COMPLIANCE MANUAL 2021

COMPLIANCE MANUAL Effective: June 01, 2021 Internal Use Only Page 1 of 34

Table of Contents 1. Introduction ……………………………………………………………………………………….………………… 5 • Primary Office Location • Compliance Manual • Chief Compliance Officer (CCO) • Branch Office Oversight • Supervision • Definition of an Investment Adviser Representative (IAR) • Supervised / Covered Persons vs. Access Persons • Fiduciary Standards • Fiduciary Principles • Violations • Whistleblower Policy 2. Portfolio Management ……………….……………………………………………………………………………. 8 • Client Contracts • Performance Based Fees • Trading • Suitability • Transactions • Trade Errors • Trade Allocation • Trade Aggregation • Best Execution • Soft Dollar Arrangements • Directed Brokerage • Principal and Cross Trades 3. Code of Ethics, Personal Trading, and Insider Trading ……………………………………………………. 11 • Responsibility • Disclosure of Holdings • Conflicts of Interest • Insider Information • Insider Trading • Responsibilities of the CCO • Disciplinary Actions • Compliance Update Form • Outside Business Activities • Gift & Entertainment • Political Contributions (Pay to Play) • Client Complaints • Litigation • COE Certifications 4. Client Management ………………………………………………………………………………………………. 15 • Advisory Agreements • Client Suitability & Investment Policy • Investment Discretion • Annual Review • Asset Management Fees • Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees) • Share Class Review • Legacy Mutual Fund Holdings Page 2 of 34

• Financial Planning Fees • Account Management • Investment Platforms • Procedures for Opening a New Advisory Account • Minimum Contract Requirements • Procedures for Closing a Terminated Advisory Account • Valuation of Securities • Voting Client Securities (Proxy Voting) • Checks & Securities Received • Anti-Money Laundering / Customer Identification Program • ERISA Clients • Government Clients • Vulnerable Clients, Death and/or Incapacitation 5. Performance Parameters and Custody...……………………………………………………………………… 25 • Quarterly Account Statements • Custody 6. Communications and Advertising …………………………………...………………………………………… 26 • Electronic Communications • Social Media • Text Messages • Advertising & Marketing • Articles from News Media • Retention Period • Violations and Questions 7. Regulatory Filings ………………………………………………………………………………………………… 29 • Investment Adviser Regulatory Depository (IARD) • Firm Registration- Form ADV Filings • Form ADV 2A – Firm Disclosure Brochure • Form ADV 2B – Individual Disclosure Brochure • Form CRS – Customer Relationship Summary • Wrap Fee Brochure • ADV Amendments • Material Changes • Form U4 • Form U5 • Financial & Disciplinary Disclosures • Additional State Requirements 8. Books & Records ………………………………………………………………………………………...………. 31 • Retention • Separate Back-up 9. Privacy & Information Security ……………………………………….………………………………………… 31 • Safeguard Rule • Changes to Client Contact Information • Financial Privacy Rule • Disposal Rule • Technology • Internet • Cybersecurity • Client Privacy • Oversight of Critical Service Providers (CSP) • Identity Protection Page 3 of 34

10. Maintaining and Servicing Client Accounts …………………….……………………………………………. 34 • Trading and Administrative Errors • Trading Existing Account • Block Trades 11. Business Continuity Plan …………………………………………………………………………………………34 12. Certification of the Compliance Manual ………………………………………………………………………. 34 Page 4 of 34

1. Introduction Primary Office Location RetireRight, LLC, doing business as RetireRight, (herein “RetireRight” or the “Advisor”) is an investment advisor registered with the U.S. Securities and Exchange Commission (“SEC”) located in West Des Moines, IA. The firm is subject to applicable federal securities laws under the Investment Advisers Act of 19401, as amended (the “Advisers Act”). Compliance Manual The Compliance Manual2 outlines the policies and procedures that are intended to help RetireRight avoid, mitigate, and disclose identified risk. The Compliance Manual is considered a “living document” to be amended from time to time to reflect changes in the Advisor’s services, business model, and regulatory requirements. To the extent that the contents of this Compliance Manual become materially inaccurate, the CCO is responsible for amending the Compliance Manual and delivering to all Advisory Persons a revised copy with any new material that is added, deleted, or amended. This Compliance Manual is designed to discuss the Advisor’s fiduciary duty to its clients, the roles and responsibilities of the Chief Compliance Officer (“CCO”) and Supervised Persons, the use and enforcement of this Compliance Manual, and the Advisor’s process for addressing complaints regarding its Compliance Program. Chief Compliance Officer (CCO) This manual also defines the roles and responsibilities of the Chief Compliance Officer3 (“CCO”) and Supervised Persons. All associated persons must review this Compliance Manual and sign an acknowledgement that they have read, understand, and will abide by the Compliance Manual. Acknowledgements will be maintained by the CCO. The Chief Compliance Officer (CCO) will conduct periodic monitoring of the compliance manual and code of ethics. Monitoring and testing may include (but not limited to): 1. General e-mail and retention 2. Transaction or trade flow 3. Allocation of block trades 4. Correspondence and marketing material 5. Personal trades In order to assist the CCO with the compliance responsibilities, the firm has contracted with various technology systems to support registered investment advisers and serve as a secure document organization and storage facility. Branch Office Oversight RetireRight has branch offices located at 1200 Valley West Drive, Suite 707, West Des Moines, Iowa 50266 and 1797 Creek Wood Drive, Dubuque, IA 52003. To ensure sufficient compliance oversight over the branch location, the CCO will: 1 Rule 206(4)-7 of the Advisers Act of 1940, as amended (the “Advisers Act”) requires that each SEC-registered investment adviser undertake the following: (i) adopt and implement written procedures designed to prevent violations of the federal securities laws (ii) review those policies and procedures annually and (iii) designate a chief compliance officer to administer its policies and procedures. 2 Under Advisers Act Rule 206(4)-7 (often termed the “CCO” Rule”), the Advisor must, among other things, adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. This Compliance Manual Policies & Procedures document (the “Compliance Manual”) sets forth the Advisor’s policies and procedures for complying with the Advisers Act, and together with the related policies and procedures in the Privacy Policy, Code of Ethics, and Business Continuity Plan form the Advisor’s “Compliance Program”. 3 Denise Brochu serves in the capacity of Chief Compliance Officer as an employee of Good Life Outsourced Compliance, LLC (GLOC). GLOC is team-based outsourced compliance solution that provides services from a remote location using custom designed technology resources. A member of the GLOC team is regularly available on-sight as needed. Denise Brochu serves as the Chief Compliance Officer for Good Life the firms, LLC, an SEC registered investment advisor with over a Billion dollars of assets under management. Page 5 of 34

• Conduct periodic electronic surveillance of remote activities including email reviews; • Review all marketing materials created in any branch office prior to dissemination; Supervision Client accounts (Wrap and Non-Wrap) shall be reviewed at least annually by the individual investment advisor representative(s) assigned to the account. Reviews may be conducted more frequently at the Client’s request. Accounts should be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account. Clients must be encouraged to notify their investment advisor representative if changes occur in their personal financial situation that might adversely affect their investment plan. Additional reviews may be triggered by material market, economic or political events. Client accounts are also reviewed by the Compliance Department utilizing our own internal program which incorporates the notifications provided by the LPL Proactive Surveillance portal. Our review addresses the following areas: Market Performance Position Concentration Risk Tolerance Trading Inactivity Asset Allocation Senior Suitability High Cash Balance Fee Calculation Review Investment Experience Definition of an Investment Adviser Representative (IAR) Investment Adviser Representatives (IARs) are Supervised Persons of the Advisor whose main responsibility is to provide investment related advice to clients of the Advisor. Details about the Advisor’s IARs, including their responsible supervisors, are described in the Form ADV Part 2B Brochure Supplement, which is a required disclosure document for all IARs providing investment advice. Each IAR must be registered according to state level registration requirements. For an SEC registered investment adviser state registration is generally only required based on the state where an office is maintained. In order to be eligible for registration an IAR must hold either a Series 65, a Series 7 and 66 or have an eligible professional designation. Supervised / Covered Persons vs. Access Persons Supervised / Covered Persons “Supervised Persons” person(s) subject to the Compliance Program, which typically includes any and all future partners, officers, directors (or other person occupying a similar status or performing similar functions), associated persons of the Advisor, solicitors, independent contractors, or other persons who provide investment advice on behalf of the investment adviser and is subject to the supervision and control of the investment adviser. “Access Persons” are any Supervised Persons who have access to material non-public information about client account holdings or trades, including securities recommendations, who are consequently in a position to exploit such information of personal gain. RetireRight has designated all Investment Adviser Representatives (“IARs”), administrative staff and members of the leadership team to be Access Persons. Fiduciary Standards Under the Advisers Act an investment advisor has a fiduciary duty to its advisory clients. As a fiduciary, it is the Advisor’s responsibility to always act in the best interest of their clients. The Advisor will never place its own interests ahead of any clients’ interests. Specific obligations include: • Having a reasonable, independent basis for investment advice. • Obtaining best execution when implementing the client’s transactions • Ensuring that investment advice is suited to each individual client’s objectives, needs, and personal circumstances. • Maintaining the confidentiality of client information. • Exercising reasonable care to avoid misleading clients. • Making full and fair disclosure to the client of all material facts and conflicts of interest • Placing client interests first and always acting in good faith. Page 6 of 34

