PJS INVESTMENT MANAGEMENT

Part 2A of Form ADV: Firm Brochure PJS Investment Management Registered as: P.J. Schmidt Investment Management, Inc. W62 N570 Washington Avenue Cedarburg, WI 53012 Telephone: 1-262-377-0484 Email: pjsman@pjschmidt.com Web Address: www.pjsinvestment.com March 27, 2026 This brochure provides information about the qualifications and business practices of PJS Investment Management. If you have any questions about the contents of this brochure, please contact us at 1-262- 377-0484 or pjsman@pjschmidt.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. Additional information about PJS Investment Management also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 104701.  Item 2 Material Changes Since the last annual update to our brochure dated March 26, 2025, the following material changes have been incorporated in the brochure to align our business practices and compliance program: Item 8- Methods of Analysis, Investment Strategies and Risk of Loss This item was updated to add risks related to the use of artificial intelligence. 2  Item 3 Table of Contents Item 4 Advisory Business .....................................................................................................................4 Item 5 Fees and Compensation ............................................................................................................7 Item 6 Performance-Based Fees and Side-By-Side Management ...........................................................9 Item 7 Types of Clients ........................................................................................................................9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss.................................................... 10 Item 9 Disciplinary Information ......................................................................................................... 15 Item 10 Other Financial Industry Activities and Affiliations ................................................................... 15 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 15 Item 12 Brokerage Practices ................................................................................................................ 16 Item 13 Review of Accounts ................................................................................................................ 19 Item 14 Client Referrals and Other Compensation ................................................................................ 19 Item 15 Custody .................................................................................................................................. 20 Item 16 Investment Discretion ............................................................................................................. 20 Item 17 Voting Client Securities ........................................................................................................... 21 Item 18 Financial Information .............................................................................................................. 21 Other Information.................................................................................................................................. 21 3  Item 4 Advisory Business PJS Investment Management (“PJS”) is an SEC-registered investment adviser with its principal place of business located in Wisconsin. Phillip Schmidt founded the firm and began conducting business in 1981. PJS is currently owned by a group of employees of the firm. No single individual controls more than 25% of the outstanding shares of the company. PJS offers the following advisory services to our clients: PORTFOLIO MANAGEMENT Our firm provides continuous asset management of client funds based on the needs of the client. Through personal discussions in which goals and objectives based on the client's circumstances are established, we develop the client's investment policy. We create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s objectives, time horizons, risk tolerance, investment restrictions and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. We manage advisory client accounts on a discretionary basis. We do have some legacy advisory client accounts that we manage on a non-discretionary basis, but we no longer accept new advisory clients on a non-discretionary basis. Account supervision is guided by the client's stated objectives (e.g., growth, growth and income, balanced or income), as well as tax considerations. Once the client's portfolio has been established, we review the portfolio periodically, and if necessary, rebalance the portfolio based on the client's investment policy. Individual holdings are reviewed on a continuous basis. Our investment recommendations are not limited to any specific product or service. We will generally include advice regarding the following security types: • Exchange-listed securities • Securities traded over the counter • Certificates of Deposit • Corporate debt securities (other than commercial paper) • Municipal securities • Mutual funds and Exchange Traded Funds (“ETFs”) • Unregistered private funds • United States governmental securities • Annuities • ETFs investing in precious metals (gold, silver, platinum, and palladium), bullion or coin 4  Because some types of investments involve certain additional degrees of risk, they will only be implemented when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. FINANCIAL PLANNING We provide financial planning services only to clients who choose to use this service and engage PJS for portfolio management services. Financial planning is a comprehensive evaluation of a client’s current and future financial situation by using currently known variables to predict future cash flows, asset values and withdrawal plans. Moreover, according to the Certified Financial Planner Board of Standards, financial planning is a collaborative process that maximizes a client’s potential for meeting life goals through financial advice that integrates relevant elements of the client’s personal and financial circumstance. Through the financial planning process, all questions, information, and analysis are considered as they affect and are affected by the financial and life situation of the client. We gather the required information through personal interviews, collection of documents and by asking the client to complete questionnaires. The information gathered includes the client's current financial status, income, expenses, tax status, future goals, return objectives and attitudes towards risk. We carefully review the information supplied by the client and provide a plan with recommendations. