF aims to be beta, style, and market cap neutral for equity strategies, and to control the impact of duration and curve positioning for fixed-income strategies. This results in the largest contribution of risk from sector allocation and security selection. Initially, BWF assesses and quantifies the client’s return and risk expectations, specific investment guidelines and restrictions, and the desired benchmark for the portfolio. From there, the Firm engages in an iterative process of quantitative and qualitative assessments of proposed Independent Portfolio Manager combinations. Philosophically, the number of managers needed within a given client mandate is driven by an assessment of how many would be necessary to cover the specified investment universe in a prudent (i.e. accounting for emerging manager risk) and value-additive (i.e. eliminating unnecessary redundancy) way. Risk Analysis No investment is free of risk. Current and prospective investors are cautioned that investments in securities involve risk of loss, including the possibility of a complete loss of the amount invested, and that they should be prepared to bear these risks. Based on the types of investments that Westfuller and BWF may recommend, all investors should be aware of certain risk factors, which include, but are not limited to, those discussed in the following paragraphs. Alternative Investment Risk Investments in real estate, private equity, hedge funds, real assets, and venture capital (“alternative investments”) may be illiquid, which may impair the ability of the Client or direct investors to exit such investments in times of adversity. Investments in alternative investments may utilize highly speculative investment techniques, including leverage, highly concentrated portfolios, senior and/or subordinated securities positions, control positions and illiquid investments. Clients that invest in alternative investments will pay Westfuller or BWF’s advisory fees and those of the underlying investment managers, and certain other fees and expenses of underlying investment funds in which the Client or direct investor invests. Investors in alternative investments may also pay carried interest, performance or incentive allocations to an underlying manager or sponsor of an underlying investment fund in which they invest, all of which contribute to the overall cost of the investment The performance of alternative investments can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have 16  concentrated positions and investments that may carry higher risks. Westfuller and BWF believe that Clients should only have a portion of their assets in these illiquid investments. Artificial Intelligence (AI) Risk Recent technological advances in generative AI and machine learning technology (collectively, “Artificial Intelligence (AI)”) pose risks to Westfuller, BWF, and their clients. AI is a branch of computer science focused on creating systems capable of performing tasks that typically require human intelligence; this includes, among other things, methods for analyzing, modeling, and understanding language, as well as developing algorithms that can learn to perform various tasks. Westfuller and WBF do not use AI for portfolio management or investing purposes. Still, Westfuller, BWF, and the companies in which clients invest could be further exposed to the risks of AI if third-party service providers or any counterparties, whether or not known to Westfuller and BWF, also use AI in their business activities. Westfuller and BWF, cannot control third-party operations, product development, or service provision. AI is generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that AI utilizes to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error — potentially materially so — and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of AI. To the extent that Westfuller and BWF, or the companies in which Clients invest are exposed to the risks of AI, any such inaccuracies or errors could have adverse impacts on a Client’s performance. Counterparty Risk The institutions (such as banks) and prime brokers with which Westfuller and BWF, does business, or to which securities have been entrusted for custodial purposes, could encounter financial difficulties. This could impair the operational capabilities or the capital position of Westfuller and BWF or create unanticipated trading risks. Debt/Fixed Income Securities Risk The value of an investment in a fixed income strategy changes in response to changes in interest rates. An increase in interest rates typically causes a fall in the value of the debt securities in which the strategy invests. The longer the duration of a debt security, the more its value typically falls in response to an increase in interest rates. The value of an investment in a fixed-income strategy typically changes in response to the credit ratings of the strategy’s portfolio of debt securities. The degree of risk for a particular security may be reflected in its credit rating. Typically, investment risk and price volatility increase as a security’s credit rating declines. The financial condition of an issuer of a debt security held by a strategy can cause it to default or become unable to pay interest or principal due on the security. A strategy cannot collect interest and principal payments on a debt security if the issuer defaults. Emerging Investment Manager Risk Emerging managers may not have access to the same data and systems as larger, more established firms. BWF seeks to mitigate the challenges of investing in emerging managers by utilizing a process-driven approach to identifying quality managers in inefficient asset classes early in their growth, as well as understanding and evaluating the specific risks associated with each firm from both an investment and non-investment (compliance and operations) perspective. 