Overview

Assets Under Management: $523 million
Headquarters: PORTSMOUTH, NH
High-Net-Worth Clients: 129
Average Client Assets: $2 million

Frequently Asked Questions

NVEST FINANCIAL, LLC charges 1.30% on the first $0 million, 1.00% on the next $1 million, 0.60% on the next $2 million, 0.40% on the next $5 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #128868), NVEST FINANCIAL, LLC is subject to fiduciary duty under federal law.

NVEST FINANCIAL, LLC is headquartered in PORTSMOUTH, NH.

NVEST FINANCIAL, LLC serves 129 high-net-worth clients according to their SEC filing dated August 14, 2025. View client details ↓

According to their SEC Form ADV, NVEST FINANCIAL, LLC offers financial planning, portfolio management for individuals, portfolio management for institutional clients, pension consulting services, and selection of other advisors. View all service details ↓

NVEST FINANCIAL, LLC manages $523 million in client assets according to their SEC filing dated August 14, 2025.

According to their SEC Form ADV, NVEST FINANCIAL, LLC serves high-net-worth individuals, institutional clients, and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (2025 ADV PART 2A BROCHURE)

MinMaxMarginal Fee Rate
$0 $500,000 1.30%
$500,001 $1,000,000 1.00%
$1,000,001 $2,500,000 0.60%
$2,500,001 $5,000,000 0.40%
$5,000,001 and above 0.30%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $11,500 1.15%
$5 million $30,500 0.61%
$10 million $45,500 0.46%
$50 million $165,500 0.33%
$100 million $315,500 0.32%

Clients

Number of High-Net-Worth Clients: 129
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 59.05
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 1,244
Discretionary Accounts: 1,244

Regulatory Filings

CRD Number: 128868
Filing ID: 2009743
Last Filing Date: 2025-08-14 16:57:00
Website: https://nvestfinancial.com

Form ADV Documents

Additional Brochure: 2025 ADV PART 2A BROCHURE (2025-08-14)

