CLEAN YIELD ASSET MANAGEMENT

Clean Yield Group, Inc. d/b/a Clean Yield Asset Management 16 Beaver Meadow Rd. PO Box 874 Norwich, VT 05055 Ph: (802) 526-2525 Fax: (802) 526-2528 www.cleanyield.com ADV Part 2A This brochure provides information about the qualification and business practices of Clean Yield Asset Management. If you have any questions about the contents of this brochure, please contact us at (802) 526-2525 or by email at dorigen@cleanyield.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 Clean Yield Asset Management is available on the SEC’s website at www.adviserinfo.sec.gov. March 2026  Material Changes Annual Update Clean Yield is providing this information as part of our annual updating amendment, which contains material changes from our last annual update. This section discusses only material changes since the last annual update, which most recently occurred February 2025. Material Changes since the Last Update The Securities and Exchange Commission (SEC) adopted amendments to Part 2 of Form ADV effective October 2010. The newly revised Part 2 consists of Part 2A (the "Brochure") and Part 2B (the "Brochure Supplement"). Each update of the Brochure must now include a summary of all material changes since the last annual update. Since our last annual amendment filing in February 2025, we have had no material changes to our disclosure brochure. Full Brochure Availability The Firm Brochure for Clean Yield is available by contacting us at (802) 526-2525. March 2026 2  Table of Contents Material Changes .................................................................................................................................2 Annual Update............................................................................................................................................. 2 Material Changes since the Last Update ..................................................................................................... 2 Full Brochure Availability ............................................................................................................................. 2 Advisory Business ................................................................................................................................5 Firm Description .......................................................................................................................................... 5 Principal Owners ......................................................................................................................................... 5 Types of Advisory Services .......................................................................................................................... 5 Tailored Relationships ................................................................................................................................. 6 Client Assets ................................................................................................................................................ 6 Fees and Compensation .......................................................................................................................7 Description .................................................................................................................................................. 7 Fee Billing .................................................................................................................................................... 7 Other Fees ................................................................................................................................................... 8 Fees Paid in Advance ................................................................................................................................... 8 Additional Compensation ............................................................................................................................ 8 Performance-Based Fees & Side-by-Side Management ..........................................................................8 Sharing of Capital Gains or Capital Appreciation ......................................................................................... 8 Types of Clients ...................................................................................................................................8 Description .................................................................................................................................................. 8 Account Minimums ..................................................................................................................................... 8 Methods of Analysis, Investment Strategies and Risk of Loss .................................................................9 Methods of Analysis & Investment Strategy ............................................................................................... 9 Risk of Loss ................................................................................................................................................ 10 Disciplinary Information .................................................................................................................... 11 Legal and Disciplinary ................................................................................................................................ 11 Other Financial Industry Activities and Affiliations ............................................................................ 11 Material Relationships or Arrangements with Financial Industry ............................................................. 11 Recommend or Select Other Investment Advisers ................................................................................... 