Our History and Organization Fayez Sarofim & Co., also referred to herein as “the firm”, was founded in August 1958. Since our founding, we have focused on the investment counseling business. The firm is located in one office in Houston, Texas. Fayez Sarofim & Co. is registered under the Investment Advisers Act of 1940, as amended, and regulated by the Securities and Exchange Commission. The firm’s registration as an investment adviser is required by law and does not imply a certain level of skill or training. Fayez Sarofim & Co. is a wholly-owned subsidiary of The Sarofim Group, LLC, which is 100 percent owned by current, active employees of Fayez Sarofim & Co. and members of the Sarofim family. Fayez Sarofim & Co. is principally owned by the Sarofim SGI Voting Trust, which is the majority shareholder of The Sarofim Group. The Sarofim SGI Voting Trust is controlled by Christopher Sarofim, the Chairman of the firm. The Sarofim Group is the ultimate corporate parent of a group of affiliated companies that generally operates as a single advisory business and includes the firm, two other registered investment advisers, and other business entities. The other registered adviser affiliates are:  Sarofim International Management Company, LLC  Sarofim Trust Co., LTA The firm is also affiliated with Sarofim Realty Advisors, LLC which is a separately registered real estate investment adviser. In our more than six decades of operations, Fayez Sarofim & Co. has served a broad range of clients through numerous business cycles. As of December 31, 2023, the firm’s assets under management totaled approximately $24.2 billion. The firm’s other registered investment adviser affiliates had assets under management of approximately $9.8 billion. Thus, the total client assets under management by the investment professionals of the firm and the registered investment adviser affiliates were approximately $34.0 billion as of December 31, 2023. Please refer to “Our Advisory Services” below for a discussion of the client assets managed by Fayez Sarofim & Co. on a discretionary and non-discretionary basis. Our Advisory Services Fayez Sarofim & Co. provides investment supervisory services and other investment advisory services to a broad range of clients. Portfolio managers at the firm operate within the guidelines set by our Investment Committee. The Committee, chaired by Mr. Sarofim, is comprised of six senior investment professionals and five sector leaders that serve in a non-voting capacity. The Investment Committee is responsible for the firm’s portfolio structures and all investment decisions. The firm’s advisory services are detailed in the applicable governing documents, separate account agreements and other offering documents. The firm has and may in the future enter into side letters or other similar agreements with certain investors that have the effect of establishing rights (including economic or other terms) under, or altering or supplementing the Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 5 of 42 terms of, the relevant governing documents or separate account agreements with respect to such investors. Large Capitalization Equity Product Fayez Sarofim & Co.’s primary investment product is our Large Capitalization Equity Product, which is available to both institutions and individuals. You can access this product directly by opening an account at Fayez Sarofim & Co. You can also access this product by opening a wrap fee account through a sponsoring financial services firm, by investing in certain of the mutual funds that we sub-advise for BNY Mellon Investment Adviser, Inc., a subsidiary of Bank of New York Mellon Corp, or by investing in the Sarofim Equity Fund (an SEI Advisors’ Inner Circle Fund). The firm also has advisory and sub-advisory arrangements with banks and trust companies. Our equity strategy is focused on domestically traded common stocks with large market capitalizations and high daily trading volumes. American Depositary Receipts, preferred stocks, and foreign stocks may also be included if permitted by client guidelines. We seek to invest in the stocks of high quality, financially sound industry leaders that have an expanding global presence. We seek to maintain an investment perspective of at least three to five years, which generally results in low portfolio turnover and is typically tax efficient for taxable investors. Our strategy does not use derivatives, options, short-selling, leverage, or initial public offerings. We do not attempt to time the market. Global Equity Product Institutions and individuals seeking greater international equity exposure may wish to invest in Fayez Sarofim & Co.’s Global Equity Product. While the investment approach is similar to that of our Large Capitalization Equity Product, the Global Equity Product has a larger concentration in foreign-based companies and may include shares that are not traded on domestic exchanges. Global Equity Product portfolios primarily have their assets in common stock, ordinary shares, or American Depository Receipts. We focus on high quality multinational companies with large market capitalizations. Generally, at least 25 percent of assets are invested in companies organized in the United States and at least 25 percent of assets are invested in companies organized in other countries. We maintain an investment perspective of at least three to five years, which generally results in low portfolio turnover and is typically tax efficient for taxable investors. You can access this product by opening a separate account with the firm; by investing in the BNY Mellon Worldwide Growth Fund, which we sub-advise; or by opening a wrap fee account through a sponsoring financial services firm. Additionally, non-US investors may access this product