1834 Investment Advisors Co. (“1834”, the “firm”, or “we”) is a corporation organized under the laws of the state of Wisconsin and is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). 1834 has been offering investment advisory services since 1976. The firm is a wholly owned subsidiary of Old National Bancorp, Inc. (“ONB”), a publicly traded regional bank holding company (NASDAQ Global Select Ticker: ONB). INVESTMENT MANAGEMENT SERVICES 1834 provides investment management services that include portfolio assessment, asset allocation, financial planning and ongoing review and management of the client’s portfolio. To begin services, 1834 reviews the client’s present financial situation to assess the client’s investments and other aspects of the client’s financial circumstances. After a meeting(s) and/or a telephone conference(s), 1834 analyzes the client’s individual needs, goals, investment time horizons, and risk tolerance. 1834 believes that knowing a client’s financial circumstances, to the extent possible, is important to long-term investment success. As such, 1834 provides on-going financial planning software at no expense to our clients. 1834 utilizes the information provided by the client to develop an Investment Policy Statement (“IPS”), agreed upon and approved by the client, which serves as a guideline to provide investment recommendations and on-going management. It is 1834’s policy to have all IPS’s fully executed. If, for some reason, the client has not returned a signed IPS to 1834, 1834 portfolio managers will continue to manage the account per the IPS. This may include strategies designed to meet long-range goals (e.g., retirement planning or college funding) to an investment plan. 1834 may assist the client in selecting an account custodian of his choice in the event that he does not have a custodial relationship or one which is satisfactory for one’s current investment needs, however, the selection of a custodian is the client’s sole responsibility. An 1834 portfolio manager will then be responsible for managing the client’s account, using the written discretionary authority granted by the client to make purchases and sales of investments in the amounts and at the times they deem appropriate, within the confines of the IPS and restrictions placed therein by the client. Discretionary service is the managed account relationship most preferred by 1834 and represents the vast majority of the services it provides to clients. 1834 will consider managing client portfolios on a nondiscretionary basis under certain circumstances. Under this arrangement, prior client approval is necessary for the purchase and sale of investments. Investments may be made by 1834 in securities of any kind, including, but not limited to, mutual funds, exchange-traded funds, stocks, bonds, options, alternative asset classes, and other securities. 1834 may hire sub-advisers, including its affiliate Old National Bank, to perform any or all of 1834’s investment management responsibilities under a client’s investment advisory agreement. 1834 provides alternatives investment models through our partnership with our affiliate, Old National Bank, via a third-party alternatives’ platform provider Proteus. Portfolio reviews are performed regularly at the times determined by the client’s portfolio manager and in conjunction with investment policy established by 1834. Client consultations about the account’s performance occur as often as the client requests or as deemed necessary by the portfolio manager. RETIREMENT PLAN SERVICES When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The receipt of our advisory fee for making a recommendation creates a conflict of interest under ERISA/IRC with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. For example, if we recommend that you rollover assets from one retirement account to another and we will receive increased compensation as a result of that recommendation, we have a conflict that requires us to operate under this special rule. Defined Contribution Plans 1834 can provide services to defined contribution retirement plan accounts. 1834 may act in one or more of the following capacities: (1) an Employee Retirement Income Security Act of 1974 (“ERISA”) Section 3(21) fiduciary to the plan providing non-discretionary advisory services, (2) an ERISA Section 3(38) investment manager to a plan fiduciary providing discretionary advisory services, or (3) as a non-fiduciary providing services other than investment advice under ERISA. ERISA Section 3(21) Plan Investment Advisory Services: 1834 can perform non- discretionary investment advisory services at the retirement plan level that may include preparation or review the plan’s IPS, advice regarding appropriate investment categories and options, and monitoring performance of the investment options and providing advice regarding possible changes to the investment selections. ERISA Section

3(38) Plan Investment Management Services: 1834 can perform discretionary investment management services at the plan level including, among others, preparation of an IPS for the plan in consultation with the client, and review, selection, and monitoring of investment options. 1834 is not responsible for any notices or communications to plan participants that may be required under ERISA, the Internal Revenue Code of 1986 or other applicable laws, but will provide information to the client to assist the client in compliance with any applicable participant-level fee disclosure requirements. Non-Fiduciary Services: 1834 can perform certain non-fiduciary services, such as discussing investment performance or providing performance and benchmark information; assistance in benchmarking fees and services of service providers and investment options; assistance in evaluating plan design; and providing participant education services. Defined Benefit Plan - Cash Balance Plans The Cash Balance Pension Plan is a form of a defined benefit plan. In the plan, each participant has an account balance representing his or her benefit under the plan. The account grows annually through two additions, a contribution and an interest credit, and the Accumulation Interest Rate (“AIR”) as defined in the plan. The objective of the plan’s investments is to achieve a rate of return approximately equal to the AIR. 1834 will manage cash balance plan assets with a specific strategy with the objective of achieving the AIR. The specific calculation of the AIR is defined in the plan and is not the responsibility of 1834. While plan assets may be invested in various securities, plan assets will generally be invested in fixed income securities, mutual funds and/or individual common stocks. PRIVATE INVESTMENT CONSULTING 1834 may offer certain private investment consulting services to certain eligible clients. These services are separate from the investment management services described above. When providing these services, 1834 seeks to identify private investment opportunities that may be of interest to a client and assist a client in determining whether to invest in such private investment. These investment opportunities may involve direct investment in private operating companies or real estate investments or in privately offered funds that invest in such investments. 1834’s consulting services also encompass due diligence activities that are reasonably requested by a client, such as performance reviews, reviews of management’s operating history, reviews of fees, expenses and deal terms and performance monitoring. 1834 also provides certain administrative services, such as facilitating and coordinating documentation related to a client’s investment, including tax reporting documentation. Finally, 1834 can assist its clients in developing disposition strategies for their investments, if applicable. The scope of 1834’s representation and fees 1834 charges for these services are individually negotiated with each client and are separate from and in addition to any investment advisory fees collected by 1834. These services do not involve discretionary investment management or discretion and clients are responsible for all investment decisions, instructions and transactions related to private investments. Clients should carefully review their consulting agreement with 1834 to understand the scope of services and limitations. 1834 does not provide legal, tax, accounting or estate planning advice or reporting, and clients must consult their own advisors on those and related matters in connection with any private investment. 1834 may recommend private investments in which 1834, its affiliates or any director, manager, officer or other agent of 1834 or an affiliate have a financial interest or acts as sponsor, adviser, distributor, director, manager, or marketing agent. 1834, its affiliates or any director, manager, officer or other agent of 1834 or an affiliate may receive certain additional compensation in connection therewith that is in addition to the compensation payable to 1834 by clients. CLIENT OBJECTIVES Services provided to clients will be provided on the basis of the client’s known or communicated financial situation and investment objectives. Clients are asked to inform 1834 promptly if there has been any change in the client’s financial status or investment objective information. Providing this information allows 1834 to determine if there needs to be a change in investment strategies or recommendations. Clients may place reasonable restrictions on the management of an advisory account, including the designation of particular securities or types of securities that should not be purchased for their account or that should be sold if held in the account. Under certain circumstances 1834 may decline to accept certain client-imposed guidelines or restrictions. Clients may also call 1834’s office at any time during normal business hours to discuss the status of the client’s account, financial situation, or investment needs with their account portfolio manager. WRAP FEE PROGRAMS 1834 does not participate in any wrap fee programs. CLIENT ASSETS UNDER MANAGEMENT As of December 31, 2023, 1834 had total assets under management of $1,117,168,761 all of which managed with discretionary authority.