In addition, the Advisers Act states that it is unlawful for an investment advisor: • To employ any device, scheme, or artifice to defraud a client or prospective client. • To engage in any transaction, practice or course of business which defrauds or deceives a client or prospective client. • To knowingly sell any security to, or purchase any security from a client when acting as a principal for his or her own account, or knowingly execute a purchase or sale of a security for a client’s account when also acting as a broker for the person on the other side of the transaction, without disclosing to the client in writing before the completion of the transaction the capacity in which the advisor is acting and obtaining the client’s consent to the transaction. • To engage in fraudulent deceptive or manipulative practices. Fiduciary Principles • Disinterested Advice - The Company must provide advice that is in the client’s best interest and neither RetireRight nor any of its associated persons may place their interests ahead of any client's interests under any circumstances. • Written Disclosures - Both the Disclosure Brochure (Form ADV) and the Company’s Advisory Services Agreement must include language detailing all material facts regarding the Company, the advisory services rendered, compensation and conflicts of interest. It is the responsibility of the CCO to establish procedures designed to ensure that all clients are provided with these documents and that they contain the proper disclosure language. • Conflicts of Interest - Investment Adviser Representatives (“IARs”) must disclose any potential or actual conflicts of interest when dealing with clients. For example, if investment advice includes transaction recommendations that would be executed through the Company or an affiliate of the Company, then the advice given would be subject to a potential conflict of interest. • Confidentiality - Client records and financial information must be treated with strict confidentiality. Under no circumstances should any such information be disclosed to any third party that has not been granted a legal right from the client to receive such information. • Fraud - Engaging in any fraudulent or deceitful conduct with clients or potential clients is strictly prohibited. Examples of fraudulent conduct include but are not limited to: misrepresentation; nondisclosure of fees; and misappropriation of client funds. Violations If the CCO or the review officer finds that a person has violated the Policies, the CCO will approve a proposed resolution of the situation or impose upon the person sanctions based on the below guidelines. • First Violation - If an advisory representative violates the Compliance Policies and/or Procedures, the violation was accidental, and the violation did not harm clients in any way, the person will be warned, in writing, that that they have violated the Compliance Policies and/or Procedures. • Second Violation - If an advisory representative violated the Compliance Policies and/or Procedures a second time, the advisory representative will be given a second documented warning, in writing. • Third Violation and/or Willful Misconduct - If an advisory representative, violates the Compliance Policies and/or Procedures three times or if the person engages in willful misconduct, the person may be subject to immediate termination. If the violation is accidental, then another warning will be given. The CCO is responsible for investigating any potential violations, discussing such violations with any individual or service provider believed to have committed a violation and determining, in consort with the members of RetireRight not involved in the violation(s), an appropriate remedy. Page 7 of 34

Whistleblower Policy4 Employees, current or future, may submit complaints on a confidential and anonymous basis without fear of dismissal or retaliation of any kind. While the Advisor does not encourage frivolous complaints, the Advisor does expect its officers, associated persons, and agents to report any potential violations of applicable law, including the policies described in this Compliance Manual, as well as the Advisor's Code of Ethics. Persons reporting complaints may request to discuss the complaint with the CCO. • Reporting Persons Protected – Complaints reported in good faith will not be subject to any retaliation. • Scope of Complaints – Internal Supervised Persons and external vendors, consultants, etc. are all encouraged to report suspected wrongdoings. • Confidentiality of Complaint – All complaints from internal Supervised Persons reported in good faith will be kept confidential and privileged to the fullest extent permitted by law. • Investigation of Complaints – The CCO or delegate will confirm the complaint pertains to a violation by investigating the complaint promptly and document the results. • Retention of Complaints – The CCO will keep records of complaints and the results of their investigation. • Reporting and Annual Review – The CCO will include all complaints and any remedial actions taken in the IA Annual Review. 2. Portfolio Management RetireRight focuses on providing wealth management, investment advisory and financial planning services for high- net-worth individuals, families, pension and profit-sharing plans, trusts, estates, corporations, and charitable organizations. At the beginning of a client relationship, an Investment Adviser Representative shall conduct an initial review of materials and information provided by the client to ascertain the investment objective and investment parameters, policies, and guidelines, including any investment restrictions, of the prospective client. RetireRight will enter into a written asset management agreement with each client that, among other things: o Contains a non-assignment clause o Obtains discretionary authority o Discloses the fee o Provides that RetireRight will manage client accounts in accordance with client investment objectives o Complies with the applicable regulatory standards governing RetireRight. • Performance-Based Fees - RetireRight does not receive performance-based fees. • Trading – Conducted in such a way as to afford fair opportunities to all clients, and no advantage will be specifically reserved for any client over any other. As outlined below, and in Exhibit 2 when possible and practicable, RetireRight may aggregate client trades if such action is advantageous to the clients as a group. • Suitability – All recommendations of investments to clients must be suitable based on the individual client's situation. The firm is required to review client accounts and investment recommendations based upon the client's risk tolerance, level of financial sophistication, current financial situation and investment objectives. 4 Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act Page 8 of 34

• Transactions – As fiduciaries, RetireRight’s duty is to put the clients' interest before its own. RetireRight takes seriously its obligations with regards to the processing of client transactions. RetireRight has established controls and procedures for the following areas: • Trade Errors – When a trade error occurs, the individual associated persons are required to report it to the designated supervisor. Examples of trading errors include, but are not limited to purchasing or selling the wrong security, selling a security when it should have been purchased, incorrect account allocations, buying or selling an incorrect amount of shares, incorrect price was obtained from purchase or sell, violation of account restrictions, etc. Records of all trade errors should be sent to the designated supervisor. When an adviser corrects an error, the client must not be disadvantaged. Any trade errors that occur need to be detailed on a Trade Error Form. The documentation should specify any effect on the client. Trade Errors will be maintained in a file and will be reviewed by compliance quarterly. The firm reviews the handling of trading errors to ensure that client accounts are not disadvantaged. • Trade Allocation – The custodians for RetireRight, LPL Financial and Asset Mark, allocate trades fairly and do not favor certain client accounts with \"hot issues\". In addition, RetireRight prohibits allocating profitable trades at each day's end disproportionately favoring certain clients. RetireRight does not manage a proprietary account. The IARs of RetireRight will review the allocation of transaction costs and securities among clients’ accounts. The CCO will review trades to ensure that RetireRight is not unfairly favoring any client account. Determination of whether an allocation is unfair will depend on the individual facts, circumstances, clients’ needs and financial objectives. • Trade Aggregation – When the purchase or sale of a security is deemed to be in the best interest of more than one client account, the custodian, will aggregate or “batch” orders for the purchase or sale of securities for all such client accounts. RetireRight will ensure that aggregated securities transactions in participating client accounts are allocated in a fair and equitable manner. Generally, aggregated transactions are averaged as to price and transaction costs and will be allocated among participating accounts in proportion to the purchase and sale orders placed for each account on any given day (i.e., pro rata). For each aggregated order, the books and records of the Advisor will separately reflect the securities bought, sold, and held by each account. All such records will be maintained in accordance with the applicable book and recordkeeping provisions of the Advisers Act and the rules thereunder. The IARs of RetireRight do not favor any advisory account over any other managed account and provide individual investment advice to each account. Best Execution Section 206 of the Advisors Act imposes on investment advisors a fiduciary duty to act in the best interest of their clients. That duty includes, among other things, an obligation to seek the most favorable execution terms reasonably available under the circumstances. • The fiduciary duty does not necessarily require an advisor to recommend the lowest cost investment products or strategy. • An advisor does not satisfy their fiduciary duty by simply recommending the least expensive investment without an analysis of other factors. • The determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution. Page 9 of 34

Among the specific factors that may be relevant to an investment advisor’s best execution determination are the following: • Competitiveness of commission rates and spreads • Promptness of execution • Past history of execution of orders • Clearance and settlement capabilities • Ability to prospect for and provide liquidity • Difficulty of trade and security’s trading characteristics • Size of the order • Availability of accurate information regarding the market for the security in question • Liquidity of the market for the security in question • Trading style and strategy • Block trading and arbitrage capabilities • Access to new issues of securities for client accounts The CCO will periodically review execution practices used for transactions placed in client accounts of the Firm. Documentation supporting this review will be maintained in the Firm’s books and records. In order to assure the firm satisfies best execution standards, the firm has implemented a two-prong control. 1. Confirm the executing broker/dealer is meeting best execution standards by reviewing the quarterly best execution report card. 2. Confirm that a sampling of trades executed on behalf of the firm are reviewed quarterly to confirm trades were within 2 (two) standard deviation of the Variable Weighted Average Price (VWAP) for the trading session. This review is completed on a quarterly basis. a. Any trades that are outside of 2 (two) standard deviation are subject to further review against the best execution factors listed above that may include VWAP at the time of execution. Best execution as it relates to mutual fund shares is not necessarily always achieved by selecting the lowest cost share class; the most favorable terms require an investment advisor to consider other applicable fees in the context of the overall relationship and other service providers, particularly ticket charges and the overall cost to clients to achieve their desired strategy. Shares of mutual funds are otherwise executed at NAV. Soft Dollar Arrangements RetireRight does not engage in any soft dollar5 arrangements. RetireRight does receive research from a number of brokerage firms. Directed Brokerage Directed brokerage is defined when a client \"directs\" the firm in writing to utilize a certain broker-dealer(s) for execution of trades. RetireRight does not offer directed brokerage, instead Investment Advisor Representatives are individually registered representatives of LPL Finanical, a FINRA/SIPC member broker/dealer subject to selling away restrictions. Principal and Cross Trades RetireRight does not affect cross transactions or principal trades for its client accounts. 5 Section 28(e) of the Securities Exchange Act of 1934 addresses the issue of paying \"soft dollars\" for products and services. This practice occurs when an adviser 'with discretionary authority causes an account to pay more than the lowest available commission to a broker/dealer in return for products and services from that broker/dealer. Page 10 of 34

3. Code of Ethics, Personal Trading, and Insider Trading The Code of Ethics6 is a core component of RetireRight’s compliance program. Each Supervised Person of the Advisor must comply with the Advisor’s Code of Ethics, which provides a standard for conducting business, to be upheld by all Supervised Persons. The standards imposed by the Code of Ethics include reporting requirements and restrictions on the purchase or sale of securities for Supervised Persons determined to be Access Persons7 with regard to their own accounts and the accounts of certain affiliated persons. Disclosure of Holdings Access persons must identify any personal investment account and any account in which the employee has a beneficial interest, upon hire, annually thereafter and upon opening or closing any account(s). Access persons must submit a complete report of securities holdings, within 10 days of becoming an access person and at least once a year thereafter. The holdings reports must be current as of a date not more than 30 days prior to the individual becoming an access person (initial report) or the date the report is submitted (annual report), December 31 of each year. Personal investments in initial public offerings and limited offerings by access persons are required to be pre- cleared. Access persons must report all required information for covered personal securities transactions on a quarterly basis within 30 days of the end of each calendar quarter to the Compliance Officer. All associated persons shall submit to the CCO a report of every securities transaction which they have participated in. The report shall include the name of the security, nature and date of the transaction, quantity, price, and broker-dealer through which the transaction was effected. This can be handled by submitting custodial statements. All personal securities transactions are covered except: • Managed Accounts where there is no direct or indirect influence or control • Variable annuities or variable insurance policies held directly at carrier • Shares issued by open-end mutual funds or UITs (other than exchange-traded funds) • 401(k) and 403(b) accounts that hold mutual and ETFs only • Accounts held directly at 529 plans • Direct obligations of the US Government • Money Market instruments Conflicts of Interest All conflicts of interest must be disclosed. This includes potential and real conflicts that may impact a client’s decision to conduct business with the Advisor. Conflicts include any financial interest or compensation received in recommendations made to clients, outside business activities involving supervised persons of the Advisor, and business affiliations involving the Advisor. 6 The Code of Ethics has also been adopted in compliance with the requirements of Rule 204A-1 under the Advisers Act to ensure compliance with Federal securities laws. 7 Under rule 204A-l, the adviser's code must require certain supervised persons, called \"access persons,\" to report their personal securities transactions and holdings. An access person is a supervised person who has access to nonpublic information regarding clients' purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are nonpublic. A supervised person who has access to nonpublic information regarding the portfolio holdings of affiliated mutual funds is also an access person. Page 11 of 34