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, and insurance agent. Implementation of financial plan recommendations is entirely at the client's discretion. In general, the financial plan can address any or all the following areas, depending on each client’s needs and desires: PERSONAL: Review family records, budgeting, personal liability, estate information and financial goals. INVESTMENTS: Analyze investment strategies, expectations, tolerance for risk, and their effect on the client's portfolio. BUDGETING AND CASH FLOW: Analyze the client’s income tax and spending while planning for past, current, and future years. TAX PLANNING: Assist tax advisors with planning particularly when it comes to investment and future cash- flow planning, e.g., illustrate the impact of various investments on the client's current income tax and future tax liability. INSURANCE (RISK MANAGEMENT): Review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. RETIREMENT: Analyze current strategies and investment plans to help the client achieve their retirement goals. 5  DEATH & DISABILITY: Review the client’s cash needs at disability and death to determine income needs for surviving dependents. ESTATE: Assist the clients and their legal professionals in assessing and developing long-term strategies, including as appropriate, living trusts, wills, reviewing estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. We also provide general non-securities related financial advice and assistance on life transitions such as marriage, loss of a spouse, divorce, business planning, receiving an inheritance or other sudden accumulation event. RETIREMENT PLAN SERVICES We offer retirement plan services as defined under Section 3(38) (“3(38) services”) of the Employee Retirement Income Security Act (“ERISA”) which means PJS has discretionary authority to determine investment options. For certain existing clients we provide retirement plan services as defined under Section 3(21) of ERISA which means we make investment recommendations to the plan sponsor who has discretion to accept or reject. The primary clients for these services are pensions, profit sharing and 401(k) plans. Retirement Plan Services are comprised of the following: Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We will meet with the client to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the plan. Our firm then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring investment performance. Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We will then review various mutual funds (both index and managed) and ETFs to determine which investments are appropriate to implement the client's IPS. The number of investments to be recommended will be determined by the client, based on the IPS. When PJS is providing 3(38) services, PJS has discretionary authority to determine investment options. Monitoring Investment Performance: We monitor client investments and the overall performance of the account and provide advice regarding potential changes to the investment options. When PJS provides 3(38) services, PJS has discretionary authority to make investment decisions on behalf of the client. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account ('self-directed plans’), we also provide educational support and investment workshops designed for the plan participants when the plan sponsor engages our firm to provide these services. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. 6  AMOUNT OF MANAGED ASSETS As of 12/31/2025, we were actively managing client assets in the amount of $852,009,988 of which, $826,755,700 were on a discretionary basis plus $25,254,288 of client assets on a non-discretionary basis. Item 5 Fees and Compensation PORTFOLIO MANAGEMENT SERVICES FEES Effective December 2008, the annualized investment advisory fee for Portfolio Management Services is charged as a percentage of assets under management, according to the following schedule: Assets Under Management Annual Fee $0-$1,000,000 1% $1,000,001-$2,000,000 .8% $2,000,001-$3,000,000 .7% $3,000,001-$4,000,000 .6% Balance of Assets .5% Clients of PJS retained prior to December 2008 may pay investment advisory fees based on a lower fee schedule. FINANCIAL PLANNING FEES Financial Planning services are provided exclusively to clients for whom PJS provides portfolio management services, for no additional fee. RETIREMENT PLAN SERVICES FEES Effective March 2014, our fees for Retirement Plan Services are as follows. Assets Under Management Annual Fee $0 - $4,000,000 .6% Balance of plan assets .4% Retirement Plan Services clients retained prior to March 2014 may pay fees based on lower fee schedule. Plan sponsors are invoiced in advance at the beginning of each calendar quarter. A total minimum fee of $5,000 is required. This minimum fee may prevent PJS from providing services to very small ERISA plans. 