PITCAIRN WEALTH ADVISORS LLC

Pitcarn Wealth Advisors ADV Part 2A - Disclosure Brochure Dated: July 21, 2025 Contact: Eight Tower Bridge 161 Washington Street, Suite 801 Conshohocken, Pennsylvania 19428 This brochure provides information about the qualifications and business practices of Pitcairn Wealth Advisors, LLC ("Pitcairn"). If you have any questions about the contents of this brochure, please contact us at 215.887.6700 or r.pollard@pitcairn.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Pitcairn also is available on the SEC’s website at www.adviserinfo.sec.gov. Registration as an investment adviser does not imply a certain level of skill or training. 1  ITEM 2: MATERIAL CHANGES In this section, the firm is required to describe any material changes to this Brochure since its last annual update, which was filed on February 19, 2025. We have updated Item 4 to describe the firm's services relating to digital assets, Item 5 to include fees for additional services such as bill payment, Item 8 to describe the firm's services relating to digital assets, Item 12 to add information relating to a custodian of digital assets, and Item 15 to add information relating to a custodian of digital assets. 2  ITEM 3: TABLE OF CONTENTS Item 2: Material Changes .................................................................................................................................... 2 Item 4: Advisory Business .................................................................................................................................. 4 Item 5: Fees and Compensation .......................................................................................................................... 9 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 ......................................................................................................................... 12 Item 10: Other Financial Industry Activities and Affiliations ................................................................................ 12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................. 13 Item 12: Brokerage Practices ............................................................................................................................. 14 Item 13: Review of Acounts ................................................................................................................................ 15 Item 14: Client Referrals and Other Compensation .............................................................................................. 16 Item 15: Custody ................................................................................................................................................ 16 Item 16: Investment Discretion .......................................................................................................................... 17 Item 17: Voting Client Securities ........................................................................................................................ 17 Item 18: Financial Information............................................................................................................................ 17 3  ITEM 4: ADVISORY BUSINESS The Pitcairn family office was established in 1923. In 1987, the Pitcairn family established the Pitcairn Trust Company, which has provided investment management and trust services to clients. In 2024, the Pitcairn family formed Pitcairn Wealth Advisers ("Pitcairn"), which has been in business since becoming registered as an investment adviser with the U.S. Securities and Exchange Commission in 2024. The firm is owned by Pitcairn Financial Group LLC. Investment Advisory Services Pitcairn provides full-service wealth management solutions for individuals, families, trusts, foundations, and other business entities (each, a “Client”). Pitcairn assists Clients in the thoughtful creation of customized long-term wealth management strategies to meet their specific circumstances and goals. Such discretionary and non- discretionary investment advisory services (individually and collectively “Investment Advisory Services”) are offered on a fee basis. Pitcairn’s Investment Advisory Services are set forth in an investment advisory agreement entered into between Pitcairn and the Client. Pitcairn provides investment advisory services specific to the needs of each Client. Before providing such services, an investment adviser representative will ascertain the Client’s investment objectives including short and long-term goals, and risk tolerance. Thereafter, Pitcairn will recommend and/or allocate investment assets consistent with the designated investment objectives. Pitcairn primarily recommends Client allocations of investment assets among various individual equity (stocks), debt (bonds) and fixed income securities, mutual funds and/or exchange traded funds (“ETFs”) in accordance with the Client’s designated investment objective(s). Once allocated and evidenced through an investment policy statement, Pitcairn provides ongoing monitoring and review of account performance, asset allocation and Client investment objectives. It remains the Client’s responsibility to promptly notify Pitcairn if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Pitcairn’s previous recommendations and/or services. The Client may, at any time, impose reasonable restrictions, in writing, on the firm's investment management services. Family Office Services Pitcairn offers Clients a broad range of Family Office Services, as further described below, to families, individuals, and institutions. These Family Office Services include guidance pertaining to tax and estate planning, tax preparation, CFO services (including bill pay and cash flow forecasting), insurance and risk management (life, health, and property), and charitable gifting strategies and grant management. Additionally, Pitcairn provides its Clients with consolidated asset and investment portfolio reporting. At times, Pitcairn may propose suggestions to the Client regarding the Client’s life, health, or