SPURSTONE

Cover Page 12 Scovil Rd. Higganum, Connecticut 06441 Spurstone Form ADV Part 2A – Firm Brochure 860-264-1111 www.spurstone.com Version date: March 12, 2026 This Brochure provides information about the qualifications and business practices of Spurstone Advisory Services, LLC, d/b/a Spurstone. If you have any questions about the contents of this Brochure, please contact us at 860-264-1111. 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. Spurstone Advisory Services, LLC is registered as an Investment Adviser with the SEC. Registration of an Investment Adviser does not imply any level of skill or training. 1  Additional information about Spurstone is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the firm’s identification number 284158. Item 2: Material Changes Since our last annual amendment dated February 4, 2025, we updated: (i) Item 4 to clarify our use of SEI’s wrap fee program and our non-sponsorship status; (ii) Item 10 and Item 14 to enhance disclosures of conflicts related to our affiliated insurance agency and incidental economic benefits from SEI; and (iii) Item 15 to clarify that Spurstone is deemed to have custody solely due to fee-deduction authority and, where applicable, standing letters of authorization (SLOAs), and to describe the safeguards, reviews, and procedures we follow to avoid inadvertent custody. Spurstone has not made other material changes to our advisory services or business 2  Item 3: Table of Contents Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and CompensaCon 11 Item 6: Performance-Based Fees and Side-By-Side Management 13 Item 7: Types of Clients 13 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 14 Item 9: Disciplinary InformaCon 16 Item 10: Other Financial Industry AcCviCes and AffiliaCons 17 Item 11: Code of Ethics, ParCcipaCon or Interest in Client TransacCons and Personal Trading 18 Item 12: Brokerage PracCces 19 Item 13: Review of Accounts 20 Item 14: Client Referrals and Other CompensaCon 20 Item 15: Custody 21 Item 16: Investment DiscreCon 22 Item 17: VoCng Client SecuriCes 22 Item 18: Financial InformaCon 22 Privacy NoCce 23 3  Item 4: Advisory Business Description of Advisory Firm Spurstone Advisory Services, LLC dba Spurstone (“Spurstone”) is registered as an Investment Adviser with the SEC. Spurstone filed its initial application to become registered as an investment advisor in May of 2016. Theodore de Groot and Timothy Golas are the principal owners of Spurstone. As of December 31, 2025, Spurstone manages $192,115,319 in assets on a discretionary basis and $16,733,682 in assets under advisement. Types of Services Provided This brochure provides an overview of the services provided by Spurstone. Some of the services Spurstone provides constitute investment advice, while other services Spurstone provides are non-advisory consulting services. Generally, Spurstone provides the following categories of services: • Business Owner & Entrepreneur ConsulCng & Business Exit Planning • Corporate ExecuCve Services • Comprehensive Financial Planning, ReCrement Planning & Goals Based Planning Business Owner & Entrepreneur Consulting & Business Exit Planning Business owners and entrepreneurs have unique needs and complex assets. These individuals and the organizations they lead can benefit from specialized advice, guidance, techniques and planning in driving toward their goals. Spurstone consults with business owners, utilizing the Value Acceleration Methodology, in the pursuit of significant business growth, value acceleration and business exits. We bring an entrepreneurial mindset and fresh perspective to the multigenerational wealth planning needs of clients. Clients gain access to Spurstone’s Certified Exit Planning Advisors (CEPAs) who can work with clients in many areas, including but not limited to: 4  Identifying and Addressing Wealth Gaps • Grind To Good Life Program and Exit Planning • Business Value Acceleration Methodology: Deployment & Management • Business Preparedness & Readiness • • Transition Planning • Business Exit/Sale Consulting & Deal Management/Guidance • Sitting side by side with owners to evaluate, negotiate, structure and complete business sales. • Seeking to maximize value in terms that meet their objectives. • Owner Workshops & Education • Strategic Business Planning • Exit Options Education & Evaluation • Business Owner Wealth Management & Personal Financial Planning • Spurstone works with successful business owners, and their families, to marry their business and personal wealth, which can have a profound positive impact on both while creating lasting multigenerational legacies. Spurstone provides Business Owner & Entrepreneur Consulting & Business Exit Planning services as non-advisory consulting services through Spurstone Advisory Services, LLC. These consulting services are separate and distinct from investment advisory services provided by the firm. Compensation for these consulting services is based on an agreed upon on fixed fee, hourly and/or recurring monthly subscription basis. in a written consulting agreement. Spurstone does not receive success-based, transaction-based, or contingent compensation in connection with the sale, transfer, or exit of a client’s business. Grind to Good Life is Spurstone’s structured exit planning process created specifically for entrepreneurs and business owners preparing for a significant transition. The program is designed to help owners strengthen and optimize their exit, bring clarity and confidence to the process, and align the ownership group around a shared vision to move forward with clarity and confidence well in advance of a liquidity event. We work alongside clients and their other trusted advisors to coordinate key business and personal priorities so that decisions are intentional rather than reactive. The goal of Grind to Good Life is to help business owners move thoughtfully from the demands of building their company to a well- planned and purpose-driven next chapter. Spurstone does not provide legal or tax advice in connection with Business Exit Planning services. Clients are encouraged to consult with qualified legal and tax professionals. 