7  NEGOTIABILITY OF ADVISORY FEES AND MINIMUMS Although PJS has established these fee schedule(s), we retain the discretion to negotiate alternative fee schedules, minimum required investable assets and minimum fees. As a result, some clients will pay different fees compared to other similarly situated clients. The client fee schedule is identified in the contract between PJS and each client. We may group certain related client accounts for the purpose of achieving the minimum account size and determining the annualized fee. Discounts not generally available to our advisory clients are often offered to family members and friends of associated persons of our firm. Fees associated with accounts managed by PJS for employees are waived. FEE CALCULATION PROCEDURES Fees are billed quarterly in advance based on the market value of the client’s account on the last day of the prior quarter. No adjustments to fees are made based on cash flows in the client account in any quarter. Initial investment advisory fees are charged in arrears on a pro rata basis using the market value of the account from the first day PJS begins trading through the end of the calendar quarter in which the account was opened. See the General Information section below which describes how terminated accounts are handled. PJS believes that all asset classes (e.g., equities, fixed income, and cash) are valuable tools in implementing investment strategies. As such, fees for our services are based on each account’s total value including cash and cash equivalents. Fees may be paid by direct debit from client accounts, or clients may choose to receive an invoice and pay by check. PJS uses pricing information provided by the client’s custodian for purposes of valuing client portfolios, whether for fee billing or investment performance calculations. The prices of securities we routinely recommend to clients are generally available through the client’s custodian, and do not generally require us to independently determine a fair market value. PJS maintains account valuation (including fair valuation) policies and procedures designed to provide reasonable assurance that the prices used for fee billing and investment performance calculation purposes are accurate. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled as delineated in the client’s investment advisory agreement. As disclosed above, fees are paid in advance of the services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement, we consider fees earned from the beginning of the calendar quarter through 30 days following notice of termination from the client. Fund Fees and Expenses: All fees paid to PJS for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds, exchanged traded funds, or unregistered private funds to their shareholders and investors. These fees and expenses are described in each fund's prospectus or governing documents. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client will pay an initial or deferred sales charge. A client could invest in a fund directly, without our services. In that case, the client would not receive 8  the services provided by our firm which are designed, among other things, to assist the client in determining which funds are most appropriate to each client's financial situation and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction or commission charges imposed by a broker dealer with which PJS effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Retirement Accounts: PJS is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Internal Revenue Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, PJS will only charge fees for investment advice, and our firm and related persons do not receive any commissions or 12b-1 fees. Advisory Fees in General: Clients should note that similar advisory services may be available from other registered (or unregistered) investment advisers for similar or lower fees. Item 6 Performance-Based Fees and Side-By-Side Management PJS does not charge performance-based fees but some of the private funds we recommend to clients could charge performance-based fees. A performance-based fee arrangement is one in which a client is assessed by the private fund a percentage of the net profits of the client’s investment in the private fund. Information about the private fund’s fees is included in the fund’s governing documents provided to the client before investing in the private fund. PJS only recommends private funds that charge performance-based fees to clients who meet the eligibility requirements of Rule 205-3 under the Investment Advisers Act of 1940. The minimum requirements under the rule state that the client generally is not eligible unless he/she has at least $1,100,000 under management with PJS or has a net worth of at least $2,200,000. Item 7 Types of Clients PJS provides advisory services to the following types of clients: • Individuals (other than high-net-worth individuals) • High net worth individuals • Pension, profit-sharing and 401(k) plans • Charitable organizations 9  • Corporations or other businesses not listed above PJS also manages accounts for employees, family members and friends of PJS employees. All clients are required to enter into an investment advisory agreement with PJS prior to providing any services. We prefer to manage a minimum of $500,000 of investable assets under this service; however, this minimum may be waived at our discretion. We may group certain related client accounts for the purpose of achieving the minimum account size and determining the annualized fee. PJS also manages a proprietary firm account invested in ETFs that are also recommended to clients. PJS maintains an investment policy statement for this account that is reviewed by PJS’s Board of Directors. When there is an overlap in trade recommendations for this proprietary account and client accounts, the proprietary account trades will go after any client trades in the same security. PJS maintains trading policies and a Code of Ethics and Personal Trading policy designed to assist in addressing conflicts of interest should they arise. Please see Item 12 for a discussion of PJS’s trading practices. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS The combined use of Fundamental Analysis, Technical Analysis, Cyclical Analysis, Qualitative Analysis and Asset Allocation is intended to gain the advantages of each method while limiting the risk of solely relying on a single approach. Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is attractively priced for purchase or overpriced (indicating it may be time to sell). Fundamental analysis does not focus on anticipated market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis: We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk that a poorly managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. 10  A risk is using qualitative analysis is that our subjective judgment may prove incorrect. Asset Allocation: We attempt to identify an appropriate ratio of stocks, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of exclusively using asset allocation is that it may limit client participation in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of equity, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to successfully invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF to determine if there is a significant overlap in the underlying investments held in other funds in the client’s portfolio. We also monitor the funds or ETFs to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as with all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES AND MODELS Our Wealth Advisers work closely with clients to develop portfolios that we believe are best suited to meet the client’s objectives. Our typical approach to portfolio construction includes investment strategies based on individual securities, model portfolios made up of open-end mutual funds and exchange traded funds, or a combination of the two approaches. The chosen approach depends on the client’s individual circumstances, preferences, size of the account to be managed, and whether there are special requests or restrictions placed on the account. All investment strategies and models are overseen by the Chief Investment Officer of PJS with support from the Investment Committee. Selection of securities for the investment strategies is completed by the Chief Investment Officer utilizing various industry research resources available to us for free or by subscription. To support the design of model portfolios, PJS has entered into a licensing agreement with Fidelity Institutional Wealth Adviser LLC (“FIWA”), an affiliate of Fidelity Brokerage Services LLC (see Item 12 for information on this brokerage relationship). This arrangement allows PJS to leverage the research services of FIWA to provide 11  model optimization and augment our due diligence capabilities. The models provided by FIWA include Fidelity sponsored funds as well as third-party funds. Models provided by FIWA are based on parameters and criteria defined by PJS and PJS retains the responsibility to review and approve all models and updates to models before they are implemented in client accounts. PJS does not pay a fee to FIWA for this service, but the agreement with FIWA requires PJS to commit to maintaining a minimum amount of assets in the licensed model portfolios. This requirement provides an incentive for PJS to incorporate model portfolios into client accounts so PJS can continue to use the services provided by FIWA. PJS maintains portfolio management policies and procedures to ensure appropriate oversight of the use of the services provided by FIWA and the conflicts associated with this arrangement. We use the following methods in managing client accounts, provided that they are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases: We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when: • We believe the securities to be currently undervalued, and/or • We want exposure to a particular asset class over time, regardless of the short-term projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-term purchases: When utilizing this strategy, we purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. For example, purchasing a stock that is fundamentally sound but may have declined in value due to near-term market conditions or company developments. Asset Allocation: We use allocation as a central part of formulating client investment strategies. Each client portfolio is assigned an asset allocation objective which is designed to balance income needs, risk tolerance and relative opportunities among stocks, bonds, cash and other assets. Our other strategies are applied to individual investments within each allocation sector. GENERAL RISKS PJS does not offer any products or services that guarantee rates of return on investments for any time period to any client. All clients assume the risk that investment returns may be negative or below the rates of return of other investment advisers, market indices or investment products. 12  SECURITY RISKS Client accounts may be subject to the following risks: Market Risk: Clients should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Market risks, including but not limited to political, regulatory, economic and social developments, and developments that impact specific economic sectors, industries or segments of the market, can affect the prices of securities in which clients invest which impacts the value of client accounts. In addition, turbulence in financial markets and reduced liquidity in equity, credit and/or fixed income markets may negatively affect many companies, which could adversely affect client accounts. These risks may be magnified if certain events or developments adversely interrupt the global supply chain. In these and other circumstances, such risks might affect companies on a worldwide scale. Recent examples include risks related to the coronavirus pandemic and the implementation of broad-based tariffs. Allocation Risk: At times, our judgments as to the asset classes in which client accounts should invest may prove to be wrong, as some asset classes may perform worse than others or the equity and bond markets generally from time to time or for extended periods of time. Mutual Fund Risk: Mutual funds vary in risk