View Document Text
Item 1: Cover Page Form ADV Part 2A August 14, 2025 Nvest Financial, LLC Two International Drive, Suite 110 Portsmouth, NH 03801 207.985.8585 www.nvestfinancial.com This Brochure provides information about the qualifications and business practices of Nvest Financial, LLC. If you have any questions about the contents of this Brochure, please contact us at 207.985.8585 or info@nvestfinancial.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. Nvest Financial, LLC is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Nvest Financial, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. 1 Form ADV Part 2A continued Item 2: Material Changes Since our brochure was last updated on March 13, 2025, we have made the following changes: • Nvest is no longer affiliated with Commonwealth Financial Network. • Nvest has established an institutional relationship with Fidelity Clearing & Custody Solutions and related entities of Fidelity Investments, Inc. For more information, please see Item 12 and Item 14. • Certain Advisory Persons are also Registered Representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”). Please see Item 10. • For certain clients, Nvest will recommend one or more unaffiliated investment managers or investment platforms for all or a portion of a client’s investment portfolio. For more information, please see Item 4, Item 5, and Item 10. Currently, our Brochure may be requested by contacting Nichole D. Raftopoulos, Chief Executive Officer, at 207.985.8585 or info@nvestfinancial.com. Additional information about Nvest Financial, LLC is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Nvest Financial, LLC who are registered, or are required to be registered, as investment adviser representatives of Nvest Financial, LLC. 2 Rev. 8/2025 Form ADV Part 2A continued 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 ..................................................................................................................... 7 Item 6: Performance-Based Fees and Side-By-Side Management .............................................................. 11 Item 7: Types of Clients ................................................................................................................................. 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 11 Item 9: Disciplinary Information ..................................................................................................................... 15 Item 10: Other Financial Industry Activities and Affiliations ........................................................................... 15 Item 11: Code of Ethics ................................................................................................................................. 15 Item 12: Brokerage Practices ........................................................................................................................ 16 Recommendation of Custodian[s] .................................................................................................................. 16 Item 13: Review of Accounts ......................................................................................................................... 17 Item 14: Client Referrals and Other Compensation ....................................................................................... 17 Item 15: Custody ........................................................................................................................................... 18 Item 16: Investment Discretion ...................................................................................................................... 18 Item 17: Voting Client Securities ..................................................................................................................... 19 3 Rev. 8/2025 Item 4: Advisory Business Nvest Financial, LLC (“Nvest”) was formed on 05/14/2003. The firm was registered with the Securities and Exchange Commission (“SEC”) in 2022. The firm is jointly owned by Nichole Raftopoulos and George Raftopoulos. Nichole Raftopoulos is the Chief Executive Officer and Chief Compliance Officer of Nvest. This Brochure is designed to provide detailed and clear information relating to each item noted in the table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred to in an effort to be as comprehensive as possible on the broad subject matters discussed. Within this Brochure, certain terms in either upper- or lowercase are used as follows: • • “We,” “us,” and “our” refer to Nvest. “Advisory Persons” refers to investment adviser representatives who provide investment recommendations or advice on behalf of Nvest. “You,” “yours,” and “client” refer to clients of Nvest and its Advisory Persons. • Investment Management Services Nvest provides customized investment management services for its clients. Our investment management services are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Nvest will work closely with each client to identify their investment goals, objectives, risk tolerance, and financial situation to create an overall portfolio strategy. Nvest will then construct an investment portfolio using a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products (“ETPs”); options and derivatives; unit investment trusts (“UITs”); and variable and fixed-indexed insurance products, as well as other products and services, including the use of unaffiliated investment managers or investment platforms, financial planning, and consulting services. Our Advisory Persons provide advice related to direct participation programs, private placements, and other alternative investments, such as structured products, alternative energy programs, research and development programs, leasing programs, real estate programs, and pooled commodities futures programs, when appropriate to the client’s investment goals and objectives. Use of Independent Managers – For certain clients, Nvest will recommend one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a client’s investment portfolio, based on the client’s needs and objectives. In certain instances, the client will be required to authorize and enter into an investment management agreement with an Independent Manager that defines the terms in which the Independent Manager will provide its services. Nvest will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with the client’s investment objectives and overall best interests. Nvest will also assist the client in the development of the initial policy recommendations and managing the ongoing client relationship. The client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services Nvest provides financial planning services on a wide range of topics, including, but not limited to, budgeting and cash flow analysis, retirement planning, tax planning, estate planning and wealth transfer, risk management and fringe benefit analysis, education planning, and philanthropic and legacy planning. Our financial planning services begin with a formal consultation with the client to determine the client’s assets, liabilities, investment objectives, present and future foreseeable financial obligations, income, and risk tolerance. Using this information, we will create a financial plan consistent with the client’s needs. When the plan is completed, your Advisory Person will meet with you to present the plan and answer any question you may have. You may also engage us for an annual update of your financial plan for an additional charge. The fees for both the initial plan and the annual update are listed in Item 5 of this brochure. Budgeting and Cash Flow Analysis Our Advisory Persons will assist clients with creating a personal financial statement as well as creating and monitoring a budget. Retirement Planning Our Advisory Persons work with clients to help them financially plan and prepare for their retirement. Once retired, we develop or implement our existing plan with a focus on making sure clients have the right tools in place to overcome financial challenges they may face during this phase of life. 4 Rev. 8/2025 Tax Planning* Minimizing your current and future tax burdens through financial tax strategies that consider the tax implications of individual, investment, and/or business decisions. Estate Planning and Wealth Transfer* The creation of a master plan for the preservation of your estate while alive, and the most efficient manner to transfer your estate at demise through the evaluation of wills, trusts, and other wealth transfer techniques. Risk Management and Fringe Benefit Analysis An assessment to evaluate and minimize financial and other losses potentially associated with risks to your assets, business, health, and/or life. Education Planning Our Advisory Persons will perform an analysis of your family’s educational funding needs, including a projection of potential costs and the selection of a vehicle to assist you in meeting your educational