Insider Information Investment Adviser Representatives in possession of material8, non-public information9, also called “insider information,” are prohibited from trading that security, tipping the information to others who then trade that security, or recommending the purchase or sale of that security to anyone. Insider Trading Insider trading has never been specifically defined by the 1934 Act. The definition has evolved through case law and administrative proceedings to include: • Buying or selling securities on the basis of material non-public information. This would include purchasing or selling: (i) for employee's own account or for one in which the employee has a financial interest, or (ii) for the Firm's inventory account. If any employee is uncertain as to whether information is \"material\" or \"non-public,\" the designated CCO should be consulted immediately. • Disclosing insider information to inappropriate personnel whether for consideration or not (i.e., tipping). Insider information must be disseminated on a \"need to know basis\" to appropriate personnel. A principal of the Firm should be consulted should a question arise as to who in the Firm is entitled to the insider information. • Assisting someone who is transacting business on insider information from a third party. All associated persons of RetireRight will be subject to the insider trading policies contained within this section. For purposes of this section, an \"employee\" is defined as any person who is associated with and/or performs any duties on behalf of the firm. All associated persons must make a diligent effort to ensure that a violation of the Insider Trading Act does not intentionally or inadvertently occur. In this regard, all of RetireRight’s associated persons are responsible for: • Reading, understanding, and consenting to comply with the Insider Trading information contained in this section. • Ensuring that no trading occurs for the employee's account, or for any account which the employee has a beneficial interest, in securities for which they have insider information. • Not disclosing any insider information obtained from any source to any inappropriate persons. Disclosure to family, friends or acquaintances will be grounds for immediate termination. • Consulting the CCO when a question(s) may arise regarding insider trading or when the employee suspects a potential violation of insider trading. • Advising the CCO of all outside activities, directorships, or material ownership in a public company (over 5%). No employee may engage in any outside activities as employee, proprietor, partner, consultant, trustee, officer, or director without prior written consent by the CCO. This does not include outside activities with non-profit organizations. Responsibilities of the CCO The CCO will be responsible for detecting and preventing insider trading abuses. Such measures will consist of: • Creating, modifying, and supervising the policies of the Firm concerning insider trading • Communicating the insider trading policies to associated persons upon hiring 8 Material Information is information for which there is a substantial likelihood that a reasonable investor would consider it important in making his or her investment decisions, or information that is reasonably certain to have a substantial effect on the price of a company’s securities. Material Information includes, but is not limited to, dividend changes, earnings estimates, changes in previously released earnings estimates, significant merger or acquisition proposals or agreements, major litigations, liquidation problems and extraordinary management developments. 9 Nonpublic information is information that has not been effectively communicated to the marketplace. One must be able to point to some fact to show that the information is generally public. For example, information found in a report filed with the SEC, or appearing in Dow Jones, Reuters Economic Services, The Wall Street Journal, or other publications of general circulation would be considered public. Page 12 of 34

• Reviewing employee confirmations and statements for potential insider trading violations and noting evidence of such review • Answering employee questions regarding insider trading • Accordingly, IARs must be cognizant of any client who may be a “control person” (e.g., officer, director, or 10 percent shareholder) of any publicly traded company. If an IAR believes that he/she or a client possesses insider information, the IAR should immediately contact the CCO before taking any action. Disciplinary Actions Violations of the Insider Trading Act can result in severe penalties to the firm, the principals, and the individuals violating the rules. Violations (whether inadvertent or intentional) will not be tolerated by RetireRight and will result in severe disciplinary action including the immediate termination of the employee. Penalties for trading on or communicating inside information can be severe, both for individuals involved in such unlawful conduct and their employers. A person can be subject to some or all of the penalties below, even if he or she does not personally benefit from the violation. Penalties include: • Civil injunctions; • Treble damages; • Disgorgement of profits; • Jail sentences and fines for the person who committed the violation of up to three times the profit gained or loss avoided, whether or not the person actually benefited; and • Fines for the employer or other controlling person of up to the greater of $1,000,000 or three times the amount of the profit gained, or loss avoided. Compliance Update Form The CCO or delegate will request that all Supervised Persons complete a Compliance Update Form at least monthly. The form is made available using a third-party vendor. At a minimum, the form collects trade errors, political contributions, outside business activities, unsolicited trades in an advisory account, incoming and outgoing correspondence, non-cash compensation log and provides the ability to upload any outside brokerage account statements. The information provided is then reviewed by the CCO or delegate and stored accordingly. Outside Business Activities Supervised Persons that are engaged in an outside investment related as well as non-investment related activity must disclose it when they begin employment with the Advisor, or as it arises during the course of employment. The CCO will determine if the activities must also be disclosed on the Supervised Person’s U4 and/or their Form ADV Part 2B. Gifts & Entertainment Gifts and gratuities for supervised persons that are permissible cannot be so frequent, monetarily excessive, or so extensive as to raise any question of propriety and cannot be preconditioned on achievement of a sales target, and includes: Occasional Meals, Sporting Events or Comparable Entertainment (Collectively \"business entertainment\") from Product Sponsors. The value of a single occasion benefit should generally be limited to $500.00 per supervised person. The Firm’s supervised persons aggregate values of all such items received from product sponsors or outside vendors should be limited to $1,500.00 per product sponsor or vendor, per calendar year. Clients and/or prospects cannot be in attendance. Gifts are allowed, provided the following: • Gifts to and from, any person or entity with which the Firm does business with or on behalf of, does not exceed $100.00 in total value, per person or entity, per calendar year, per supervised person. • Gift certificates that are valued at $100.00 or less and are redeemable for merchandise or services. Gift certificates cannot be redeemable for cash or cash equivalents. Page 13 of 34

When giving/receiving a gift to/from, a person or entity with which the Firm does business with or on behalf of, IARs should consider whether the gift, the nature of the relationship with the person or entity, and the occasion to which the gift applies is appropriate. Gifts and entertainment, both given and received, must be added to the Firm’s Non-Cash Compensation Log. Political Contributions (Pay to Play) Commonly known as the \"Pay to Play\" Rule10, an investment advisor is prohibited from providing advisory services for compensation to a government client for two years after the advisor or certain covered associates contribute to applicable elected officials or candidates. This rule applies across the firm and its IARs; meaning, that if one IAR contributes above certain thresholds (de minimis) as described below or solicits contributions, then all IARs are prohibited from receiving fees for providing advisory services to the applicable government entity for a period of two years. Covered associates who intend to contribute to a state or local government official or candidate are required to notify the Firm’s CCO describing their forthcoming contribution before making it. Covered associates may only make contributions to state or local officials or candidates of up to $350 per election per candidate if the contributor is entitled to vote for the candidate or officeholder and up to $150 per election per candidate if the contributor is not entitled to vote for the candidate or officeholder. A contribution is defined to include a gift, subscription, loan, advance, deposit of money, or anything of value made for the purpose of influencing an election for a state or local office, including any payments for debts incurred in such an election. This can include any expenses incurred while volunteering time to a campaign. It also includes transition or inaugural expenses incurred by a successful candidate for state or local office. This rule applies to state and local government officials and candidates. It does not apply to contributions made to a political action committee (PAC), a current federal officeholder, or a candidate for federal office (unless that candidate is a current state or local government officeholder). The rule also prohibits an investment advisor from providing or agreeing to provide, directly or indirectly, payment to any third party for a solicitation of advisory business from any government entity on behalf of such investment advisor unless such third parties are registered broker/dealers or registered investment advisors. In each case, they are subject to pay to play restrictions. Additionally, the rule prevents an investment advisor or its covered associates from soliciting from others, or coordinating, contributions to certain elected officials or candidates or payments to political parties where the investment advisor is providing or seeking government business. The Pay to Play Rule also requires a registered investment advisor to maintain certain records of the political contributions made by the investment advisor or covered associates. Client Complaints While providing advisory services, the Advisor may receive a complaint11 regarding their services or other related matters. Client complaints received will be investigated promptly and fully in order to resolve any issues in a timely and complete manner. RetireRight will respond appropriately and promptly to client complaints that it receives and, when appropriate, take corrective actions to prevent future complaints 10 SEC Rule 206(4)-5 under the Advisers Act 11 Any statement alleging specific inappropriate conduct on the part of the Advisor constitutes a complaint. A client complaint must be initiated by the client and must involve a grievance expressed by the client. In many instances, it is difficult to determine whether or not a communication constitutes a “complaint”. A mere statement of dissatisfaction from a client about an investment or investment performance in most cases does not constitute a complaint. When in doubt, Supervised Persons should consult with the CCO to determine if a particular communication should be construed as a “complaint”. Page 14 of 34