depending on their investments, with aggressive growth funds being riskier than conservative, income-oriented funds. Mutual funds are subject to investment advisory, transactional, operating, and other expenses. The value of mutual funds’ investments and the net asset value of the funds’ shares will fluctuate in response to changes in market and economic conditions, as well as the financial condition and prospects of companies in which the funds invest. The performance of each fund will depend on whether the fund’s investment adviser is successful in pursuing the fund’s investment strategy. ETF Risk: You may lose money investing in an ETF if the value of securities owned by the ETF declines. You could pay more to purchase ETF shares, or receive less in a sale of shares, than the actual net asset value of the shares. In addition, when you invest in an ETF, you will bear additional expenses based on your pro rata share of the ETF’s operating expenses. The risk of owning an ETF generally reflects the risks of the underlying securities that the ETF is designed to track and the investment strategies employed by such ETF. The ETF may not track the underlying index or be successful in pursuing its investment strategy. Fixed Income Risk: A bond’s market value is affected significantly by changes in interest rates. Generally, when interest rates rise, the bond’s market value declines and when interest rates decline, its market value rises. Generally, a bond with a longer maturity will entail greater interest rate risk but may have a higher yield. Conversely, a bond with a shorter maturity will entail less interest rate risk but may have a lower yield. An additional risk is reinvestment risk that future cash flows will need to be invested in lower yielding securities. A bond’s value may also be affected by changes in its credit quality rating or the issuer’s financial condition. Equity Securities Risk: Stocks generally increase or decrease in value based on the earnings of a company and based on general industry and market conditions. The value of a company’s share price may decline as a result of poor decisions made by management, lower demand for the company’s services or products or if the company’s revenues fall short of expectations. There are also risks associated with the stock market overall. The stock market may experience periods of turbulence and instability. 13  Municipal Securities: Municipal securities carry different risks than other fixed income securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal level but may be taxable in individual states other than the state in which both the client and municipal issuer are domiciled. Longevity Risk: This is the risk of outliving your savings. This risk is particularly relevant for people who are retired or are nearing retirement. Environmental, Social and Governance (“ESG”) Risk: Mutual funds and ETFs in which clients invest may invest in companies that have an ESG focus or hold themselves out as ESG funds. This may result in the funds investing in securities or industry sectors that underperform the market as a whole or underperform other funds screened for ESG standards. Precious Metals Risk: Mutual funds and ETFs in which clients invest may invest a portion of, or even all their assets, in precious metals and precious metals mining companies. This may result in lower returns as they respond to economic and market conditions. Foreign Securities Risk: Mutual funds and ETFs in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that the mutual funds and ETFs invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. CYBERSECURITY RISK PJS and its service providers rely on information technology and electronic communications to conduct business, which subjects PJS and its clients to the risk of cyber incidents. While PJS has reasonable controls designed to protect against cyber incidents resulting in unauthorized access to confidential information or business disruptions, not all cyber incidents are preventable. Should a cyber incident occur, it could have a negative impact on PJS and its clients. NATURAL DISASTER/EPIDEMIC/PANDEMIC RISK Natural or environmental disasters, such as severe weather and widespread disease, including pandemics and epidemics, have been and can be highly disruptive to economies and markets, adversely impacting individual companies, sectors, industries, markets, currencies, interest and inflation rates, credit ratings, investor sentiment, and other factors affecting the value of client accounts. Given the increasing interdependence of global economies and markets, conditions in one country, market, or region are increasingly likely to adversely affect markets, issuers, and/or foreign exchange rates in other countries, including the U.S. These disruptions 14  could prevent PJS from executing advantageous investment decisions in a timely manner and negatively impact PJS’s ability to achieve the investment objectives of its asset allocations. These disruptions could also prevent PJS and its vendors or service providers from maintaining normal business operations or could result in the loss of services of key personnel on a temporary or long-term basis due to illness or other reasons. Any such event(s) could have a significant adverse impact on the value of client accounts and the risk profile of clients’ asset allocations. ARTIFICIAL INTELLIGENCE (“AI”) RISK PJS currently uses Artificial Intelligence (“AI”) programs, software or vendors to assist an employee in performing their job more productively or efficiently. PJS maintains a list of approved AI tools, including the specific permitted use for each. Given the rapidly evolving nature of AI tools, PJS may begin using AI for other purposes in the future. Use of AI and machine learning technology can result in enhanced productivity and efficiency, however use of such technology also leads to additional risk to PJS and its clients. AI tools could potentially rely on