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 12 Code of Ethics ............................................................................................................................................ 12 Recommend Securities with Material Financial Interest ........................................................................... 12 March 2026 3  Brokerage Practices ............................................................................................................................ 13 Selecting Brokerage Firms ......................................................................................................................... 13 Research and Soft Dollars .......................................................................................................................... 13 Brokerage for Client Referrals ................................................................................................................... 14 Directed Brokerage .................................................................................................................................... 14 Order Aggregation ..................................................................................................................................... 14 Review of Accounts ........................................................................................................................... 15 Periodic Reviews ........................................................................................................................................ 15 Review Triggers ......................................................................................................................................... 15 Regular Reports ......................................................................................................................................... 15 Client Referrals and Other Compensation .......................................................................................... 15 Economic Benefits ..................................................................................................................................... 15 Third Party Solicitors.................................................................................................................................. 15 Custody ............................................................................................................................................. 15 Account Statements .................................................................................................................................. 16 Investment Discretion ........................................................................................................................ 16 Discretionary Authority for Trading .......................................................................................................... 16 Limited Power of Attorney ........................................................................................................................ 16 Voting Client Securities ...................................................................................................................... 16 Proxy Voting .............................................................................................................................................. 16 Class Action Settlements ................................................................................................................... 16 Financial Information ......................................................................................................................... 17 Prepayment of Fee .................................................................................................................................... 17 Financial Condition & Bankruptcy ............................................................................................................. 17 March 2026 4  Advisory Business Firm Description Clean Yield Asset Management specializes in socially responsible portfolio management. Clean Yield Group, the parent company of Clean Yield Asset Management, began publishing a socially responsible stock market newsletter in 1985 and established an asset management firm in 1986. Principal Owners Clean Yield is wholly owned by Eric Becker, Elizabeth Glenshaw and Dorigen Hofmann. Types of Advisory Services Clean Yield manages investment portfolios for clients in a highly individualized manner. All portfolios are managed using both financial and environmental/social screens. In their initial paperwork and during their first meeting, clients choose an equity or balanced account, indicate their risk tolerance, and discuss any specific social screens they would like to impose on their account. Client portfolios are primarily composed of publicly traded stocks and/or fixed-income securities, but occasionally include exchange-traded funds, mutual funds, commercial paper, warrants, partnerships investing in real estate, community investment promissory notes, or options contracts. When appropriate for the client, we may also present opportunities to invest in high impact social private equity deals and other alternative investments. Retirement Plan Rollover Recommendations When Clean Yield provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Clean Yield 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. The way Clean Yield makes money create a conflict with your interests, so Clean Yield operates under a special rule that requires Clean Yield to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, Clean Yield must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC: • • • • Meet a professional standard of care when making investment recommendations (e.g., give prudent advice); Never put the financial interests of Clean Yield ahead of you when making recommendations (e.g., give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that Clean Yield gives advice that is in your best interest; Charge no more than is reasonable for the services of Clean Yield; and Give client basic information about conflicts of interest. • • To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Clean Yield, please know that Clean Yield and our investment March 2026 5  adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Clean Yield. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Clean Yield. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA, which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Clean Yield receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Clean Yield and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to you regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Clean Yield or our affiliated personnel. Tailored Relationships All client accounts are managed in a customized manner based on Clean Yield’s model portfolios. Clean Yield portfolio managers buy and sell securities for individual accounts depending on the needs of the client. Clean Yield portfolio managers also use a set of general social and environmental screens that our staff has developed over more than 25 years. The screens are kept up-to-date and apply to the securities that make up the publicly held securities in Clean Yield’s universe. The screens are available to all clients and potential clients. In addition to Clean Yield’s general screens, our portfolio managers attempt to tailor portfolios to the needs and interests of individual clients when possible. Clients may discuss particular social screens for their accounts and request particular asset allocation levels with their portfolio manager. We may not be able to meet all client social-screen requests, particularly if they are excessively restrictive or pose too much risk. In that case, we discuss limiting the additional screen or finding other solutions that are acceptable to the client. Client Assets Clean Yield manages all fee-based client accounts on a discretionary basis. As of December 31, 2025, Clean Yield’s total discretionary assets under management totaled $571,222,836. March 2026 6  Fees and Compensation Description Clients who contracted with Clean Yield for asset management services after June 30, 2010, pay fees based on the appraised market value of the client's account according to the following schedule: Market Value of Account Balance Annual Rate First $2,000,000 Next $3,000,000 Next $5,000,000 Above 1.00% 0.75% 0.60% Negotiated Clients who contracted with Clean Yield for asset management services prior to June 30, 2010 pay fees based on the appraised market value of the client’s account according to the following schedule: Equity Accounts Market Value of Account Balance Annual Rate First $500,000 Next $500,000 Next $2,000,000 Next$2,000,000 Above 1.25% 1.00% 0.80% 0.50% Negotiated Balanced Accounts Market Value of Account Balance Annual Rate First $500,000 Next $500,000 Next $2,000,000 Next$2,000,000 Above 1.00% 0.80% 0.60% 0.50% Negotiated These rates may be negotiated for lower, but not higher, fees. Family members of Clean Yield employees typically pay lower or no fees. Fees are paid quarterly in advance of service based on the account value at the end of the previous quarter. For example, the fee for January – March is calculated using the value of the account on December 31. This fee covers all portfolio management services provided to clients. We do not charge any other fees for additional services. Fee Billing Clients are sent a copy of their quarterly management fee bill with their quarterly reports every quarter. When clients set up their account to be managed by Clean Yield, they usually sign a limited power of attorney, allowing Clean Yield to directly withdraw cash from their brokerage account to pay Clean March 2026 7  Yield’s quarterly fees. In a few cases, clients pay their fees from an account that is not managed by Clean Yield. Other Fees In very limited instances, when a client does not want his or her account actively invested, but instead held in cash for a period of time, Clean Yield will charge a flat fee of $500/year. Decisions on when to re- invest the account are made by the client, and at that time, the client will be charged a percentage of assets under management. Fees Paid in Advance All fees are paid quarterly, in advance, based on the appraised market value of the client’s account at the end of the prior quarter. A client can cancel the contract with Clean Yield within five days of signing the contract without incurring any penalty or fee. A client, or Clean Yield, can cancel the investment supervisory service contract with a written or email notification, allowing ten days before taking effect. The client will be refunded any fees on a pro-rata basis. Additional Compensation Clean Yield does not charge clients fees other than their quarterly management fees. On occasion, Clean Yield may provide consulting services to social businesses or other groups for a fee. These services are intended to improve the socially responsible investment landscape and eventually provide more investing opportunities for clients. Performance-Based Fees & Side-by-Side Management Sharing of Capital Gains or Capital Appreciation Clean Yield does not charge any performance fees. Clean Yield does not share in capital gains or capital appreciation, except insofar as the account grows, Clean Yield’s fees also grow. Clean Yield only charges a tiered management fee based on an account’s market value at the end of the preceding quarter or, very occasionally, a flat or minimum fee, when appropriate, as discussed above under “Other Fees”. Types of Clients Description Applicant provides investment supervisory services to clients, including individuals, institutions, trusts, and foundations. Account Minimums Clean Yield imposes