17  ETF Risk The risk of owning an ETF generally reflects the risks of owning the underlying securities of the ETF. The Client will bear additional expenses based on your pro rata share of the ETF’s operating expenses. The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Equity Market Risk Overall stock market risks may affect the value of the investments in equity strategies causing the market value of securities to move up and down, sometimes rapidly and unpredictably. These fluctuations may cause a security to be worth less than the price that was originally paid, or less than it was worth at an earlier time. Market risk may affect a single issuer, an industry, or a sector of the economy or the market as a whole. Equity markets are affected by factors such as economic growth and market conditions, interest rates, currency exchange rates and political events in the U.S. and abroad, as well as the expectations market participants have of those factors. Inflation Risk Inflation, deflation and rapid fluctuations in inflation rates have had in the past, and may in the future have, negative effects on economies and financial markets. For example, wages and prices of inputs increase during periods of inflation, which can negatively impact rates of returns on investments. Interest Rate Risk The value of investments may go down when interest rates rise. A rise in rates tends to have a greater impact on the prices of longer term or duration debt securities. Similarly, a rise in interest rates may also have a greater negative impact on the value of equity securities whose issuers expect earnings further out in the future. When interest rates fall, the issuers of debt obligations may prepay principal more quickly than expected, and a Client account may be required to reinvest the proceeds at a lower interest rate. When interest rates rise, debt obligations may be repaid more slowly than expected, and the value of the Client account’s holdings may fall sharply. A Client may lose money if short-term or long-term interest rates rise sharply or in a manner not anticipated. Management Risk There is no guarantee that individual securities will perform as anticipated. Judgments for an individual security or a particular asset class regarding the attractiveness, value and potential appreciation may be inaccurate. If investment strategies do not produce the expected results, a Client’s investment could be diminished or even lost. Mutual Fund Risks The risk of owning a mutual fund generally reflects the risks of owning the underlying securities the mutual fund holds. The Client will bear additional expenses based on the pro rata share of the mutual fund’s operating expenses. The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value 18  of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Certain Mutual Funds also invest in the equity securities of private operating or growth companies or real estate and are structured as a closed-end interval fund. Similar to a private fund, these mutual funds can also bear a high degree of risk, be leveraged, speculative and volatile, and an investor could lose all or a substantial amount of their investment. Interval funds are less liquid than a standard mutual fund, as they usually limit shareholders to quarterly or other specific repurchase window and may also be limited as to the dollar amount that can be liquidated in each window. Natural & Unavoidable Events Risk Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led, and may in the future lead, to increased short- term market volatility and may have adverse long-term and wide-spread effects on the world economies and markets generally. Clients may have exposure to countries and markets impacted by such events, which could result in material losses. Private Placement Risk Privately issued securities are restricted securities that are not publicly traded. Accordingly, the market liquidity for specific privately issued securities may vary. Delay or difficulty in selling such securities may result in a loss in the investment. Real Assets Risk Investments in the energy, materials, industrials, utilities and real estate sectors involve a high degree of risk, including significant financial, operating, and competitive risks. Investments in REITs and MLPs can be exposed to adverse macroeconomic conditions, such as changes and volatility in commodity prices, a rise in interest rates or a downturn in the economy in which the asset is located, elevating the risk of loss. Third-Party Investment Managers BWF does not control the investment decisions of third-party investment managers in a Client’s broader portfolio. Investing in multiple investment products could cause a Client to hold opposite positions in an investment. This could decrease or eliminate the possibility of positive returns from such investments. Item 9 – Disciplinary Information Westfuller is required to disclose all material facts regarding legal or disciplinary events that would be material to our Client’s or prospective client’s evaluation of Westfuller or the integrity of our management or investment advisor representatives. Generally, such disclosure is required if the firm or its management persons have been involved in certain criminal, civil or administrative proceedings within the last ten years. 