When a complaint is received, the Supervised Person that receives the complaint should promptly notify the CCO. The CCO will document receipt of the complaint and the log will be maintained in the Advisor’s books and records along with any correspondence or supporting documents related to the complaint. The Advisor will make every effort to ensure that the complaint is addressed and settled in a timely manner and will document the resolution in a file or log designated for client complaints. Verbal Complaints In the case of a verbal complaint, the Supervised Person shall make notes of the conversation and retain a copy in the investment advisory complaint file. These notes must include the date of the complaint, the complainant’s name, address, telephone number and a summary of the complaint. Notes of verbal complaints must be submitted to the CCO. Written Complaints A copy of each written complaint must be forwarded to the CCO. Supervised Persons may not respond to a written complaint without first consulting with the CCO. Written complaints must be maintained in a separate investment advisory complaint file. Litigation Files containing all written communications received or sent regarding any litigation involving RetireRight or any investment adviser representative, employee or supervised person should be maintained for a period of no less than five years from the date of resolution. COE Certifications All Supervised Persons must certify annually to the CCO that they have read and understand the Code of Ethics, that they have complied with ALL requirements of the Code of Ethics and that they have provided the CCO with all transactions required to be reported under the Code of Ethics. The CCO will deliver a copy of the Code of Ethics along with required certifications to all Supervised Persons annually as well as any amendments to the Code of Ethics. 4. Client Management To manage client relations, the Advisor will review the client’s personal information and situation before finalizing the engagement with a client agreement. The Advisor will perform further analysis as needed and required to further manage the client relationship. Advisory Agreements The Advisor requires a written Asset Management Agreement for all clients. The CCO or delegate is responsible for reviewing the Asset Management Agreement to ensure that it meets all of the Advisor’s standards and legal requirements. The advisory agreement contains an acknowledgment of the Disclosure Brochure delivery as well as an acknowledgment of receipt of the Advisor’s Privacy Policy. All signed copies of Asset Management Agreements are maintained. The Advisor will also accept electronic receipt of original documents either via scan or facsimile. Electronic signature documents will also be maintained in a client file pursuant to the Books and Records requirements. Advisory agreement cannot be assigned without client consent. Client Suitability & Investment Policy The Advisor has a fiduciary duty to provide investment advice to each client that is suitable to that particular client. The Advisor is responsible for managing the client’s assets and is also responsible for making a reasonable inquiry into the client’s investment objectives, financial situation, investment experience, and tolerance for risk. Based on that information, the Advisor shall determine whether any investment advice rendered to the client is suitable. The required scope of a suitability inquiry depends on the standard of what is reasonable under the circumstances. The Advisor generally should obtain and review as much information as possible concerning the client. A large part of the suitability determination with respect to clients may depend on the client’s written and/or documented Page 15 of 34

investment objectives, which may be contained in a formal questionnaire. As the level of risk increases, an increasingly thorough review of a client’s background is warranted. In addition, the Advisor typically obtains the following: • General background information typically obtained as part of the account opening process, for example, retirement plan documents, constitutional, statutory, or regulatory restrictions on client investments, internal client investment policies and guidelines, trust documents, and partnership agreements, etc. • General information about the client and their primary business activities. • Financial information about the client, for example, total value of the client’s assets, percentage of assets invested with other managers or in other investment vehicles, and short- and long-term liabilities. • The IAR shall prepare and place in a client’s file a memorandum identifying any information requested, but not provided by the client, as well as the person from whom such information was requested and the reason why the client did not provide the information. The suitability of individual investments, absent a specific restriction on the purchase of that investment, generally should be evaluated in the context of the client’s entire portfolio. Investments should adhere to any client-imposed investment restrictions and should be permissible and authorized under any offering memorandum, prospectus or other disclosure document, retirement plan documents, constitutional, statutory, or regulatory restrictions on client investments, internal client investment policies and guidelines, trust documents, and partnership agreement, or similar limitations on client investment authority. Any proposed investment strategy should take into consideration the nature and characteristics of a client, such as, among other things, the client’s investment objectives, risk tolerance, investment experience, financial condition, and assets available for investment, investment restrictions and their remaining investment horizon. Additional considerations to a strategy proposal might be the types of securities purchased, the composition of the client’s existing portfolio, the sophistication of the client, and whether the nature of the strategy may alter the risk profile of a client’s portfolio for each specific client. Investment Discretion RetireRight manages portfolios on a discretionary basis. This means that after an Investment Plan is developed for the client’s investment portfolio, RetireRight will execute that plan without specific consent from the client for each transaction. RetireRight has the authority to carry out various activities in the account, generally including the following: trade execution; the ability to request checks on behalf of the client; and the withdrawal of advisory fees directly from the account. RetireRight then directs investment of the client’s portfolio using its discretionary authority. The discretionary relationship is further described in the Asset Management Agreement between RetireRight and the client. Annual Review The Firm’s policy requires an annual client meeting (one review every 12 months) to determine if there have been any changes in the client's financial situation, investment objectives, or restrictions. In addition, the meeting should incorporate the account performance, appropriateness of the account, and any other information determined pertinent to the client situation. The annual meeting may occur by phone, in person, via e-mail, or via video conference and will be documented in writing using a method that covers at a minimum the following topics: The client’s financial status, Risk Tolerance, Time Horizon, Investment Objective and Goals, and Asset Allocation. A record of the contact is maintained in the client’s files and/or updated in electronic records (i.e., compliance system, CRM system), specifying the mode of contact. If a letter was sent, a copy of the letter is sufficient. Page 16 of 34

Asset Management Fees The methodology for client fees is disclosed in the ADV 2A - Firm Disclosure Brochure under Item 5, in addition to the asset management agreement. The CCO or delegate will perform fee calculations on a sampling of accounts as part of the IAR’s account reviews. The specific manner in which fees are charged by the firm is established in a client’s written agreement between the client and RetireRight – up to 2% of assets under management in a non- wrap program account and up to 2% of assets under management in a wrap program account. Clients can determine to engage the services of RetireRight on a discretionary or non- discretionary basis. The firm’s annual investment advisory fee shall be based upon a percentage (%) of the market value under the firm’s management to be charged quarterly in advance and if applicable, in arrears for the first quarterly cycle. Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees) RetireRight will seek to determine the most advantageous share class available to each client. While institutional share classes are usually the lowest cost alternative, under certain circumstances clients may be better served to pay a higher annual expense ratio and avoid a transaction fee on each trade. When selecting a mutual fund for a client’s advisory account, the investment advisor representative has a fiduciary duty to select the share class that helps manage the overall fee structure of the account. The overall fee structure includes such fees as: Asset Management Fees, Expense ratio, which includes 12b-1 fees, generally .25% for A shares and/or trade ticket charges. Investment Advisor Representatives must anticipate and monitor trading volume, and the asset management fee that is determined based on account size, complexity, and time requirements. RetireRight does not allow a mutual fund which pays a 12b-1 fee within an advisory account were the advisor pays ticket charges unless deemed to be in the client’s best interest. An exception form to allow the 12b-1 fee paying fund to remain in the account can be completed and if approved by the Compliance Department the asset will be allowed to remain in the account. RetireRight realizes that in some instances the desire of the client’s beliefs, trading volume and expense analytics could make holding a 12b-1 fee paying asset more advantageous to the client. This determination must be documented by receiving compliance approval to the exception request. RetireRight recognizes that in some situations an alternative share class to a 12b-1 fee paying mutual fund may not be available. In such an instance, the advisor must document their due diligence and present to the compliance department why keeping the fund is in the client’s best interest. If deemed valid by the compliance department, the advisor would be allowed to complete an indemnification agreement. The indemnification agreement is completed by fund. Share Class Review On a bi-monthly basis, the CCO or delegate will review client mutual fund holdings according to share class. RetireRight will conduct research, as to whether a non 12b-1 fee paying share class is available. • If in the client’ best interest and the position meets the minimum investment criteria, RetireRight will place instructions for the custodian to convert to the non 12b-1 fee paying share class. • If there is not a non 12b-1 fee paying share class available, RetireRight will require an exception form to be signed by the client acknowledging their awareness and consent to the 12b-1 fee associated with these positions. The bi-monthly review will be documented and maintained as part of the firms Books and Records. Page 17 of 34

Legacy Mutual Fund Holdings When a client transfers assets into a managed account, the portfolio advisor will review the client’s mutual fund holdings. If not one of the custodian’s recommended funds, the mutual fund will generally be sold unless the client needs to avoid a taxable gain or directs the Company to hold the position. In some circumstances, if the legacy holding fits into the asset allocation of the portfolio, it may be held going forward. When legacy holdings are maintained in a client’s account, the client’s primary advisor (or his designee) is responsible for conducting an initial analysis of the mutual fund share class that he or she believes is in the client’s best interest to hold based on the account size, investment strategy and eligibility requirements. If in the client’s best interest to convert to an alternative share class, RetireRight will place instructions for the custodian to convert the position. Financial Planning Fees Financial planning services are negotiable not to exceed $500 an hour, based on 15-minute increments, without extenuating circumstances and approval by the Chief Compliance Officer. The hourly fee will be based on the type of services to be provided, the experience and expertise required, and the sophistication of the client. The lowest hourly charge is generally not less than $250 but, in some instances, financial planning services may be provided at no additional cost. The negotiated fee will be documented on the Financial Planning Agreement and Schedule A and signed by the Investment Advisor Representative and the client. In other instances, financial planning may be provided based on a fixed fee for services. While individual complexities will determine the fixed fee charged, the minimum fixed fee is generally not less than $250 and will be based on the number of hours estimated to complete the plan but not billed based on actual hours. The following criteria should be considered when determining the number of hours expected to create a client specific financial plan. • Total income (wages, investment, business, alimony, rental, etc.) • Net-Worth • Marital Status • Tax Bracket • Children • Education Costs • Timeframe • Risk-Tolerance and Objectives • Account Types and Holdings • Investment Experience • Budget • Assets Under Management Account Management Investment Advisor Representatives must emphasize continuous and regular account supervision as part of their asset management service. A combination of charting, fundamental and technical analysis may be used to formulate investment advice when managing assets. Depending on the analysis the Investment Advisor Representatives will implement a long or short-term trading strategy based on the particular objectives and risk tolerance of a particular client. Investment Platforms Investment Advisor Representatives must consider the different investment platforms available and determine the best interests of each client. Page 18 of 34

Procedures for Opening a New Advisory Account A new advisory account may be opened after the IAR has determined that an advisory account is in the best interest of the client. An Asset Management Agreement is completed for each new client/household and an ADV2A, ADV2B, Privacy Policy and the firm’s Form CRS are provided to the client. The Firm reviews certain advisory accounts for appropriateness based on several suitability parameters, including the account owner's age, investment objective, estimated account value, and liquid net worth. In recommending and selecting investments or portfolio managers for clients, IARs should refer to the Custodian’s list of available products including mutual funds, stocks, bonds, and portfolio managers. IARs should, regularly consult with each client; review the performance of the client’s advisory account and investment objectives. • IARs are required to discuss client's risk tolerances, financial goals, concerns, and other relevant topics with each client at the beginning of the engagement. All notes should be placed in client's file. • IARs should manage each portfolio prudently and with consideration of the client's investment objective and goals. • If the IAR determines that the client's investment objectives or risk tolerance have changed, it should be noted in the client's file. If applicable, the Investment Policy Statement should be updated. • IARs should have consistent reviews of client's portfolios and meet with the client as the client wishes. Review of all accounts shall be done at least annually. Minimum Contract Requirements The following provisions are outlined in the RetireRight Asset Management Agreement: • Assignability of Contract - The Firm may not assign the contract to any other IA without the prior consent of the client. • Discretion - Any discretionary trading authority granted to the Firm must be obtained in writing from the client. • Prohibition on Waiver of Compliance with the Investment Advisers Act - The contract must not permit for a waiver of any compliance with the IA Act. • Disclosure of Partnership Changes - The firm will notify the client of any change in membership of such partnership within a reasonable time. • Establish a client file, which includes, among other things: the advisory agreement, quarterly statements, invoices, and correspondence as it relates the management of client accounts. • If applicable, complete forms to authorize the transfer of client assets to the custodian. Procedures for Closing or Terminating an Advisory Account An account is terminated by an ACAT notice from the client’s clearing firm, a verbal or written client request or by the IAR. • Calculation of a pro-rated fee or refund are made. • Funds will be distributed per the client’s instructions or by check to the address of record. • The account will be listed on the closed account report and documents will be retained for a period of no less than 5 years from the end of the fiscal year in which the account was closed or terminated. If an IAR wishes to terminate the advisory relationship with a client, a letter will be sent to the client notifying them of the termination providing a 30-day notice period. After the 30-days have passed, the Asset Management Page 19 of 34