funding goals. Philanthropic and Legacy Planning Many of our client relationships have philanthropic and charitable desires that can be integrated into their investment and estate plans through our philanthropic and legacy planning. Financial planning and consulting recommendations pose a conflict between the interests of Nvest and the interests of the client. For example, Nvest has an incentive to recommend that clients engage us for investment management services or to increase the level of investment assets with us, as it would increase the amount of advisory fees paid to Nvest. Clients are not obligated to implement any recommendations made by us or maintain an ongoing relationship with Nvest. If the client elects to act on any of the recommendations made by us, the client is under no obligation to implement the transaction through Nvest. *We work with qualified financial, legal, and tax professionals who understand the importance of the tax and estate laws. Nvest Financial, LLC is neither a certified public accountant nor an attorney. You should consult a tax or legal professional in those fields regarding your individual situation. We will, however, work together as a team to bring to you coordinated advice for your situation. Retirement Plan Consulting Services Nvest provides 3(21) retirement plan consulting services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). Nvest retirement plan consulting services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring • Plan Participant Enrollment • • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance These services are provided by Nvest serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Wrap Fee Programs We do not manage or place client assets into a wrap fee program. Investment management services are provided directly by Nvest. No Legal or Tax Advice Investment recommendations and advice offered by Nvest, and its Advisory Persons do not constitute legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice they receive from us with their attorney and accountant. Clients should also inform their Advisory Person promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify the Advisory Person of any material changes could result in investment advice not meeting the changing needs of the client. IRA Rollover Considerations As part of our financial planning services, we may provide you with recommendations and advice concerning your employer 5 Rev. 8/2025 retirement plan or other qualified retirement account. We may recommend that you withdraw the assets from your employer’s retirement plan or other qualified retirement account and roll the assets over to an individual retirement account (“IRA”). You are under no obligation, contractually or otherwise, to complete the rollover. Employers may permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: • Leave the funds in your employer’s (former employer’s) plan. • Roll over the funds to a new employer’s retirement plan. • Cash out and take a taxable distribution from the plan. • Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your financial advisor, CPA and/or tax attorney. Before rolling over your retirement funds to an IRA, carefully consider the following. NOTE: This list is not exhaustive. • Determine whether the investment options in your employer’s retirement plan address your needs or whether other types of investments are needed. • Employer retirement plans generally have a more limited investment menu than IRAs. • Employer retirement plans may have unique investment options not available to the public such as employer securities or previously closed funds. • Your current plan may have lower fees than the new IRA. o If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer’s retirement plan and how the costs of those share classes compare with those available in an IRA. o You should understand the various products and services available through an IRA provider and their o potential costs. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. If your plan offers management services, there may be a fee associated with the service that is higher or lower than the new IRA. • The IRA provider’s strategy may have higher risk than the option(s) provided in your plan. • Your current plan may offer financial advice, guidance, management, and/or portfolio options at no additional cost. • If you keep your assets titled in a 401k or retirement account and you are still working, you could potentially delay your required minimum distribution beyond required minimum distribution age. • Your 401k may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies; however, there can be exceptions. Consult an attorney if you are concerned about protecting your retirement plan assets from creditors. • You may be able to take out a loan on your 401k, but not from an IRA. • IRA assets can be accessed any time; however, prior to age 59 1/2, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses, or a home purchase. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. • • Your plan may allow you to hire another firm as the manager and keep the assets titled in the plan name. • It is important that you understand your options, their features and differences and decide whether a rollover is best for you. If you have questions, you may speak with your advisor for guidance in your specific situation. In addition to complying with applicable SEC rules, Nvest is subject to certain rules and regulations adopted by the U.S. Department of Labor when we provide nondiscretionary investment advice to retirement plan participants and IRA owners. When these DOL rules apply, our Advisory Persons and Nvest are “fiduciaries,” for purposes of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, and the Internal Revenue Code of 1986 (“the Code”), as amended. Therefore, Nvest and our Advisory Persons may not receive payments that create conflicts of interest when providing fiduciary investment advice to plan sponsors, plan participants, and IRA owners, unless we comply with a prohibited transaction exemption (“PTE”). Nvest and our Advisory Persons will comply with ERISA and the Code by using PTE 2020-02. As fiduciaries under ERISA and the Code, we render advice that is in plan participants’ and IRA customers’ best interest. Nvest and our Advisory Persons status as an ERISA/Code fiduciary is limited to ERISA/Code covered nondiscretionary advice and recommendations regarding rolling over a retirement account and does not extend to all situations. 6 Rev. 8/2025 Individualized Services and Client-Imposed Restrictions The investment advisory services provided by our Advisory Persons depend largely on the personal information the client provides to the Advisory Person. In order for our Advisory Persons to provide appropriate investment advice to, or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very important that clients provide accurate and complete responses to their Advisory Persons questions about their financial condition, needs, goals, and objectives and notify the advisor of any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their account. It is also important that clients promptly inform their Advisory Person of any changes in their financial condition, investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the management of their account, if any, that may affect their overall investment goals and strategies, or the investment advice provided, or investment decisions made by their advisor. Assets Under Management As of December 31, 2024, Nvest Financial LLC manages $523,359,300 in assets. All assets are managed on a discretionary basis. Clients may request more current information at any time by contacting Nvest. Item 5: Fees and Compensation Financial Planning Services As part of a client’s initial engagement with Nvest, clients are encouraged to work with the Advisory Person to create a financial plan prior to engaging Nvest for investment management services. The creation of this plan sets the foundation for the relationship and allows us to manage your assets in a manner that takes into account a holistic view of your financial life. The fees described for financial planning services are separate from and in addition to fees charged for ongoing investment management services. The fee for a comprehensive financial plan will range from $1,750 to $15,000 depending on the scope of the work. Fifty percent of the fee is due in advance, and the remainder is due upon delivery of the plan to the client. We also offer an hourly billing option at a rate of $350 per hour (fees are paid as services are rendered). Fees are negotiable and are payable by check to Nvest Financial, LLC. Fees for financial planning services may be discounted or waived at Nvest’s sole discretion. Nvest requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The client may also terminate the financial planning agreement within five (5) business days of signing the