19  Westfuller and its employees have never been the subject of an investment-related regulatory or legal complaint. Item 10 – Other Financial Industry Activities and Affiliations Westfuller is not engaged in any other financial industry activities other than offering investment and financial advisory advice. Westfuller does not sell products or services other than investment and financial advisory services to its Clients. A minority ownership in Westfuller is owned by Daryl S. Hersch, who also holds interest in Celadon Financial Group, LLC, a registered broker dealer and member of FINRA. Westfuller conducts no investment advisory services or business activities with Celadon Financial Group, LLC. As noted in Item 4, Westfuller may implement all or a portion of a Client’s investment portfolio with one or more Independent Portfolio Managers. Westfuller does not receive any compensation nor does this present a material conflict of interest. Westfuller will only earn its investment advisory fee as described in Item 5.A. Westfuller has a joint venture with Bivium Capital Partners, LLC for managing OCIO clients. Westfuller and Bivium will jointly contract with the client and manage assets. Other than splitting client fees, Westfuller and Bivium are not financially connected nor are they subsidiaries of each other. Westfuller and Bivium sign joint-advisory agreements with each client, which include fee rate and how fees are collected. All clients, including OCIO clients, are billed in arrears. OCIO clients will either pay Westfuller or Bivium directly depending on preference. Dual Employee Westfuller employs a Chief Operating Officer (“COO”), who is also an employee of Bivium. The COO performs work on a 50% Bivium / 50% Westfuller workweek basis. In consideration of the services provided by the COO to Westfuller and Bivium, the firms have agreed to evenly split all expenses relating to the COO, including base salary, bonus and overhead expenses. In addition, Westfuller and Bivium have a Facilities Agreement in which each firm allows the other firm’s employees to use its office space, as necessary. Item 11 – Code of Ethics Westfuller has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its Clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition against disseminating rumors or other false information, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Westfuller must acknowledge the terms of the Code of Ethics annually, or as amended. 20  We anticipate that, in appropriate circumstances, consistent with Clients’ investment objectives, we will recommend to investment advisory clients or prospective clients the purchase or sale of securities in which we, our affiliates and/or Clients, directly or indirectly, may have a position of interest. A conflict of interest arises when the securities Westfuller’s employees buy or sell are the same securities Westfuller is buying of selling or holding for our Clients. Our employees and other persons associated with Westfuller are required to follow our Code of Ethics. Subject to satisfying this policy and applicable laws, officers, members and employees of Westfuller and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for our Clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. It is the expressed policy of Westfuller that no person employed by Westfuller may purchase or sell any security prior to a transaction(s) being implemented for an advisory Client’s account, and therefore, preventing such employees from benefiting from transactions placed on behalf of an advisory Client’s accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Westfuller’s Clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Westfuller and its Clients. You can request a copy of our Code of Ethics by contacting the Chief Administrative Officer at (212) 219-6198 or advisors@westfulleradvisors.com. Other Potential Conflicts of Interest Principal Transactions “Principal transactions” are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys any security from or sells any security to any client. Westfuller does not effect such principal transactions. Cross Trading “Cross Trades” reduce transaction costs, increase execution efficiency, and capitalize on timing opportunities, by selling a security for one advisory client to another advisory client, without interposing a broker-dealer. Cross trades, however, may present an inherent conflict of interest because an adviser and/or its affiliates represent the interest of the buyer and seller in the same transaction. As a result, clients involved in a cross-trade bear the risk that the price obtained from a cross-trade may be less favorable than if the trade had been executed in the open market. Westfuller prohibits cross trades. 21  Item 12 – Brokerage Practices Westfuller will supervise and direct the investments in Westfuller Client accounts subject to such limitations as the Client imposes in writing, if any. Westfuller, after prior consultation with the Client, will (i) direct the purchase, sale, exchange, conversion, and otherwise trade in stocks, bonds and other securities including money market instruments, (ii) direct the amount of securities purchased, sold, exchanged, and otherwise traded; and (iii) place orders for the execution of such securities transactions. Client assets are held in separately managed accounts by a clearing broker-dealer that meets the criteria for a “qualified custodian” under the Investment Advisors Act of 1940 and provides custody, securities execution, clearance and administrative services. Fidelity and Pershing are the preferred custodians for accounts introduced by Westfuller and managed either by Westfuller or a third-party portfolio manager recommended by Westfuller. Fidelity and Pershing provide Westfuller with access to their institutional trading and custody services, which are typically not available to retail investors. These services generally are available to independent investment advisors. Prospective clients are hereby advised that lower brokerage fees for comparable services may be available from other sources. For BWF Clients, both investment and brokerage discretion are delegated to the Independent Portfolio Managers selected to manage the Client’s account. The investment management agreement with each Independent Portfolio Manager contains certain requirements regarding