Agreement is terminated. If applicable, the account may be converted to a brokerage account or a custodial house account at that time. If a client is unresponsive in scheduling or a client annual review has not occurred in 24 months, the CCO will review and determine whether the Asset Management Agreement is be terminated and client notified by letter Valuation of Securities RetireRight does not provide valuation services. Valuations are provided by the custodian. Voting Client Securities (Proxy Voting) RetireRight does not vote client proxies, but third-party money managers selected or recommended by our firm may vote proxies for clients. Clients will receive their proxies or other solicitations directly from their custodian. Investment Advisor Representatives may discuss proxies with a client. Checks & Securities Received Checks received are processed within 24 hours. If not able to be processed in the branch office, the IAR or Supervised Person will forward to the applicable custodian and document on the Non-Local Deposit Check Log. For checks which can be processed in the branch, the deposit is made following the custodian’s instructions. Documentation of the processed checks are retained for five years. Securities received are forwarded by client to the custodian along with Stock and Bond Power Authorization Form. Copies of certificate are made, and the security log completed. These records are retained for five years. Anti-Money Laundering / Customer Identification Program Registered investment advisors are not yet subject to extensive anti-money laundering12 (“AML”) requirements under State or Federal U.S. Law. However, money laundering is a federal crime. ERISA13 Clients Prior to acting as the advisor to an ERISA plan, the Advisor will amend its practices so that they comply with the Employee Retirement Income Security Act of 1974 (ERISA). The Employment Retirement Income Security Act of 1974 (“ERISA”) is a federal law that sets standards of protection for individuals in most voluntarily established, private-sector retirement plans. ERISA was enacted to protect the interests of employee benefit plan participants and their beneficiaries by: • Requiring the disclosure of financial and other information concerning the plan to beneficiaries • Establishing standards of conduct for plan fiduciaries • Providing for appropriate remedies and access to the federal courts • ERISA is administered by the Employee Benefits Security Administration (EBSA), a division of the U.S. Department of Labor (“DOL”). The Internal Revenue Code (“IRC”) includes standards of conduct for IRAs and other non-ERISA plan retirement accounts which mirror ERISA requirements. The CCO is responsible for ensuring the Company complies with the Advisers Act; and is also likely to be assigned oversight of compliance with separate rules and regulations governing its activities under ERISA and the IRC. The information and procedures contained in this section represent general guidelines to be followed by the CCO and are not designed to be all inclusive of ERISA or IRC requirements or restrictions. 12 Money laundering is a crime that involves use of the financial system to disguise the origin of assets, for example, by creating complex layers of financial transactions and by the integration of the laundered proceeds into the economy as clean money. There are various laws and regulatory standards that govern entities in the effort to deter money laundering, including: The Bank Secrecy Act of 1970; the Money Laundering Control Act of 1986 and the USA PATRIOT Act. 13 The Employee Retirement Income Security Act of 1974 (“ERISA”) is a federal law that establishes legal guidelines for private pension plan administration and investment practices. ERISA was written to protect plan beneficiaries and participants from problems and abuses. Page 20 of 34

Plans Covered by ERISA ERISA plans include defined contribution and benefit plans, employee stock ownership plans, and profit- sharing and 401(k) plans. The DOL is responsible for enforcement. Non-ERISA “Plans” Non-ERISA plans covered by the DOL’s fiduciary requirements include Traditional and Roth IRAs, Archer medical savings accounts, Health Savings Accounts (“HSAs”) and Coverdell education savings accounts. However, the IRS is responsible for enforcement of violations of the IRC’s rules governing fiduciary conduct. Definition of a Fiduciary under ERISA sec. 3(21) and IRC sec. 4975 A fiduciary is a person who, for compensation renders investment advice to a plan or IRA (including participants of a plan) through a recommendation as to: • The advisability of investing in securities or other investment property, including advice on rollovers, transfer or distributions from a plan or IRA. • The management of securities or other investment property, including recommendations on investment policies or strategies, portfolio composition, professional referrals for investing services, types of investment accounts (such as brokerage versus advisory) and rollover activities including the destination. • Fiduciary status is also triggered when an adviser or its employee represents or acknowledges they are acting as a fiduciary to the client. Fiduciary Obligations under ERISA An ERISA plan fiduciary has the obligation to: • act solely in the interest of the participants and their beneficiaries • Defray reasonable expenses in administering the plan • Act with the care, skill, prudence, and diligence that a prudent man would use in the same situation14; • Diversify plan investments to reduce the risk of large losses unless it is clearly prudent not to do so; and • Act according to the terms of the plan documents, to the extent the documents are consistent with ERISA. Investment Policy Statement ERISA plans shall be formulated to include an Investment Policy Statement (“IPS”). The IPS, at minimum, should address the following: • The purpose of the plan • Suitability standards • Risk parameters, return requirements, and • Portfolio diversification standards. This IPS is normally prepared by the Plan Sponsor and is utilized to select the appropriate Investment Portfolio(s) offered by the Company. A member of the Investment Committee will review or be familiar with the Investment Policy Statement of any ERISA plan for which the Company acts as an adviser. An IPS is not legally required for a non-ERISA plan, such as an IRA account. However, many advisers use an IPS for other types of clients. 14 ERISA 404(a) Where the Company acts as an adviser to an ERISA plan, it must adhere to the \"Prudent Man Standard\" which generally requires that an adviser act solely in the interest of the plan using the skill, care, prudence, and diligence of a prudent man. The Prudent Man Standard considers the total performance of the entire portfolio rather than the actual performance of any particular investment. The Prudent Man Standard is deemed satisfied if the Company has given appropriate consideration to the facts and circumstances that it knows, or should know are relevant, including the role the investment plays in the plan's investment portfolio. This is often referred to as the \"prudent expert\" rule. Page 21 of 34

Directed Brokerage ERISA plan sponsors may direct the Company to execute its securities transactions for the plan through certain broker-dealers in return for research, performance evaluation, administrative services, master trustee services, discounted commissions, or cash rebates. This area is also referred to as \"soft dollar\" arrangements. ERISA requires the Company and the plan sponsors to act prudently and for a purpose that exclusively benefits the plan's beneficiaries. In addition, to rely on the safe harbor of Section 28(e) of the 1934 Act, the Company must make a good faith determination that the amount of commission is reasonable, given the value of services provided by the broker. Use of Affiliated Brokers ERISA prohibits certain transactions between ERISA plans and service providers with conflicts of interest. Entities in this category are referred to as, \"Parties in Interest\". For example, if the Company has investment discretion over plan assets, it cannot use the brokerage services of an advisory affiliate unless it qualifies for an exemption from the prohibition. The following conditions under Prohibited Transaction Exemption 86-128must be met in order to qualify for an exemption against the prohibition against using an affiliated broker: • The Company acts in the best interest of the plan at the time of the transaction • The transaction must not be excessive under the circumstances, either in amount or in frequency • Compensation related to the transaction is reasonable • Statements by the Company or a related entity about the transaction, fees or other conflicts of interest are not misleading • The written authorization must be terminable at will by the plan without penalty • The affiliated broker must make annual disclosures to the authorizing fiduciary concerning, among other things, the total of all charges incurred by the plan that relate to securities transactions Use of an Affiliated Mutual Fund ERISA rules prohibit the Company from receiving a dual fee. As a result, the Company can only invest in shares of an affiliated mutual fund under certain conditions as outlined in ERISA Prohibited Transaction Exemption 77-4. As of June 9, 2017, the Impartial Conduct Standards apply. (See Section O of this Policy” ERISA Bonding Requirements ERISA Section 412 requires advisers with discretionary authority over plan assets to ensure that a fiduciary bond is in place to protect the plan against loss from acts of fraud or dishonesty. If the Company renders investment advice to an ERISA plan, but does not have discretionary authority, it is not required to be bonded solely because it provides investment advice. A fidelity bond is only required where the Company has custody, holds discretion, or otherwise handles funds or other plan assets on behalf of the plan. Documentation In addition to the customary files and statement of objectives, guidelines, and restrictions, whenever possible the Company shall maintain the following items (or other documentation sufficient to establish suitability) for ERISA clients: • A copy of the governing trust agreement • A copy of the governing plan document (if separate from the trust agreement) • All subsequent amendments to the plan and trust documents • Certified resolution of the named fiduciary of the plan authorizing the appointment of RetireRight as an “investment manager” (if applicable) • A copy of any endorsement (or assurances of the same) of the client’s fidelity bond naming RetireRight as an additional party against whose acts the plan is insured Page 22 of 34

