Valpey Financial Services LLC

VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE 100 North Main Street, Suite 500 Concord, NH 03301 (603) 856-7945 https://www.valpeyfinancialservices.com March 31, 2026 This brochure provides information about the qualifications and business practices of Valpey Financial Services, LLC. If you have any questions or concerns about the contents of this brochure, please contact us at (603) 856-7945 or ron@valpeyfinancialservices.com. Valpey Financial Services, LLC is a registered investment adviser with the United States Securities and Exchange Commission (“SEC”). Registration of an investment advisor does not imply any level of skill or training. Additional information about Valpey Financial Services, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Valpey Financial Services, LLC is 154154. Part 2A - i  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE Item 2 – Material Changes The date of our previous annual update to our brochure was March 31, 2025. Since that date, we have made no material changes to this brochure; however, the content of this brochure has been amended to remove duplicate information and to clarify and consolidate disclosures. Part 2A - ii  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE Item 3 – Table of Contents Page Item 2 – Material Changes ............................................................................................................................... ii Item 3 – Table of Contents ............................................................................................................................. iii Item 4 – Advisory Business.............................................................................................................................. 1 Item 5 – Fees and Compensation ................................................................................................................... 2 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 3 Item 7 – Types of Clients ................................................................................................................................. 3 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 3 Item 9 – Disciplinary Information .................................................................................................................. 4 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 4 Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ......... 4 Item 12 – Brokerage Practices ......................................................................................................................... 5 Item 13 – Review of Accounts ........................................................................................................................ 6 Item 14 – Client Referrals and Other Compensation .................................................................................. 7 Item 15 – Custody ............................................................................................................................................. 7 Item 16 – Investment Discretion .................................................................................................................... 7 Item 17 – Voting Client Securities .................................................................................................................. 8 Item 18 – Financial Information ..................................................................................................................... 8 Part 2A - iii  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE Item 4 – Advisory Business Valpey Financial Services, LLC (“VFS” “we” or “us”) is an independent investment advisory firm located in Concord, NH and registered with the Securities and Exchange Commission. We provide investment management services and financial planning services. VFS has been in business since 2010 and is solely owned by its President, Ronald L. Valpey. Investment Management Services Our investment advisory services are centered around each client’s individual financial goals. Through personal discussions with the client, including exploration of their financial goals and objectives, VFS develops a client’s personal investment policy, then manages the client’s assets based on that policy, which includes the client’s stated objectives (i.e., aggressive, moderately- aggressive, moderate, moderately conservative or conservative). Client accounts are continuously monitored, and portfolios are reviewed on a regular basis. Conversations with clients related to their ongoing financial and investment needs occur on a periodic basis (no less than annually), and the client’s investment policy statement is updated, as needed. VFS requests that clients acknowledge these updates in writing. In the management of a client’s assets, we select or recommend securities based on the individual needs of the client. When a client elects to grant us with discretion, we will place transactions in the client’s account without prior approval from the client. If a client wishes to retain discretion over the management of their assets, we will obtain the client’s consent before placing transactions in the client’s account. Clients may impose reasonable restrictions, in writing, on investing in certain securities or types of securities. See Item 8 for a more thorough description of our investment strategies. Financial Planning & Consultation VFS provides financial planning advice via a financial needs analysis. This service is included as part of our investment management service at no additional charge. We also provide our financial planning and consultative services to individuals and families who have not engaged us for ongoing investment management via a written Fee for Service Agreement. In either case, VFS will prepare a customized plan based on the client’s stated financial goals and objectives. Information for the plan is gathered through personal interviews and includes current financial status, future goals and attitudes towards risk. In general, the financial plan will address any or all of the following areas: • general financial planning questions • retirement or income planning • education planning • social security drawing analysis • charitable giving • risk mitigation • portfolio allocation(s) recommendations (no specific security recommendations are provided to clients who are not also investment management clients) Part 2A - 1  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE Implementation of the recommendations made in the plan will be at the discretion of the client. Our financial planning services are included as part of our investment management engagements and are provided at no additional charge. We also provide consultative investment advice on a more limited basis. This can include advice regarding an isolated area of concern such as retirement planning or reviewing your existing portfolio. We also provide specific consultation and administrative services regarding your investment and financial concerns when within our area of expertise. Regulatory Assets Under Management As of 12/31/2025, VFS provided continuous and regular supervisory or management services on $211,634,164 of client assets on a discretionary basis and $14,375,047 of client assets on a non- discretionary basis. Item 5 – Fees and Compensation Investment Management Services VFS’s fee schedule for investment management services, which include financial planning services, is as follows: Total Net Asset Value First $1,000,000 Next $1,000,000 Next $1,000,000 Over $3,000,000 Annual Rate 0.85% 0.75% 0.65% 0.25% Our advisory fees are deducted directly from the client’s account(s). The specific manner in which fees are charged is established in the client’s asset management agreement. Fees are charged quarterly in advance and are based on the average daily balance of the account during the previous quarter. Fees are prorated for accounts that are opened or closed during a calendar quarter. Upon the closing of an account, unearned fees will be promptly refunded. Our minimum annual household fee for ongoing investment management services is $6,000, which may be reduced or waived at the firm’s discretion. We will aggregate, or group, household accounts for the purposes of achieving lower fee breakpoints. Fees are not negotiable, but VFS may quote alternative fee schedules when planning and investment circumstances dictate. The agreed-upon fee schedule will be reflected in the client’s asset management agreement. Clients receive account statements reflecting our advisory fee directly from the account custodian. Financial Planning & Consultation Financial planning is offered free of charge to investment management clients. It is also offered on an hourly basis at our standard hourly rate, which is currently $405/hour. Creating, reviewing and adjusting a financial plan usually takes two to six hours. Subsequent updates generally take from one to three hours. VFS can provide an advance estimate for any financial planning or consultative service. Hourly Part 2A - 2  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE services may be limited or unavailable depending on time constraints. Other Fees Incurred by Clients When we manage client assets, our clients will incur other fees in addition to our advisory fees. These include brokerage transaction costs and may include custodial fees, exchange fees, transfer fees or taxes, administrative fees, mutual fund fees and exchange traded fund (ETF) fees, when applicable. VFS primarily recommends exchange traded funds, “no-load” or “load-waved” mutual funds and/or fixed securities not held in exchange traded funds or mutual funds. Clients could invest in a mutual fund, exchange traded fund or other investment vehicle directly, without our engagement. In that case, the client would not receive the services we provide which are designed, among other things, to assist in determining which options are most appropriate to the client’s financial condition and objectives. Clients should review all fees associated with the investments we recommend and the brokerage and custodial services they receive, in addition to our fees, to fully understand the fees you will pay for our services. Item 6 – Performance-Based Fees and Side-By-Side Management VFS does not charge any performance-based fees for its services or engage in side-by-side management. Item 7 – Types of Clients VFS provides investment management and financial planning services to individuals, including high net worth individuals, as well as to trusts, estates, corporations, and charitable organizations. In order to maintain the highest level of service to existing clients, we accept only a limited number of new clients into our practice each year. Our minimum requirement to accept a new client is $750,000 in assets to be managed by our firm. This minimum may be reduced or waived at our discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss VFS uses Strategic Asset Allocation (SAA) to help our clients meet their goals. SAA is creating, constructing, monitoring and managing a diversified portfolio specific to the individual’s financial needs, time horizon and risk tolerance. SAA is balancing what are generally considered more risky equities (stocks) with what are generally considered less risky debt investments (typically bonds, treasuries, bills, notes, certificates of deposit (CDs), and money market accounts). Other types of investments may also be used. It should be noted that debt investments (fixed income), while generally considered less risky than stocks, are not risk free, and some debt investments can actually be riskier than some stocks. We generally prefer passive management (passive selection), or indexing, to active management (predictive selection) with regard to stocks. We generally show preference to low-cost investment options, whether passive or active, except in cases where historical return has warranted higher expenses. Part 2A - 3  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE Investing in securities involves risk of loss that clients should be prepared to bear. Investment results will vary, and past performance is not a guarantee of future results. Market conditions, interest rates, issuer-specific events, economic developments, and other factors may cause the value of