property insurance needs. Please refer to Conflicts Related to Affiliations in Item 10.C below for further information regarding insurance affiliates. Pitcairn provides guidance to Clients in tax and estate planning decisions – primarily related to our Clients achieving their investment planning objectives in the most tax-efficient manner possible. In doing so, Pitcairn does not act as an attorney in the implementation or oversight of a tax or estate plan or strategy; rather, it works with the Client’s independent counsel to achieve the Client’s objectives. Each of our Clients is served by the entire Pitcairn team which is supported by our in-house financial analysts, investment specialists, and our tax department. While each of these services is available on a stand-alone basis, certain family office services may also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management 4  engagement. If a Client retains Pitcairn to manage their investment portfolio on a discretionary or non- discretionary basis, such Client will need to also enter into an agreement outlining the desired specific family office services. In performing these services, Pitcairn is not required to verify any information received from the Client or from the Client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. Clients are advised that it remains their responsibility to promptly notify Pitcairn of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Pitcairn’s recommendations and/or services. Family Engagement Services Pitcairn offers extensive family engagement services to its ultra-high net worth Clients. These services focus on purpose and impact of wealth within a family. Family may be composed of one generation or a dynastic family comprised of many generations. The services Pitcairn provides include but are not limited to family governance, family dynamics, learning and development of the rising generation, and leadership and transition planning. Important Disclosures Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a Client, Pitcairn may provide financial planning and related consulting services separate from its advisory fee as set forth at Item 5 below. However, neither Pitcairn nor its investment adviser representatives assist Clients with the implementation of any financial plan, unless they have agreed to do so in writing. Pitcairn does not monitor a Client’s financial plan, unless specifically engaged to do so, and it is the Client’s responsibility to revisit the financial plan with Pitcairn, if desired. Furthermore, although Pitcairn may provide recommendations regarding non-investment related matters, such as estate planning, tax planning, and insurance, the Firm does not serve as an attorney, and no portion of its services should be construed as legal services. Accordingly, the Firm does not prepare estate planning documents. To the extent requested by a Client, the firm may recommend the services of other professionals for certain non- investment implementation purposes (i.e., attorneys, accountants, insurance, etc.), including certain of the Firm’s representatives in their individual capacities as licensed insurance agents (See disclosure at Item 10.C below). The Client is under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Firm and/or its representatives. If the Client engages a recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not the Firm, shall be responsible for the quality and competency of the services provided. Tax Preparation Services. Pitcairn may provide tax preparation services to Investment Advisory Services and Family Office Services Clients. Clients will be required to enter into a separate agreement detailing the tax preparation services to be provided as well as any additional fee that may be due to Pitcairn for providing such services. Fees for tax preparation services are negotiable and may vary depending on the type of tax return required to be prepared and the complexity involved with such preparation. No Client is under any obligation to engage Pitcairn to provide tax preparation services. Non-Discretionary Service Limitations. Clients that decide to engage Pitcairn for investment advisory services on a non-discretionary basis must be willing to accept that Pitcairn cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the Client. Therefore, Firm will be unable to affect any account transactions (as it would for its discretionary Clients) without first obtaining the Client’s consent. 5  Independent Managers. Pitcairn may recommend that the Client allocate a portion of a Client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the Client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets. Pitcairn will continue to render investment supervisory services to the Client relative to the ongoing monitoring and review of account performance, asset allocation, and Client investment objectives. The Firm generally considers the following factors when recommending Independent Manager(s): the Client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s) are exclusive of, and in addition to, Firm’s ongoing investment advisory fee, subject to the terms and conditions of a separate agreement between the Client and the Independent Manager(s). Firm’s advisory fee is set forth in Item 5 below. Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective Client can obtain many of the funds that may be utilized by Firm independent of engaging Firm as an investment advisor. However, if a prospective Client determines to do so, they will not receive Firm’s initial and ongoing investment advisory services. In addition to Firm’s investment advisory fee described below, and transaction and/or custodial fees discussed below, Clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Affiliated Private Fund. Firm and/or its owners are affiliated with GLAS Funds, an affiliated private investment fund of funds (the “Fund”), the complete description of which (the terms, conditions, risks, conflicts and fees) is set forth in the Fund’s offering documents. Firm, on a non-discretionary basis, may recommend that qualified Clients consider allocating a portion of their investment assets to the Fund. Firm’s Clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Unaffiliated Private Investment Funds. Firm also provides investment advice regarding unaffiliated private investment funds. Firm, on a non-discretionary basis, may recommend that certain qualified Clients consider an investment in unaffiliated private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. Firm’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a Client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Firm calculating its investment advisory fee. Firm’s fee shall be in addition to the fund’s fees. Firm’s Clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Risk. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each Client for review and consideration. Unlike liquid investments that a Client may own, private investment funds do not provide daily liquidity or pricing. Each prospective Client investor will be required to complete a Subscription Agreement, pursuant to which the Client shall establish that the Client is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation. In the event that Firm references private investment funds owned by the Client on any supplemental account reports prepared by Firm, the value(s) for all private investment funds owned by the Client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. 6  As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, Firm shall calculate its fee based upon the latest value provided by the fund sponsor. Interval Funds/Risks and Limitations. Where appropriate, Firm may utilize interval funds (and other types of securities that could pose additional risks, including lack of liquidity and restrictions on withdrawals). An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Therefore, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a Client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a Client may direct Firm, in writing, not to purchase interval funds for the Client’s account. Socially Responsible (ESG) Investing Limitations. Firm does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a Client to do so. If implemented, Firm shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Firm), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Portfolio Activity. Firm has a fiduciary duty to provide services consistent with the Client’s best interest. As part of its investment advisory services, Firm will review Client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager 7  tenure, style drift, account additions/withdrawals, and/or a change in the Client’s investment objective. Based upon these factors, there may be extended periods of time when Firm determines that changes to a Client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Cash Positions. Pitcairn treats cash as an asset class. As such, unless determined to the contrary by Pitcairn, all cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating Firm’s advisory fee. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Firm’s advisory fee could exceed the interest paid by the Client’s cash positions. Retirement Plan Rollovers–Conflict of Interest. A Client or prospective Client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the Client’s age, result in adverse tax consequences). If Firm recommends that a Client roll over their retirement plan assets into an account to be managed by Firm, such a recommendation creates a conflict of interest if Firm will earn new (or increase its current) compensation as a result of the rollover. If Firm provides a recommendation as to whether a Client should engage in a rollover or not, Firm is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No Client is under any obligation to roll over retirement plan assets to an account managed by Firm. Bitcoin, Cryptocurrency, and Digital Assets: Most digital assets use blockchain technology, an advanced cryptographic digital ledger to secure transactions and validate asset ownership. Unlike conventional currencies issued and regulated by monetary authorities, cryptocurrencies generally operate without centralized control, and their value is determined by market supply and demand. While regulatory oversight of digital assets has evolved significantly since their inception, they remain subject to variable regulatory treatment globally, which impacts their risk profile and liquidity. Bitcoin, cryptocurrency, and digital asset investments are speculative and subject to extreme price volatility, liquidity constraints, and the potential for total loss of principal. Investment in Bitcoin, cryptocurrencies, or digital assets carry the potential for liquidity constraints, extreme price volatility, regulatory risk, technological risk, security and custody risk, and complete loss of principal. At this time, the Firm does not consider digital assets to be a strategic asset holding and does not provide advice on investment in cryptocurrencies or digital assets or include an allocation to digital assets within a client's investment portfolio. If a client holds an account at Fidelity Digital Asset Services LLC ("FDAS"), the Firm will execute the client's unsolicited instructions to buy or sell digital assets in the client's FDAS account. The Firm will also report on the holdings (which will be shown as "non- managed" on portfolio reports) but will not take them into account when evaluating the client's portfolio. Client Obligations: In performing its services, Firm shall not be required to verify any information received from the Client or from the Client’s other professionals and is expressly authorized to rely thereon. Moreover, each Client is advised that it remains their responsibility to promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Firm’s previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that Firm and its third-party service providers use to provide services to Firm’s Clients employ various controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Firm’s operations and/or result in the unauthorized acquisition or use of Clients’ confidential or non-public personal information. 