ERISA 408(b)(2) Disclosures Responsible plan fiduciaries must ensure that arrangements with their service providers are necessary in order to administer the plan and that only “reasonable” compensation is paid for services. In February 2012, the Department of Labor adopted a new disclosure regulation under ERISA Section 408(b)(2) to assist plan fiduciaries in making informed decisions about selecting and retaining service providers and whether those costs are reasonable. Final Regulation 408(b)(2) requires “covered service providers” to make written disclosure of their services, status, and compensation to responsible plan fiduciaries reasonably in advance of the arrangement. A “covered service provider” is a service provider that enters into a contract or arrangement with an ERISA- covered defined benefit or defined contribution plan and reasonably expects $1,000 or more in compensation, indirect or direct, to be received in connection with providing certain services.15 As a registered investment adviser, RetireRight is considered a covered service provider to ERISA-covered plans.16 Prohibited Transactions/Reasonable Fees RetireRights’ arrangements with an ERISA-covered plan will not be deemed reasonable unless RetireRight delivers the required 408(b)(2) disclosures. Should the disclosures not meet the applicable content and delivery standards, the use of any plan assets to pay RetireRight’s fees will result in a prohibited transaction. Engaging in a prohibited transaction will subject the Company to punitive excise taxes as well as civil liability and penalties under ERISA. 408(b)(2) Required Disclosures A covered service provider’s disclosures must include the following information: • The roles (fiduciary or non-fiduciary) and services provided by the service provider. • All direct and indirect compensation received by the service provider (including the identity of the payer of any indirect compensation). • Any applicable fees charged or refunded by the service provider upon termination of the agreement. • Detailed fee descriptions along with the services being performed for each fee. • Description of the manner in which compensation is paid, such as automatic deduction or via invoice. • Compensation disclosures will include allocations of compensation made among related parties (i.e., among a service provider’s affiliates or subcontractors) when such allocations occur as a result of charges made against a plan's investment or are set on a transaction basis. RetireRight’s Form ADV Brochure, with the client’s investment management agreement, contains much or all of the required information. Certain specific disclosures, such as those pertaining to soft dollar or indirect compensation arrangements, may require a separate explanatory document. The Company will ensure all required disclosures are provided, whether described in one document, or provided separately among several documents. 15 The final rule applies to ERISA-covered defined benefit and defined contribution pension plans. It does not apply to simplified employee pension plans (SEPs), SIMPLE retirement accounts, IRAs, and certain annuity contracts and custodial accounts described in Internal Revenue Code section 403(b). The final rule does not apply to employee welfare benefit plans. EBSA intends to separately publish proposed disclosure requirements for welfare benefit plans in the future. 16 The final rule applies to the following covered service providers: • ERISA fiduciary service providers to a covered plan or to a \"plan asset\" vehicle in which such plan invests; • Investment advisers registered under Federal or State law; • Record-keepers or brokers who make designated investment alternatives available to the covered plan (e.g., a \"platform provider\"); • Providers of one or more of the following services to the covered plan who also receive \"indirect compensation\" in connection with such services: Accounting, auditing, actuarial, banking, consulting, custodial, insurance, investment advisory, legal, recordkeeping, securities brokerage, third party administration, or valuation services. Page 23 of 34

Timing of Disclosures RetireRight shall provide the 408(b)(2) disclosures reasonably in advance of entering into a new contract or engagement, as well as in advance of a contract renewal or extension. If any information within the disclosure changes, a new disclosure will be made within 60 days. Unless the information in the disclosure changes, no annual disclosure is required. Disclosure Errors The final rule allows for timely corrections of an error or omission in required disclosures when a covered service provider is acting in good faith and with reasonable diligence. Such corrections must be made not later than 30 days from the date that the provider knows of the error or omission. Government Clients Government Clients are all government entities to which the investment advisor provides or has provided investment advisory services, or which are or were investors in any covered investment pool to which the investment advisor provides or has provided investment advisory services. Currently, RetireRight does not have any Government Clients. Vulnerable Clients, Death, and/or Incapacitation To align with industry standards, the Advisor has determined that any client over the age of 62, subject to a state- specific Adult Protective Services statute, or exhibiting diminished capacity behavior is considered a “Vulnerable Client.” During the client’s review, the Advisor’s will verify that the client’s profile information is updated based on current life circumstances, including but not limited to job status, retirement, changes to named trustees/beneficiaries, or death. Supervised Persons should consider the following red flags for diminished capacity: • Confusion with simple concepts - A long-standing Client, demonstrates confusion with concepts that he or she had understood previously. • Repeating instructions or questions - Repeatedly asks the same question over the course of a meeting or from a previous meeting. • Memory loss or disorientation - Forgets or come several hours late to a scheduled meeting, incorrectly answer verification questions, or forget other items related to the engagement. Additionally, the Client becomes frustrated with the proposed investment plan or delivery after agreed upon discussions and documented meetings. • Difficulty performing familiar tasks - Demonstrates difficulty signing his or her name to a personal check or any other document. • Discussion of unusual or unexpected investments - Client brings up investments that may be indicative of a pyramid, Ponzi scheme, other fraudulent schemes, or extremely unsuitable investments. Advisory Persons should consider the following red flags for financial exploitation: • Unexpected addition of authorized persons or changes to beneficiaries, trustees and/or powers of attorney • Oversight of accounts is surrendered to others without consent. • Assets are transferred to third party to assist with account maintenance. • Changes to account beneficiaries that appear out of character for the Client. • Unknown individual appears in the client relationship • An unfamiliar individual accompanies the Client to a meeting. • Client may reference unfamiliar individual in conversation. Page 24 of 34

In the event of a suspected instance of diminished capacity or financial exploitation, RetireRight will recommend the Client designate a trusted third-party (“Authorized Individual”) through a Third-Party Authorization agreement that gives authority to contact them via phone, email, fax or in person related to account activity. Instances of Diminished Capacity or Financial Exploitation Upon detection of diminished capacity or financial exploitation, an IAR shall notify the CCO promptly to document the instance, along with proper documentation of the findings and any actions taken. In the event of diminished capacity, the IAR will work with the Authorized Individual, attorneys, trustees/beneficiaries on taking appropriate measures with the client. In the event of financial exploitation, the IAR will present documentation and records, that are relevant to the suspected or attempted financial exploitation, to respective parties, including but not limited to trusted third parties, state or government authorities. Death of a Client In the instance of death of a client, an IAR shall notify the custodian. The account will be frozen until proper documentation is received regarding the disbursement of assets. No trading or further disbursements will be allowed in the account. 5. Performance Parameters and Custody The client will receive statements from the custodian, at least quarterly that describe all activity in the account for the period, including transactions, contributions, withdrawals, fees, and expenses, and the beginning and ending account value. In addition, this quarterly statement directs the client to contact the IAR with any changes or questions regarding investment objective, financial situation, or specific instructions regarding the management of the account to ensure that the client receives advice that is tailored to meet the client’s specific needs. Performance Reports are provided to the client as part of the client’s annual review. The Performance Report must contain all disclosure pages produced by the 3rd-party software. Custody Rule17 RetireRight does not permit physical custody of client funds or securities. However, it is deemed to have custody based on the ability to deduct client fees by invoice and maintaining “Standing Letters of Authorization” to transfer client funds. As an adviser with authority to directly debit advisory fees for client custodian accounts, RetireRight has adopted the following procedures: • Periodic testing of a sample of client fee calculations to verify accuracy; and • Overall testing of the reasonableness of fees in comparison to aggregate assets under management. • Procedures to insure accuracy of fees includes quarterly review of all accounts fee schedules, manual review of all statements comparing fee downloads to insure proper proration charges and correct fee amount. Review also ensures assets deemed non-discretionary are correctly coded and reasonableness of fee amount. • A Quarterly Review Checklist as well as a Reconciliation of Fees will be kept with documentation of fees debited from accounts. The Annual Review testing performed by RetireRight further documents a sampling of client fee calculations. Fee Deduction Although when fees are debited directly from client accounts an adviser shall be deemed to have custody, the Advisers Act does not require an adviser to indicate that it has custody on its Form ADV18, if the withdrawal of fees is the only practice that would place the firm in a custody situation. RetireRight clients provide written authorization for the withdrawal of fees by the Custodian from a managed account within the account opening documents and Asset Management Agreement. 17 Rule 206(4)-2 18 For advisers registered at the state level (vs SEC), this may be different. Page 25 of 34

Client funds and/or securities It is the expressed policy of RetireRight that the firm will not take physical custody of client funds or securities. Avoidance of custody will be accomplished through the following procedures: • Certificates. Should a certificate for any security be received into the offices of RetireRight through the mails or other delivery service, such certificate shall be immediately returned to the client or sender via Federal Express, two-day delivery (or a similar type of carrier). A letter of explanation and instruction shall accompany the certificate. • Checks. Should a check be received in the offices of RetireRight made payable to RetireRight or any associated person thereof, such checks shall be returned to the client. Exceptions to this policy would be if the check is to pay for services being rendered by RetireRight such as financial planning, consulting, and retirement advisory services. Also checks made payable to the Custodian where the advisor or supervised person has the ability to deposit the check remotely, these checks can be processed in the branch. Checks received from a third party and made payable to the client shall be promptly returned to the client. [The exception to this is if RetireRight receives client assets (funds or certificates) inadvertently from a third party, such as class action settlements, tax refunds, and the like, in the interest of the safety and proper handling of the assets, RetireRight may forward such client assets promptly (preferably same day but in no instance more than five (5) days) to the appropriate account custodian.] • Checks drawn by the client and made payable to the account custodian. In these instances, the check will be scanned or copied and sent to the appropriate custodian via overnight carrier the day it arrives. The person receiving and forwarding the check to the custodian will monitor the account to ensure the deposit is properly credited. The individual will also document the receipt and forwarding of the check on the non-local deposit check log. This log will be maintained for five years. • Standing Letters of Authorization – Third Party Money Movement Authority. RetireRight does not permit a standing letter of authorization (“SLOA”) to disburse assets to one or more third parties. Procedures to Avoid Inadvertent Custody RetireRight could have custody if a client enters into an agreement with a Qualified Custodian that grants RetireRight broad access to the client’s funds and securities. RetireRight will review its clients’ arrangements with Qualified Custodians to assure the Qualified Custodians’ agreements do not result in custody. Due Inquiry” Requirement A due inquiry19 is required to establish a basis that the qualified custodian sends account statements to each client no less frequently than quarterly. To accomplish the “due inquiry” requirement, the CCO of the Advisor receives written confirmations on his own personal accounts from the custodian that the account statement was sent, giving the Advisor reasonable belief and assumption that client statements were executed by the custodian. Accessing the custodian’s account statements on their website does not satisfy the “due inquiry” requirement because it does not confirm the account statement was actually delivered to the client. Exceptions to the surprise annual examination RetireRight is not subject to surprise examinations. 6. Communications and Advertising Any form of communication to clients that is designed to solicit or maintain advisory service (“Client Communications”) is covered by regulations under Securities Laws. Electronic Communications RetireRight has adopted this policy to set forth the policies and procedures of RetireRight with respect to electronic messages, including, but not limited to, email and social media content composed, distributed, received, or stored by any employee or agent of RetireRight, or by any other person using company-provided electronic messaging resources. 19 Amendment to Custody Rule 206-4(2) Page 26 of 34

