A. Organization Formed in October, 2019, NIS is the successor registered investment adviser to National Investment Services, Inc. (“NIS, Inc.”). NIS, Inc. was formed in November 1993 and began operations on April 1, 1994. NIS is a majority-owned asset management subsidiary of Resolute Investment Managers, Inc. (“Resolute”). Resolute is an indirect wholly-owned subsidiary of Resolute Investment Holdings, LLC, which is owned primarily by Kelso Investment Associates VIII, L.P. B. Advisory Services NIS is primarily an institutional-oriented investment management firm that manages client portfolios across a variety of fixed income strategies, as well as a preferred stock strategy. NIS manages separate accounts, as well as private funds. The firm also provides subadvisory services to a mutual fund. Through a subadvisory agreement with Pullen Investment Management, NIS offers advisory services for certain equity strategies. Any reference to the private funds within this Brochure is for informational purposes only and is intended to address required disclosures about NIS’s business practices and the conflicts associated with managing the private funds. References to the private funds in this Brochure is solely intended and included to the extent NIS believes it is necessary to meet its disclosure obligations. Only qualified investors are able to invest in the private funds, and they should read that fund’s confidential private placement memorandum before investing. No reference within this Brochure should be viewed as an offer to sell or an offer to buy an interest in the private funds. C. Specific Client Needs and Restrictions Whether or not NIS tailors portfolios to individual client needs depends on the type of client. Institutional clients typically have investment policy statements that contain parameters and restrictions that require varying degrees of portfolio customization. Each of the private funds is managed in accordance with the private fund’s offering documents which are provided to investors prior to investment in the private fund. If a client has particular investment restrictions or parameters that they want NIS to adhere to, the firm will generally accept the assignment (subject to minimum account values) as long as the restrictions or parameters do not unnecessarily hinder NIS’s ability to properly manage the account in line with the applicable strategy. NIS is currently reviewing how it might develop and integrate Environmental, Social and Governance (ESG) criteria into its research and investment process. At the direction of certain clients,

and in accordance with their investment policy statement or guidelines, NIS currently manages certain clients’ accounts in a manner that adheres to prescribed social and governance criteria. NIS will consider client-specific guidelines or restrictions on a case-by-case basis. D. Investment Advisory Agreements NIS enters into individually-negotiated investment advisory agreements with its clients (i.e., non- uniform agreements). Since the firm does not negotiate uniform terms with all clients, some clients obtain more favorable terms relating to, for example, management or performance fees, “MFN” rights, key-man, notices, customized reporting and client service requirements, consent, indemnity, and exculpation rights. Further, certain understandings with investors include investment-related restrictions that potentially impact the investment parameters of an entire private fund, thereby affecting other investors in the same private fund. Varying investment advisory agreement terms could create preferences or priorities for certain clients or investors as compared to other clients or investors. Clients are not entitled to identical or similar terms as other clients. Clients not offered certain potentially more favorable terms do not have any right of claim against NIS, its affiliates, the private funds or any other clients or investors. E. Limitations on NIS’s Liability NIS’s management or advisory agreements with its clients typically contain provisions that may act as a waiver, release or limitation on certain rights clients may have against the firm arising from its services. In substance, the agreements usually state that NIS, and its employees and affiliates, are not liable for any loss arising out of NIS’s advice or for any other act or omission taken with respect to its services, except for any act or omission which constitutes willful malfeasance, fraud, bad faith, or gross negligence in the performance of its duties. Notwithstanding the liability limiting nature of these provisions, clients should be aware that federal and state securities laws may impose liabilities on NIS under certain circumstances. Therefore, nothing in those or any other provisions in the agreements will have the effect of waiving, releasing or limiting any rights a client may have under those laws or under any other laws that are not permitted to be waived by contract. F. Assets Under Management As of December 31, 2022, the regulatory assets under management of NIS were approximately $7,925,313,000. The firm has discretionary authority over all of the assets that it manages.