a minimum initial account size of one million dollars ($1,000,000). This minimum may be waived at the sole discretion of an officer. Accounts may also be taken below the minimum but may be charged a minimum annual management fee of $7,500. The accounts of family members of clients may be accepted at amounts less than $1,000,000. March 2026 8  Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis & Investment Strategy Clean Yield portfolio managers look at financial, social, governance, and environmental criteria when analyzing stocks for inclusion in client portfolios. Financial Clean Yield’s investment strategy emphasizes quality stocks, with a focus on valuation. We seek to invest in high quality, undervalued stocks that we anticipate will outperform the market over the long term. We may include growth stocks that are trading at reasonable valuations relative to their historic averages. Clean Yield pays close attention to the balance sheet and related financial statements, regardless of whether we are interested in a company for its growth or value characteristics. Our investment philosophy is based on a long-term perspective. All stocks considered for inclusion must, at a minimum, be consistent with the social and environmental screens, described below, and undergo assessment of social and environmental profiles, including product and service attributes. Our Investment Committee meets weekly, and includes all our investment analysts and portfolio managers. During these sessions, the economy, the investment markets, and individual securities (including the particular environmental or social merits of individual securities) are discussed at length. Changes in investment strategy, as well as additions and deletions to the approved security universe, are also discussed in these meetings. For fixed income, Clean Yield uses a strategy of laddering short, mid, and occasionally long-term bonds in client portfolios. Usually, these bonds will be Federal Agency bonds, but also may include CDs, municipal bonds, corporate bonds, fixed income exchange traded funds or mutual funds, and preferred stocks. In addition, Clean Yield invests in community investment promissory notes as a form of fixed income. When appropriate for a client, and only with their specific consent, Clean Yield may invest in an options strategy to protect client portfolios from a substantial market downturn. This is done by purchasing longer term “put” options. If a client would like to employ this strategy, Clean Yield will provide additional disclosures and explanation of how “puts” work. Social and Environmental Screens Clean Yield aims to screen out companies materially involved in the following areas: Fossil fuel extraction, exploration, production, and refining • • Production of electric power generated primarily by coal, oil, or nuclear fuels • Hydraulic fracturing (fracking) of oil and gas shale • Deriving more than 5% of revenues from conventional or nuclear weapons and their support systems • Deriving any portion of their revenues from chemical or biological weapons, cluster bombs and landmines March 2026 9  Fur production Factory farming • Deriving any portion of revenues from the manufacture or sale of firearms for civilian use • Animal testing, beyond legal requirements* • • Abuse of animals for entertainment • • Manufacture of gaming equipment or operation of casinos • Tobacco, tobacco products, and e-cigarettes • Use of genetically modified organisms (GMOs) in seed production • Business activities that provide strategic economic support to repressive regimes (e.g., Burma and Sudan) • We avoid investing in companies and sectors that benefit from or contribute to racism. *Corporate disclosure on animal testing tends to be very poor. As such, we will adhere to this screen as faithfully as possible. Additional social screens are determined during an initial consultation with the client. With regard to both social/environmental and financial screens, Clean Yield uses third party research, databases, websites, journals, and trade and industry publications. In addition, we may speak with the management of a company whose stock we are interested in buying or selling, and we may participate in conference calls with the company. From time to time, Clean Yield may approve funds for investment. When evaluating the environmental and social credentials of fund for investment, Clean Yield focuses on the mandate of the fund and does not screen underlying fund investments against Clean Yield’s social and environmental screens. Instead, we trust the manager with security selection that is aligned with the fund mandate. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Clean Yield feels it is important that our clients understand the nature of investing in equity securities. Although stocks in general have increased in value over the long term, they can rise or fall over the short term. Clients’ principal is not guaranteed, and if the securities in client accounts decline in value, the client will suffer losses. The value of client portfolios may fluctuate over a wide range, depending in part on the movement of the stock market and the economy. We believe, however, that prudent investment in stocks provides the best opportunity to increase capital over the long term. Clients investing with Clean Yield face a variety of risks: • General market risk. This is the risk that the value of any security may fluctuate, sometimes unpredictably and rapidly. This will cause clients to lose some or all of the value of the security. • Small and medium sized company risk. Clean Yield portfolios often hold securities from small and medium sized companies. These companies may be more vulnerable to adverse business or economic conditions than larger companies. Thus, the market value of these securities may be more volatile. In addition, these securities