SLOCUM, GORDON & CO. LLP

Part 2A of Form ADV Firm Brochure Slocum, Gordon & Co. LLP 39 Mill Street Newport, RI 02840 Telephone: 401-849-4900 Email: mmoeller@slocumgordon.com Web Address: www.slocumgordon.com February 5, 2026 This brochure provides information about the qualifications and business practices of Slocum, Gordon & Co. LLP. If you have any questions about the contents of this brochure, please contact us at 401-849- 4900 or mmoeller@slocumgordon.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. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. Additional information about Slocum, Gordon & Co. LLP 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 104929.  Item 2: Material Changes The Material Changes section of this brochure will be updated annually and/or when material changes have occurred since the previous release of the Firm Brochure. The following changes have been incorporated into this version of the Brochure since our last annual amendment: Since our last annual filing we have made the following material changes: Item 4 (Advisory Business) – Changes were made to reflect our ownership change. The principal owners of our firm are Jeffrey Gordon and Barclay Douglas. Item 5 (Fees and Compensation) – Updated language to further clarify how the Firm charges for its portfolio management services and the process for billing on assets withdrawn during the quarter. Please see Item 5 for additional details. Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) – Added additional risk to describe risk associated with the type of investments utilized, including risk associated with investing in equities, ETFs, mutual funds, fixed income, and real estate. Please refer to Item 8 for additional details. Item 15 (Custody) - Updated the custody section to reflect that SGCo is deemed to have custody as a result of employees acting as trustee on client accounts. SGCo is subject to the surprise examination requirement. Please refer to Item 15 for additional information. Additional changes were made throughout for language consistency and clarification. 2  Item 3: Table of Contents Item 1 Cover Page 1 Item 2 Material Changes 2 Item 3 Table of Contents 3 Item 4 Advisory Business 4 Item 5 Fees and Compensation 5 Item 6 Performance-Based Fees and Side-By-Side Management 6 Item 7 Types of Clients 6 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 6 Item 9 Disciplinary Information 8 Item 10 Other Financial Industry Activities and Affiliations 8 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 8 Item 12 Brokerage Practices 9 Item 13 Review of Accounts 10 Item 14 Client Referrals and Other Compensation 11 Item 15 Custody 11 Item 16 Investment Discretion 11 Item 17 Voting Client Securities 12 Item 18 Financial Information 12 3  Item 4: Advisory Business Slocum, Gordon & Co. LLP (“SGCo” or “Firm”) is a SEC-registered investment adviser with its principal place of business located in Rhode Island. SGCo began conducting business in 1978 and is owned by the firm's principal shareholders, Jeffrey L. Gordon, Managing Partner and Barclay Douglas Jr., Partner. The Firm offers the following advisory services to our clients: INDIVIDUAL PORTFOLIO MANAGEMENT Our portfolio management services are offered to assist you with ongoing management of your investment accounts. We provide continuous advice and through personal discussions we establish goals and objectives based on your particular investment objectives, time horizon, risk tolerance and liquidity needs. With this information we create a customized portfolio for you and will monitor your portfolio on an ongoing basis. We will rebalance your portfolio as required by changes in the market conditions and changes in your financial circumstance. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. We will manage your advisory accounts on a discretionary basis. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and will generally include advice regarding the following securities: exchange-listed securities, securities traded over-the-counter, foreign issuers, municipal securities, mutual fund shares, and/or United States governmental securities. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. IRA Rollover Recommendations When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. 4  AMOUNT OF MANAGED ASSETS As of 12/31,2025, we were actively managing $219,150,565 of clients' assets on a discretionary basis. Item 5: Fees and Compensation INDIVIDUAL PORTFOLIO MANAGEMENT FEES The annualized fee for Portfolio Management Services is a blended fee and based on a percentage of assets under management in your account. Our annual portfolio management tiered fee schedule is indicated below: Assets Under Management Annual Fee $0 - $5,000,000 1.0% Above $5,000,001 0.50% Our portfolio management fee is billed and payable monthly in arrears based on the month-end value as provided by the custodian. Fees will be deducted monthly directly from your account(s) based on the client’s authorization to the custodian. When applicable, assets will be sold to pay management fees when insufficient cash levels are maintained. If the investment management agreement is executed at any time other than on the first day of the calendar month, our fees will apply on a pro-rata basis, which means that the management fee is payable in proportion to the number of days in the month for which you are a client. For distributions above $10,000 withdrawn after the 15th of the month, you will be charged a pro-rata management fee for the number of days of service rendered during the prior month. In limited circumstances, SGCo may charge clients a flat monthly portfolio management fee. This fee will be collected in arrears and directly deducted from your account based on the client’s authorization to the custodian. Although SGCo has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, reports, among other factors. Discounts, which are not generally available to our advisory clients, may be offered to employees and family members associated with our firm. Your specific annual fee schedule will be identified in your Investment Management Agreement. Additional Fees and Expenses: Our portfolio management fee does not include brokerage commissions, transaction fees, or other related costs and expenses that are incurred by you. You may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. These charges, fees, and commissions are exclusive of and in addition to our fee and we will not receive any portion of these charges, fees, or commissions. 