the manager's brokerage practices. Included in these requirements are that Independent Portfolio Managers maintain comprehensive trading policies and procedures that place Clients’ interests first, prohibit unfair trading practices, detail their broker selection process, manage counterparty risk, and seek to disclose and avoid conflicts of interests or resolve such conflicts in the Client’s favor. BWF does not directly trade securities for its clients; the Independent Portfolio Managers have been delegated this discretion. When orders are generated, the decision on which accounts should participate, and in what amount, is based on the type of security or other asset, the present or desired structure of the various portfolios and the nature of the account’s goals. Other factors include risk tolerance, tax status, permitted investment techniques and, for fixed-income accounts, the size of the account and other practical considerations. As a result, we may have different price limits for buying or selling a security in different accounts. Portfolio information systems, portfolio reports and quality control reports permit us to consider these factors as appropriate. When our investment professionals decide to sell a security regardless of tax considerations, both taxable and tax-deferred accounts are eligible for sale simultaneously. In situations where capital gains influence the sale, securities in the tax-deferred accounts may be placed for sale first, as additional time is needed to consider the tax implications for each taxable account. Conversely, when capital losses influence the sale, Westfuller may prioritize taxable Clients first, as the loss has a specific impact in a given year. In any event, the prioritization process is applied consistently over time. Best Execution 22  To the extent consistent with our obligation to obtain “best execution,” Westfuller will arrange for the execution of Westfuller Client securities transactions through Fidelity and Pershing. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the broker-dealer’s services, execution capability, commission rates, and responsiveness. We are cognizant of our duty to obtain best execution and have implemented policies and procedures reasonably designed in such pursuit. As a general matter, we consider it appropriate to utilize Fidelity’s and Pershing’s execution services for the purchase and sale of securities for our advisory clients. BWF requires that Independent Portfolio Managers seek to obtain best execution for BWF Clients. Best execution is not necessarily the lowest price per share, but an evaluation of the total value of the transaction. Some of the factors considered when seeking best execution of Clients' orders include the opportunity to get a better price than what is currently quoted, the speed of execution, and the likelihood that the trade will be executed and settled promptly. Aggregation of Orders Transactions for each Client account generally will be executed independently unless we decide to purchase or sell the same securities for several Clients at approximately the same time. Westfuller may (but is not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our Clients’ differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our Clients in proportion to the purchase and sale orders placed for each client account on any given day. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order. Westfuller shall not receive any additional compensation or remuneration as a result of the aggregation. Allocation of Investment Opportunities and Orders Westfuller has adopted the following policies and procedures related to the fair allocation of investment opportunities. These policies are designed to help ensure that each Client receives fair and equitable treatment in the investment process. • Investment ideas are equally disseminated among all appropriate investment professionals responsible for selecting investments. • Transactions in the same security on behalf of more than one Client are aggregated, when possible, to facilitate best execution. This results in all Clients within the aggregate receiving the same average share price on the transaction. • When orders cannot be aggregated, we employ a trading process that is fair among all • Clients, regardless of size. IPOs are only allocated to accounts when the issuer meets the investment objectives of participating accounts as well as a review process for allocations. • We do not short sell securities. • Accounts in which our employees or affiliates have a beneficial interest, or in which Westfuller has a conflict of interest, do not receive preferential treatment. • All Clients receive fair and equitable treatment for investment opportunities that are too limited to be effectively allocated among all accounts. 23  Research Services/Soft Dollars Fidelity and Pershing offer other services intended to help advisors manage and further develop their business enterprise. These services can include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession, and (iii) third- party investment research on their website. Westfuller does not accept research or other products or services from Fidelity, Pershing, or other broker dealers (other than execution services) in connection with client securities transactions. Further, Westfuller does not have any formal or informal soft-dollar arrangements and does not receive any soft dollar benefits. BWF’s investment management agreement with each Independent Portfolio Manager will contain certain requirements regarding the Independent Portfolio Manager's brokerage practices. If a client allows for the use of soft dollars, BWF will allow Independent Portfolio Managers to use soft dollars for the purchase of research necessary for the management of the account. BWF requires that each Independent Portfolio