are often traded at low volumes (i.e., there are not many buyers or sellers), which can result in high volatility and/or the inability to sell the security immediately. March 2026 10  • Alternative investment risk. When it is appropriate for a client’s portfolio, and only with the client’s consent, Clean Yield occasionally purchases alternative investments. These investments can take a variety of forms and are structured in different ways. Examples include private convertible debt in an organic seed company, private preferred stock in an organic dairy company, timber fund shares, etc. Before purchasing these investments, clients review a memorandum written by the company explaining the deal and the associated risks. The risks often include illiquidity (the investment is not easy to sell or redeem), small business risk, below market-rate return, and the myriad risks that attend a very young company. Often these investments are intended to give below market-rate financial return compared to the level of risk involved. In these cases, part of the return is considered social return and the investor’s money is purposely being used to provide affordable financing for a business that may be in a low profit margin industry. These investments and associated risks are always thoroughly discussed with the client and are only purchased with the client’s permission. Disciplinary Information Legal and Disciplinary Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Clean Yield. Clean Yield has never experienced any disciplinary event or lawsuit of any kind. Other Financial Industry Activities and Affiliations Clean Yield and its employees are solely investment advisors. Neither the firm, nor any employees, are involved in or affiliated with other financial industry activities. Specifically, Clean Yield is not a broker dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or any associated entity. Material Relationships or Arrangements with Financial Industry Clean Yield does not have any relationships with other companies or service providers in the financial industry. Recommend or Select Other Investment Advisers When a prospective client does not meet Clean Yield’s minimums or does not fit Clean Yield’s client profile, we may suggest other investment advisors or mutual funds that may be of interest. Clean Yield does not get any financial benefit from these suggestions, and it is solely the prospective client’s decision whether to pursue these suggestions. March 2026 11  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Clean Yield has a Code of Ethics, encompassed in its compliance policies and procedures, that governs all personal securities transactions and all employee responsibilities. The Code of Ethics is based on the principle that Clean Yield, and each of its employees, owe a fiduciary duty to its clients and a duty to comply with federal and state securities laws. The Code of Ethics is available to all clients and prospective clients upon request. Recommend Securities with Material Financial Interest Clean Yield employees do not recommend or place trades in securities in which they have a material financial interest. Invest in Same Securities Recommended to Clients Clean Yield employees are permitted to own positions in the same securities as clients. Employees must strictly follow Clean Yield’s personal trading rules, outlined below. Clean Yield employees are generally not allowed to own positions in private investments that we may recommend and purchase for clients, except under specific circumstances that will be disclosed to clients and must be approved by Clean Yield’s compliance officer. Personal Trading Policies Clean Yield has compliance policies and procedures, including a Code of Ethics, that govern all personal trading activities. All Clean Yield employees are prohibited from using non-public information regarding portfolio holdings, portfolio changes, or client transactions for their personal benefit. Specifically, employees are prohibited from using advance knowledge of client trades to trade ahead of, or otherwise benefit from, such knowledge. In order to avoid conflicts of interest and ensure that employees do not trade ahead or benefit from such knowledge, all client trades must be completed prior to personal trades in any one trading day. Once client trades are made, they are considered public information. These same rules also apply to clients who are immediate family members (e.g. spouse or minor children) of the officers and employees, where the employee is trading for the family member. In a few cases, Clean Yield’s portfolio managers manage paying accounts for non-officer or non-portfolio manager employees and/or their immediate family members. These clients are treated no differently than other clients with similar financial and social goals. Likewise, the non-immediate family members of officers (e.g. siblings, nephews, uncles, and aunts) are treated the same as regular clients with similar financial and social goals, whether or not they are charged a fee. March 2026 12  Brokerage Practices Selecting Brokerage Firms Clean Yield selects a small number of brokers and suggests these brokers to clients when requested. The factors considered in Clean Yield’s selection of brokers are: reasonableness of commissions; trade execution; client accessibility to the account; special client needs (e.g., if the client spends significant time overseas). • • quality of account management and bookkeeping; • • • online services available to the client; and • Commission reasonableness is determined by occasionally comparing commission rates to those of retail brokers and discount brokers. Account management and bookkeeping quality is determined by the timeliness of reports and advices, and the error rate in compiling reports and advices. Trade execution is determined by occasionally