outdated, inaccurate, incomplete or biased data which could create inaccurate output. Use of AI tools creates risk around security, privacy and confidentiality of data entered into AI tools. Additionally, because of the evolving nature of AI technology and common uses by businesses in the financial service industry, AI use could be subject to rapidly evolving regulatory environment which may impact if and how PJS is able to use AI in the future. Finally, PJS’s service providers may utilize AI tools, potentially without PJS’s knowledge, despite efforts to oversee such service providers, leading to additional AI risk exposure. PJS maintains an Artificial Intelligence Policy to govern the use of AI which aims to ensure any risks or conflicts of interest associated with such tools are evaluated and mitigated. The Artificial Intelligence Policy includes provisions for the review and approval of AI tools prior to their use, a requirement for human oversight of the output of any AI tool, controls around maintaining the confidentiality of data associated with AI tools and a requirement that PJS employees be appropriately trained on AI use and related risks. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations Our firm and our related persons are not engaged in other financial industry activities and have no other industry affiliations. Code of Ethics, Participation or Interest in Client Transactions and Item 11 Personal Trading Our firm has adopted a Code of Ethics which sets forth the ethical standards of business conduct that we 15  require of our employees, including compliance with applicable federal securities laws. PJS and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics is designed to ensure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and individuals associated with our firm may buy or sell securities for their personal accounts identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in certain securities which are also recommended to a client. Our Code of Ethics includes policies and procedures for the preclearance of certain personal securities transactions, review of personal securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. No access person is permitted to execute a personal security transaction in the same security if it being purchased or sold in a client account or if PJS has decided to purchase or sell the same security in a client account but has not yet submitted the trade. PJS has adopted an exception to the aforementioned restrictions for certain equity and ETF personal security transactions if they meet a stated de minimis as outlined in PJS’s Code of Ethics and personal trading policy. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that transactions in these securities would not materially interfere with our client’s best interest. However, the Code requires pre-clearance of transactions in many other securities including the acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Nevertheless, because the Code of Ethics permits employees and advisors to invest in the same securities (or related securities such as warrants, options or futures) as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Our Code provides for oversight, enforcement and record keeping provisions as well as the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to pjsman@pjschmidt.com, or by calling us at 1-262-377-0484. Item 12 Brokerage Practices PJS permits the client to select a broker/dealer. Clients who direct a specific broker/dealer, including pre-existing broker/dealers, may limit or eliminate PJS's ability to obtain best execution and the ability to negotiate commissions. Resulting broker/dealer commissions and transaction fees may be higher than what might have been charged for transactions at another qualified 16  broker/dealer. In accounts where the client has not directed the use of a specific broker/dealer we will recommend a broker/dealer that has demonstrated an ability to provide efficient execution and service. In those situations, we usually recommend Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") to serve as broker/dealer and custodian. PJS and Fidelity are not affiliated. However, we do maintain an arrangement through which they provide their Institutional Brokerage services. The details of this arrangement are disclosed below. Fidelity Investments Institutional Brokerage: PJS has an arrangement with National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which Fidelity provides our firm with their "institutional platform services.” The platform services include, among others, brokerage, custody, and other related services. Fidelity’s institutional platform services are intended to support intermediaries like PJS in serving the best interests of our clients, but these services also benefit us directly. As part of the arrangement, Fidelity’s platform services that assist us in managing and administering client accounts include software and technology that provide (i) access to client account data; (ii) facilitate trade execution and allocate aggregated trade orders; (ii) facilitate payment of fees from clients’ accounts; and (iv) assist us with back-office functions, recordkeeping and client reporting. Fidelity also offers other services intended to help our firm manage and further develop its advisory practice. Such services include, but are not limited to, performance reporting, contact management systems, third party research, publications, access to educational conferences, roundtables and webinars, practice management resources, access to consultants and other third-party service providers who provide a wide array of business-related services and technology with whom PJS may contract directly. Further, we have entered into a licensing agreement with Fidelity Institutional Wealth Adviser LLC (“FIWA”), an affiliate of Fidelity. Please see Item 8 – Investment Strategies and Models for information on our agreement with FIWA and