5  Business Exit Planning services may identify assets that are or will be available for investment advisory management. Business Exit Planning clients are under no obligation to engage Spurstone for investment advisory services as a result of consulting services. What is a CEPA™? A Certified Exit Planning Advisor (CEPA) is a credential for professional advisors obtained through The Exit Planning Institute focused on advising business owners to build value within their business (often their most valuable asset) and aiding them to exit on their own terms. Through Exit Planning, utilizing the Value Acceleration Methodology, owners can build more valuable companies, have stronger personal financial plans, and align their personal goals. If you’re a business owner considering the next steps for an exit or transition, CEPA professionals have the exact skillset to help you map it out. Corporate Executive Services Spurstone has extensive experience consulting and advising successful executives. We are focused on the cultivation and protection of wealth by delivering services unique to this group which can include: • Concentrated Stock Management: Risk hedging, tax mitigation and diversification strategies for large & concentrated stock positions. • Equity/Stock Award Planning: Analyze and execute strategies focusing on risk and tax mitigation. This can include equity grant analytics, strategic award retention, sales and hedging strategies. • Executive Benefits & Compensation Planning: Evaluate and maximize benefit plan • structures with integration into personal financial plans. Insider, Director and Officer Solutions: Develop regulatory compliant strategies for transacting employer shares. This can include strategic executions in open trading windows, Rule 144 transactions and 10b5-1 plans. • Portfolio Risk Strategies: In order to limit increased portfolio risk, executive clients can include specific stock investment restrictions within their investment policy statement in order to reduce increased exposure and ensure regulatory compliance. Comprehensive Financial Planning, Retirement Planning & Goals Based Planning Spurstone offers the following investment advisory programs: 6  Spurstone Private Client Management Spurstone clients enjoy a uniquely executive experience focused on the cultivation and protection of wealth. We build these experiences around the unique vision and needs of each family on a platform of great people providing great solutions. By developing and executing great solutions, utilizing innovative technologies and communicating often with our clients, we strive to foster the environment executive families desire when growing and protecting their wealth. Comprehensive Portfolio Management Spurstone recommends that certain clients allocate investment assets among the various ETF & mutual fund asset allocation models, underlying mutual funds, and/or independent investment manager programs offered through SEI Investments Management Corp. (“SEI”). SEI is a global asset management company and sponsor of its own proprietary mutual funds. SEI Private Trust Company, an affiliate of SEI, serves as custodian for each SEI account, and provides each client with reporting services, including consolidated monthly statements, quarterly performance reports, and year-end tax reports. SEI enables investment advisers such as Spurstone to offer its clients mutual fund asset allocation models, underlying individual mutual funds, and investment management programs that are not otherwise available to the general public. As part of its overall investment management program, SEI offers quarterly rebalancing of each client’s investment assets for the purpose of maintaining the assets in accordance with the client’s previously designated asset allocations for the SEI account. Asset Allocation Portfolios: The Asset Allocation Portfolios consist of SEI mutual funds and are periodically adjusted to the target allocation of the portfolio, which is based on the particular investment goals of each model. Spurstone maintains discretion over the investments made in the account and may adjust asset allocation to help ensure the investment mix reflects the objectives of the strategy selected. Managed Account Program: The Managed Account Program is a wrap fee program provided by SEI, which charges a bundled fee that includes advisory, brokerage and custody services. Spurstone may select from a variety of separately managed account (SMA) models managed by third-party subadvisors to build a customized portfolio using various types of securities and investment styles. Comprehensive Financial Planning & Management Comprehensive Financial Planning & Management is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect is that through the financial planning process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the 7  client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The client always has the right to decide whether to act upon our recommendations. If the client elects to act on any of the recommendations, the client always has the right to affect the transactions through anyone of their choosing. In general, the financial plan will address any or all of the following areas of concern. The client and advisor will work together to select the specific areas to cover. These areas may include, but are not limited to, the following: • Ancillary Services: from time to time, we may provide advice or services other than those listed below. If a client is engaging Spurstone for such services, those services would be more fully outlined in the Agreement between Spurstone and the client. • Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. • Charitable Gifting: Includes planning, designing and executing philanthropic objectives including family philanthropy education, efficient gift planning, legacy and next generation planning, and other relevant topics as needed. • College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate). • Estate & Trust Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. 