investments to fluctuate, sometimes significantly, and clients may lose some or all of their principal. No investment strategy, risk management technique, or asset allocation approach can eliminate the risk of loss or guarantee profits in all market environments. Diversification may reduce risk but does not ensure a profit or protect against loss in declining markets. Below is a list of risks that our clients should consider: ETF & Mutual Fund Trading Risk. If we use ETFs, clients should understand that ETFs trade intraday at market prices that may differ from NAV (premiums/discounts). During periods of market volatility or reduced liquidity, premiums/discounts and trading costs (e.g., bid-ask spreads) may increase and may adversely affect returns. Index construction rules Index Methodology/Concentration Risk. (including weighting methodologies) can lead to concentration in particular issuers, industries, or sectors, which can increase volatility and losses when those exposures decline. Passive/Index Investing Risk. We may recommend or invest client assets in index mutual funds, index ETFs, or other passive strategies designed to track the performance of a securities index rather than selecting securities to outperform the market. Index-tracking strategies are subject to the general risks of the underlying index constituents, and market declines may result in losses. Index strategies may have less flexibility to react to price declines, and index funds/ETFs may not perfectly track their benchmark due to factors such as sampling, fees and expenses, trading costs, and operational constraints. As a result, index products may underperform their index. Item 9 – Disciplinary Information VFS does not have any reportable disciplinary events. Item 10 – Other Financial Industry Activities and Affiliations VFS’ President, Ron Valpey, is licensed as an insurance agent. In this capacity, Ron can suggest insurance products and strategies, but does not sell insurance products, receive any commissions or share in any commissions related to any insurance products that may be purchased by a VFS client. Ron can refer a client to an insurance specialist upon the client’s request; however, the client is not obligated to use the specialist or to purchase an insurance product. The implementation of any or all insurance recommendations or strategies is solely at the discretion of the client. Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading As an SEC-registered investment adviser, VFS has adopted a Code of Ethics designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”). The Code establishes rules Part 2A - 4  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE for all employees of VFS and is designed to, among other things, govern personal securities trading activities in the accounts of employees. The Code is based upon the principal that VFS and its employees owe a fiduciary duty to VFS’s clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. If a VFS employee intends to invest in the same securities (or related securities, e.g. warrants, options or futures) for which VFS is investing for one or more clients, VFS’ CCO will ensure that it upholds its fiduciary duty and will either (i) aggregate the employee trade with the client trade(s) so that all trades are executed at the same time and at the same price, or (ii) ensure that client trade(s) take precedence over those of the employees’ with the intent of achieving more favorable pricing for the client. VFS will provide a copy of its Code of Ethics to clients and prospective clients upon their request. Item 12 – Brokerage Practices Brokerage Recommendation While clients may direct us to execute their transactions through a brokerage firm of their choosing, we primarily recommend Charles Schwab & Co., Inc. ("Schwab"), a registered broker-dealer, for brokerage and custody services. VFS is not affiliated with Schwab. The final decision to custody assets with Schwab is at the discretion of our clients. Benefits We Receive Schwab provides VFS with access to services that are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge, and include brokerage services related to the execution of securities transactions, custody of client assets, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab also makes available products and services that benefit VFS, but may not benefit its clients’ accounts. These benefits can include national, regional or adviser-specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of VFS personnel by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Schwab also makes available products and services that benefit VFS in the management of its clients’ accounts, including software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of our fees from clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Part 2A - 5  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE Schwab also makes available other services which may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to VFS by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to VFS. Best Execution Clients should be aware that our receipt of above-described benefits creates a potential conflict of interest and influence our recommendation of Schwab to clients. Consistent with our fiduciary duty to clients, we periodically assess the services that Schwab provides to our clients, including a determination of whether clients receive best execution of their transactions. Clients should note that they may pay a commission that is higher than what another broker-dealer charges based on the total value of services received. Price is not the only factor to consider for best execution. Instead, best execution takes into consideration the full range of a broker-dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we seek competitive rates, we may not necessarily obtain the lowest possible commission rates for our clients. Soft Dollars VFS does not have any formal soft dollar arrangements. Aggregation & Allocation of Transactions We manage each client’s account on an individual basis. As such, we generally do not aggregate (block or bundle) client transactions. Rather, we execute trades for individual