associated conflicts of interest. PJS does not engage in pre-arranged soft dollar arrangements, which are formal arrangements where PJS specifically directs client brokerage commissions to a broker-dealer in return for brokerage or research services that PJS may use in making investment decisions for its clients. However, Fidelity is providing PJS with certain brokerage and research products and services that qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934 ("Exchange Act"). Items and services provided by Fidelity, which meet the criteria, include research, practice management tools, proprietary software, invitations to conferences free of charge including the payment of related travel expenses, compliance resources, webinars, pricing and market data. PJS maintains a Code of Ethics and brokerage policies to address such conflicts of interest. Fidelity charges brokerage commissions and transaction fees to our clients for affecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity, ETF and debt securities transactions). Fidelity enables PJS to purchase many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates. However, the 17  commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As a result of receiving the services outlined above at no additional cost, we have an incentive to continue to use or expand the use of Fidelity's services. We examined this potential conflict of interest when we chose to enter the relationship with Fidelity and have determined that the relationship is in the best interests of PJS's clients and satisfies our client obligations, including our duty to seek best execution. 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 broker-dealer’s services, including the value of research provided, execution capability, commission rates, responsiveness, knowledge of and dominance in specific markets, securities and industries, financial condition of the firm and reputation and integrity of the firm and acceptable record keeping, administrative and settlement functions. Accordingly, while PJS will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. Research, brokerage or other services received in connection with soft dollar arrangements will not be used solely for the accounts that generated the brokerage commission but will generally be used in managing all client accounts. Aggregation and Allocation of Trades: PJS will aggregate (block”) trades when possible. Orders entered on behalf of more than one client for the same security that are executed through Fidelity will be aggregated, and only clients whose orders are executed through Fidelity will have the opportunity to participate in block trades. Aggregating permits the trading of securities composed of assets from multiple client accounts, in an effort to obtain best execution at the best security price available. PJS manages accounts for firm personnel (“employee accounts”) which are invested in PJS’s investment models, as appropriate. These employee accounts may be included in a block order along with client trades when PJS determines: 1) no client is harmed by the employee accounts participating in the block order; 2) the employee accounts are not unfairly advantaged by trading along with client accounts; and 3) clients received the same or better price as the employees on the security transactions. In the event there are the same security trades at multiple custodians, PJS will place those trades in a systematic rotational order. PJS manages a proprietary firm account invested in ETFs that are also recommended to clients. PJS maintains an investment policy statement for this account that is approved by PJS’s Board of Directors. When there is overlap in trade recommendations for this proprietary account and client accounts, the proprietary account trades will go after any client trades in the same security. The proprietary account does not participate in block trades with client accounts. Trades are generally placed with Fidelity for execution twice per day, but all trades are allocated at the end of the day so all clients participating in the same security trades that day will receive an average price. If a block order is filled (full or partial fill) at several prices through multiple trades, an average price will be calculated for all trades executed by the broker/dealer for the block and all participants in the block will receive the average price. Only trades executed within the block on the single day may be combined for purposes of calculating the average price. Clients participating in an aggregated order pay commission rates based on the client’s agreement with the custodian/broker, which could be charged as a flat fee per trade or on a per-share basis. Commission rates are generally the same as the client would pay if the trades had not been aggregated. 18  Trade Errors: It is PJS’s policy for clients to be made whole following a trade error. When PJS causes a trade error to occur in a client account that results in a loss, PJS will reimburse the client, unless the executing broker, third party investment company or other relevant third party has a specific policy on how client accounts are made whole. If the trade error results in a gain and the client’s account is custodied at Fidelity, the gain will be donated to the charity of PJS’s choice as periodically communicated to Fidelity by PJS. If the trade error results in a gain and the client’s account is not custodied at Fidelity, the client will keep the gain. Courtesy Trades: PJS may, on occasion, execute trades within client’s custodial account upon receipt of written or verbal direction from a client as a courtesy. PJS considers these discretionary assets under management. Item 13 Review of Accounts REVIEWS: While the underlying securities within accounts are continually monitored, individual accounts are reviewed periodically and clients are offered at least annually an opportunity to meet with a wealth adviser either in-person, by