8  In accordance with Regulation S-P, the Firm is committed to protecting the privacy and security of its Clients' non- public personal information by implementing appropriate administrative, technical, and physical safeguards. Firm has established processes to mitigate the risks of cybersecurity incidents, including the requirement to restrict access to such sensitive data and to monitor its systems for potential breaches. Clients and Firm are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although the Firm has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that the Firm does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker- dealers, qualified custodians, governmental and other regulatory authorities, exchanges, and other financial market operators and providers. In compliance with Regulation S-P, the Firm will notify Clients in the event of a data breach involving their non-public personal information as required by applicable state and federal laws. As of January 2, 2025, Pitcairn advised on approximately $1,604,267,255 in Assets Under Advisement ("AUA"), which includes $775,801,961 in discretionary regulatory Assets Under Management ("AUM"). ITEM 5: FEES AND COMPENSATION Investment Advisory Services The Firm provides discretionary and non-discretionary investment management services on a fee basis. The Firm’s annual investment advisory fee shall vary and generally does not exceed 1.25%. Fees vary depending upon various objective and subjective factors, including but not limited to: the amount of assets to be invested, the complexity of the engagement, the anticipated number of meetings and servicing needs, related accounts, future earning capacity, anticipated future additional assets, and negotiations with the Client. As a result, similar Clients could pay different fees, which will correspondingly impact a Client’s net account performance. The Client's specific fee is set forth in a written agreement with the Client. Non-advisory Administrative Services The Firm provides services such as bill payment, reporting, and other administrative services to clients. The fees for these services are set forth in a written agreement with the Client. Family Office Services The Firm’s family office services are offered on an annual fixed fee basis. Fees vary depending upon various objective and subjective factors, including but not limited to: the amount of assets to be invested, the complexity of the engagement, the anticipated number of meetings and servicing needs, related accounts, future earning capacity, anticipated future additional assets, and negotiations with the Client. As a result, similar Clients could pay different fees. The Client's specific fee is set forth in a written agreement with the Client. USE OF RESEARCH AND INTELLECTUAL CAPITAL Through Firm, Clients may purchase the research and intellectual capital from investment managers and use Firm or a third-party to implement the research into the accounts. Model Portfolios may be implemented with or without tax overlay services. MODEL PORTFOLIO ACCOUNTS WITHOUT TAX OVERLAY SERVICES Tax-exempt accounts that do not require tax overlay are implemented by Firm for a fee of 20 basis points (bps). This fee is in addition to the research provider fees, which typically range from 15 to 50bps. 9  UNIFIED MANAGED ACCOUNTS (UMAs) WITH TAX OVERLAY SERVICES Taxable investors may choose to implement their US or international equity allocation in a tax‐efficient manner through a UMA. Given the complexities of tax overlay services within Firm’s UMA program and the sophisticated combination of model portfolios, fee rates for US Equity accounts utilizing a UMA are typically between 50 and 60bps. International Equity accounts have fee rates between 75 and 80bps. The tax overlay service listed above and implemented via UMA, includes research provider fees, overlay manager fees, and Firm’s platform fee. ADDITIONAL FEES Account-level fees are charged for tax, consolidated intermediary, and technology platform services that range from $550 to $750 per account. Clients may elect to have the Firm’s advisory fees deducted from their custodial account. Both Firm’s Agreement and the custodial/clearing agreement may authorize the custodian to debit the account for the amount of the Firm’s investment advisory fee and to directly remit that advisory fee to the Firm in compliance with regulatory procedures. The Firm is permitted to engage third party service providers to assist with fee billing and processing. When the Firm bills the Client directly, payment is due upon receipt of the Firm’s invoice. As discussed below, unless the Client directs otherwise or an individual Client’s circumstances require, Firm shall generally recommend that Fidelity Investments (“Fidelity”) provide custody services through National Financial Services, LLC (“NFS”) for Client investment management assets. Broker-dealers such as Fidelity charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker- dealer/custodian. While certain custodians, including Fidelity, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. There can be no assurance that Fidelity will not change its transaction fee pricing in the future. Fidelity may also assess fees to Clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Clients will incur, in addition to Firm’s investment management fee, brokerage commissions and/or transaction fees, and, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The Firm's annual investment advisory fee is prorated and billed monthly, in arrears, based upon the average daily balance of the assets during the previous month. 