Firm Description First Fiduciary Investment Counsel, Inc., (“First Fiduciary” or “FFIC”) was founded in 1975. First Fiduciary provides discretionary investment management to individuals and institutions. Advice is provided through consultation about FFIC’s defined strategies with clients and may include: determination of financial objectives, risk tolerance, cash needs, investment management, and retirement planning. FFIC specializes in the area of equity investing where dividends are an integral part of the investment decision making process. For clients that desire fixed income investments or whom FFIC deems appropriate for fixed income investments, instruments including, but not limited to corporate bonds, U.S. Treasury instruments, certificates of deposit, municipal bonds, and mortgage-backed bonds, among others, may also be incorporated in their portfolios. Fixed income investments may be in the form of individual securities and/or pooled portfolios of securities (such as mutual funds and exchange traded funds). The firm does not sell investment products of any kind. The firm is not affiliated with entities that sell financial products or securities. Compensation in the form of commissions is not accepted by FFIC. First Fiduciary is a fee- only investment management firm. First Fiduciary is not a custodian of client assets. All client assets are held by independent, third-party custodians. Clients always maintain control of their assets. First Fiduciary places trades on behalf of its clients under a limited power of attorney or trading authorization. In some instances, First Fiduciary participates in wrap fee programs. In a wrap program, a third-party or broker offers FFIC’s investment management services to the client and charges the client a bundled fee for services. First Fiduciary receives a portion of the wrap fee as compensation for investment management services. Accounts in wrap fee programs are considered to be a form of directed brokerage services and are discussed in further detail in the section titled Brokerage Practices. As of December 31, 2023 First Fiduciary participates in the following wrap fee programs: Name of Sponsor Wrap Fee Program: Lincoln Investment CAAMS Select Advisory Lincoln Investment CAAMS Select Managers Morgan Stanley Investment Manager Services RBC Wealth Management Managed Accounts Program (MAP) UBS Financial Services Managed Account Consulting (MAC) Wells Fargo Private Advisor Network Program In some instances, First Fiduciary directly compensates individuals for client referrals. This arrangement is discussed in greater detail in the section entitled Client Referrals and other Compensation. The initial meeting with a prospective client, which may be by telephone, video conference or in person, is free of charge and is considered an exploratory interview to determine the extent to which First Fiduciary’s investment management services may be beneficial and appropriate for the prospective client. Principal Owners Mary F. Anderson, President, owns 50% of the firm. William S. Henry, Chief Operating Officer, owns 50% of the firm. Types of Advisory Services First Fiduciary provides investment supervisory services, also known as discretionary asset management services. As of December 31, 2023, First Fiduciary managed $501,961,047 in assets for approximately 297 clients with approximately 474 accounts. All fee generating managed accounts are on a discretionary basis. Tailored Relationships In most situations, First Fiduciary confers with the client (including prospective clients) or the client’s financial advisor, if any, or other advisors to understand the financial situation and needs of the client. This exploration can include understanding the time horizon, income

needs, liquidity needs, risk tolerance and return expectations of the client. What is learned from the client will guide FFIC in determining the appropriateness of its investment style for the client and designing a portfolio for that particular client. In some cases, First Fiduciary is hired by the client or representatives of the client as part of an overall asset allocation strategy amongst multiple managers or investment products. In those situations, First Fiduciary may not have direct contact with the client or have access to the information outlined in the previous paragraph to design the portfolio for the client. In those instances, the client or his representative will typically provide portfolio management instructions to FFIC. Most of FFIC’s clients have Investment Policy Statements on file with FFIC that are created to reflect their stated goals and objectives. For clients that do not have an Investment Policy Statement, FFIC may communicate with them or their advisors periodically to understand their financial situation and discuss whether changes need to be made to align their portfolios with their financial needs. Clients may choose to impose restrictions on investing in certain securities or types of securities for their portfolios managed by First Fiduciary. If these restrictions are deemed by First Fiduciary to be so restrictive that it compromises the ability to effectively manage their portfolios, FFIC will advise the client accordingly and may terminate the relationship. First Fiduciary may not assign a client agreement without the client’s consent. Type of Agreement Investment Management Agreement Assets are invested primarily in stocks, bonds, certificates of deposit, exchange traded funds and open-end mutual funds. Client transactions are executed through brokerage firms. The brokerage firm may charge a fee for stock and bond trades in the form of a trade commission or a wrap fee that may include trading commissions. Mutual fund companies and exchange traded funds/notes (ETF/ETN) charge each fund shareholder an investment management fee that is disclosed in the prospectus for the fund. In the case of individual bonds, the fee for the purchase or sale of the bond may be built into the price of the bond being purchased or sold and a commission may also be charged. Brokers may charge a transaction fee for the purchase of mutual funds and exchange traded funds. Initial public offerings (IPOs) are not available through First Fiduciary. Wealth Management Planning and Cash Flow Analysis First Fiduciary may provide wealth management planning and cash flow analysis. First Fiduciary charges a separate fee for these services. Termination of Agreement A Client may terminate First Fiduciary’s investment management services at any time by notifying First Fiduciary in writing and paying First Fiduciary’s investment management fee up to the later date of First Fiduciary’s receipt of notification or the date of termination. If the client made an advance payment, First Fiduciary will refund any unearned portion of the advance payment. If an account is terminated and the client is billed after First Fiduciary has performed work, First Fiduciary will send a bill for the proportion of the period in which FFIC has performed services for the client since the last billing. First Fiduciary may terminate the investment management agreement at any time by notifying the client in writing. If the client made an advance payment, First Fiduciary will refund any unearned portion of the advance payment. If First Fiduciary terminates an account relationship and the client is typically billed in arrears, First Fiduciary will bill the client for the proportion of the period in which it has performed services for the client.