General Description of Advisory Firm Freestate Advisors LLC (Freestate) is an investment advisory firm serving individuals, trusts, estates, charitable organizations, foundations, endowments, retirement plans, and other business entities. In our Advisory Services, we use proprietary processes to assess investment conditions, guide investment decisions and manage portfolio risk. Our investment approach is the result of more than 30 years of research and experience in finance and economic modeling. We have conducted extensive independent research into the economic, fundamental, and behavioral factors that impact capital markets. Understanding and modeling risk is a research priority. In managing investment portfolios, we believe it is important to focus on both returns and the risk taken to achieve those returns. Assets held in Freestate-managed client accounts are invested primarily in exchange-traded funds (“ETFs”), exchange-listed securities, mutual funds, and from time to time include other securities. Typically, a client, in consultation with Freestate, will determine whether they would be best suited by a discretionary portfolio, a non-discretionary personalized portfolio or some combination of strategies based on that client’s objectives, risk tolerance, and other factors relevant to that client’s circumstances. Clients can impose reasonable restrictions on the management of the account subject to the approval of Freestate. Clients pay an investment advisory fee to Freestate as well as the expenses attributable to the ETFs and other securities, and the transaction expenses charged by the account custodian for executing trading transactions in the clients’ accounts. Our Firm is a limited liability company formed under the laws of the State of Delaware and headquartered in Overland Park, Kansas, a suburb in metropolitan Kansas City. We also maintain an office in Wichita, Kansas. The Firm is owned 50% by Nathan Haskins and 50% by Melinda Parks. Freestate has been registered as an investment advisor since March 20, 2008. Clients are advised that the investment recommendations and advice offered by Freestate do not constitute legal or accounting advice. Therefore, you should coordinate and discuss the impact of financial advice with your attorney and/or accountant. Clients are advised that it is necessary to inform Freestate promptly with respect to any changes in their financial situation, investment goals and objectives. Failure to notify Freestate of any such changes could result in investment recommendations not meeting the needs of the client. Description of Primary Services Advisory Services Freestate provides investment advisory services defined as giving continuous investment advice to a client (or making investments for the client). Our goal is to help clients pursue better wealth outcomes through advanced investment strategies. As part of our advisory service, clients can receive financial planning services. Financial planning provides a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. We gather information through in-depth personal interviews. Information gathered includes the client’s current financial status, tax status, future goals, return objectives and attitudes toward risk. Our services are provided through accounts maintained at a qualified custodian, such as a registered broker/dealer or registered bank that we recommend. Through this program, Freestate will be granted either discretionary or non-discretionary trading authorization on the client’s account. Please refer to Item 16 – Investment Discretion for more information. We recommend using the Schwab Institutional division of Charles Schwab & Co., Inc. (Schwab), or the Fidelity Institutional Wealth Services division of Fidelity Investments (Fidelity), both registered broker- dealers and members of SIPC, to maintain custody of clients' assets and to effect trades for their accounts. See Item 12 – Brokerage Practices of this document for more details regarding Freestate’s arrangements with these Companies. Freestate will have limited power of attorney on accounts held through Schwab or Fidelity. Through a limited power of attorney, Freestate’s access to client accounts is restricted to implementing trades in the account, deducting advisory fees from the account when authorized by the client, and receiving duplicate statements, confirmations and other documents related to the account. Please refer to Item 15 – Custody for more information. On a select basis, Freestate also provides Advisory Services on accounts in which trading authorization is not granted. Through this service, Freestate will provide ongoing review services of the client’s assets; however, the client must implement all trades in the account and Freestate will not have direct access to the account. The client-selected qualified custodian will maintain custody of all funds and securities. Retirement Plan Services Freestate offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. Freestate’s retirement plan services can include, but are not limited to the following Fiduciary Consulting Services:  Investment Policy Statement preparation. Freestate will review the Plan’s investment objectives, risk tolerance and goals with the plan sponsors. We will help the sponsor develop an investment policy statement that establishes the investment policies and objectives for the Plan.  Non-Discretionary Investment Advice. Freestate will provide investment advice on a non- discretionary basis regarding asset classes and investment options, consistent with the Plan’s investment policy. Through this service, we are available to recommend changes to the investment options in their Plan.  Investment Selection Services. Freestate will provide recommendations of self-directed investment options consistent with ERISA section 404(c).  Investment Due Diligence Review. Freestate will provide you with periodic due diligence review of the Plan’s reports, investment options and recommendations.  Investment Monitoring. Freestate will provide assistance in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and make recommendations to maintain or remove and replace investment options.  Default Investment Alternative Advice. Freestate will provide investment advice on a non- discretionary basis to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election.  Participant Level Advice. Freestate will provide non-discretionary investment advice to an individual participant and will make recommendations to assist a participant with selection and monitoring specific investment options or models. We will provide a participant with investment options established by the Plan and consider the participant’s risk tolerance and investment time horizon. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to the plan sponsor or plan participant for their ultimate approval or rejection. The retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions unless we have agreed otherwise to assist

with the implementation of investment options in your Plan. Fiduciary Consulting Services are not management services, and Freestate does not serve as administrator or trustee of the plan. Freestate does not act as custodian for any client account or have access to client funds or securities. Freestate acknowledges that in performing the Fiduciary Consulting Services listed above it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Freestate will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Freestate to be a fiduciary as a matter of law. However, in providing Fiduciary Consulting Services, Freestate (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting the management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Additional Retirement Plan Services In addition to the services above, Freestate also offers the following non-Fiduciary services to the Plan sponsors and participants:  Participant Education. Freestate will provide education services to the Plan participants at least annually, about general investment principles and the investment alternatives available under the Plan. Freestate’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.  Participant Enrollment. Freestate may assist in the group enrollment meetings, designed to increase retirement plan participation among employees and investment and financial understanding by the employees.  Qualified Plan Development. Freestate will assist with the establishment of a qualified plan by working with Client and a selected Third-Party Administrator. If Client has not already selected a Third-Party Administrator, Advisor will assist Client with the review and selection of a Third-Party Administrator for the Plan.  Due Diligence Review. Provide periodic due diligence reviews of the Plan’s fees and expenses and the Plan’s service providers. Freestate will conduct plan reviews with Plan sponsors annually at a minimum but may conduct reviews more frequently as needed.  Fiduciary File Set-up. Freestate will help establish a “fiduciary file” for the Plan which contains trust documents, custodial/brokerage statements, investment performance reports, services agreements with investment management vendors, and the investment policy statement.  Benchmarking. Freestate will periodically provide benchmarking services and will provide analysis concerning the operations of the Plan. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, Freestate cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. Freestate will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b- 2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Limits Advice to Certain Types of Investments Freestate provides investment advice on the following types of investments.  No-Load (i.e. no trading fee) and Load-Waived (i.e. trading fee waived) Mutual Fund Shares  Exchange-listed securities (i.e. stocks)  Securities traded over-the-counter (i.e. stocks)  Fixed income securities (i.e. bonds)  Closed-End Funds and Exchange Traded Funds (ETFs) Freestate does not provide advice on interests in partnerships investing in real estate or oil and gas interests. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. Clients are advised to promptly notify the Firm if there are ever any changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon the Firm’s management services. Client Assets Managed by Freestate Advisors LLC Regulatory assets under management by Freestate Advisors LLC totaled $134,758,547 as of November 30, 2023. Of that total, $80,471,409 is managed on a discretionary basis, and $54,287,138 is managed on a non-discretionary basis. In addition, Freestate Advisors had $121,269,482 as of November 30, 2023, in managed retirement plan assets. Please refer to Item 16 – Investment Discretion.