10  However, the Firm, in its sole discretion, may charge a lesser fee, charge a flat fee, or waive its fee entirely based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, grandfathered fee schedules, Firm employees and family members, courtesy accounts, competition, negotiations with Client, etc.). As result of the above, similarly situated Clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar, lower, or higher fees. Agreements between the Firm and the Client will continue in effect until terminated by either party by written notice in accordance with the terms of the Agreement. Upon termination, Client may be due a prorated portion of the monthly advisory fee based upon the number of days services were provided during the final month of the engagement. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Neither the Firm nor any supervised person of the Firm accepts performance-based fees. ITEM 7: TYPES OF CLIENTS The Firm’s Clients shall generally include individuals, single family offices, business entities, private foundations, trusts and estates. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS The Firm utilizes the following methods of security analysis: ◼ Fundamental - (analysis performed on historical and present data, with the goal of making financial forecasts) ◼ Technical – (analysis performed on historical and present data, focusing on price and trade volume, to attempt to forecast the direction of prices) Investment Risk. Investing in securities involves risk of loss that Clients should be prepared to bear. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Firm) will be profitable or equal any specific performance level(s). All investment strategies have certain risks that are borne by the investor. Although there is no way to list all risks involved with investing, the following are common risks born by the majority of investors: Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, bond prices generally fall. Market Risk: Asset prices may drop in reaction to certain unforeseen events. Also referred to as exogenous risk, this type of risk is caused by external factors independent of a security’s particular underlying fundamentals or intrinsic value. For example, geo-political, economic, legislative, and/or societal events may amplify market risk. 11  Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. Some industries and/or companies may have historically demonstrated more stability than others. Economic factors and business functions are constantly changing. Past results are no guarantee of future performance. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. Financial Risk: Also referred to as leverage risk. Excessive borrowing to finance a business’ operations may lead to financial strain and the ability to generate profits or meet certain obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Counterparty Risk: The risk that each party may not be able to meet its contractual obligations. This may also be referred to as default risk for fixed income investments. In rare circumstances, the underlying securities within registered investment products may become illiquid which may restrict the ability of investors to redeem shares at quoted prices. Execution Risk: The risk that buy/sell transactions may not be executed at favorable prices. This may occur during periods of abnormal market conditions. The Firm’s methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risks. For example, longer term investment strategies require a longer investment time period to allow for the strategy to potentially develop. Shorter term investment strategies require a shorter investment time period to potentially develop but, as a result of more frequent trading, will generally incur higher transactional costs when compared to a longer term investment strategy. ITEM 9: DISCIPLINARY INFORMATION The Firm has not been the subject of any disciplinary actions. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Pitcairn Trust Company LLC is an affiliated trust company offering trust and related services. The Firm may recommend Pitcairn Trust Company LLC to certain Clients in need of specialty services. Certain of Firm’s representatives may also provide services through Pitcairn Trust Company LLC. The recommendation of Pitcairn Trust Company LLC services to Clients by Firm or its representatives creates a conflict of interest. No Client is under any obligation to engage Pitcairn Trust Company LLC and Clients are 12  reminded they may engage other non-affiliated entities to provide the same or similar services offered by Pitcairn Trust Company LLC. Pitcairn Insurance Agency, LLC is an affiliated licensed insurance agency. Furthermore, certain of the Firm’s representatives, in their individual capacities, are licensed insurance agents offering insurance products through the Firm’s affiliated insurance agency. Insurance-related products may be recommended on a commission basis. The recommendation by Firm’s representatives that a Client purchase an insurance commission product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular Client’s need. No Client is under any obligation to purchase any commission products from Firm’s representatives. Clients are reminded that they may purchase insurance products recommended by Firm through other, non-affiliated insurance agencies or insurance agents. The Firm does not receive, directly or indirectly, compensation from investment advisors that it recommends or selects for its Clients. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. The Firm maintains an investment policy relative to personal securities transactions. This investment policy is part of Firm’s overall Code of Ethics, which serves to establish a standard of business conduct for all of Firm’s Representatives that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request. In accordance with Section 204A of the Investment Advisers Act of 1940, the Firm also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by the Firm or any person associated with the Firm. B. As disclosed above, the Firm has a financial interest in an affiliated fund. The terms and conditions for participation in the affiliated fund, including management fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. C. The Firm and/or representatives of the Firm may buy or sell securities that are also recommended to Clients. This practice may create a situation where the Firm and/or representatives