A. Description of the Advisory Firm Sterling Investment Counsel, LLC (hereinafter “SIC”) is a Limited Liability Company organized in the State of New York. The firm was formed in February 2016, and the principal owners are Christopher Michael Marks, Cynthia Eileen Vance, Philip Kenneth Vance and John Lawrence Langer. B. Types of Advisory Services Portfolio Management Services SIC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring SIC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SIC will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Our clients are advised to promptly notify us if there are changes in their financial situations or investment objectives or if they wish to impose any reasonable restrictions upon our advisory services. SIC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SIC’s economic, investment or other financial interests. To meet its fiduciary obligations, SIC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SIC’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SIC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. We also offer investment management services through a managed account program provided by AssetMark, Inc., a registered investment adviser ("AssetMark Platform"). Portfolios that are developed and implemented using asset allocations composed by a group of independent investment strategists are offered through the AssetMark Platform, with

the portfolios and asset allocations designed to satisfy a gradient of risk/return objectives. After gathering information about your financial situation and objectives, we will make recommendations regarding the suitability of a strategist, and a proposed asset allocation approach and/or model, based on factors such as investment strategy, performance, and methods of analysis. We will periodically monitor the performance of your account to ensure the performance and investment style remains aligned with your investment goals and objectives. Clients will receive a separate disclosure brochure from AssetMark. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning and college planning. Services Limited to Specific Types of Investments SIC generally limits its investment advice to mutual funds, fixed income securities, real estate funds, equities, ETFs, treasury inflation protected/inflation linked bonds and non- U.S. securities. SIC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SIC offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client information and risk tolerance questionnaire, which outline each client’s current situations (income, tax bracket, investment objectives, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SIC from properly servicing the client account, or if the restrictions would require SIC to deviate from its standard suite of services, SIC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. SIC does not provide portfolio management services to any wrap fee programs. E. Assets Under Management SIC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 656,058,753 $ 771,541 December 2023