STILLWATER CAPITAL ADVISORS, LLC

Part 2A of Form ADV: Firm Brochure Stillwater Capital Advisors, LLC 80 W. Lancaster Avenue Suite 230 Devon, PA 19333 Telephone: 877-790-9904 Email: info@stillwateradv.com Web Address: www.stillwateradv.com 02/20/2026 This brochure provides information about the qualifications and business practices of Stillwater Capital Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 877-790-9904 or info@stillwateradv.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 Stillwater Capital Advisors, LLC 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 149946. 1  Item 2: Material Changes This Firm Brochure, dated 03/10/2025, provides you with a summary of Stillwater Capital Advisors, LLC's services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This Item is used to provide our clients with a summary of new and/or updated information; we will inform of the revision(s) based on the nature of the information as follows. 1. Annual Update: We are required to update certain information at least annually, within 90 days of our firm’s fiscal year end (FYE) of [December 31]. We will provide you with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of our FYE or we will provide you with our revised Brochure that will include a summary of those changes in this Item. 2. Material Changes: Should a material change in our operations occur, depending on its nature we will promptly communicate this change to clients (and it will be summarized in this Item). "Material changes" requiring prompt notification will include changes of ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates – any information that is critical to a client’s full understanding of who we are, how to find us, and how we do business. The following summarizes new or revised disclosures based on information previously provided in our Firm Brochure dated 03/10/2025: 2  Page Item 3: Table of Contents Item 1 Cover Page Item 2 Material Changes Item 3 Table of Contents Item 4 Registered Investment Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information 1 2 3 4 6 8 8 8 10 10 10 10 12 13 13 14 14 15 3  Item 4: Registered Investment Advisory Business Stillwater Capital Advisors, LLC is a SEC-registered investment adviser with its principal place of business located in PA. Stillwater Capital Advisors, LLC began conducting business in 2009. Our sole owner is Douglas A. Swope, Managing Member - Principal Stillwater Capital Advisors, LLC offers the following services to our clients: PORTFOLIO MANAGEMENT SERVICES PROGRAM Our firm manages individually tailored investment portfolios for clients utilizing individual equities, bonds, mutual funds and exchange traded funds. Each portfolio is designed to meet a particular investment goal. We provide continuous advice regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s individual investment plan and manage a portfolio based on that plan. During our data gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. Our Portfolio Management Services are implemented on a discretionary basis as agreed upon with each client. We will implement transactions without seeking prior client consent. However, clients may impose reasonable restrictions on investing in certain securities, or industry sectors. Account supervision is guided by the stated objectives of the client (i.e. aggressive growth, conservative growth, balanced growth or income) as well as tax considerations. INVESTMENT ADVISORY SERVICES PROGRAM Our firm also offers advice regarding the investment of client funds based on their individual needs in a non-discretionary format. Through personal discussions, goals and objectives are established based on a client's particular circumstances. We create and advise on a portfolio based on these objectives. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We will seek prior client consent for every contemplated transaction. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients who choose to use our Investment Advisory Services should understand that any delay in obtaining consent may result in less favorable transaction terms, including higher security price and/or limited availability of the recommended securities. 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 securities, mutual funds, exchange traded funds, corporate bonds, government bonds or municipal bonds. 4  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. PENSION & ENDOWMENT SERVICES Clients may choose to use any or all of the following Pension & Endowment Services. Fees are determined by the selected investment program (Portfolio Management Services or Investment Advisory Services). • Preparation of Investment Policy Statement (''IPS''): We will meet with the client (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall 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 of investment performance. • Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We will then review mutual funds and exchange-traded funds (both active and passive) 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. • Monitoring of Investment Performance: We monitor client investments continually, based on the procedures and timing intervals delineated in the Investment Policy Statement. We supervise the client's portfolio and will make recommendations to the client as market factors and the client's needs dictate. FINANCIAL PLANNING SERVICES We provide financial planning services. Financial planning 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. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients requesting this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. 5  In general, the financial plan can address any or all of the following areas: • PERSONAL: We may review family records, budgeting, estate information and financial goals. • TAX & CASH FLOW: We may review the client’s income tax, spending and planning for past, current and future years; then illustrate the impact of various investments on the client's future tax liability. We work with client’s existing or recommended tax professional. • • INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio. INSURANCE: We may review existing policies to ensure proper coverage for life, disability and long-term care. • RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. • ESTATE: We may assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney and asset protection plans. We work with client’s existing or recommended attorney. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney and/or accountant. Implementation of financial plan recommendations is entirely at the client's discretion. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. ASSETS UNDER MANAGEMENT As of 02/20/26, we were actively managing approximately: Investment Advisory Services Program: $63,634,879 • Portfolio Management Services Program: $1,280,638,579 • Item 5: Fees and Compensation The annualized fee for the following services is charged as a percentage of assets under management in each individual account according to the following schedule. Portfolio Management Services Program: Account Assets On the first $1,000,000 On the next $2,000,000 On the next $2,000,000 On the next $5,000,000 On assets over $10,000,000 Annual Fee 1.00% 0.85% 0.75% 0.65% Negotiable 6  Investment Advisory Services Program: Account Assets On the first $1,000,000 On the next $2,000,000 On the next $2,000,000 On the next $5,000,000 On assets over $10,000,000 Annual Fee 1.00% 0.85% 0.75% 0.65% Negotiable The value of each account including accrued interest at the end of the previous quarter will be used to calculate the blended fee for each account as reported to our portfolio management and accounting system, Tamarac. This amount may differ slightly from your billing statement from your account custodian in the event of a late-in-quarter transaction that was posted to the account custodian after the quarter end but posted to Tamarac as of a previous date. We expect any differences to be de minimis. Clients are billed in advance at the beginning of each calendar quarter by directly debiting client accounts. If assets greater than or equal to $100,000 are deposited or withdrawn from an account after the beginning of a quarter, the fee will be prorated. Fees for 529 accounts are also billed in advance at the beginning of each calendar quarter by directly debiting client accounts. In limited circumstances as agreed upon in writing with the client, fees may be calculated for each quarterly period ending the last business day of February, May, August and November and shall be the product of (i) the rate of no more than 50 basis points, (ii) the average daily net asset value of the Client’s assets invested in the Fund through the Program during the quarter; divided by (iii) the number of days in the year multiplied by the number of days in the quarter. Fees in these circumstances will be debited directly from your 529 account. Limited Negotiability of Advisory Fees: Although Stillwater Capital Advisors, LLC 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 needs, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. We may aggregate certain related client account assets for the purposes of determining the annualized fee. Discounts, not generally available to our clients, may be offered to family members and friends of associated persons of our firm. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon written notice. As disclosed above, certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will prorate the reimbursement according to the number of days remaining in the billing period. Mutual Fund Fees: All fees paid to Stillwater Capital Advisors, LLC for registered investment 7  advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee and other fund expenses. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition 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, including, but not limited to, any transaction charges imposed by a custodian with which an independent investment manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. 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 higher, similar or lower fees. Item 6: Performance-Based Fees and Side-By-Side Management Stillwater Capital Advisors, LLC does not charge performance-based fees. Item 7: Types of Clients Stillwater Capital Advisors, LLC provides advisory services to the following types of clients: Individuals (other than high net worth individuals) • • High net worth individuals • Pension and profit sharing plans(other than plan participants) • Charitable organizations • Corporations or other businesses not listed above 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: 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. 8  Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular equity against the overall market in an attempt to predict the price movement of the security. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of equities, 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 equities, 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 invest over a period of time and in different economic conditions. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in 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 We use the following strategy 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. We may believe the securities to be currently undervalued. We may do this because 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. Risk of Loss. Securities investments are not guaranteed, and you may lose money on your investments. We ask that you work with us to help us understand your tolerance for risk. 9  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 material, legal or 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 A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, political contributions, gifts, entertainment and trading guidelines. Item 12: Brokerage Practices Stillwater Capital Advisors, LLC does not have any soft-dollar arrangements and does not receive any soft-dollar benefits. Stillwater Capital Advisors, LLC will execute block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a prorated basis between all accounts included in any such block. Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. Stillwater Capital Advisors, LLC will typically aggregate trades among clients whose accounts can be traded at a given broker. Stillwater Capital Advisors, LLC's block trading policy and procedures are as follows: • Transactions for any client account may not be aggregated for execution if the practice is prohibited by or inconsistent with the client's advisory agreement with Stillwater Capital Advisors, LLC, or our firm's order allocation policy. • In discretionary managed accounts, Stillwater Capital Advisors, LLC will determine that the purchase or sale of the particular security involved is appropriate for the client and consistent with the client's investment objectives and with any investment guidelines or restrictions applicable to the client's account. 10  • The portfolio manager must reasonably believe that the order aggregation will benefit, and will enable Stillwater Capital Advisors, LLC to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20- 20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price. • If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated pro rata among the participating client accounts in accordance with the initial order ticket or other statement of allocation. However, adjustments to this pro rata allocation may be made to participating client accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in smaller accounts. • Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions made to fill the order, and is generally charged a flat commission regardless of the client’s participation. Under the client’s agreement with the custodian/broker, transaction costs may be based on the number of shares traded for each client. • If the order will be allocated in a manner other than that stated in the initial statement of allocation, a written explanation of the change must be provided to and approved by the Chief Compliance Officer no later than the morning following the execution of the aggregate trade. • Stillwater Capital Advisors, LLC's client account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. • Funds and securities for aggregated orders are clearly identified on Stillwater Capital Advisors, LLC's records and to the broker-dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. • No client or account will be favored over another. Stillwater Capital Advisors, LLC has an arrangement 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. 