Item 5Additional Compensation ............................................................................................. 24 Item 6Supervision ................................................................................................................... 24 Item 7Requirements for State-Registered Advisers ................................................................ 24 Dana Investment Advisors, Inc. (“Dana”) is an independent investment management firm that was founded and began managing assets in 1980. On April 1, 1985, the Firm was incorporated under the same name and elected treatment as a Sub Chapter S Corporation. Also on that date, Dana became an SEC registered investment advisor under the Investment Advisors Act of 1940. Dana’s principal owners are: Mark R. Mirsberger and Jerome (Joe) Veranth. Dana has been 100% employee owned since inception. Dana currently has broad ownership spread throughout senior management and portfolio management staff, as well as other professionals, in the form of voting and nonvoting stock. We expect continued dispersion of employee ownership as part of our employee retention and long-term succession plan. Dana is primarily engaged in the business of furnishing “investment supervisory services” to clients, which is defined as the giving of continuous advice to clients as to the investment of funds on the basis of individual needs of each client. Investment supervisory services may be provided on a discretionary or non- discretionary basis. As of December 31, 2023, Dana managed $3,963,389,595 of client discretionary regulatory assets under management and $542,022,497 of client non-discretionary regulatory assets under management. Model Based and Unified Managed Account (UMA) program assets were $2,135,030,593. Dana may provide advisory services for clients that do not involve direct investment supervision as is the case in Model Based and UMA program portfolio arrangements traded by third parties. Dana does not have final trading authority on Model Based and UMA program portfolios traded by third parties; therefore, these assets are excluded from Dana’s regulatory assets under management. Dana does not issue periodic publications relating to securities on a subscription basis, nor prepare or issue special reports, analyses, charts, graphs, formulas, or other devices that clients may use to evaluate securities that are not part of its investment supervisory services. At the beginning of each new relationship, a client’s overall objectives are explored at length. Dana’s investment processes are then explained in detail. Clients are able to place reasonable restrictions on Dana’s investment discretion, to include limiting investments in certain securities and types of securities. Any such restrictions must be communicated to Dana in writing. Either the client’s own Investment Policy Statement or Dana’s completed Account Guidelines Form is used to identify where Dana’s investment processes could help clients achieve their overall investment objectives while taking into account any stated restrictions. Among other things, this process helps to outline the client’s investment time horizon, potential cash flow needs, and comfort level with the return volatility of the proposed investment process. Because market conditions and security valuations are constantly changing, the

overall suitability of the investment process is periodically re-assessed and any required changes to the original allocation are made at that time. Dana participates as an investment manager for multiple wrap fee programs that are sponsored by third- party institutions. Dana does not sponsor its own wrap fee program. Investment management provided to wrap fee clients is substantially the same as that provided to non-wrap fee clients. However, practical restraints to the management of wrap fee accounts may exist. Most notably, the smaller asset value of certain wrap fee accounts may result in a higher concentration of individual portfolio holdings. Administrative restrictions imposed by wrap fee sponsors can result in differences as well. In addition to wrap fee programs, Dana’s investment management services are also made available through various Model Based and Unified Managed Account (UMA) programs that are sponsored by third-party institutions. Dana provides Model Based and UMA program sponsors with regular updates to the investment holdings (i.e., “models”) contained in certain Dana managed investment strategies. Program sponsors then utilize one or more of Dana’s investment models to invest their client assets. In these situations, the program sponsor is ultimately responsible for implementing (i.e., trading) Dana’s ongoing investment recommendations and for performing many other services and functions typically handled by Dana in a discretionary managed account program. When requested by program sponsors, Dana may provide educational support for third party advisers. Dana offers no other services to Model Based and UMA accounts. Model Based and UMA program sponsors generally exercise investment discretion and, in many cases, brokerage discretion, so performance and other information relating to services for which Dana does exercise investment and/or brokerage discretion, is generally provided for informational purposes only and may not be representative of actual Model Based and UMA program client results or experience. Providing investment management services to both discretionary separately managed and wrap fee client accounts, as well as nondiscretionary wrap fee, Model Based, and UMA program sponsors can give rise to certain conflicts of interest. Changes to Dana’s investment recommendations implicit in the investment models provided to Model Based and UMA program sponsors typically reflect changes in strategy-specific recommendations also being made by Dana to other separately managed client accounts. As a result, Dana may have already commenced trading for its discretionary separately managed client accounts before the program sponsor has received, or had the opportunity to evaluate and act upon, Dana’s investment model recommendations. In such cases, client trades placed by the program sponsor may become subject to price movements, particularly with large orders or with securities that are experiencing lower trading volume. This may result in model program clients receiving prices that are less favorable than those prices obtained by Dana for its discretionary client accounts. In order to address this potential conflict, Dana has developed a trade rotation policy that helps to ensure that all Dana investment recommendations are communicated to Model Based and UMA program sponsors on a fair and equitable basis.