client accounts when the account is ready for trading, such as when funds are available and the transaction has been determined to be suitable for the client. We do not hold or delay trades for the purpose of aggregating client transactions. Because we generally do not aggregate client trades, clients may pay higher overall transaction costs than they would if client transactions were aggregated. For example, executing smaller orders for individual accounts may result in less favorable prices, higher commissions or markups/markdowns (where applicable), and/or less efficient execution than could be achieved through a single, larger order. In addition, when orders are not aggregated, some client accounts may receive different execution prices than other accounts placing similar trades around the same time due to market movement. If the opportunity is available (if multiple client accounts are ready for the placement of the same trade at the same time), VFS may aggregate the trades of multiple clients into one trading block for execution so that all clients receive the same execution price. Item 13 – Review of Accounts Client accounts are reviewed with clients no less than annually and are reviewed at least monthly by a principal of VFS or the designated investment adviser representative assigned to the account. More frequent reviews may be triggered by account withdrawals or deposits, changes in the client’s individual circumstances, significant market activity, and the political or economic environment. Part 2A - 6  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE In addition to the monthly or quarterly statements and confirmations of transactions that clients receive from their designated custodian, clients will be sent an objective report from VFS summarizing account performance, balances and/or holdings upon request. Item 14 – Client Referrals and Other Compensation VFS do not compensate others for client referrals and does not accept referral fees from other parties. As noted in Item 12, VFS receives economic benefits from Schwab. The availability of these benefits is not based on us providing investment advice or other advisory services to our clients. Item 15 – Custody VFS does not act as a custodian for client funds or securities; however, VFS is deemed to have custody of client assets due to its ability to direct the custodian to deduct its advisory fees from client accounts. All investment management client receive monthly or quarterly statements from the qualified custodian. VFS is also deemed to have custody of client funds due to its ability to effect wire transfers from client accounts to one or more third parties designated in writing by the client without obtaining written client consent for each separate, individual transaction as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. We are not required to obtain a surprise annual audit on assets subject to third-party Standing Letters of Authorization, as would otherwise be required, as long as the following criteria are met: 1. Client provides a written, signed instruction to the qualified custodian that includes the third party’s name and address or account number at a custodian; 2. Client authorizes us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Client's qualified custodian verifies client's authorization (e.g., signature review) and provides a transfer of funds notice to client promptly after each transfer; 4. Client has the ability to terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Client's qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16 – Investment Discretion Clients may grant VFS with discretion to select the identity and amount of securities to be bought or sold in their account(s). In all such cases, VFS exercises this authority in a manner consistent with the stated investment objectives for the particular client account. In addition, when selecting securities and determining amounts, we observe the investment policies, limitations and restrictions imposed by the client in writing. Part 2A - 7  VALPEY FINANCIAL SERVICES, LLC PART 2A OF FORM ADV – FIRM BROCHURE Item 17 – Voting Client Securities VFS does not accept authority or responsibility to vote on any security held by any client. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in their accounts. Clients receive all proxies and other solicitations directly from the custodian or transfer agent. Clients may contact us to discuss questions they may have about particular proxy votes or other solicitations. Item 18 – Financial Information We do not require the prepayment of fees in an amount more than $1,200 six months or more in advance from any client. We also have no financial commitments that impair our ability to meet contractual or fiduciary obligation and have never been the subject of a bankruptcy proceeding. Part 2A - 8  VALPEY FINANCIAL SERVICES, LLC PART 2B OF FORM ADV – BROCHURE SUPPLEMENT Item 1 - Cover Page Ronald L. Valpey, CFP®, AIF® Form ADV Part 2B – Brochure Supplement (CRD No. 3220507) 100 North Main Street, Suite 500 Concord, NH 03301 (603) 856-7945 https://www.valpeyfinancialservices.com March 31, 2026 This brochure supplement provides information about Ronald L. Valpey that supplements the VFS disclosure brochure. You should have received a copy of that brochure. Please contact Valpey Financial Services at the telephone number above if you did not receive VFS’ brochure or if you have any questions about the contents of this supplement. Additional information about Ronald L. Valpey is available on the SEC’s website at www.adviserinfo.sec.gov. Part 2A - 2  VALPEY FINANCIAL SERVICES, LLC PART 2B OF FORM ADV – BROCHURE SUPPLEMENT Item 2 - Educational Background and Business Experience This section of the brochure supplement includes the supervised person’s name, age (or year of birth), formal education after high school, and business background (including an identification of the specific positions held) for the preceding five years. Ronald L. Valpey Year of birth: 1967 Education Program (1998-2000) • Northeastern University, Boston, Massachusetts, BS (1991) • Emerson College, Boston, Massachusetts, MA (1993) • Attended