telephone, or via video conference. Accounts are reviewed in the context of each client's portfolio, performance, asset allocation, market conditions, financial circumstances and stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive from their broker-dealer and custodian, PJS will provide quarterly written reports summarizing account performance, balances, and holdings. Item 14 Client Referrals and Other Compensation Fidelity Wealth Advisor Solutions Although PJS no longer participates in the program as of December 2018 certain of our clients were referred to us under the Fidelity Wealth Advisor Solutions Program (the “WAS Program”). Through this program PJS received referrals from Strategic Advisers, Inc. (“SAI”), a registered investment adviser and subsidiary of FMR LLC, the parent company of Fidelity Investments. PJS is independent and not affiliated with SAI or FMR LLC. SAI does not supervise or control PJS, and SAI has no responsibility or oversight for PJS’s provision of investment management or other advisory services. Under the WAS Program, SAI acted as a solicitor for PJS, and PJS pays ongoing fees to SAI for each past referral received based on PJS’s assets under management attributable to each client referred by SAI or members of each client’s household. Referred clients were not charged additional fees to cover solicitation fees paid to SAI by PJS. Pursuant to these arrangements, PJS has agreed not to solicit WAS Program clients to transfer their brokerage accounts from affiliates of SAI or establish brokerage accounts at other custodians for referred clients other than when PJS’s fiduciary duties would require; therefore, PJS has an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of SAI. However, participation 19  in the WAS Program does not limit PJS’s duty to select brokers on the basis of best execution. Other Compensation and Benefits It is PJS’s policy not to accept or allow our employees to accept cash, sales awards or other prizes from third parties in conjunction with the advisory services we provide to our clients. From time to time, certain employees receive non-cash benefits from investment managers or fund sponsors with which PJS does business. Examples of these benefits include invitations to attend conferences or educational seminars, payment of related travel, lodging and meal expenses, and receipt of gifts and entertainment. Receipt of these benefits provides an incentive to favor those that provide these benefits. PJS addresses this conflict of interest through disclosure in this Brochure and by implementing a Code of Ethics designed to address and limit the receipt of non-cash benefits. In addition, PJS’s due diligence and selection process does not consider any benefits that have or may be received. PJS occasionally hosts events, the expenses of which may be paid, in whole or in part, by firms whose products, such as mutual funds or ETFs, are recommended to clients by PJS which creates an incentive for PJS to recommend investments to clients where the sponsor of the fund is reimbursing PJS for such expenses. PJS has procedures in place to monitor these event sponsorships for conflicts of interest and to provide reasonable assurance the amounts received do not exceed $5,000 from any one party. Item 15 Custody PJS does not maintain custody of client assets, except as a consequence of our ability to directly debit fees from client accounts and our ability to direct transactions to third parties contingent upon a signed standing letter of authorization from a client and certain other requirements being met. We have written authorization from clients to engage in these transactions and comply with applicable regulatory guidance. As part of the billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there is an error in their statement. In addition to the periodic statements that clients receive directly from their custodians, we also send account statements directly to our clients on a quarterly basis. We urge our clients to carefully compare the information provided in these statements to ensure that all, holdings and values are correct and current. We also maintain policies and procedures designed to provide reasonable assurance our client’s qualified custodian is sending monthly and quarterly statements to our clients and that we do not inadvertently obtain further custody over client assets. Item 16 Investment Discretion 20  Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell; and/or • determine the amount of the security to buy or sell Clients give us discretionary authority when they sign a discretionary agreement with our firm. PJS no longer accepts new advisory clients on a non-discretionary basis. Pre-existing advisory clients that entered into a non-discretionary relationship are subject to the terms that were in effect at that time of the agreement. Item 17 Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Class Action Lawsuits From time to time, securities held in client accounts may be subject to class action lawsuits. PJS does not have an obligation or responsibility to advise or act for the client in any legal proceedings involving securities held or previously held in an account managed by us. However, on a case-by-case basis, we may be able to assist clients in gathering information if the client chooses to pursue an action. Item 18 Financial Information We have no financial conditions to disclose which would impair our ability to meet our contractual commitments to our clients. Other Information Patrick Sommerfield serves as President, Chief Investment Officer, Wealth Adviser and Chief Compliance Officer which could result in competing priorities. PJS believes this conflict is well managed through its Investment Committee and the Director of Compliance’s role. Further, PJS maintains policies, procedures and controls to assist in mitigating this conflict, and does not believe it results in unfair treatment of its clients. 21