5  Additional Services: In certain instances, Clients may elect a partner of SGCo to serve as trustee on an account managed by the Firm. Based on the nature of this trustee relationship SGCo will be deemed to have custody on those assets and would be required to have a surprise audit. Clients utilizing this service will be assessed an additional fee to offset the cost of the audit. This additional fee will be pro-rated based on your account size relative to the total assets the firm has that are subject to the custody audit. The fee will be directly debited from your account on a monthly basis. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1200 more than six months in advance of services rendered. Termination of the Advisory Relationship: You may terminate any service for any reason within the first five (5) business days after signing the contract without any cost or penalty. Thereafter, you may terminate the portfolio management services upon 10-day written notice. You will incur a pro rata charge for services rendered prior to the termination of the investment advisory agreement, which means you will incur advisory fees only in proportion to the number of days in the month for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Item 6: Performance-Based Fees and Side-By-Side Management SGCo does not charge performance-based fees. Item 7: Types of Clients SGCo provides advisory services to Individuals, high net worth individuals, Pension and profit-sharing plans, charitable organizations, corporations, and state / municipal government entities. We do not require a minimum account size. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS We use the following methods of analysis in formulating our investment advice and/or managing client assets: Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. 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 underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate 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. 6  Quantitative Analysis. We use mathematical models in an attempt to obtain more accurate measurements of a company's quantifiable data, such as the value of a share price or earnings per share and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. 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. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client's investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, 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. INVESTMENT STRATEGIES We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) 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 current 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. RISK OF LOSS Past performance is not indicative of future results. Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal. Equity (Stock) Risks. Common stocks are subject to general stock market fluctuations and to volatile increases and decreases in value as market confidence and perception of their issuers change. There is also a certain level of company or industry specific risk that is inherent in each investment. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. 7  ETF Risks. The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if an ETF has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks. The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Fixed Income (Bonds) Risks. Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; interest rate movements (Interest Rate Risk); when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Real Estate Risks. Funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. 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. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics. 8  Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. Additionally, our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("block trading"). Refer to the Brokerage Practices section in this brochure for information on our block trading practices. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Item 12: Brokerage Practices SGCo does not have any soft-dollar arrangements and does not receive any soft- dollar benefits. Although we do not require you to use a specified broker-dealer, SGCo has established a relationship with National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with "institutional platform services." The institutional platform services include, among others, brokerage, custody, and other related services. Fidelity's institutional platform services that assist us in managing and administering clients' accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist 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, financial planning, 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 SGCo may contract directly. SGCo is independently operated and owned and is not affiliated with Fidelity. Fidelity generally does not charge its advisor clients separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Fidelity provides access to many no-load mutual funds without transaction charges and other 9  no-load funds at nominal transaction charges. As a result of receiving such services for no additional cost, we may 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 into the relationship with Fidelity and have determined that the relationship is in the best interests of our clients and satisfies our client obligations, including our duty to seek best execution. A client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. 