8  We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. • Family Governance: This may involve the creation of multi-generational family plans, family communication strategies and family meeting facilitation. • Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. • Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. • Life, Long Term Care & Disability Insurance: Review of existing policies to ensure proper coverage. • Lifestyle Planning: We will work with clients to create, execute and monitor customized, goal based financial plans (i.e. Retirement, legacy, real estate acquisition, education, etc.). This can involve portfolio sustainability evaluation, savings and spending projections, risk analytics, banking and other financial arenas that directly relate to the targeted goals. • Tax Mitigation: Known as a silent wealth killer, taxes have a substantial impact to the long-term, multi- generational, wealth of successful families. It is prudent to mitigate this constant risk in portfolios through a proactive and ongoing process. Spurstone clients enjoy innovative tax hedging techniques and technologies designed to mitigate tax exposure and preserve wealth. By taking a holistic wealth view, integrating multiple client advisor sources such as the client’s accountant, and managing tax exposure at a global level, we seek to reduce tax exposure on a proactive basis. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for 9  accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Educa&onal Seminars We may provide educational seminars on an “as announced” basis for groups seeking general advice on investments and other areas of personal finance. The content of these seminars will vary depending upon the needs of the attendees. These seminars are purely educational in nature and do not involve the sale of any investment products. Information presented will not be based on any individual person’s need, nor does Spurstone provide individualized investment advice to attendees during these seminars. Written Acknowledgement of Fiduciary Status Rollover Recommendations and Related Conflicts of Interest — When recommending that you roll over assets from an employer-sponsored retirement plan to an IRA that we manage, Spurstone may receive compensation that we would not receive if you were to leave your assets in your plan account. This difference in compensation creates a conflict of interest. To address this conflict, Spurstone follows written policies and procedures intended to ensure rollover recommendations are made in your best interest. This includes reviewing and comparing the relevant features of your existing plan and the proposed IRA—such as fees and expenses, investment options, services, withdrawal rules, and your personal financial circumstances—and documenting the specific reasons why a rollover is or is not appropriate. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries under the Employee Retirement Income Security Act and/or the Internal Revenue Code, and therefore must act in your best interest and not put our interests ahead of yours. Under this fiduciary standard, we must: • Meet a professional standard of care when making investment recommendaCons (give prudent advice); • Never put our financial interests ahead of yours (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 • Provide clear informaCon about the conflicts of interest that may affect our recommendaCons. 10  Client Tailored Services and Client Imposed Restrictions We offer the same suite of services to all our clients. However, specific client financial plans and their implementation are dependent upon a client Investment Policy Statement, which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Wrap Fee Programs Spurstone does not sponsor a wrap program but may recommend/enroll clients into SEI’s wrap fee program. Item 5: Fees and Compensation Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the client within five (5) business days of signing the contract without incurring any advisory fees and without penalty. How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below. Comprehensive Portfolio Management Our standard advisory fee is based on the market value of the assets under management and is calculated as follows: Account Value Annual Advisory Fee First $500,000 1.40% Next $250,000 1.20% Next $250,000 1.00% Next $1,000,000 0.80% 11  Next $1,000,000 0.60% Next $2,000,000 0.50% Next $5,000,000 0.40% Amounts over $10,000,000 0.30% The above fee schedule does not include the advisory fee paid to SEI. Spurstone’s Annual Advisory fees are negotiable and are pro-rated and paid in arrears on a quarterly basis. No change in the annual fee shall be effective without written disclosure to the client. Advisory fees are directly debited from client accounts. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice. Since fees are paid in arrears, no rebate will be needed upon termination of the account. Complete details on the SEI fees and expenses, are disclosed in SEI’s Form ADV Part 2A which will be given to all clients subscribing to this advisory service. The exact fee and/or fee schedule for each client will be disclosed in SEI’s Client Agreement. Comprehensive Financial Planning & Management Fee Comprehensive Financial Planning & Management will generally be offered on a fixed fee basis. The fixed fee will be agreed upon before the start of any work. The fixed fee can range between $500.00 and $25,000.00. The fee is negotiable. The fee is due at the beginning of the process when the Financial Agreement is signed. In the event of early termination, the client will be billed for the hours worked at a rate of $500.00, per hour. If the initial deposit is greater than the amount billed, then the client will be refunded the difference. If the initial deposit is less, then the client will be billed the difference. Business Owner & Entrepreneur Consulting & Business Exit Planning is offered on fixed fee, hourly and recurring monthly subscription basis. This fee and terms is negotiable and agreed upon when the Financial Agreement is signed. 