UCLA Accelerated Certified Financial PlannerTM • Graduated from the College of Financial Planning - Denver, Colorado (2002) Business Experience • Investment Advisor Representative, Valpey Financial Services, LLC 07/2010 to present. Professional Exams & Designations • FINRA Series 7 - General Securities Representative Examination, 06/1999. • FINRA Series 24 - General Securities Principal, 10/2002. • FINRA Series 66, Uniform Combined (Series 63 & 65) State Law Examination, 06/2001. Certified Financial Planner™ - CFP® Issuing Organization: Certified Financial Planner Board of Standards, Inc. Prerequisites: Candidate must have a bachelor's degree (or higher) from an accredited college or university, and three years of full-time personal financial planning experience or the equivalent experience (2,000 hours equals one year full-time). Educational Requirements: Candidate must complete a CFP-board registered program, or hold one of the following: CPA, ChFC, CLU, CFA, Ph.D. in business or economics, Doctor of Business Administration, or an Attorney's License. Examination Type: Final certification examination. Ethics Requirements: Candidate must agree to adhere to CFP Board’s ethical and professional standards by signing the Ethics Declaration, and must successfully complete a CFP Board background check. Continuing Education Requirements: 30 CE credits every two years. Accredited Investment Fiduciary® (AIF®) Issuing Organization: Fi360 (a Broadridge company) Prerequisites: Candidate must meet one of the following qualification pathways: • Min of 2 years of relevant experience plus a bachelor’s degree and a professional designation; OR • Min of 5 years of relevant experience plus either a bachelor’s degree or a professional designation; OR • Min of 8 years of relevant experience. Educational Requirements: Candidate must complete an AIF® training program and agree to adhere to the AIF® Designee Code of Ethics and Conduct Standards as part of the designation requirements. Part 2A - 3  VALPEY FINANCIAL SERVICES, LLC PART 2B OF FORM ADV – BROCHURE SUPPLEMENT Examination Type: Final closed-book, proctored certification examination Continuing Education Requirements: Six (6) hours of continuing education annually, affirming adherence to the Code of Ethics and Conduct Standards, and completing the annual renewal process. Item 3 - Disciplinary Information This section includes any legal or disciplinary events and material to a client's or prospective client's evaluation of the supervised person. There are no legal or disciplinary events required to be disclosed in response to this item. Item 4 - Other Business Activities This section includes any relationship between the advisory business and the supervised person’s other financial industry activities that create a material conflict of interest with clients and describes the nature of the conflict and generally how it is addressed. Ronald L. Valpey is not engaged in any other investment-related business. Item 5 - Additional Compensation This section includes details regarding if someone who is not a client provides an economic benefit, including sales awards and other prizes, to the supervised person for providing advisory services. No person who is not a client provides an economic benefit to Ronald L. Valpey for providing advisory services. Item 6 – Supervision This section explains how VFS supervises its supervised persons and how advice provided to clients is monitored. As Chief Compliance Officer, Ronald L. Valpey is responsible for ensuring all advice provided to clients adheres to VFS’ fiduciary standard of putting client interests ahead of those of VFS and its employees. Ronald L. Valpey, as the Firm’s managing member and sole owner, is also involved in overseeing the business operations and activities. Mr. Valpey can be contacted at (603) 856-7945. Part 2A - 4  VALPEY FINANCIAL SERVICES, LLC PRIVACY POLICY Privacy Policy Effective: October 03, 2024 Our Commitment to You Valpey Financial Services (the “the firm”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. The firm (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. The firm does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number(s) Income and expenses E-mail address(es) Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Account applications and forms Investment questionnaires and suitability documents Other advisory agreements and legal documents Transactional information with us or others Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Part 2A - 1  VALPEY FINANCIAL SERVICES, LLC PRIVACY POLICY How do we share your information? An RIA shares Client personal information to affectively implement its services. In the following section, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We share information with technology vendors and third-party service providers to manage and support operations and regulatory compliance (such as administrators, brokers, custodians, regulators, credit agencies, consultants and other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Marketing Purposes The firm does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Valpey Financial Services or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). No Not Shared Information About Former Clients The firm does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Other Important Information California, North Dakota, and Vermont. In response to applicable state law, if the mailing address provided for your account is in California, North Dakota, or Vermont, we will automatically treat your account as if you do not want us to disclose your personal information to non-affiliated third parties for purposes of them marketing to you, except as permitted by the applicable state law. Massachusetts. In response to a Massachusetts law, clients must “opt-in” to share non-public personal information with non- affiliated third parties before any personal information is disclosed. We may disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter Part 2A - 2  VALPEY FINANCIAL SERVICES, LLC PRIVACY POLICY the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 603-856-7945 or ron@valpeyfinancialservices.com. Part 2A - 3