looking at the trade price obtained and comparing that price to the price at other brokers and the market. Client accessibility and other services are determined by client feedback on the ease of working with the broker and ease of viewing accounts online. Clients should not anticipate paying materially higher rates for the same level of service available from other brokers. All else being equal, Clean Yield may recommend that clients establish brokerage account with the Schwab Institutional division of Charles Schwab & Co. (“Schwab”), a registered discount broker-dealer, to maintain custody of clients' assets and to effect trades for their accounts. Clean Yield is independently owned and operated and is not affiliated with Schwab. Schwab provides Clean Yield with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as total of at least $10 million of the advisor's clients' assets is maintained in accounts at Schwab Institutional. It is not otherwise contingent upon the advisor committing to Schwab any specific amount of business (assets in custody or trading). Schwab's services include brokerage, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a higher minimum initial investment. For Clean Yield’s client accounts maintained at Schwab, Schwab does not charge separately for custody but is compensated by account holders through commissions or other transaction-related fees. Research and Soft Dollars Clean Yield does not have any soft dollar contracts or arrangements with brokerage firms. Schwab and other brokers, however, do make products and services available to Clean Yield that benefit us but may not directly benefit clients. These products and services assist us in managing and administering clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all, or a substantial number, of Clean Yield clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technologies that: • provide access to client account data (e.g. duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple client accounts facilitate payment of fees from clients’ accounts • • provide pricing and other market data • March 2026 13  • assist with back-office functions, recordkeeping, and client reporting. In addition, Schwab also offers some services that generally only benefit Clean Yield; services intended to help the company manage and further develop its business enterprise. These services include: consulting on technology, compliance, legal, and business needs • educational conferences and events • • publications and conferences on practice management and business succession • access to employee benefits providers, human capital consultants, and insurance providers Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Clean Yield. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of Clean Yield personnel. While as a fiduciary, Clean Yield always has a duty to act in its clients' best interests, our recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefit to Clean Yield of the availability of some of the products and services and not solely on the nature, cost, or quality of custody and brokerage services provided by Schwab. This creates a conflict of interest. Although we believe that these products and services on a whole improve the level of service that Clean Yield can provide to clients, the services and products are not necessarily proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits. Brokerage for Client Referrals Clean Yield does not generally suggest or direct clients to any particular broker-dealer because that broker-dealer refers clients to us. Occasionally, a broker-dealer who already has custody of a client’s account will refer the client to us for advisory services. In this case, if the client wishes, we will continue to use that broker-dealer for that client. This presents a conflict of interest since the broker-dealer may not offer the most favorable execution, may charge higher fees, and thus cause the client to pay more money. Clean Yield discloses this fact to the client and will facilitate the client changing brokers if requested. However, Clean Yield does not use any broker with the intent of creating an incentive for that broker to refer new clients to Clean Yield. Directed Brokerage A client may ask us to use the services of a particular broker. Clean Yield’s staff is not empowered to negotiate commission rates with brokers that have been suggested by the client and may not be able to achieve the most favorable execution for the client’s transactions. Specifically, the client may end up paying higher brokerage commissions and may receive less favorable prices, thus costing the client more money. In cases where the broker is not a discount broker, we may suggest to the client and to the broker that the client should reasonably expect a discount from full retail commission rates. Order Aggregation On occasion, when offered by the broker-dealer, and when trades happen to be placed at the same time, Clean Yield portfolio managers may aggregate trade orders in the same stock. This allows a larger purchase and may result in a better overall price. When orders are aggregated for the trade, they are immediately allocated to individual client accounts per the manager’s discretion. Far more often, however, because of Clean Yield’s manner of reviewing and managing accounts individually, trades are made at different times and on different days; this prevents trades from being aggregated. It is possible March 2026 14  that clients will receive a slightly less favorable stock price because multiple client trades have not been aggregated. Review of Accounts Periodic Reviews Clean Yield’s portfolio managers discuss all accounts under management on a regular basis. No reviewer manages more than one hundred accounts. Accounts are managed and under continuous review for appropriateness of the individual investments