12  Educational Seminars Fees for Educational Seminars will vary due to varying scope, length, and complexity of seminars. Fees may be negotiated with and paid for by employers. In the event that seminar attendees will be responsible for payment, the fee will be published on the seminar announcement or invitation. Spurstone may also provide pro bono seminars at its own discretion. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, oddlot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending broker- dealers for client’s transactions and determining the reasonableness of their compensation (e.g., commissions). We do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees. Item 7: Types of Clients Spurstone provides financial planning and portfolio management services primarily to individuals and high net-worth individuals and their related entities such as trusts, charitable organizations, corporations, business entities, qualified retirement plans and other for profit and not for profit entities. We do not have a minimum account size requirement. 13  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss We refer clients to third-party investment advisers (“outside managers”). Our analysis of outside managers involves the examination of the experience, expertise, investment philosophies, and past performance of the outside managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, and concentrations. A risk of investing with an outside manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as we do not control the manager’s daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater 14  brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zerocoupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate 15  of return than most other types of bonds. However, because of a municipal bond’s tax- favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market- wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which clients invest. Item 9: Disciplinary Information Criminal or Civil Actions Spurstone and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Spurstone and its management have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings 16  Spurstone and its management have not been involved in legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Spurstone or the integrity of its management. Item 10: Other Financial Industry Activities and AfQiliations No Spurstone employee is registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. No Spurstone employee is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. Spurstone Advisory Services, LLC is the owner of Spurstone Wealth Management, LLC, a licensed insurance agency. Certain supervised persons may receive commission-based compensation through this affiliated entity in connection with the sale of insurance products. This creates a conflict of interest because supervised persons have a financial incentive to recommend insurance products. Clients are under no obligation to purchase insurance products through Spurstone or its affiliated agency. Recommendations or Selections of Other Investment Advisers As discussed in Item 4, Spurstone utilizes SEI Investments Management Corp to manage client accounts. In such circumstances, the advisory client will pay an advisory fee to Spurstone and a separate advisory fee to SEI. This situation creates a conflict of interest. However, when referring clients to other investment advisers, the client’s best interest and suitability of SEI will be the main determining factors of Spurstone. This relationship is disclosed to the client at the commencement of the advisory relationship and the client will execute separate advisory agreements with Spurstone and SEI. Clients are not obligated, contractually or otherwise, to use the services of SEI. Additionally, Spurstone will only recommend another investment adviser who is properly licensed or registered as an investment adviser. 17  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all our dealings. Code of Ethics Description This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below. Integrity - Associated persons shall offer and provide professional services with integrity. Objectivity - Associated persons shall be objective in providing professional services to clients. Competence - Associated persons shall provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. Confidentiality - Associated persons shall not disclose confidential client information without the specific consent of the client unless in response to proper legal process, or as required by law. Professionalism - Associated persons’ conduct in all matter shall reflect credit of the profession. Diligence - Associated persons shall act diligently in providing professional services. 18  We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide of copy of its Code of Ethics to any client or prospective client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a transaction for a client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation. Trading Securities At/Around the Same Time as Client’s Securities From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the same time as clients. We will not trade non-mutual fund securities prior to the same security for clients. Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers Spurstone Advisory Services, LLC does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. Research and Other Soft-Dollar Benefits We currently do not receive soft dollar benefits. 19  Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use We do recommend a specific custodian for clients to use, however, clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing clients to choose a specific custodian, we may be unable to achieve most favorable execution of client transaction and this may cost clients’ money over using a lower-cost custodian. Aggregating (Block) Trading for Multiple Client Accounts Outside Managers used by Spurstone may block client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12. Item 13: Review of Accounts Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by Timothy Golas, Chief Compliance Officer. The account is reviewed with regards to the client’s investment policies and risk tolerance levels. Events that may trigger a special review would be unusual performance, addition or deletions of client-imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per client's needs. Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. Item 14: Client Referrals and Other Compensation We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to our clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for client referrals. 20  Spurstone may send gifts and/or pay for meals for existing and prospective clients, in certain situations, in accordance Spurstone’s Code of Ethics. SEI may provide incidental economic benefits to Spurstone, including lodging or attendance support for conferences and educational events. These benefits create a conflict of interest because Spurstone has an incentive to continue recommending SEI. Spurstone does not consider these benefits when selecting service providers and makes recommendations based on the client’s best interest. Item 15: Custody Spurstone does not accept custody of client funds. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client's investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Pursuant to SEC Rules, Spurstone is deemed to have custody solely because we are authorized to deduct our advisory fees from your account(s) held with a qualified custodian. Spurstone does not otherwise maintain custody of client funds or securities. Your assets are maintained with a qualified custodian, and we have a reasonable basis, after due inquiry, to believe the custodian sends account statements directly to you at least quarterly. We urge you to compare any reports you receive from us with the statements you receive from the custodian. If you have executed a standing letter of authorization (SLOA) with your custodian permitting Spurstone to instruct the custodian to transfer funds to a third party you have designated, that arrangement may be deemed custody. In such cases we rely on the SEC guidance and the custodian’s controls (including written client authorization delivered directly to the custodian, limited adviser authority as agent, client revocation rights, and custodian confirmations) to safeguard your assets. We periodically review custodial agreements to help ensure they do not confer authority beyond our advisory agreement to avoid inadvertent custody. If we identify language that could be read to allow disbursements or transfers at our instruction, we seek to amend it or decline to use that agreement form. Spurstone does not require or solicit prepayment of more than $1200 in fees per client six months in advance. 21  Item 16: Investment Discretion We provide discretionary investment advisory services to clients. The Investment Advisory Contract established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, we generally manage the client’s account and make investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, or the price per share. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. Item 18: Financial Information Registered Investment Advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding. 22  Privacy Notice Spurstone Advisory Services, LLC, d/b/a Spurstone recognizes the importance of protecting our clients’ privacy. We have policies to maintain the confidentiality and security of your nonpublic personal information. The following is designed to help you understand what information we collect from you and how we use that information to serve your account. Categories of Information We May Collect In the normal course of business, we may collect the following types of information: Information you provide in the subscription documents and other forms (including name, address, social security number, date of birth, income and other financial-related information); and Data about your transactions with us (such as the types of investments you have made and your account status). How We Use Your Information That We Collect Any and all nonpublic personal information that we receive with respect to our clients who are natural persons is not shared with nonaffiliated third parties which are not service providers to us without prior notice to, and consent of, such clients, unless otherwise required by law. In the normal course of business, we may disclose the kinds of nonpublic personal information listed above to nonaffiliated third-party service providers involved in servicing and administering products and services on our behalf. Our service providers include, but are not limited to, our administrator, our auditors and our legal advisor. Additionally, we may disclose such nonpublic personal information as required by law (such as to respond to a subpoena) or to satisfy a request from a regulator and/or to prevent fraud. Without limiting the foregoing, we may disclose nonpublic personal information about you to governmental entities and others in connection with meeting our obligations to prevent money laundering including, without limitation, the disclosure that may be required by the Uniting and Strengthening America Act by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 and the regulations promulgated thereunder. In addition, if we choose to dispose of our clients’ nonpublic personal information that we are not legally bound to maintain, we will do so in a manner that reasonably protects such information from unauthorized access. The same privacy policy also applies to former clients who are natural persons. 23  Confidentiality and Security We restrict access to nonpublic personal information about our clients to those employees and agents who need to know that information to provide products and services to our clients. We maintain physical, electronic and procedural safeguards to protect our clients’ nonpublic personal information. We respect and value the fact that you have entrusted us with your private financial information, and we will work diligently to maintain that trust. We are committed to preserving that trust by respecting your privacy as provided herein. 24