agreement at no cost to the Client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Investment Management Services Investment management fees are paid quarterly in advance pursuant to the terms of the client’s written agreement with Nvest. Fees are based on the market value of assets under management (“AUM”) on the last business day of the previous calendar quarter. In limited circumstances, estimated quarter-end values of alternative investments provided by the product issuer may be used when calculating billable AUM. Fees are based on the following schedule: Standard Fee Schedule Assets Under Management ($) First $500,000 Next $500,000 Next $1,500,000 Next $2,500,000 Above $5,000,000 Annual Rate (%) 1.30% 1.00% 0.60% 0.40% 0.30% Fee Schedule for Non-Profit Organizations Assets Under Management ($) First $2,500,000 $2,500,001 - $5,000,000 Above $5,000,001 Annual Rate (%) 0.65% 0.30% 0.25% 7 Rev. 8/2025 Fee Schedule for SIMPLE IRA Plans Assets Under Management ($) Any and All Amounts Annual Rate (%) 0.92% The initial quarterly fee will be prorated based on the number of billing days in the initial quarter. Fees are based on account value and account type and are negotiable. Other methods of fee calculation exist or are possible, depending on the specific program, the services provided, client circumstances, and the account size. These methods include, but are not limited to, hourly, flat, breakpoint, and blended fee billing. Clients may make additions to and withdrawals from account[s] at any time. However, reconciliations are performed on a quarterly basis to capture if, at any point, assets in excess of $250,000 are deposited into or withdrawn from an account after the start of the quarterly billing period. An adjustment will be made in the form of a credit or debit the following billing period to reflect the interim change in portfolio value from the date of the deposit/withdrawal until the end of the quarter. In certain circumstances, Nvest allows for the aggregation of assets among a client’s “related” managed accounts for purposes of determining the value of AUM and the applicable advisory fee to be paid by a client. The firm reserves the right to determine whether client accounts are “related” for purposes of aggregating a client’s accounts together for a reduction in the percentage fee amount. Investment management fees are calculated by Nvest and deducted from the client’s account[s] at the custodian. Nvest will send an invoice to the custodian indicating the amount of fees to be deducted from the client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Nvest at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the custodian reflecting deduction of the investment management fee. Clients are urged to also review and compare the statement provided by Nvest to the brokerage statement from the custodian, as the custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Nvest to be paid directly from their account[s] held by the custodian as part of the investment advisory agreement and separate account forms provided by the custodian. Nvest is compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The client may also terminate the investment advisory agreement within five (5) business days of signing the agreement at no cost to the client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the client. Upon termination, Nvest will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The client’s investment advisory agreement with Nvest is non-transferable without the client’s prior consent. Use of Independent Managers – As noted in Item 4, Nvest will implement all or a portion of a client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, Nvest does not earn any compensation from an Independent Manager. Nvest will only earn its investment advisory fee as described above. Independent 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 Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. Clients pay the Independent Manager platform fee and investment management fee not to exceed 0.35% annually in addition to the investment advisory fees paid to Nvest as described above. For client accounts implemented through an Independent Manager, the client’s overall fees will include Nvest’s investment management fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the Independent Manager platform and investment management fees and deducting those fees from the Client’s account[s]. Nvest will be responsible for calculating its investment management fee and deducting from the Client’s account[s]. 8 Rev. 8/2025 Retirement Plan Consulting Services Retirement plan consulting fees are charged an annual asset-based fee based on the following schedule: Fee Schedule for Corporate Retirement Plan Consulting Assets Under Management ($) Under $1,000,000 $1,000,001 - $3,000,000 $3,000,001 - $5,000,000 $5,000,001 - $10,000,000 $10,000,001 - $20,000,000 Above $20,000,001 Annual Rate (%) 0.75% 0.50% 0.45% 0.40% 0.35% 0.30% Fees may be billed monthly or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan consulting agreement. Retirement plan fees are based on the market value of assets under management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated above. Retirement plan consulting fees may be directly invoiced to the Plan Sponsor and paid via check or deducted from the assets of the Plan, depending on the terms of the retirement plan consulting agreement. Checks for Retirement Plan Consulting Services should be made payable to Nvest Financial, LLC. Checks should never be made payable to your Advisory Persons. Clients who are asked or instructed by their Advisory Person to make checks payable to the Advisory Person should contact Nichole Raftopoulos directly for verification. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Nvest, in connection with investments made on behalf of the client’s account[s]. The client is responsible for all custody platform and securities execution fees charged by the custodian, as applicable. Nvest’s recommended custodian does not charge securities transaction fees for ETF and equity trades in a client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Nvest are separate and distinct from these custody and execution fees. In addition, all fees paid to Nvest for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A client may be able to invest in these products directly, without the services of Nvest, but would not receive the services provided by Nvest which are designed, among other things, to assist the client in determining which products or services are most appropriate for each client’s financial situation and objectives. Accordingly, the client should review both the fees charged by the fund[s] and the fees charged by Nvest to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Clients should be aware that, when assets are invested in shares of mutual funds or variable insurance products, clients will pay investment advisory fees to Nvest for their advisory services in connection with the investments. In addition to the payments received by Nvest, clients will also typically pay management fees and other fees charged by the investment company, alternative investment, or insurance product sponsor. Clients may be able to invest directly in the investment company, alternative investment, or insurance product without incurring the investment advisory fees charged by Nvest. If a client’s assets are invested in a fee-based annuity, the client will pay both the direct management fee to Nvest and his or her Advisory Person for the advisory services provided by Nvest and the Advisory Person in connection with that investment and, indirectly, the management and other fees charged by the underlying annuity investment options, as well as the charges assessed by the insurance company for the product. Clients should also be aware of the tax implications of investing, as well as of the existence of deferred sales charges or redemption fees charged by some product sponsors for positions the client subsequently sells in Nvest managed accounts. Mutual Fund Share Classes In most cases, mutual fund companies offer multiple share classes of the same mutual fund. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares or other share classes that are eligible for purchase in an advisory account. Mutual funds that offer institutional share classes, advisory share classes, and other share classes with lower expense ratios are available to investors who meet specific eligibility requirements that are described in the mutual fund’s prospectus or its statement of additional information. These eligibility requirements include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the 9 Rev. 8/2025 fund considers qualified fee-based programs. The lowest-cost mutual fund share class for a fund may not be offered through our clearing firm or made available by Nvest for purchase within our managed accounts. Clients should never assume that they will be invested in the share class with the lowest possible expense ratio or cost. Nvest urges clients to discuss with their Advisory Person whether lower-cost share classes are available in their program account. Clients should also ask their advisor why the funds or other investments that will be purchased or held in their managed account are appropriate for them in consideration of their expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, trading frequency, the amount of the advisory fee charged, whether the client will pay transaction charges for fund purchases and sales, whether clients will pay higher internal fund expenses in lieu of transaction charges that could adversely affect long-term performance, and relevant tax considerations. Your Advisory Person may recommend, select, or continue to hold a fund share class that charges you higher internal expenses than other available share classes for the same fund. The existence of various fund share classes with lower internal expenses that Nvest may not make available for purchase in its managed account programs present a conflict of interest between clients and Nvest or its Advisory Person. A conflict of interest exists because Nvest and your Advisory Person have a greater incentive to make available, recommend, or make investment decisions regarding investments that provide additional compensation to Nvest that cost clients more than other available share classes in the same fund that cost you less. For those advisory programs that assess transaction charges to clients or to Nvest or the Advisory Person, a conflict of interest exists because Nvest and your Advisory Person have a financial incentive to recommend or select NTF funds that do not assess transaction charges but cost you more in internal expenses than funds that do assess transaction charges but cost you less in internal expenses. Advance Payment of Fees and Termination Financial Planning Services Nvest requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The client may also terminate the financial planning agreement within five (5) business days of signing the Nvest’s agreement at no cost to the client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the client. Upon termination, the client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisory Person. The client’s financial planning agreement with Nvest is non-transferable without the client’s prior consent. Investment Management Services Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the client. In the event a client terminates an advisory agreement with Nvest, any unearned fees resulting from payments made by clients in advance will be refunded to the client. The client’s investment advisory agreement with the Advisor is non-transferable without the client’s prior consent. Use of Independent Managers – In the event that Nvest has determined that an Independent Manager is no longer in the client’s best interest or a client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the client or Nvest and the Independent Manager. Nvest will assist the client with the termination and transition as appropriate. Retirement Plan Consulting Services Nvest may be compensated for its retirement plan consulting services at the beginning of the Billing Period before services are rendered pursuant to the terms of the retirement plan consulting agreement. Either party may request to terminate a retirement plan consulting agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for fees up to and including the effective date of termination. If the fees are billed in advance, Nvest will refund any unearned, prepaid retirement plan consulting fees from the effective date of termination to the end of the Billing Period. The Client’s retirement plan consulting agreement with the Advisor is non-transferable without the Client’s prior consent. Compensation for Sales of Securities Nvest does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Special Disclosures for ERISA Plans Nvest has adopted policies and procedures that are designed to ensure compliance with the prohibited transaction rules under the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended. For example, Nvest has taken several steps to address the conflict of interest associated with Nvest’s or Nvest’s advisors’ receipt of compensation for services provided 10 Rev. 8/2025 to ERISA plans. First, an advisor negotiates the compensation with ERISA plan sponsors or participants (“ERISA clients”) and the compensation is either an annual fee for ongoing services based on a percentage of assets under advisement, a flat fee, or an hourly rate. Second, to the extent that an advisor receives additional compensation from a third party, the advisor must report it to Nvest to enable the additional compensation to be offset against the fees that the ERISA clients would otherwise pay for the advisor’s services. Third, Nvest has established a policy not to influence any advisor’s advice or management of assets at any time or for any reason based on any compensation that Nvest or the advisor might receive from third parties. In no event will Nvest allow advisors to provide advice or manage assets for ERISA clients if they have conflicts of interest that Nvest believes are prohibited by ERISA. As a covered service provider to ERISA plans, Nvest will comply with the U.S. Department of Labor regulations on fee disclosures, effective July 16, 2011 (or such other date as provided by the Department). Thus, Nvest and its advisors will disclose (i) direct compensation received from ERISA clients; (ii) indirect compensation (e.g., 12b-1 fees) received from third parties; and (iii) transaction-based compensation (e.g., commissions) or other similar compensation shared with related parties servicing the ERISA plan. These fee disclosures will be made reasonably in advance of entering, renewing, or extending the advisory service agreement with the ERISA client. Item 6: Performance-Based Fees and Side-By-Side Management Nvest does not charge any performance-based fees. Fees are not based on a share of capital gains on or capital appreciation of the assets of a client. Nvest does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7: Types of Clients Nvest provides services to individuals, high net worth individuals/families and small businesses. Nvest does not apply specific criteria for the acceptance of a client, rather Nvest assesses each prospective client on a case-by-case basis. Nvest generally requires a minimum relationship size of $500,000 to effectively implement its investment process. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that investors should be sure they understand and should be prepared to bear. Nvest primarily serves retail investors. Nvest maintains a firm philosophy with how investments and strategies are analyzed. The Investment Committee meets monthly to review in-house recommended lists, market outlooks and implementation of strategies. Firm level decisions are executed by the Chief Executive Officer and President. There are several sources of information that Nvest and Advisory Persons may use as part of the investment analysis process. These sources include, but are not limited to: • Financial publications • Research materials prepared by others • Corporate rating services • SEC filings (annual reports, prospectus, 10-K, etc.) • Company press releases Nvest does not favor any specific method of analysis over another and, therefore, would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a few common approaches that may be used by Nvest or your Advisory Person, individually or collectively, in the course of providing advice to clients. Please note that there is no investment strategy that will guarantee a profit or prevent loss. Following are some common strategies employed by Advisory Persons in the management of client accounts: Dollar Cost Averaging (“DCA”): The technique of buying a fixed dollar amount of a particular investment on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single investment at higher price. DCA strategies are not effective and do not prevent against loss in declining markets. Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes—equities (stocks), fixed income (bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes are often further divided into domestic and foreign investments, and equities are often divided into small, intermediate, and large capitalization. The general theory behind asset allocation is that each asset class will perform differently from the others in different market conditions. 