NEW ENGLAND RESEARCH & MANAGEMENT, INC.

New England Research & Management, Inc. 53 W. Jackson Blvd., Suite 603, Chicago, IL 60604 Phone: (312) 212-1704 Website: www.nerminc.com Email: info@nerminc.com 7/30/25 Investment Advisor Brochure Cover Page This brochure provides information about the qualifications and business practices of New England Research & Management, Inc. (“NERM” or the “Firm”) If you have any questions about the contents of this brochure, please contact Marguerite M. Collins, President and CEO, at (312) 212-1704 or info@nerminc.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. New England Research & Management, Inc. is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. The oral and written communications of an investment advisor are intended to provide you with information to assist you in your determination as to whether or not you retain the services of that investment advisor. Additional information about New England Research & Management, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for New England Research & Management, Inc. is 110739.  2. Material Changes There are no Material Changes  3. Table of Contents 1. Cover Page ............................................................................................................................................... 1 2. Material Changes .................................................................................................................................... 2 3. Table of Contents .................................................................................................................................... 3 4. Advisory Business ................................................................................................................................... 4 5. Fees and Compensation .......................................................................................................................... 5 6. Performance-Based Fees and Side-By-Side Management ................................................................... 6 7. Types of Clients ....................................................................................................................................... 6 8. Methods of Analysis, Investment Strategies, and Risk of Loss ........................................................... 7 9. Disciplinary Information ........................................................................................................................ 8 10. Other Financial Industry Activities and Affiliations ......................................................................... 8 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .............. 8 12. Brokerage Practices ............................................................................................................................ 99 13. Review of Accounts ........................................................................................................................... 100 14. Client Referrals and Other Compensation ....................................................................................... 11 15. Custody .............................................................................................................................................. 111 16. Investment Discretion ......................................................................................................................... 12 17. Voting Client Securities ...................................................................................................................... 12 18. Financial Information ....................................................................................................................... 133  4. Advisory Business New England Research & Management, Inc. (also known as New England Research & Management or NERM) offers investment management services to high net worth individuals and families by managing their revocable and irrevocable trusts, retirement and pension accounts, custodian accounts, foundations, and estates on a discretionary basis. NERM customizes its advisory services to the individual needs, goals, and situation of each client. Our investment management tools are not limited to any specific products or services, and will generally include using a combination of the tools listed below: -exchange-listed securities -securities traded over-the-counter -exchange traded funds (including open and closed end funds) -municipal securities -mutual fund shares -U.S. government securities -corporate debt securities -certificates of deposit -foreign issuers -warrants Each account is managed individually given specific goals, needs, and history. Accounts may be reviewed in a group with other similar accounts, but we do not trade as a comingled fund and no two accounts will ever be identical. Clients may from time to time offer suggestions or preferences, but final discretion and authority is with the firm. Of course, when required to abstain from certain securities due to legal or job- related restrictions, the firm will always comply. NERM relies on Clients to notify them of any changes in their objectives, goals, and risk tolerance, as well as any other material changes in their personal circumstances (such as employment, marital status, financial condition, etc.) These changes may require adjustments in a Client’s investment account and to the investment strategies employed. All investments involve varying degrees of risk and investments will only be considered when consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and suitability. New England Research & Management does not participate in wrap fee programs. As of 6/30/25, assets under management are $285,171,832, of which $825,776 of those assets were non-discretionary stock positions.  