of the Firm are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if the Firm did not have adequate policies in place to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of the Firm’s Clients) and other potentially abusive practices. The Firm has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of the Firm’s “Access Persons”. The Firm’s securities transaction policy requires that an Access Person of the Firm must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after 13  becoming an Access Person. Additionally, each Access Person must provide or make available to the Chief Compliance Officer or his/her designee a list of reportable transactions each calendar quarter as well as a written annual report of the Access Person’s securities holdings; provided, however that at any time that the Firm has only one Access Person, he or she shall not be required to submit any securities report described above. D. The Firm and/or representatives of the Firm may buy or sell securities, at or around the same time as those securities are recommended to Clients. This practice creates a situation where the Firm and/or representatives of the Firm are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. As indicated above in Item 11 C, the Firm has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Firm’s Access Persons. ITEM 12: BROKERAGE PRACTICES If the Client requests that the Firm recommend a custodian for execution and/or custodial services (exclusive of those Clients that may direct the Firm to use a specific custodian), the Firm recommends that investment management accounts be maintained at Fidelity. Before engaging the Firm to provide investment management services, the Client will be required to enter into a formal advisory agreement with the Firm setting forth the terms and conditions under which the Firm shall manage the Client's assets, and a separate custodial/clearing agreement with each designated custodian. Factors that the Firm considers in recommending Fidelity (or any other custodian to Clients) include historical relationship with the Firm, financial strength, reputation, execution capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid by our Clients shall comply with duty to seek best execution, a Client may pay a commission that is higher than another qualified custodian might charge to affect the same transaction where the Firm determines, in good faith, that the commission/transaction fee is reasonable. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a custodian’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although the Firm will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for Client account transactions. The brokerage commissions or transaction fees charged by the designated custodian are exclusive of, and in addition to, the Firm's investment management fee. The Firm’s best execution responsibility is qualified if securities that it purchases for Client accounts are mutual funds that trade at net asset value as determined at the daily market close. Research and Additional Benefits Although not a material consideration when determining whether to recommend that a Client utilize the services of a particular custodian, Firm receives from Fidelity (or another custodian, investment platform, unaffiliated investment manager, vendor, unaffiliated product/fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist Firm to better monitor and service Client accounts maintained at such institutions. Included within the support services that may be obtained by Firm may be investment-related research, pricing information and market data, software and other technology that provide access to Client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Firm in furtherance of its investment advisory business operations. 14  As indicated above, certain of the support services and/or products received may assist Firm in managing and administering Client accounts. Others do not directly provide such assistance, but rather assist Firm to manage and further develop its business enterprise. There is no corresponding commitment made by Firm to Fidelity or any other entity to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. The Firm does not generally accept directed brokerage arrangements (when a Client requires that account transactions be affected through a specific broker-dealer). In such Client directed arrangements, the Client will negotiate terms and arrangements for their account with that broker-dealer, and Firm will not seek better execution services or prices from other broker-dealers or be able to “batch” the Client's transactions for execution through other broker-dealers with orders for other accounts managed by Firm. As a result, Client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. In the event that the Client directs Firm to effect securities transactions for the Client's accounts through a specific broker-dealer, the Client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the Client determined to effect account transactions through alternative clearing arrangements that may be available through Firm. Higher transaction costs adversely impact account performance. Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. To the extent that the Firm provides investment management services to its Clients, the transactions for each Client account generally will be effected independently, unless the Firm decides to purchase or sell the same securities for several Clients at approximately the same time. The Firm may (but is not obligated to) combine or “bunch” such orders to seek best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among Clients in proportion to the purchase and sale orders placed for each Client account on any given day. The Firm shall not receive any additional compensation or remuneration as a result of such aggregation. As noted in Item 4, above, for clients who hold digital assets at Fidelity Digital Asset Services, LLC (“FDAS”), a New York state-chartered, limited liability trust company, the firm will execute client instructions to buy or sell digital assets in their FDAS accounts and will include those assets in the firm's consolidated reports. FDAS is not a broker-dealer, bank or other “qualified custodian” as that term is defined in the SEC Rules. FDAS stores and transacts in digital assets. Clients should be aware that although FDAS agrees to maintain an accurate, distinct record of each of its customers' digital assets, the assets themselves are commingled with those of other FDAS customers. ITEM 13: REVIEW OF ACCOUNTS A. For those Clients to whom Firm provides investment supervisory services, account reviews are conducted on an ongoing basis by the Firm’s representatives. All investment advisory Clients are advised that it remains their responsibility to advise the Firm of any changes in their investment objectives and/or financial situation. All Clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with the Firm on an annual basis. 15  B. The Firm may conduct account reviews on an other than periodic basis upon the occurrence of a triggering event, such as a change in Client investment objectives and/or financial situation, market corrections and Client request. C. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the custodian and/or program sponsor for the Client accounts. The Firm may also provide a written periodic report summarizing account activity and performance. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. As referenced in Item 12.A.1 above, the Firm receives an economic benefit from broker-dealers. The Firm, without cost (and/or at a discount), receives support services and/or products from broker-dealers. There is no corresponding commitment made by the Firm to a broker-dealer or any other entity to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. B. Neither the Firm nor its representatives compensate any non-supervised persons for Client referrals. ITEM 15: CUSTODY The Firm shall have the ability to have its advisory fee for each Client debited by the custodian on a monthly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the custodian and/or program sponsor for the Client accounts. The Firm may also provide a written periodic report summarizing account activity and performance. To the extent that the Firm provides Clients with periodic account statements or reports, the Client is urged to compare any statement or report provided by the Firm with the account statements received from the account custodian. The account custodian does not verify the accuracy of the Firm’s advisory fee calculation. Clients who hold digital assets at Fidelity Digital Asset Services, LLC , should be aware that FDAS is not a bank or broker-dealer or other “qualified custodian.” The firm will not accept authorization to deduct advisory fees or otherwise to move the Clients’ money or assets from their accounts at FDAS. The Firm also engages in other practices and services on behalf of its Clients that require disclosure at ADV Part 1, Item 9. Some of the practices and services subject the affected accounts to an annual surprise CPA examination in accordance with the requirements of Rule 206(4)-2 under the Investment Advisers Act of 1940. In addition, certain Clients have signed asset transfer authorizations which permit the qualified custodian to rely upon instructions from the Firm to transfer Client funds to “third parties.” These arrangements are also reflected at ADV Part 1, Item 9, but in accordance with the guidance provided in the SEC’s February 21, 2017 Investment Adviser Association No- Action Letter, the affected accounts are not subjected to an annual surprise CPA examination. 16  ITEM 16: INVESTMENT DISCRETION The Client can determine to engage the Firm to provide investment advisory services on a discretionary basis. Prior to the Firm assuming discretionary authority over a Client’s account, the Client shall be required to execute an Investment Advisory Agreement, naming the Firm as the Client’s attorney and agent in fact, granting the Firm full authority to buy, sell, or otherwise effect investment transactions involving the assets in the Client’s name found in the discretionary account. Clients who engage the Firm on a discretionary basis may, at any time, impose reasonable restrictions, in writing, on the Firm’s discretionary authority (i.e., limit the types/amounts of particular securities purchased for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe the Firm’s use of margin, etc.). Any restrictions on the Firm’s discretionary authority must be acknowledged by the Registration prior to becoming effective. ITEM 17: VOTING CLIENT SECURITIES Unless a Client directs otherwise, in writing, Firm shall be responsible for directing the manner in which proxies solicited by issuers of securities purchased by Firm for the Client’s account shall be voted. However, the Client shall maintain exclusive responsibility for all legal proceedings or other type events pertaining to the assets, including, but not limited to, class action lawsuits. Firm and/or the Client shall correspondingly instruct each custodian of the assets to forward to Firm copies of all proxies and shareholder communications relating to the assets. Absent mitigating circumstances and/or conflicts of interest (to the extent any such circumstance or conflict is presented), it is Firm’s general policy to vote proxies consistent with the recommendation of the senior management of the issuer. Firm shall monitor corporate actions of individual issuers and investment companies consistent with Firm’s fiduciary duty to vote proxies in the best interests of its Clients. Firm shall maintain records pertaining to proxy voting as required under the Advisers Act. Information pertaining to how Firm voted on any specific proxy issue is also available upon written request. ITEM 18: FINANCIAL INFORMATION A. The Firm does not require Clients to pay fees of more than $1,200, per Client, six months or more in advance. B. The Firm is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain Client accounts. C. The Firm has not been the subject of a bankruptcy petition. 17