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, and responsiveness. Accordingly, while SGCo 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. Trade Aggregation We may aggregate transactions in equity and fixed income securities for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. We may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If we do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. Mutual Fund Share Class Selection Mutual funds generally offer multiple share classes available for investment based upon certain eligibility and/or purchase requirements. For instance, in addition to retail share classes (typically referred to as class A, class B and class C shares), funds may also offer institutional share classes or other share classes that are specifically designed for purchase by investors who meet certain specified eligibility criteria, including, for example, whether an account meets certain minimum dollar amount. Institutional share classes usually have a lower expense ratio than other share classes. When recommending investments in mutual funds, it is our policy to review and consider available share classes. Our policy is to select the most appropriate share classes based on various factors including but not limited to: minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. When considering all of the appropriate factors, we can select a share class other than the ‘lowest cost’ share class. To select the most appropriate share class, we consider retail, institutional or other share classes of the same mutual fund. Regardless of such considerations, clients should not assume that they will be invested in the share class with the lowest possible expense ratio. Clients should ask their adviser whether a lower cost share class is available instead of those selected by the Firm. SGCo periodically reviews the mutual funds held in client accounts to select the most appropriate share classes considering its duty to obtain best execution. Item 13: Review of Accounts Reviews: SGCo continually monitors the underlying securities within Clients’ portfolios. At least quarterly, accounts are reviewed in the context of each client's stated investment objectives and guidelines. We 10  encourage you to notify SGCo if any changes occur in financial situation, goals or objectives. 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. These accounts are reviewed by: Jeffery L. Gordon, Managing Partner and Michael Moeller, CIMA®, Portfolio Manager & Director of Research. Reports: Clients are provided with monthly / quarterly statements and confirmations of transactions directly from the custodian. In addition, SGCo will provide a quarterly report- summarizing your account balances and holdings. Clients should compare the account statements they receive from their custodian with those they receive from SGCo. Item 14: Client Referrals and Other Compensation SGCo does not engage promoters or pay related or non-related persons for referring potential clients to our firm. SGCo does not accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. Item 15: Custody SGCo and its employees do not maintain physical custody of your assets and will not intentionally take custody of your cash or securities. Your assets will be held with an independent third-party custodian based on the services provided to you. SGCo is deemed to have custody because we have the ability to directly debit client advisory fees from accounts. Additionally, SGCo claims custody as a result of employees acting as trustee on client accounts. According to the SEC Custody Rule, SGCo is subject to a surprise audit by a public accounting firm based on these client relationships. SGCo has engaged an independent public accounting firm to conduct a surprise examination of these accounts. 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 may be 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 on these statements to ensure that all account transactions, holdings and values are correct and current. Item 16: Investment Discretion SGCo provides discretionary asset management services to clients, 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. SGCo has the ability to determine the security to buy or sell and/or the amount of the security to buy or sell. Clients give us discretionary authority when they sign an investment management agreement with our firm. 11  Item 17: Voting Client Securities We vote proxies for all client accounts; however, you always have the right to vote proxies yourself. You can exercise this right by instructing us in writing to not vote proxies in your account. We will vote proxies in the best interests of its clients and in accordance with our established policies and procedures. Our firm will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to making a decision on how to vote proxies, and a copy of each written client request for information on how the adviser voted proxies. SGCo has processes in place to address conflicts of interest in voting a particular action if it should occur, which may include obtaining client consent, voting based on a predetermined voting policy or notifying the client of the conflict and retaining an independent third-party to cast a vote. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting SGCo using the contact information on the cover page of this brochure. Clients may request, in writing, information on how proxies for his/her shares were voted. If any client requests a copy of our complete proxy policies and procedures or how we voted proxies for his/her account(s), we will promptly provide such information to the client. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client's account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. You can instruct us to vote proxies according to particular criteria. These requests must be made in writing. Item 18: Financial Information As an advisory firm that has discretionary authority or client accounts, we are also required to disclose any financial condition that is reasonable likely to impair our ability to meet our contractual obligations. SGCo has no such financial circumstances to report. Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. SGCo has not been the subject of a bankruptcy petition at any time during the past ten years. 12