5. Fees and Compensation NERM is compensated with a quarterly fee, payable in advance, which is calculated based on a percentage of the market value of the assets under management on the last business day of the previous quarter. The fee schedule is clearly laid out in the investment advisory agreement, which is signed between all clients and NERM (Marguerite Collins). All clients are given a copy of the executed investment advisory agreement for their records. The quarterly schedule is following: Account Value Quarterly Fee First $500,000 0.300% $500,00 - $1,000,000 0.250% $1,000,000 - $5,000,000 0.200% $5,000,000 - $10,000,000 0.150% Above $10,000,000 0.100% Fees are not now negotiable. Fees may be allocated among family accounts, on a reasonable basis, as the clients may prefer. For example, a client may request to have the fee for an IRA account billed directly to the client’s taxable account. Fees are deducted from client accounts quarterly, although upon request, bills may be sent directly to clients for outside payment. In addition to the advisory fees paid to NERM, clients may also incur certain charges imposed by unaffiliated third parties such as broker-dealers, custodians, trust companies, banks and other financial institutions and Service providers (collectively, “Financial Institutions”). These additional charges may include brokerage commissions, transaction fees, custodial fees, reporting service fees, reporting fees, tax overlay fees, fees attributable to alternative assets, margin or other borrowing costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions. These fees are disclosed to clients directly by the financial institutions. NERM does not receive any portion of the above fees and has no financial incentive to invest client funds in any product, style, or method.  NERM’s standard fee schedule applies equally to all assets under management, including mutual funds, although the firm does not charge fees on accounts too small to justify the administrative burden of billing (generally accounts <$50,000.00). The fees are billed in advance as described above. Fees are refundable upon termination of the Investment Advisory Agreement. A pro-rated portion of the fees, based upon the number of days remaining in the calendar quarter based upon the effective date of termination, will be returned to the client by the firm. The agreement may be termination by either the firm or the client, by written notice delivered to the other at any time. The Investment Advisory Agreement may be terminated by the client without penalty within five business days after initially entering into the relationship. None of our supervised persons accept compensation for the sale of securities or other investment products. In addition to asset-based charges for advisory accounts as described above, New England Research & Management offers Clients with taxable accounts an Income Tax Summary to assist Clients in the filing of their tax returns. The fee for this optional service is $300 per year. 6. Performance-Based Fees and Side-By-Side Management Performance-based fee arrangements are designed to give a portion of the return of an investment to the Advisor as reward for a positive performance. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. NERM does not charge any performance-based fees on any of our Client accounts, so this topic does not apply. 7. Types of Clients New England Research & Management generally offers investment services to high net worth individuals and families via managing their revocable and irrevocable trusts, retirement and pension accounts, custodian accounts, foundations, and estates on a discretionary basis. As a condition for starting and maintaining an advisory relationship with NERM, it is generally required that Clients have a minimum investment amount of $500,000.00. At NERM’s sole discretion, the firm may accept accounts with lower market values in certain circumstances, i.e. related accounts, high funding levels, or indicated low levels of administration.  8. Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis NERM uses a variety of methods of analysis, drawing from both fundamental and technical theories. Sources of information include: financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, filings with the SEC, company press releases, seminars, and company presentations. Investment Strategy/Risk of Loss Investing in securities always involves a certain degree of risk of loss that clients should be prepared to bear. Clients face the following investment risks: -Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. -Market Risk: The price of a security may drop in reaction to both tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular circumstances. Examples would be political, economic, global, and social conditions that would trigger market movements. -Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar in the future, as purchasing power erodes at the inflation rate -Currency Risk or Exchange Rate Risk: Overseas investments are subject to fluctuations in the value of the dollar versus the currency of the originating country. -Business Risk: This risk is associated with a particular industry or with a particular company within an industry. Certain industries are inherently riskier than others- for example an oil- drilling company which depends on finding oil and refining it before making a profit (a lengthy process) would be risker than an electric company which generates its profits from a steady stream of customers who will buy electricity despite outside circumstances. A client may experience loss of principal (invested amounts) and any profits that have not yet been realized (securities that were not sold to “lock in” profit). An account may decline in value. Stock and bond markets can fluctuate substantially over any given time. In addition, as recent global and domestic events have indicated, performance of any investment is not guaranteed. As a result, there is risk of loss of the assets that may be out of NERM’s control. The firm will do the very best they can as a fiduciary in managing client assets; however, there can be no guarantee of any level of performance or that a client will not experience loss in their account(s).  9. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to the evaluation of the firm or the integrity of the firm’s management. NERM and its employees have had no legal or disciplinary events and therefore have no disclosure applicable to this item. 10. Other Financial Industry Activities and Affiliations New England Research & Management does not have any financial industry affiliates and no member of New England Research & Management is a registered broker-dealer nor a representative of one. 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading To avoid any potential conflicts of interest involving personal trades, the firm has adopted a Code of Ethics to establish policies addressing its fiduciary duties to its clients. The Code of Ethics requires, among other things, that employees: -Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, and any other participants in the global market; -Place the integrity of the investment profession, the interests of clients, and the interests of the firm above individual and personal interests; -Avoid any actual or potential conflict of interest; -Conduct all personal securities transactions in a manner consistent with this policy; -Comply with all applicable provisions of the federal securities laws. NERM has implemented procedures designed to ensure compliance with the Code of Ethics, including quarterly transaction reports, annual affirmations of compliance, and annual holding reports. All such employee affirmations and reports are reviewed thoroughly by Marguerite M. Collins. A copy of the Code of Ethics will be provided to any client or prospective client upon request. Neither NERM nor any of our employees recommends to clients, or buys or sells for client accounts, securities in which we have a direct material financial interest. It is firm policy not to effect any principal or agency cross securities transactions for client accounts. The firm will also not cross trades between client accounts. Personal Trading NERM’s corporate accounts and/or employee/family accounts may occasionally engage in transactions in securities that are also owned by clients. All trades in the same security in the  same day will receive the same average price if done in a block at the same custodian, to ensure that there is no preferential treatment. Clients will always receive better or at least equal prices of securities by comparison of those received by the firm & its employees. NERM and its officers, employees, and relatives of employees may acquire and sell securities that are also purchased and sold for clients. Security transactions executed in the accounts of related persons are done on the same basis as non-related accounts. Neither applicant nor any of its related persons shall intentionally profit through staggered timing of securities, as explained by the average price policy above. All employee trades are reviewed each quarter by Marguerite Collins. These reviews ensure that the personal trading of employees does not affect the markets at all and that clients of the firm are not affected or disadvantaged in any way. 12. Brokerage Practices NERM does not currently have any soft dollar arrangements. The custodian has made certain direct payments to vendors on behalf of NERM as related transition expenses. These vendor agreements were already in place before selecting the custodian and these custodian payments are not a conflict of interest. Otherwise, all research and non-research services received are purchased directly by NERM. NERM is responsible for decisions to buy and sell securities for its clients and for the placement of their portfolio business and the negotiation of commissions paid on transactions. This selection is done primarily by the firms’ estimation of the quality of execution of orders by various brokers, seeking best execution by taking into account price, promptness of execution reports, and other advantages to the clients. Other factors include: the size and nature of the transaction, the nature of the market for the security, the broker’s ability to execute a particular trade, the broker’s specific industry and regional expertise, the level of service, the quality of the broker’s research, and the capability, experience, and financial condition of the broker. The vast majority of trades are currently done at with zero commission. The firm’s clients do not direct brokerage. In general, investment decisions for each client (or group of clients with similar investment objectives) are made independently from those of other client accounts. Because investment decisions frequently affect more than one client account or group of accounts (for example, a particular stock may be a good investment for numerous clients or groups of clients), at times it will be desirable to acquire or dispose of the same securities for more than one client or group of clients at the same time. When the firm determines that a particular investment opportunity would be desirable for more than one client account, the firm will allocate the security among client accounts in a manner that is deemed fair and equitable under the particular circumstances. The factors that may be  considered in making this determination include (but are not limited to): the relative amounts of capital in each account, the intended investment goals and strategy of each account, the results of recent reviews for that account, applicable tax considerations, and the overall portfolio composition of each account. Due to the nature of NERM’s primary business of providing customized investment advisory services to the accounts of individuals and trusts, orders are often submitted for single accounts and executed at market levels or at a specified price limit. However, when two or more portfolios are simultaneously engaged in the purchase or sale of the same security, NERM may, but is not obligated to, combine and aggregate the transactions to form a “bunched trade” or “block trade.” NERM may, but is not required to, aggregate orders into block trades where