• Electronic Mail Service Provider and System - RetireRight uses a third-party service provider offered through LPL Financial to capture and archive email correspondence. All email composed, distributed, and received must be communicated through the email system of the company (i.e., associated persons and agents are prohibited from using personal email for firm-related business). • Appropriate Electronic Communications - The use of Electronic Communications to discriminate on any or all of the aforementioned bases is inappropriate and strictly prohibited. • Electronic Messages as Property - Business-related electronic communications are the property of RetireRight and LPL Financial. All such communication composed, distributed, received, or stored by any employee or agent, or by any other person using the Company’s electronic communications system, is the property of RetireRight and LPL Financial. Additionally, the unique email addresses assigned to any employee or agent of RetireRight is the property of RetireRight and LPL Financial. • Monitoring and Review of Email and Other Electronic Communications - RetireRight reserves the right (through, without limitation, content filtering software, computer checks by the CCO or his designee or third parties contracted by RetireRight) to intercept, monitor, review, copy, record, disclose or take such other necessary action on any and all electronic communications composed, distributed, received, or stored using the Company’s electronic communication systems. • RetireRight associated persons are prohibited from using non-firm email accounts for business related emails since the firm cannot readily retrieve or archive these emails. In the event a client does use a non-firm email account for business related contact then RetireRight employee must forward email to RetireRight and LPL Financial for recording. All emails are firm property and are not private. • Emails are stored, backed up, and searchable. • Emails cannot be deleted, altered, or destroyed. • On an ongoing basis the CCO will review a random sample of emails for compliance and perform a word search (search for word such as “guaranteed performance”). Any employee using a smart phone or any other mobile or electronic device with access to the firm’s computer network and data, for example business emails or contacts, must notify the CCO. All such devices must be appropriately secured with automatic shut off and password protected. Any lost/stolen/or compromised device should be immediately reported to the CCO. Social Media Employees of RetireRight are permitted to market their business through the use Linked In, Facebook and Twitter. The static content must be pre-approved and subject to a 3rd party monitoring service and archiving. Unless permitted and pre-approved by the CCO, or delegate, Social Media activity from the Supervised Person’s personal account are prohibited from referencing the Advisor’s services or information on their personal accounts. In addition to the Advisor’s Code of Ethics generally, all permitted Social Media activities on behalf of the Advisor or Supervised Persons, must adhere to the Advisor’s Client Communications guidelines, as defined above and highlighted below: • Must not contain any false or misleading statements or omission of material facts. • Must not contain any specific securities recommendations. • Must not contain any testimonials; and • Must not contain any confidential client or employer information Text Messages If conducting business-related business by text messages, ie any text containing any discussion of client accounts or information; the IAR and /or Supervised Person must adhere to the 3-party vendor’s requirement. Currently MyRepChat is used to capture and archive business related text message. Page 27 of 34

Advertising & Marketing The Advertising Rule20 defines the term “advertisement” to include any notice, circular, letter or other written communication addressed to more than one person, or any notice or other written announcement in any publication or by radio or television, which offers, among other things, “any investment advisory service regarding securities”. This definition includes all communications that advisors may use to solicit new clients as well as maintain existing ones. Additionally, written communications on a one-to-one basis to existing, or prospective, advisory clients designed to offer advisory services, or maintain the existing client, are deemed to be an advertisement. However, if the written communications to existing advisory clients are solely designed to present the performance of their accounts, they are generally not considered advertisements. Advertisements must not: • Refer, directly or indirectly, to any testimonial • Refer, directly or indirectly, to past specific recommendations • Represent, directly or indirectly, that any graph, chart, formula, or other device being offered can, in and of itself, be used to determine which securities to buy or sell, or when to buy or sell them (unless sufficiently qualified) • Contain any statement to the effect that any report, analysis, or other service will be furnished for free or without charge, unless such report, analysis or other service actually is or will be furnished entirely for free and without any condition or obligation, directly or indirectly; or • Contain any untrue statement of a material fact, or which is otherwise false or misleading. • Advertise its “past specific recommendations The CCO or their delegate reviews all material prior to use to ensure that there are proper disclosures, that no fraudulent, deceptive, or manipulative acts are in the material, and that it complies with all required aspects of the Advisers Act and the Advertising Rule. Articles from News Media Distribution of a bona fide news article21, written by an unbiased third party, is not subject to the requirements of the rule governing advertisements; articles that refer to prior recommendations of Advisors may be distributed if the prior recommendations are solely contained within the article. Retention Period All books and records required to be made under the provisions of Rule 204-2(a) to (c)(2) of the Advisers Act, inclusive, are maintained and preserved pursuant to Rule 204-2(e) of the Advisers Act in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in the appropriate office of RetireRight and the office of Good Life Outsourced Compliance. Articles of incorporation, charters, minute books, and stock certificate books of RetireRight and of any predecessor are maintained in the principal office of RetireRight and preserved until at least three years after termination of RetireRight. Records relating to performance advertising, now or in the future, will be kept longer as necessary to comply with applicable rules. [Rule 204-2(e)] The CCO shall work with an appropriate service provider to help ensure that Business Record Electronic Communications are maintained in accordance with the above policies and may be accessed and retrieved in a timely manner (generally, within a 24-hour period). Violations and Questions Any and all violations of this policy or questions regarding this policy should be reported to the CCO. 20 Investment advisor advertising is regulated by Rule 206(4)-1 of the Advisers Act (the “Advertising Rule”). 21 Reprints are subject to Advisers Act Rule 206(4)-1(a)(5), which makes it a violation for an Advisor to publish an advertisement that contains any untrue statement of a material fact or is otherwise misleading. Page 28 of 34

7. Regulatory Filings Investment Adviser Regulatory Depository (IARD) The Investment Adviser Registration Depository (IARD) is an electronic filing system for Investment Advisers. RetireRight uses the IARD system to maintain registration, reporting and disclosure information. A “Super Account Administrator” and controls who has access to the IARD account, which is required to be certified on annual basis. Firm Registration- Form ADV Filings RetireRight filed and maintains From ADV on the IARD system. In addition to Form ADV, RetireRight maintains an ADV 2A, firm disclosure brochure, and an ADV 2B, individual disclosure brochure, for each investment adviser representative. The primary purpose of Form ADV to provide clients with the details of the services, fees, business practices, conflicts of interest and material business relationships with affiliates. Form ADV 2A- Firm Disclosure Brochure The firm disclosure brochure includes details about the services and fees as well as any conflicts of interest and firm disciplinary matters. IARs must provide the ADV 2A before or at account opening. If it is not provided 48 hours in advance, a client may terminate an agreement for a full refund. Clients do not need to confirm receipt or acknowledge understanding but it must be delivered in hard copy or electronically. The Advisor’s client agreements will contain an acknowledgement of ADV Part 2A delivery, to be maintained in the Advisor’s books and records and serve as proof of delivery. Documentation of subsequent deliveries will also be maintained in the Advisor’s books and records. Form ADV 2B – Individual Disclosure Brochure The individual disclosure brochure provides details of the individual IAR such as education, work history and any disciplinary matters and conflicts of interest. An ADV 2B must be provided along with the ADV 2A and such delivery is also evidenced with the client account agreement. The Brochure Supplement is known as Form ADV Part 2B. It is not required to be filed through the FINRA IARD system for SEC registered Advisors, but such Advisors need to keep copies and all amendments in their books and records. Form CRS = Customer Relationship Summary Form CRS is intended to be a simple, easy-to-read summary document regarding the nature of a client’s relationship that must not exceed two (2) pages. The document must include: • Item 1: Introduction • Item 2: Relationship and Services • Item 3: Fees, Conflicts, and Standards of conduct • Item 4: Disciplinary History • Item 5: Additional Information such as information about brokerage services. Form CRS must be delivered to a new client or an existing client, who is opening a new account type, at or before the time an account is opened, when educating client on the options of a retirement account roll over or when adding additional features to an existing account. Form CRS is in addition to the disclosures already required in Parts 1 and 2 of Form ADV. When the Form CRS becomes materially inaccurate it must be updated and filed within 30 days as a Form ADV other-than-annual amendment or as part of the annual amendment. Any changes to the Form CRS must be communicated to clients within 60 days after are made and the recent changes must be highlighted. Page 29 of 34

• Form CRS will be subject to SEC filing, updating and recordkeeping requirements. • Form CRS must be delivered within 30 days upon request. • Form CRS must be prominently posted on the firm website. Wrap Fee Brochure A wrap fee brochure provides details of an account type where more than one fee is combined into a single fee. RetireRight does not offer a Wrap Fee Program. ADV Amendments On at least an annual basis the ADV documents must be filed to account for any changes as an amendment or confirmed if nothing has changed. Such amendments / confirmations must occur within 90 days following its fiscal year end (3/31). Once amended / confirmed, RetireRight will “deliver” at no cost to the client: The amended Disclosure Brochure that contains a summary of material changes since the last delivery to clients; or a summary of material changes to the amended Disclosure Brochure that includes an offer to provide a full copy and information on how a client may obtain the Disclosure Brochure. The Advisor will deliver a current Disclosure Brochure to clients in an acceptable format that is easily accessible and readable (i.e., searchable PDF format). Electronic versions of the Disclosure Brochure and Brochure Supplements can be delivered by email. For clients that do not have an established email address for Advisor communications, a paper version must be mailed to the client’s mailing address. Delivery must be made without charge to the client. Upon request, a hard copy version of Disclosure Brochure and Brochure Supplements must be sent by regular, first-class mail or overnight carrier. Material Changes In the event of a material change (something a reasonable investor would want to know) an amended disclosure brochure will be promptly (within 30 day) provided to clients. An interim amendment can be in the form of a document describing the material facts relating to a disciplinary event or some other change. Further, the Advisor will inform all clients of any material information that could affect the advisory relationship. The Advisor will disclose material changes to such information to clients even if those changes do not trigger delivery of an interim amended brochure. The Advisor will maintain all written and electronic records regarding client accounts in accordance with the Books and Records policy. Transfer of more than twenty five percent (25%) ownership of the advisory firm constitutes a change in control and is considered a material change. Client consent must be obtained. Form U4 The U4 Filing is the Uniform Application for Securities Registration or Transfer and is used by investment advisor representatives to enable their individual registration with applicable regulators and jurisdictions. Form U5 The U5 Filing is submitted to withdraw an individual’s registration as an investment advisor representative. A partial U5 can either remove IAR registrations in specific jurisdictions or, if they have fully resigned from the firm, a full U5 can be submitted to remove all registrations of that individual with the firm, such as during a termination of employment. Financial & Disciplinary Disclosure Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. The ability to view the Advisor’s IARs backgrounds is on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by using their name or CRD# to search. Page 30 of 34