Manager conducts periodic reviews to ensure that they are in compliance with all soft dollar regulations should the Independent Portfolio Manager choose to engage in soft dollar arrangements. Directed Brokerage With regard to Westfuller client-directed brokerage, Westfuller is required to disclose that we may be unable to negotiate commissions, block or batch client orders or otherwise achieve the benefits described above, including best execution, if you limit our brokerage discretion. Directed brokerage commission rates may be higher than the rates you might pay for transactions in non- directed accounts. Also, Clients that restrict our brokerage discretion may be disadvantaged in obtaining allocations of new issues of securities that we purchase or recommend for purchase in other Clients’ accounts. Moreover, a client request to utilize a non-affiliated broker dealer may not be practicable under our internal policies and procedures or applicable securities industry rules and regulations then in effect so we reserve the right to deny a request to use a non-affiliated broker in specific instances. Should we agree, however, you will have the sole responsibility to negotiate terms and arrangements for the particular account with the non-affiliated broker dealer and we will not seek better execution services or prices or be able to “batch” transactions for execution with orders for other managed accounts held with an account custodian. As a result, you may pay commissions or other transaction costs, greater spreads, or receive less favorable net prices on such transactions than would otherwise be the case. It is our policy that such accounts not participate in allocations of new issues of securities obtained through brokers and dealers other than those designated by the Client. As a general rule, we encourage each Client to compare the possible costs or disadvantages of directed brokerage against the value of the custodial or other services provided by the broker to the Client in exchange for the directed broker designation. Details regarding BWF Client’s directed brokerage arrangements are included in the investment management agreement executed with BWF and will also be included in the investment management agreement executed with each Independent Portfolio Manager, as applicable. In selecting to direct brokerage, Clients have chosen to evaluate independently the broker-dealer(s), accept their offer of a fixed commission schedule, and understand that BWF underlying Independent Portfolio Managers placed in the client’s portfolio do not negotiate commissions. Independent Portfolio Managers will direct brokerage as requested by BWF’s Client(s). Clients should understand that by having directed brokerage arrangements there may be differences in the brokerage commissions in their account and quality of execution versus other BWF clients that do not have directed brokerage arrangements. Clients should also understand that by directing 24  brokerage, they may not necessarily obtain commission rates and execution as favorable as those that could be obtained if Independent Portfolio Managers were able to place transactions with other broker-dealers. Item 13 – Review of Accounts The Westfuller Investment Committee is responsible for all account reviews. The Westfller Investment Committee conducts account reviews as a regular course of action during monthly meetings. Westfuller review Client accounts no less than semi-annually but may do so on a more frequent schedule if requested by the Client. Subjects that are reviewed include, but are not limited to, current market activity, economic outlooks, review and analysis of individual issues, portfolio composition, trading activity and performance comparisons. Unique circumstances such as significant market fluctuations, changes in the Client’s financial circumstances, or issues with an Independent Portfolio Manager may trigger more frequent reviews. Westfuller provides Clients with periodic portfolio reports (usually on a quarterly basis) displaying information regarding asset allocation, balances and a statistical presentation of the performance of their account(s), based on such information as is reflected on our records and ongoing comparisons of such performance with selected industry indices. Additionally, the Client will receive monthly or quarterly reports provided by the account custodian and/or Independent Portfolio Manager, if applicable. BWF conducts ongoing evaluations of Independent Portfolio Managers’ daily transactions in a client’s portfolio and portfolio holdings through our portfolio accounting system and market data. The purpose of this review is to ensure that investments are within client investment guidelines and restrictions. BWF holds quarterly conference calls with Independent Portfolio Managers regarding the portfolios they manage for BWF Clients. The purpose of these calls is to give context to the decisions made by the Independent Portfolio Manager and aid BWF’s assessment of a Client’s overall portfolio. BWF also conducts monthly, quarterly, and annual performance and attribution analysis of each Client’s account. The purpose of this review is to ensure that each client’s account is performing as expected in absolute and relative terms and within the investment style and guidelines set for the portfolio. Additionally, BWF conducts in-person reviews of Independent Portfolio Manager’s as deemed necessary by BWF. The purpose of these reviews is to discuss client performance, any changes in clients’ investment guidelines and/or objectives, and any BWF or Independent Portfolio Manager updates. Item 14 – Client Referrals and Other Compensation Westfuller has relationships with third party consultants who advise on estate planning, insurance, tax, and pension and other corporate benefit matters. Westfuller does not receive compensation from such third-party consultants. 