the firm believes this is to be appropriate, in the best interests of the client accounts, and consistent with applicable legal requirements. Block trading allows NERM to execute equity trades in a more timely, efficient, and equitable manner. Transactions executed in a block will typically be allocated to the participating client accounts before the close of the business day. There is no difference in cost to the client or in compensation to NERM whether trades are aggregated or not. In such cases, these accounts will receive the average price of the transactions in that security for the block, thus ensuring no advisory client will be favored over any other client. At times, the firm will use short-term trading to the advantage of the clients in a volatile market, in retirement accounts, or for clients whose profiles match this style. This is always done with high quality stocks that meet our investment criteria. 13. Review of Accounts Accounts managed by NERM are reviewed on an on-going basis. Account review meetings are performed on a periodic basis at a frequency agreed upon by the Client and the Firm. The issues covered during account reviews include, but are not limited to: recent price changes of securities, relative and absolute size of security positions, realized and unrealized capital gains/losses, asset allocation, and objectives of clients. More frequent reviews may be triggered by changes in variables such as market, political, or economic conditions, or changes in a client’s individual financial objectives or circumstances. Additional reviews may also be performed at the request of a client. NERM strongly encourages clients to advise the Firm of any changes in their personal circumstances, investment goals and objectives, and risk tolerances to ensure their investments and investment strategies remain appropriate for them.  14. Client Referrals and Other Compensation NERM does not have any arrangements, oral or in writing, where it is paid cash by or receives some economic benefit from a non-client in connection with giving advice to clients. The Firm’s Code of Ethics generally prohibits employees from accepting gifts, favors, and other inducements from service providers, excepting certain common business courtesies. NERM has been fortunate to receive many client referrals over the years. The referrals have come from current and past clients, estate planning attorneys, accountants, employees, and other similar sources. The firm does not compensate referring parties for these referrals. The firm also does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to another firm. 15. Custody NERM directly debits client accounts for the payment of advisory fees, which causes the firm to exercise limited custody over client funds and securities. NERM has the authority to move client funds via first and third party money movement, with client signatures or written standing letters of authorization, in every account. An adviser with this authority therefore has access to the client’s assets. Firm personnel may serve as trustee of a few client accounts, due to existing personal relationships and not as a function of the firm. While NERM does have custody of client accounts due to the above cases, no assets are in the possession of the firm, but are held directly at qualified custodians. All clients receive statements at least quarterly prepared and sent out directly by the custodian to the client. These account statements from the custodian will indicate the amount of advisory fees deducted each billing period. All account statements are also received and reviewed by NERM for accuracy and completeness on a monthly basis. NERM does NOT create or send out any proprietary statements or reports to the clients. Due to the services provided by our qualified custodian, New England Research & Management does NOT have to obtain a surprise custody examination because the following seven criteria are met: o Client provides instruction to the custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or account number for which the money would be transferred.  o Client authorizes NERM, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. o The client’s custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. o The client has the ability to terminate or change the instruction to the client’s qualified custodian. o NERM has NO authority or ability to designate or change the identity of the third party, the address, or any other information about the third party in the client’s instructions. o NERM maintains records showing that the third party is not a related party or located at the same address as NERM. o The client’s custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instructions. 16. Investment Discretion NERM has full discretion over all client accounts per the executed Investment Advisory Agreement between each client and the NERM. NERM does not need to contact the client before buying or selling securities in the client account. The only exception is in the instance a client has asked us to hold a singular stock position and not manage it actively. 17. Voting Client Securities NERM directly votes on behalf of all client securities. It is firm policy to vote along with management. To ensure that proxies are being voted in a timely manner, we have contracted with Broadridge Investor Communication Solutions, Inc. (“Broadridge”), a nationally known and independent proxy voting service firm. Broadridge is used to vote proxies and to obtain the data needed to file the annual NPX. A full copy of the firm’s Proxy Voting Policy is available upon request, and records of all votes made are kept and can be provided upon request.  18. Financial Information NERM has no financial commitments that impair its ability to meet contractual and fiduciary commitments to the Client. NERM has not been the subject of a bankruptcy proceeding. NERM is not required to file a balance sheet as the Firm does not require the prepayment of more than $1200 in fees six or months in advance.