Winslow Asset Management Inc

Fees and Compensation

 Winslow’s management fees are calculated as a percentage of assets under management, or in
 some cases, are a fixed fee. The fee schedule is as follows:

                                         1% up to $1 Million
                                    0.75% $1 Million to $5 Million
                                      Negotiable over $5 Million

 Fees are charged quarterly in advance and are based upon market value of the securities under
 supervision. Advisory fees paid are refundable pro-rata in the event the advisory agreement is
 terminated prior to the end of the period for which fees are paid, provided the amount due to the
 client is greater than $25. If a regularly scheduled fee audit calls for a revision, the adjustment will
 be applied in the client’s next scheduled bill. Fee revisions under $5 will be waived. Investment
 advisory contracts with Winslow shall be terminable by the client upon reasonable notice.

 Winslow deducts fees from client accounts, or they may be billed directly, upon request.

 Winslow, in its discretion, can charge a lower investment advisory fee, charge a flat fee or waive
 its fee entirely based on certain criteria (i.e. anticipated future earning capacity, anticipated future
 additional assets, dollar amount of assets to be managed, related accounts, account composition,
 complexity of the engagement, grandfathered fee schedules, courtesy accounts, competition,
 negotiations with clients, etc. As a result of the above, similarly situated clients could pay different
 fees.

 Winslow may purchase mutual funds and/or ETFs in client portfolios. In these circumstances,
 clients may pay two layers of fees, Winslow’s fee set forth in the client agreement, and the internal
 management and/or commission fees of the mutual fund/ETF.

 Clients may be charged custodial fees depending on the bank or brokerage firm they choose to
 hold their assets. Winslow recommends clients use Fidelity Investments or Schwab Institutional,
 which charge no custodial fees and have minimal transaction costs. Please refer to page 10 for
 information on brokerage.

                Performance-Based Fees and Side-by-Side Management

 Winslow does not accept performance-based fees and does not engage in side-by-side
 management.

Winslow Asset Management, Inc.                                                  SEC File Number: 801-41392
ADV Part II: Firm Brochure                                                               December 31, 2025

Types of Clients

 Winslow’s clients include Taft-Hartley Plans, Corporate Profit Sharing Plans, Endowments and
 Foundations and Individuals (both taxable and non-taxable accounts). The minimum value of
 assets for starting an account is $2,000,000 for institutions and $1,000,000 for individuals.
 Minimums may be waived at our discretion.

              Methods of Analysis, Investment Strategies & Risk of Loss

 Winslow invests primarily in publicly traded equity and fixed income securities. We purchase
 small, mid and large cap stocks, as well as corporate, municipal and government bonds. We utilize
 qualitative, quantitative and technical analysis in evaluating securities. We gather information to
 evaluate securities from meetings with corporate management, press releases, conference calls,
 SEC filings, financial newspapers and magazines, industry sources and Wall Street research
 materials. Winslow may purchase mutual funds and/or ETFs for client portfolios in special
 circumstances to provide additional investment exposure.

 Investing in securities involves risk of loss that clients should be prepared to bear. Winslow’s
 strategies include the following risks:
      Market Risk: The prices of securities in which Clients invest may decline in response to
         certain events taking place around the world, including those directly involving the
         companies whose securities are owned by a fund; conditions affecting the general
         economy; overall market changes; local, regional or global political, social or economic
         instability; and currency, interest rate and commodity price fluctuations. Investors should
         have a long-term perspective and be able to tolerate potentially sharp declines in market
         value.
      Equity Risk: Equity securities tend to be more volatile than other investment choices. The
         value of an individual security or mutual fund can be more volatile than the market as a
         whole. This volatility affects the value of the client’s overall portfolio. Small and mid-cap
         companies are subject to additional risks. Smaller companies may experience greater
         volatility, higher failure rates, more limited markets, product lines, financial resources, and
         less management experience than larger companies. Smaller companies may also have a
         lower trading volume, which may disproportionately affect their market price, tending to
         make them fail more in response to selling pressure than is the case with larger companies.
      Fixed Income Risk: The issuer of a fixed income security may not be able to make interest
         and principal payments when due. Generally, the lower the credit rating of a security, the
         greater the risk that the issuer will default on its obligation. If a rating agency gives a debt
         security a lower rating, the value of the debt security will decline because investors will
         demand a higher rate of return. As nominal interest rates rise, the value of fixed income
         securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real
         interest rate and an expected inflation rate.
      Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
         For example, when interest rates rise, yields on existing bonds become less attractive,
         causing their market values to decline.

Winslow Asset Management, Inc.                                                    SEC File Number: 801-41392
ADV Part II: Firm Brochure                                                                 December 31, 2025

        Inflation Risk: When any type of inflation is present, a dollar today will buy more than a
         dollar next year, because purchasing power is eroding at the rate of inflation.
        Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
         Generally, assets are more liquid if many traders are interested in a standardized product.
         For example, Treasury Bills are highly liquid while real estate properties are not.
        Reinvestment Risk: This is the risk that future proceeds from investments may have to be
         reinvested at a potentially lower rate of return (i.e. interest rate). This is also referred to as
         exchange rate risk.
        Management Risk: The advisor’s investment approach may fail to produce the intended
         results. If the advisor’s assumptions regarding the performance of specific asset class or
         fund are not realized in the expected time frame, the overall performance of the Client’s
         portfolio may suffer.
        Foreign Securities Risk: Foreign securities are subject to additional risks not typically
         associated with investment in domestic securities. These risks may include, among others,
         currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social
         and economic instability, currency devaluations and policies that have the effect of limiting
         or restricting foreign investment or the movement of assets), different trading practices,
         less government supervision, less publicly available information, limited trading markets
         and greater volatility. To the extent that underlying funds invest in issuers located in
         emerging markets, the risk may be heightened by political changes, changes in taxation, or
         currency controls that could adversely affect the values of these investments. Emerging
         markets have been more volatile than the markets of developed countries with more mature
         economies.

     Winslow’s Small Cap Core Equity strategy involves similar risks as the All Cap Core strategy,
     but may be more volatile due to higher concentration and less diversification. Winslow’s
...