11  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 Stillwater Capital Advisors, LLC may contract directly. Stillwater Capital Advisors, LLC is independently operated and owned and is not affiliated with Fidelity. Fidelity generally does not charge its 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 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 Stillwater Capital Advisors, LLC's 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 affect the same transaction where we determine in good faith that the commission is reasonable in relation to the 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 Stillwater Capital Advisors, LLC 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. Although the investment research products and services that may be obtained by us will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. Item 13: Review of Accounts The following individuals are responsible for reviewing client accounts under all our service offerings: • Douglas A Swope - Managing Director • Christopher C Dautrich – Senior Vice President • Justin N. Thompson – Vice President • H. William Hudson – Wealth Advisor Portfolio Management Services Program & Investment Advisory Services Program Underlying securities within accounts are continually monitored and the degree of security turnover is not an indication of the frequency of reviews. Client accounts are reviewed in the context of each client's 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. 12  In addition to the monthly statements and confirmations of transactions that clients receive from their custodian, we may provide additional analytical reports at the client's request. Pension & Endowment Services Stillwater Capital Advisors, LLC will review the client's Investment Policy Statement (IPS) whenever the client advises us of a change in circumstances regarding the needs of the plan. Stillwater Capital Advisors, LLC will also review the investment options of the plan according to the agreed upon time intervals established in the IPS. Such reviews will generally occur quarterly. In addition to the monthly statements and confirmations of transactions that clients receive from their broker-dealer, we may provide additional analytical reports at the client's request. Financial Planning Services Financial Planning clients will receive a completed financial plan. Additional reports will not typically be provided unless otherwise requested. While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. Item 14: Client Referrals and Other Compensation It is Stillwater Capital Advisors, LLC's policy not to engage solicitors or to pay related or non-related persons for referring potential clients to our firm. It is Stillwater Capital Advisors, LLC's policy not to 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 While we do not take physical possession of client assets, under the current SEC rules, our firm is deemed to have constructive custody of client assets due to various arrangements which give us legal access to client funds. Custody is defined as any legal or actual ability by our firm to access client funds or securities. All client funds and securities are maintained with a qualified custodian. We encourage all of our clients to carefully review their monthly statements. We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. As part of this 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 13  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. Item 16: Investment Discretion 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 determine the security and the quantity to buy or sell without contacting the client: Clients give us discretionary authority when they sign a discretionary agreement with our firm, and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Item 17: Voting Client Securities Stillwater Capital Advisors, LLC will vote proxies on behalf of all client discretionary accounts unless otherwise noted. You always have the right to withdraw this authorization and 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 through Broadridge Financial Solutions. Through Broadridge’s ProxyEdge platform, our firm will retain all proxy records for the requisite period of time, including a copy of each proxy statement received and a record of each vote cast. We will also retain a copy of each written client request for information on how the adviser voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third-party to cast a vote. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting Christopher C. Dautrich by telephone, email, or in writing. 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. Broadridge Financial Solutions will research global securities class action cases that are not deemed by the SEC to be a “Fair Fund” lawsuit, on behalf of our clients and will generate and submit the applicable proof of claim to the Claims Administrator. Broadridge will collect all payments from the Claims Administrator and distribute such payments directly to our clients. Clients shall be obligated to pay to Broadridge a contingency fee of 20% of the total reimbursement of asset settlements it collects during the Term in consideration of the Class Action Services. Class action cases deemed as a “Fair Fund” lawsuit will be fully distributed to clients without a contingency fee. To direct us to vote a proxy in a particular manner, clients should contact Christopher C. Dautrich by telephone, email, or in writing. 14  You can instruct us to vote proxies according to particular criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called "poison pill" defense against a possible takeover). These requests must be made in writing. You can also instruct us on how to cast your vote in a particular proxy contest by contacting us at: Stillwater Capital Advisors, LLC 80 W. Lancaster Avenue Suite 230 Devon, PA 19333 Item 18: Financial Information As a registered investment advisory firm that maintains discretionary authority for client accounts, we are required to disclose any financial condition that is reasonable likely to impair our ability to meet our contractual obligations. Stillwater Capital Advisors, LLC has no financial circumstances to report. Stillwater Capital Advisors, LLC has not been the subject of a bankruptcy petition at any time during the past ten years. 15