25  At this time neither Westfuller nor BWF compensate solicitors for a Client referral. If Westfuller or BWF were to enter into a solicitation arrangement for Client referrals, policies would be implemented to follow applicable rules. Item 15 – Custody As of the date of this Client Brochure, Fidelity and Pershing are Westfuller’s preferred custodians to provide securities execution, clearance and administrative services. Fidelity is a multinational financial services company based in Boston and operates a brokerage firm, manages a large family of mutual funds, provides fund distribution and investment advice, retirement services, wealth management, securities execution and clearance, and life insurance. Pershing, a subsidiary of The Bank of New York Mellon Corporation (BNY), provides clearing, brokerage custody and other related services. Westfuller will also work with a Client’s preferred, selected qualified custodian at the Client’s request. As a “qualified custodian” under the Investment Advisers Act of 1940, Westfuller custodians provide Clients with a written confirmation of each executed transaction and account statements showing all transactions generally on a monthly basis but no less than quarterly. Westfuller also provides Clients with periodic reports that will include an inventory of account holdings and account performance relative to generally recognized market indices. We urge Clients to carefully review such reports and compare them to the official custodial records. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies for certain securities. Concerning BWF Clients, neither Westfuller nor Bivium have custody of Client funds or securities. Clients choose their custodians separately. Clients direct the custodian to open accounts in the Client’s name with Bivium named as manager. Clients will receive statements directly from their custodians that should be reviewed carefully and compared to the account reports provided by BWF. Item 16 – Investment Discretion At the beginning of each new Client relationship, Westfuller and the Client discuss and mutually agree upon investment guidelines for the Client’s account. These guidelines outline the objectives for the portfolio, along with any relevant constraints or specific Client preferences that Westfuller will take into consideration while managing the account. Our advice is furnished on a discretionary basis, which means Westfuller has full power to supervise and direct the investments of the account, making and implementing investment decisions, without prior consultation with the Client. When a Client grants investment discretion, Westfuller has authority to determine which securities are bought and sold for the account, the total amount of such purchases and sales, the broker used for the transaction and the commission rates paid. Our authority may be subject to conditions imposed by the client, such as restricting 26  transactions in certain types of securities or directing us to retain positions that have a low tax basis. For BWF Clients, investment discretion is delegated to the Independent Portfolio Managers selected to manage the Client’s account. BWF does not directly trade securities for its Clients; the Independent Portfolio Managers have been delegated this discretion. BWF Clients can set limitations on this authority (e.g., cannot act as agent of the Client; enter into agreements on behalf of the fund, etc.). Prior to acting on any discretionary authority for a Client account, BWF will ensure there is an executed investment management agreement with each Client and with each Independent Portfolio Manager and that the agreement outlines the specifics regarding who has authority to act on behalf of the account, and what acts the authorized person(s) has concerning the Client’s account. Item 17 – Voting Client Securities As a matter of firm policy and practice, Westfuller does not have any authority to and does not vote proxies on behalf of Clients. Westfuller Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in their portfolios. BWF employs providers (“Proxy Providers”) to execute proxy votes on behalf of its Clients. As the ultimate asset owner, the Client maintains full override authority for any vote recommended by these services. Proxy providers create tailored voting policies based on specific criteria outlined in each Client’s Investment Policy Statement. Clients may alternatively select established specialty policies (e.g., SRI Voting Guidelines). Proxy Providers maintain transparency by disclosing any conflicts of interest with securities issuers when making vote recommendations. As an example, in cases where a Proxy Provider identifies a material conflict of interest with a company whose proxies are being considered, they may recuse themselves from the recommendation and voting process and defer to the Client through BWF. BWF conducts regular evaluations of the Proxy Provider operational policies and procedures to ensure: 1) proxies are voted in alignment with the selected policy; and 2) any conflicts of interest are properly identified and addressed. Each Client's investment management agreement with BWF explicitly specifies whether proxy voting responsibilities are delegated or retained by the Client. You can request a copy of Westfuller’s Proxy Voting Policy by contacting the Chief Administrative Officer at (212) 219-6198 or advisors@westfulleradvisors.com. Item 18 – Financial Information Registered investment advisors are required in this Item to provide you with certain financial information or disclosures about their financial condition. Westfuller is not subject to any financial commitment or condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding. Westfuller and BWF do not solicit or require prepayment of advisory fees. 27