as well as the proper investment strategy. Account reviewers are: Eric Becker, Chief Investment Officer; Elizabeth Glenshaw, Managing Partner; Dorigen Hofmann, Portfolio Manager and Chief Compliance Officer; Kofi Kodua, Managing Director of Investment Research; and Elizabeth Levy, Managing Director of Investment Research. . Review Triggers Accounts are regularly reviewed by portfolio managers on an ongoing basis. Various events may trigger additional review including economic conditions, client needs or requests, high cash levels, etc. Regular Reports Clean Yield sends or emails formal reviews of client accounts quarterly. These reviews include an appraisal with the cost and market value of each holding, unrealized gains and losses, realized gains and losses, a performance report of the account for the prior three months (or longer, if requested), and a copy of the bill. A cover letter discusses the investment climate. The year-end report includes the above, as well as reports showing purchase and sales, income and expenses, and various graphs. Clients also receive a quarterly newsletter discussing social investing and companies in which Clean Yield invests. Client Referrals and Other Compensation Economic Benefits Clean Yield does not receive any economic benefit from client referrals to or from third parties. Third Party Solicitors Clean Yield does not use third party solicitors and does not receive any compensation from them. Custody Clean Yield is generally given the authority from clients to deduct advisory fees directly from client accounts. Such authority is deemed to be custody as defined by the SEC. Clean Yield is also deemed to have custody of client funds and securities when Clean Yield has standing authority (also known as a standing letter of authorization or “SLOA”) to move money from a client’s account to a third-party account. Clean Yield has established procedures to ensure all client funds and securities are held at a Financial Institution, as the qualified custodian, in a separate account for each client under that client's name. Clients or an independent representative of the client (other than an affiliated person of Clean Yield) are also March 2026 15  notified, in writing of the qualified custodian's name, address and the manner in which the funds or securities are maintained, promptly when the account is opened and following any changes. Account Statements Account statements are delivered directly from the qualified custodian to each client, or the client's independent representative (other than an affiliated person of Clean Yield), at least quarterly. In addition, clients will receive quarterly reports from Clean Yield as discussed above under “Regular Reports”. Clients are strongly urged to compare any statements or reports from Clean Yield against the account statements received directly from the qualified custodian. Investment Discretion Discretionary Authority for Trading All accounts are managed on a discretionary basis, meaning that Clean Yield does not need a client's permission before buying or selling securities. When a client first hires Clean Yield, we obtain a limited power of attorney, discussed below, over the client's account for the purpose of trading and withdrawal of fees. Clients are encouraged to discuss social screens, tax limitations, and any other account concerns at their initial meeting and at any other time they choose. Limited Power of Attorney When establishing an account, Clean Yield has new clients sign a limited power of attorney that allows us to place trades in client accounts and remove cash to pay for our management fees. When a client arranges for Clean Yield to be the manager of her or his brokerage account, the custodian also usually has the client sign an additional form giving Clean Yield a limited power of attorney for trading and fee withdrawal. Clean Yield does not have custody over any client accounts and does not have any other authority to withdraw or move funds or securities. Voting Client Securities Proxy Voting Beginning in 2014, clients can assign Clean Yield proxy voting authority. Clean Yield has engaged a third- party proxy voting service firm to execute client votes in accordance with Clean Yield’s proxy voting guidelines. These guidelines are prepared to comply with a variety of socially responsible principles and are always available for review. Clean Yield will report how all proxy votes have been cast annually on its website. Class Action Settlements Clean Yield has contracted with a third party to handle clients’ participation in class action lawsuits and settlements. The vendor collects holdings data from us and files on behalf of the client as appropriate. When payouts occur, the vendor receives 20% of the payout and clients receive the remainder as a check to their brokerage account. Clean Yield receives no compensation for class action settlements. If March 2026 16  a client does not want to participate in this service, she or he may request to not have her or his holdings data included in the form of an opt-out notice. Financial Information Prepayment of Fee Clean Yield bills management fees quarterly, in advance, based on the market value of the account on the last day of the preceding quarter. Thus, clients pay fees up to three months in advance. A balance sheet is not required to be provided because we do not require prepayment of fees of more than $1,200 and six or more months in advance. If a client has pre-paid a fee and leaves Clean Yield prior to the end of the quarter, we will reimburse the client for the remainder of the quarter on a pro-rata basis. Financial Condition & Bankruptcy Registered investment advisers are required to provide certain financial information or disclosures about their financial condition. Clean Yield has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. March 2026 17