11 Rev. 8/2025 By diversifying a portfolio of investments among a wide range of asset classes, advisors seek to reduce the overall volatility and risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or protect against loss. Technical Analysis (aka “Charting”): A method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with the company’s future stock price. It is important to understand that past performance does not guarantee future results. Fundamental Analysis: A method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis. Quantitative Analysis: An analysis technique that seeks to understand behavior by using complex mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real- world events, such as changes in a share price. Qualitative Analysis: Securities analysis that uses subjective judgment based on non-quantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however, are often used together. Risks of Loss Regardless of what investment strategy or analysis is undertaken, investing in securities involves risk of loss that clients must be prepared to bear; in fact, some investment strategies could result in total loss of your investment. Some risks may be avoided or mitigated, while others are completely unavoidable. Nvest and your advisor do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Some of the common risks you should consider prior to investing include, but are not limited to: Market risks: The prices of, and the income generated by, the common stocks, bonds, and other securities you own may decline in response to certain events taking place around the world, including those directly involving the issuers; conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic instability; governmental or governmental agency responses to economic conditions; and currency, interest rate, and commodity price fluctuations. Interest rate risks: The prices of, and the income generated by, most debt and equity securities may be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally will decline when interest rates rise and will increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call,” or refinance a security before its stated maturity date, which may result in having to reinvest the proceeds in lower-yielding securities. Credit risks: Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Geopolitical risks: Investments in securities issued by entities based outside the United States may be subject to the risks described above to a greater extent. 12 Rev. 8/2025 Margin transactions: Securities transactions in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan, inherently have more risk than cash purchases. If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a “margin call.” An investor’s overall risk in accounts utilizing margin includes the amount of money invested plus the amount that was loaned to them. Tax considerations: Our strategies and investments may have unique and significant tax implications. Unless specifically agreed otherwise, and in writing, however, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, it is strongly recommended that you consult with a tax professional regarding the investing of your assets. Custodians and broker/dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the first in, first out (“FIFO”) accounting method for calculating the cost basis of your equity investments and average-cost for mutual fund positions. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and Nvest will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Liquidity risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. Certain structured products, interval funds, and alternative investments are less liquid than securities traded on an exchange, and you should be aware of the fact that you may not be able sell these products outside of prescribed time periods. You should consult your advisor prior to purchasing products considered illiquid and in instances where changes in your financial situation and objectives may increase your need for liquidity. Inflation risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Time horizon and longevity risk: Time horizon risk is the risk that your investment horizon is shortened because of an unforeseen event (e.g., the loss of your job). This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or nearing retirement. Recommendation of particular types of securities: We will recommend various types of securities and do not primarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. In very general terms, however, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Descriptions of the types of securities we may recommend to you and some of their inherent risks are provided below: Money market funds: A money market fund is technically a security, and, as such, there is a risk of loss of principal, although it is generally rare. In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation (“FDIC”) insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. If it goes down, however, and you earn less than you expected to, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. Municipal securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. Bonds: Also known as corporate debt securities, bonds are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to 13 Rev. 8/2025 mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or “stocks”). In very broad terms, the value of a stock depends on the financial health of the company issuing it. Stock prices, however, can be affected by many other factors, including, but not limited to, the class of stock (e.g., preferred or common), the health of the market sector of the issuing company, and the overall health of the economy. In general, larger, more well-established companies (i.e., large-caps) tend to be safer than smaller start-up companies (i.e., small-caps), but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Mutual funds and ETFs: Mutual funds and ETFs are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) 29 rather than balancing the fund with different types of securities. ETFs differ from mutual funds in that they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are “no load,” meaning there’s no fee to buy into or sell out of the fund, other types of mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be “closed-end” or “open-end.” Open-end mutual funds continue to allow new investors indefinitely, whereas closed-end funds have a fixed number of shares to sell, which can limit their availability to new investors. Variable annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single- payment annuity) or a series of regular payments (regular-payment annuity). The payment stream from the issuer to the annuitant has an unknown duration based principally upon the date of death of the annuitant. At this point, the contract will terminate, and the remainder of the funds accumulated will be forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable annuities pay amounts that vary according to the performance of a specified set of investments, typically bond and equity mutual funds. Many variable annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges, such as mortality and expense risk charges, administrative fees, underlying fund expenses, and charges for special features, all of which can reduce the return. Structured products: A structured product is generally a prepackaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and, to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. In addition to a fixed maturity, they have two components: a note and a derivative. The derivative component is often an option. The note provides for periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell to the investor the security or securities at a predetermined price. Other products use the derivative component to provide for a call option written by the investor that gives the buyer of the call option the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a “principal guarantee” function, which offers protection of principal if held to maturity. These products are not always FDIC insured, however; they may only be insured by the issuer and, thus, have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves a number of risks, including, but not limited to, fluctuations in the price, level, or yield of underlying instruments; interest rates; currency values; and credit quality. They also involve the risk of substantial loss of principal, limits on participation in any appreciation of the underlying instrument, limited liquidity, credit risk of the issuer, conflicts of interest, and other events that are difficult to predict. Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs when governments take away a private business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. These risks may be heightened in connection with investments in developing countries. Investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Any of the common risks described above could adversely affect the value of your portfolio and account performance, and you can lose money. Even though these risks exist, Nvest and your advisor will still earn the fees and other compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that they may lose principal while Nvest and your advisor continue to earn fees and other forms of compensation. 