Additional State Requirements In addition to the standard filing requirements of the Form ADV there may be further filings required by certain States, such as notice filings required even if the Advisor is registered with the SEC. The Advisor will keep itself appraised of changes to State securities laws where they conduct business and submit any required State filings as applicable. 8. Books & Records RetireRight keeps certain books and records22 relating to its investment advisory business to document aspects of compliance and supervision of the Advisor’s Compliance Program. This includes financial and accounting records, client account information, advertisements, and others as listed below. The CCO is responsible for ensuring that the books and records are accurate and timely updated as needed or required: • Financial statements, and all books and records on which they are based, must reflect all applicable transactions accurately and on a timely basis; • All disbursements of funds and all receipts must be properly and promptly recorded; • Records related to investment advice provided to clients and related transactions; • Client agreements and other documentation related to client accounts and necessary authorizations to conduct business; • The Code of Ethics for the Advisor which addresses personal securities transactions by Supervised Persons, if they also meet the definition of Access Person; • Advertising and performance records; • No false or artificial statements or entries may be made for any purpose in the Advisor’s books and records or in any internal or external correspondence, memoranda, or communication of any type, including telephone, wire or electronic communications; • Retention of information and data must be timely and free from unauthorized alteration or use in accordance with legal requirements and operational policies and procedures; and • Falsification of business documentation, whether it results in personal gain or not, is never permissible. Retention Documentation will be kept for a period of five (5) years from the end of the fiscal year in which an entry was made or published, with the most recent two (2) years being readily accessible. Should the Advisor determine it will cease to conduct or discontinue its business as an invest advisor, it will coordinate and bear responsibility for the retention of the books and records required for a period of no less than three (3) years after closing. Separate Back-up The Business Continuity Plan (BCP) describes the manner in which the Advisor maintains the separate backup copy23 of the record in a manner that would survive the inadvertent destruction of the original record. 9. Privacy & Information Security Client information collected by RetireRight generally comes from the following sources: Information provided by clients on account applications or other forms, in correspondence, written or electronic, or by telephone; or information relating to the transaction history of a customer's account. Safeguard Rule Regulation S-P dictates that RetireRight must adopt policies and procedures reasonably designed to protect customer records and information from any anticipated threats, hazards, or unauthorized access or use that could result in “substantial harm or inconvenience” to any customer. • Any client related computer documents must be run through “s” drive. • Each individual computer also has “c” drive for personal use only. 22 Books and Records Rule (Rule 204-2) of the Advisers Act 23 Rule 204-2(g) Page 31 of 34

• No client document will be saved on a personal cloud or desktop. • Client files will be secured in the file room. • RetireRight operates under a “clean desk” policy – no client information will be left unattended on desktops. • Avoid unauthorized access to computers and systems. • Computers must be set auto lock within 20 minutes of non-use and require password to unlock. • Employees will use double authentication procedures. • Employees will manually lock computers prior to leaving unattended. Employees will monitor outside individuals visiting offices. RetireRight Capital uses Citrix Sharefile encryption software to send client information via email and for client access to RetireRight reports. Employees must use this software and under no circumstances will send sensitive information, especially account numbers or social security numbers, via email. Changes to Client Contact Information Clients who have any changes to contact information including mailing addresses and additional account authorizations have options on updating their account information. Clients can update their mailing preferences by contacting their custodian directly or using their own online login access. RetireRight cannot update information on clients’ accounts directly with the custodian but may facilitate changes by obtaining client signature authorization on custodian forms. Financial Privacy Rule RetireRight must deliver to individuals initial and annual privacy notices that describe in general terms the firm’s sharing and collecting practices. The initial delivery of this is effectuated by delivering ADV Brochure. Annual notices are sent via March quarterly newsletter to all clients as well as an offering of the updated ADV Brochure. RetireRight does not share information with non-affiliated third parties. Disposal Rule The “Disposal Rule” requires financial institutions using consumer report information for a business purpose to properly dispose of the information by taking “reasonable measures to protect against unauthorized access to or use of the information in connection with its disposal”. This includes any record regardless of medium. It is the policy of RetireRight that any paper documents that contain client information, NPI, will be shredded; utilizing office shredders or Proshred container that is kept in file room that is secured. Disposal also includes the sale, donation, or transfer of any medium, including computer equipment, on which consumer report information is stored. RetireRight will ensure devices are “sanitized” of any information prior to disposal. Please refer also to Mobile Device Cyber Plan. Technology RetireRight’s technology infrastructure is based on a server network. All critical data and information is held on a password protected server. Each PC is permitted access to this information by the network administrator. Access is allowed through password protection. Each PC is connected to the server using internal cabling and therefore is a closed system. Access to each PC is permitted only with a valid Password. Screensavers have a password feature allowing an idle PC to become protected in a limited time frame. PCs are updated periodically to insure proper protection from outside influences. Each PC has a corporate virus protection feature that updates nightly. Internet Each PC and the Server has access to the internet through an encrypted DSL modem. Access to this modem comes only through a secure router which hides unique identifiers of the PC’s and Server. PCs are given random IP addresses on each logon. Each PC has virus protection. Cybersecurity The Cybersecurity is a separate policy. Client Privacy Investment Adviser Representatives must adhere to the firm’s privacy policy. Oversight of Critical Service Providers (CSP) The firm reviews the CSP’s compliance with the terms of agreements in place and assesses the CSP’s continued suitability and capacity to perform the activities being outsourced. The firm also determines whether the CSP Page 32 of 34

maintains adequate physical and data security controls, transaction procedures, business continuity, and information technology contingency arrangements (including periodic testing), insurance coverage, and compliance with applicable laws and regulations. The firm understands that the ultimate compliance responsibility lies with the firm and cannot be delegated to the critical service provider. Prior to entering into a contract with a CSP, the firm will conduct a due diligence review. All new or renewing CSP relationships shall be memorialized in a written agreement that will be reviewed by a member of the compliance department. All CSP agreements shall include appropriate confidentiality provisions protecting the firm investors’ confidential information in accordance with the firm’s privacy policies and appropriate provisions requiring CSPs to protect the security of personal information in accordance with the firm’s privacy and data security policies. The firm will conduct a periodic due diligence review of all CSPs. The CCO will be responsible for the review, which shall include surveying Covered Persons who interact with the CSP on a regular basis and reviewing any compliance violations or other errors attributable to the CSP. If any concerns or issues arise during the course of the relationship, they shall be escalated to senior management immediately. Identity Protection Investment advisors who have the ability to direct transfers or payments from accounts belonging to individuals to third parties upon the individuals’ instructions, or who act as agents on behalf of the individuals, are susceptible to the same types of risks of fraud as other financial institutions, and individuals who hold transaction accounts with these investment advisors bear the same types of risks of identity theft and loss of assets as consumers holding accounts with other financial institutions. If such an advisor does not have a program in place to verify investors’ identities and detect identity theft red flags, another individual may deceive the advisor by posing as an investor. The red flags program of a bank or other qualified custodian that maintains physical custody of an investor's assets would not adequately protect individuals holding transaction accounts with such advisors, because the advisor could give an order to withdraw assets, but at the direction of an impostor. Investors who entrust their assets to registered investment advisors that directly or indirectly hold transaction accounts should receive the protections against identity theft provided by these rules. Acknowledging that any wire transfer or overnight check request sent without verbal confirmation with the client is a potential risk, it is the policy of RetireRight to always confirm wire transfers, overnight check requests and third- party check requests verbally over the phone, or in person, with our clients. RetireRight reviews best practices for guarding against fraudulent or phishing emails at least annually at mandatory compliance meetings. • Risk factors include the types of covered accounts the advisor offers or maintains, the methods it provides to open or access its covered accounts, and its previous experiences with identity theft. • Sources of Red Flags include incidents of identity theft that the advisor has experienced, methods of identity theft that have been identified as a result of changes in identity theft risks, and applicable regulatory guidance. • Categories of Red Flags include alerts, notifications, or other warnings received from consumer reporting agencies or service providers (such as fraud detection services) as well as suspicious documents and other customer unusual conduct or requests. A red flag is a transaction that a Supervised Person knows or suspects to: • Involve proceeds from an illegal activity • Evade currency transaction reporting requirements • Vary significantly from the client’s normal investment activities • Have no business or apparent lawful purpose and AFI knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction. As warranted, RetireRight will monitor account(s), contact the client, changing security settings, close the account(s), and/or notify custodian(s) and law enforcement, as appropriate. Page 33 of 34

10. Maintaining and Servicing Client Accounts RetireRight shall perform investment services as mutually agreed upon. RetireRight shall review client accounts regularly in relation to the client’s investment objectives and goals. All client files shall be maintained and preserved for the time periods required by the Advisers Act, and in accordance with the “Record Creation and Maintenance” section of this Compliance Manual. Trading and Administrative Errors Trading and administrative errors are to be brought to the attention of the CCO or another appropriate designee. Reports of errors should include a full statement of how the error occurred, and the amount of the potential monetary loss that may result from the error. As soon as possible, upon learning of an error, the CCO or designee shall determine what actions should be taken to correct the error. A report regarding the error and its resolution shall be recorded and maintained by the CCO or designee. Records of errors shall be reviewed by the CCO or designee as a part of the quarterly review process. Trading and administrative errors may occur in several ways, including without limitation, the following: • Misunderstanding with, or error by, the portfolio manager as to the terms of an order. • A mistake on the part of a portfolio manager or trader in entering an order. • Incorrect information as to securities held in an account. In correcting an error, RetireRight’s goal is to ensure that the client has not been disadvantaged and is, to the extent practicable, “made whole”. In each case, the client’s best interest is the overriding concern of RetireRight. As a general practice, trade errors resulting in a loss or unfavorable result for the client will, to the extent possible, be “undone” and then re-billed correctly. However, in some instances this is not possible due to the nature of the account type. In these situations, generally the client is awarded a billing credit, which reduces the next invoice(s) in the amount of the error. Erroneous trades that result in a benefit to the client (example, failed to sell a security in a timely manner, security price subsequently increased and then position is sold, resulting in more gain for the client) may not be “undone”. However, because this could result in undesirable tax consequences for the client, each such case will be carefully considered by the CCO, who in every case will make the final determination as to the resolution of the error. Whenever possible, gains resulting from trade errors will be retained in the client’s account. Soft dollars may not be used to pay for correcting RetireRight trading and administrative errors. Trade Existing Account IAR will conduct an analysis of the assets held in the account with the client during the annual client review. The IAR will place trades in the account, as necessary. A full rebalance of an account should occur at least annually to keep allocation in agreement with the investment objective on the account. Block Trades Block trades are used to rebalance a large group of portfolios quickly. This generally involves selling one security and buying another but can just be a sale of a security without a purchase. 11. Business Continuity Plan The Business Continuity Plan (“BCP”) is a separate policy and procedure document of the Advisor’s Compliance Program. 12. Certification of the Compliance Manual Supervised Persons are required to read and certify their understanding and willingness to comply with the Compliance Manual. Page 34 of 34