14 Rev. 8/2025 Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and as such may lose value. Item 9: Disciplinary Information During the period February 8, 2020, through December 24, 2020, Nvest operated an additional branch office location in Boston, Massachusetts while seeking registration as an investment adviser in Massachusetts. On January 4, 2021, without admitting or denying the allegations contained therein, Nvest entered into a consent order with the Massachusetts Securities Division and paid a $7,000 administrative fine. The order covered Nvest’s failure to register as an investment adviser and its failure to register an investment adviser representative, prior to maintaining a place of business in Massachusetts and providing investment advisory services to two (2) Massachusetts clients, in violation of the Massachusetts Uniform Securities Act, MASS. GEN. LAWS Ch. 110A, and the corresponding regulations promulgated thereunder at 950 MASS. CODE REGS. Following the entry of the order, Nvest was registered as an investment adviser in Massachusetts and Nichole Raftopoulos was registered as an investment adviser representative of Nvest in Massachusetts. You may independently view the background of Advisory Person on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with Advisory Person’s name or Individual CRD# . You may independently view the background of the Advisor on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the firm name or the Advisor’s CRD# 128868. Item 10: Other Financial Industry Activities and Affiliations Some of our Advisory Persons are also Registered Representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), a FINRA-registered broker dealer (CRD#35747), member FINRA, SIPC. In one’s separate capacity as a Registered Representative, Advisory Persons will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by the Advisory Person. Neither Nvest nor Advisory Persons will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a Registered Representative. Certain Advisory Persons are licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Nvest. As an insurance professional, the Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset investment advisory fees. This presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Nvest or Advisory Persons. George Raftopoulos, an owner of Nvest, also owns and operates ROI Cubed, LLC (“ROI”). ROI is a boutique consulting firm helping business owners attain maximum value through operational excellence, value growth and strategic planning as they plan towards a transition or succession. The services offered by ROI are separate and unrelated to Nvest. Clients of Nvest are under no obligation to engage ROI. Any fees paid to ROI for ROI’s services are separate from and in addition to fees paid to Nvest for investment advisory services. Nvest and its advisors have a conflict of interest in recommending ROI’s services to you. Should you engage ROI for services, Mr. Raftopoulos will earn additional compensation. We attempt to mitigate this conflict by disclosing the relationship between Nvest and ROI in this brochure. Item 11: Code of Ethics Nvest has adopted a Code of Ethics that governs a number of conflicts of interest we have when providing our advisory services to you. Our Code of Ethics is designed to ensure that we meet our fiduciary obligations to you and to foster a culture of compliance throughout our firm. Our Code of Ethics is comprehensive and is designed to help us detect and prevent violations of securities laws and to help ensure that we keep your interests first at all times. We distribute our Code of Ethics to each supervised person at the time of his or her initial affiliation with our firm; we make sure it remains available to each supervised person for as long as he or she remains associated with our firm; and we ensure that updates to our Code of Ethics are communicated to each supervised person as changes are made. Nvest’s Code of Ethics sets forth certain standards of conduct and addresses conflicts of interest among our employees, agents, advisors, and advisory clients. Clients and prospective clients may request and receive a copy of the firm’s Code of Ethics upon request. Advisory Persons may buy or sell securities identical to those securities recommended to clients. Therefore, Advisory Persons 15 Rev. 8/2025 may have an interest or position in certain securities that are also recommended and bought or sold to clients. Any such securities transactions are likely to be insignificant in relation to the market as a whole. As a practice the transactions, if any, are executed after related client transactions have been executed. Nvest does not act as principal in any transactions. Nvest does not act as the general partner of a fund, or advise an investment company. Nvest does not have a material interest in any securities traded in client accounts. Advisory Persons may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients. However, in all cases, full disclosure is provided to the client. Nvest is required to maintain a list of all securities holdings for its Advisory Persons. Further, Advisory Persons are prohibited from trading on non-public information or sharing such information. Clients have the right to decline any investment recommendation. Nvest and its Advisory Persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations. While Nvest allows Advisory Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Nvest, or any Advisory Person of Nvest, transact in any security to the detriment of any Client. Item 12: Brokerage Practices Recommendation of Custodian[s] Nvest does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard client assets and authorize Nvest to direct trades to the custodian as agreed upon in the investment advisory agreement. Further, Nvest does not have the discretionary authority to negotiate commissions on behalf of clients on a trade-by-trade basis. Where Nvest does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to clients for custody and execution services. Clients are not obligated to use the Custodian recommended by Nvest and will not incur any extra fee or cost associated with using a custodian not recommended by Nvest. However, Nvest may be limited in the services it can provide if the recommended Custodian is not engaged. How We Select Brokers/Custodians We seek to use custodians who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services • Capability to execute, clear and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], limited partnerships) • Availability of investment research and tools that assist us in making investment decisions. • Quality of services • Competitiveness of the price of those services and willingness to negotiate the prices • Reputation, financial strength, and stability • Prior service to us and our other clients • Availability of other products and services that benefit us Your Brokerage and Custody Costs Nvest will generally recommend that clients establish their account[s] at Fidelity Clearing & Custody Solutions and related entities of Fidelity Investments, Inc. (collectively “Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”), each a FINRA- registered broker-dealer and member SIPC. Fidelity or Schwab will serve as the client’s “qualified custodian”. Nvest maintains an institutional relationship with Fidelity and Schwab whereby Nvest receives economic benefits. Soft Dollars Nvest does not use commissions to pay for research and brokerage services (i.e., soft dollar transactions). Research, along with other products and services other than trade execution, are available to Nvest on a cash basis from various vendors. However, Nvest receives certain economic benefits form the Custodian. Please see Item 14. Brokerage Referrals Nvest does not receive any compensation from any third party in connection with the recommendation for establishing an account. 16 Rev. 8/2025 Directed Brokerage All clients are serviced on a “directed brokerage basis”, where Nvest will place trades within the established account[s] at the Custodian designated by the client. Further, all client accounts are traded within their respective account[s]. Nvest will not engage in any principal transactions (i.e., trade of any security from or to Nvest’s own account) or cross transactions with other client accounts (i.e., purchase of a security into one client account from another client’s account[s]). Nvest will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. Block Trading Policy Nvest may aggregate (“bunch”) transactions in the same security on behalf of more than one client in an effort to strive for best execution and to possibly reduce the price per share. However, aggregated or bunched orders will not reduce the transaction costs to participating clients. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Nvest conducts aggregated transactions in a manner designed to ensure that no participating client is favored over another client. Participating clients will obtain the average share price per share for the security executed that day. To the extent the aggregated order is not filled in its entirety and when possible, securities purchased or sold in an aggregated transaction will be allocated pro-rata to the participating client accounts in proportion to the size of the orders placed for each account. The amount of securities maybe increased or decreased to avoid holding odd-lot or a small number of shares for particular clients. It should be noted, Nvest does not receive any additional compensation or remuneration as a result of aggregation. Advisory clients purchase funds at net asset value. Item 13: Review of Accounts All asset management client accounts are reviewed by an Advisory Person on an annual basis, or when changes in client circumstances or market conditions warrant. Securities held in managed accounts are regularly reviewed by the firm’s investment committee. Clients will be provided statements at least quarterly directly from the Custodian where your assets are maintained. Additionally, you will receive confirmations of all transactions directly from the Custodian. All non-retirement accounts and retirement accounts for those clients taking distributions will receive an annual tax reporting statement. Item 14: Client Referrals and Other Compensation The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Nvest has established an institutional relationship with Fidelity to assist Nvest in managing client account[s]. Nvest receives access to software and related support because Nvest renders investment management services to clients that maintain assets at Fidelity. The software and related systems support may benefit Nvest, but not its clients directly. In fulfilling its duties to its clients, Nvest endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence Nvest’s recommendation of this Custodian over one that does not furnish similar software, systems support, or services. The following benefits are also received from Fidelity: financing services (e.g. margin, securities based lines of credit), receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; access to an electronic communication network for client order entry and account information, and transition credits to provide financial support to assist with the client transition to the Fidelity platform. Nvest has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like the Advisor. As a registered investment advisor participating on the Schwab Advisor Services platform, Nvest receives access to software and related support without cost because Nvest renders Wealth management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit Nvest and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, Nvest endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits can influence Nvest's recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. 17 Rev. 8/2025 Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, Nvest may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, Nvest may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, Nvest receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist Nvest in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit Nvest – Schwab also offers other services to Nvest that may not benefit the Client, including: educational conferences and events, start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for Nvest to recommend Schwab, which results in a potential conflict of interest. We believe, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Item 15: Custody Nvest does not maintain physical custody of any client fund or securities. Under the rules of the Investment Advisers Act of 1940, we are deemed to have custody of your assets despite not having physical custody in certain instances. For example, if you authorize us to instruct your custodian to deduct our advisory fees directly from your account or if you establish certain first party and/or any third-party Standing Letters of Authorization (SLOAs) to move money from your account with us to a different account, we are deemed to have custody. Our firm complies with certain safe harbor provisions and is therefore exempt from the annual surprise custody examination requirement for Advisers that have custody due to the existence of SLOAs. Nvest clients may also receive portfolio summary or performance reporting for their managed accounts from their advisor that are in addition to the account statements clients receive directly from the respective account custodian. Nvest urges you to compare the account statements you receive from your account custodian with any account summary statements or reports you receive from us or your advisor. Although account holdings and asset valuations should generally match, for purposes of calculating performance and account valuations on your account, our summary or performance reporting month-end market values sometimes differ from custodial account statement month-end market values. The three most common reasons why these values may differ are differences in the manner in which accrued interest is calculated, the date upon which “as of” dividends and capital gains are reported, and settlement date versus trade date valuations. If you believe there are material discrepancies between your custodial statement and the summary statements or reports you receive from us or your Advisory Person, please contact Nvest at 207.985.8585. Item 16: Investment Discretion Nvest renders investment advice to the vast majority of its clients on a discretionary basis, pursuant to written authorization granted by the client to the firm and your Advisory Person. This authorization grants to Nvest and your Advisory Person the discretion to buy, sell, exchange, convert, or otherwise trade in securities and/or insurance products, and to execute orders for such securities and/or insurance products with or through any distributor, issuer, or broker/dealer as Nvest or your Advisory Person may select. Your Advisory Person may, without obtaining your consent, determine which products to purchase or sell for your managed account, as well as when to purchase or sell such products, and the prices to be paid. All discretionary trades made by Nvest will be in accordance with each client's investment objectives and goals. Neither Nvest nor your Advisory Person, however, is granted authority to take possession of your assets or direct the delivery of your assets to anywhere other than your address of record. You may terminate this discretionary authorization at any time by providing written notice to us. Clients may impose reasonable restrictions on their managed account, including, but not limited to, the type, nature, or specific names of securities to be bought, sold, or held in their managed account, as well as the type, nature, or specific names of securities that may not be bought, sold, or held in their managed account. Clients generally grant Nvest and their Advisory Person discretionary trading authority over their managed accounts. If not specifically requested otherwise by the client, discretionary authority will be established at the time the account is first opened. As a matter of firm policy, neither Nvest nor its Advisory Person have or will accept the authority to file class action claims on behalf of clients. This policy reflects Nvest’s recognition that it does not have the requisite expertise to advise clients with regard to participating in class actions. The firm and its advisors have no obligation to determine if securities held by the client 18 Rev. 8/2025 are subject to a pending or resolved class action settlement or verdict. The firm and its advisors also have no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Nvest and its advisors have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. The decision to participate in a class action or to sign a release of claims when submitting a proof of claim may involve the exercise of legal judgment, which is beyond the scope of services provided to clients by Nvest or your advisor. In all cases, clients retain the responsibility for evaluating whether it is prudent to join a class action or to opt out. Item 17: Voting Client Securities Nvest does not accept proxy-voting responsibility for any client. Clients will receive proxy statements directly from the Custodian. Nvest will assist in answering questions relating to proxies, however, the client retains the sole responsibility for proxy decisions and voting. Item 18: Financial Information Neither Nvest, nor its management persons, have any adverse financial situations that would reasonably impair the ability of Nvest to meet all obligations to its Clients. Neither Nvest, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Nvest Financial is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. 19 Rev. 8/2025