by investing in the Sarofim Global Equity Fund. International Equity Product Institutions and individuals seeking discrete international equity exposure may wish to invest in Fayez Sarofim & Co.’s International Equity Product. The International Equity Product shares an Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 6 of 42 investment approach consistent with our other products, with the key point of differentiation being its exclusive focus on internationally domiciled companies. International Equity Product portfolios primarily have their assets in common stock, ordinary shares, or American Depository Receipts. The International Equity Product invests in the stocks of high-quality international companies with large market capitalizations and does not seek specific geographic exposures. Stock selection is primarily driven by the assessment of a company’s total return potential over a three-to-five-year investment horizon, which results in low portfolio turnover and is typically tax efficient for taxable investors. You can access this product by opening a separate account with the firm. Concentrated Equity Product Institutions and individuals seeking a concentrated portfolio composition may wish to invest in Fayez Sarofim & Co.’s Concentrated Equity Product. While the investment approach is similar to that of our Large Capitalization Equity Product, the Concentrated Equity Product owns more concentrated positions in our highest conviction holdings. You can access this product by opening a separate account with the firm. Concentrated Equity Product portfolios are primarily invested in domestically traded common shares with large market capitalizations and high daily trading volumes. American Depositary Receipts, preferred stocks, and foreign stocks may also be included if permitted by client guidelines. Concentrated Equity Product portfolios will typically be comprised of 15-30 stocks with a maximum weighting of 20% of the portfolio in a single security. Stock selection is primarily driven by the Investment Manager’s assessment of the stock’s total return potential relative to downside risk and not by adherence to a singular “growth” or “value” strategy. As such, the composition of the portfolio will vary depending upon market conditions and the opportunities available in the market at any given time. As a result, the portfolio is likely to experience a higher level of turnover and volatility than the Large Capitalization Equity Product and is not managed for tax efficiency. You can access this product by opening a separate account with the firm. Equity Income Product The Sarofim Equity Income Product seeks income and long-term capital appreciation by primarily investing in large capitalization domestic equities and other income-producing securities. Over periods of three-to-five years or longer, we strive to achieve a growing stream of income and total returns in excess of the income generated. Our Equity Income investment strategy primarily utilizes common stock, ordinary shares, and American Depository Receipts of high-quality companies based either in the United States or in other countries. Companies represented in the portfolio typically have market capitalizations of at least $5 billion. Using fundamental analysis, we seek to identify companies in business segments that have demonstrated the ability to maintain and grow earnings with a desire to return increasing amounts of cash to shareholders. Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 7 of 42 You can access this product by opening a separate account with the firm. Core Fixed Income Product Fayez Sarofim & Co. also offers a Core Fixed Income Product, which is available directly to both institutions and individuals when they open an account with the firm. Our fixed income strategy emphasizes risk-averse management, current income and low cash reserves. Portfolio holdings may include United States Treasury securities, United States government agency securities, high quality corporate and municipal bonds, high quality commercial paper, and shares of money market funds. We select specific sectors and securities that we believe offer the best combination of quality, liquidity, income generation, and relative value consistent with our risk parameters. Foreign government and foreign corporate bonds are generally not part of our strategy. Municipal Bond Portfolios The firm also manages tax-free income portfolios, consisting of high quality municipal bonds rated AA or higher. Portfolios are customized relative to the client’s state of residence. Balanced Portfolios Fayez Sarofim & Co. will also construct balanced portfolios for our institutional and individual clients. These balanced portfolios combine the firm’s equity and fixed income strategies in proportions tailored to client requirements. Private Placements From time to time, Fayez Sarofim & Co. provides certain firm clients with greater than $20 million invested with the firm, as well as certain third-party investors or other persons, including the firm’s principals, personnel and certain other persons associated with Fayez Sarofim & Co., investment opportunities to directly or indirectly invest in certain privately-held companies and/or pooled investment vehicles, in each case via a private placement. In connection with any such private placement, Fayez Sarofim & Co. will endeavor to negotiate investment terms for participating clients as part of the firm’s collective negotiations for its other client accounts and proprietary accounts participating in the investment. Meeting Individual Client Needs The firm manages its separate portfolios for institutions and individuals on an account by account basis, taking into consideration a client’s financial resources, investment objectives, and needs. The firm addresses individual requirements for such items as current income, cash flow, and taxes. The firm will also vote the proxies related to securities held in a client’s account if requested to do so by the client. Proxies are voted in accordance with the firm’s Proxy Voting policy and established procedures. Please refer to Item 17—Voting Client Securities. Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 8 of 42 Fayez Sarofim & Co. prefers not to be constrained by client instructions that prohibit holding certain securities. We believe that the ability to select from the widest range of investments that are consistent with our strategy results in higher returns over time. However, the firm does manage a number of accounts subject to instructions that specify various exclusions or that limit weightings in individual sectors, industries, or securities. We will accept new accounts subject to these types of instructions as long as we do not view the proposed directives

as overly restrictive or too difficult or impossible to implement and monitor. Discretionary and Non-Discretionary Accounts Fayez Sarofim & Co. manages clients’ assets on either a fully discretionary basis or a non- discretionary basis. Most of our clients have granted us full discretionary authority to manage the investment of assets in their accounts. With full discretionary authority for an account, we are able to do the following without obtaining the client’s consent:  Determine which securities to buy or sell and when to execute the transactions  Determine the total amount of securities to buy or sell, subject to available funds  Determine the broker or dealer through which securities are bought or sold  Negotiate with the selected broker regarding commission rates for securities transactions Item 12 of this brochure provides more information on the firm’s brokerage practices, and Item 16 discusses investment discretion. When we provide services on a non-discretionary basis, we give the client investment advice, but we do not have the authority to implement our recommendations in the client’s portfolio without the client’s approval. In certain non-discretionary arrangements, the client’s portfolio is not managed by Fayez Sarofim & Co., and the firm provides advice only. The information provided above about the investment advisory services provided by Fayez Sarofim & Co. is qualified in its entirety by reference to the applicable governing documents, separate account agreements and other offering documents. As of December 31, 2023, the firm managed approximately $24.2 billion in client assets on a discretionary basis and approximately $234 million on a non-discretionary basis. Wrap Fee Programs The firm also provides advisory services for equity portfolios under various agreements related to wrap fee programs. Wrap fee programs are sponsored by third-party financial services firms, in most cases brokerage firms. Program sponsors make the advisory services of a registered investment adviser such as Fayez Sarofim & Co. available to their clients. Fayez Sarofim & Co. manages most portfolios of wrap fee program clients with a strategy that is similar to its Large Capitalization Equity Product. Fayez Sarofim & Co. has been introduced to wrap fee program sponsors primarily through the efforts of BNY Mellon Securities Corporation (BNYMSC). In our wrap fee programs, Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 9 of 42 BNYMSC acts as the account administrator and serves as the liaison between Fayez Sarofim & Co. and the sponsors and the sponsors’ clients in accordance with our agreement with BNYMSC. Each wrap fee program sponsor establishes the fees to be paid by program clients. BNYMSC receives a fee for its account administration services and calculates the fee to be paid to Fayez Sarofim & Co. in accordance with our agreement with them. Currently, the firm participates directly or indirectly in wrap fee programs sponsored by:  Charles Schwab & Co. Inc.  Envestnet, Inc.  Lockwood Advisors, Inc.  UBS Financial Services, Inc.  Wells Fargo Bank, National Association Each sponsor is paid a fee based on the amount of assets under management. The sponsor then pays BNYMSC a fee ranging from 25 to 55 basis points annually for BNYMSC’s account administration services and the investment advisory services of Fayez Sarofim & Co. In accordance with an agreement between BNYMSC and Fayez Sarofim & Co., BNYMSC in turn pays Fayez Sarofim & Co. a fee of 21.75 basis points annually based on the amount of assets under management. Client suitability for participation in a wrap fee program is generally determined by the client and program sponsor. Fayez Sarofim & Co. may accept or reject a wrap fee program client, but the information received from a wrap program sponsor with respect to a potential client may not be sufficient for Fayez Sarofim & Co. to make an investment suitability determination. Fayez Sarofim & Co. recognizes that certain conflicts of interest may arise with respect to trading for clients in wrap fee programs. Wrap arrangements generally require or encourage trading through the sponsoring broker-dealer. Such arrangements can result in “breaking up” trades across several brokers that might otherwise be sent to a single broker, and there is a potential for wrap program clients to trade after non-wrap clients, possibly on less favorable terms. In an effort to mitigate these potential conflicts, wrap clients and UMA clients (discussed below) trade at specific times throughout the day as determined by a randomly generated number run daily. Fayez Sarofim and Co.’s equity trading desk is responsible for developing and maintaining a record of the rotation schedule for wrap program clients. ERISA Plans in Wrap Fee Programs For ERISA plans that participate in wrap fee programs, Fayez Sarofim & Co. acts not only as a registered investment adviser under the Investment Advisers Act of 1940 as amended but also as a plan fiduciary within the meaning of the Employee Retirement Security Act of 1974 as amended (ERISA). Fayez Sarofim & Co. does not receive direct compensation from ERISA plans for the services we provide through wrap fee programs. As discussed above, the program sponsor or an affiliate makes a payment to BNYMSC for Fayez Sarofim & Co.’s services. For information about the direct compensation the program sponsor receives in conjunction with these programs, please see your client agreement with the sponsor and the sponsor’s fee disclosure notice as required by section 408(b)(2) of ERISA (408(b)(2) disclosure notice). Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 10 of 42 Fayez Sarofim & Co. does not receive soft dollar benefits related to wrap fee accounts. We do not pay compensation to other parties in conjunction with wrap fee accounts, and we do not receive compensation when an account in a wrap fee program terminates. UMA Programs Fayez Sarofim & Co. also participates in various model-based programs, which are often referred to as unified managed account (UMA) programs. Under its UMA agreements, the firm provides the sponsoring broker our model portfolio and position weightings. The firm continuously updates the model portfolio with specific instructions to buy or sell certain securities. The model portfolio furnished by the firm under these agreements is substantially similar to the portfolios of institutional and individual clients who are invested in the firm’s Large Capitalization Equity Product. UMA programs may be either active or passive. When the firm participates in an active program, an overlay portfolio manager at the sponsor is responsible for model level and individual account level trades and has the discretion to deviate from the model portfolio and instructions provided by Fayez Sarofim & Co. In passive programs, the sponsor executes trades strictly in accordance with our model portfolio and instructions. Deviations are not permitted in passive programs except to accommodate specific client restrictions. The firm’s UMA agreements differ by program sponsor, but the role played by BNYMSC in the UMA programs in which the firm participates is similar to its role in the wrap fee programs. BNYMSC is the primary administrative contact with plan sponsors and acts as account administrator. The plan sponsor establishes the fees to be paid by program clients. The division of the fee between Fayez Sarofim & Co. and BNYMSC is determined by an agreement between them (Please refer to the discussion in the next paragraph). Currently, the firm participates in UMA programs sponsored by:  Edward D. Jones & Co. L.P.  Envestnet Asset Management, Inc.  FolioDynamix, Inc.  LPL Financial Corporation  Merrill, Lynch, Pierce, Fenner & Smith Incorporated  Morgan Stanley Smith Barney Consulting Group  PNC Financial Services Group, Inc.  Stifel, Nicolaus & Company, Incorporated  Vestmark Advisory Solutions, Inc.  Wells Fargo Advisors Each sponsor is paid a fee based on the amount of assets under management. The sponsor then pays BNYMSC a fee ranging from 25 to 55 basis points for BNYMSC’s account administration services and the investment advisory services of Fayez Sarofim & Co. In accordance with an agreement between BNYMSC and Fayez Sarofim & Co., BNYMSC in turn pays Fayez Sarofim & Co. a fee of 21.75 basis points based on the amount of assets under management. Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 11 of 42 ERISA Plans in UMA Programs For ERISA plans in certain UMA programs, Fayez Sarofim & Co. acts as a registered investment adviser under the Investment Advisors Act of 1940 as amended and, in some instances, as a plan fiduciary within the meaning of the Employee Retirement Security Act of 1974 as amended (ERISA). Fayez Sarofim & Co. does not receive direct compensation from ERISA plans for the services we provide through UMA programs. As discussed above, the program sponsor or an affiliate pays a fee to BNYMSC for Fayez Sarofim & Co.’s services. For information about the direct compensation the program sponsor receives in conjunction with these programs, please see your client agreement with the sponsor and the sponsor’s fee disclosure notice as required by section 408(b)(2) of ERISA (408(b)(2) disclosure notice). Fayez Sarofim & Co. does not receive soft dollar benefits related to UMA program accounts. We do not pay compensation to other parties in conjunction with UMA program accounts, and we do not receive compensation when an account in a UMA program terminates. Sub-Advised Mutual Funds Fayez Sarofim & Co. is the sub-adviser for four mutual funds established by BNY Mellon Investment Adviser, Inc. BNY Mellon Investment Adviser, Inc. serves as the investment adviser for the funds. These mutual funds are:  BNY Mellon Appreciation Fund, Inc.  BNY Mellon Worldwide Growth Fund  BNY Mellon Tax Managed Growth Fund  BNY Mellon Variable Investment Fund, Appreciation Portfolio, a separate diversified portfolio of BNY Mellon Variable Investment Fund Our role as sub-adviser is subject to the approval of BNY Mellon Investment Adviser, Inc. and the boards of directors of the mutual funds. Currently, we provide investment advisory assistance and day-to-day management of the funds, including placing orders to execute trades. We also provide investment research and statistical information. For our services as a sub- adviser, Fayez Sarofim & Co. is paid monthly fees by either the mutual fund or BNY Mellon Investment Adviser, Inc., according to the contract for each fund. Sarofim Equity Fund Fayez Sarofim & Co. serves as investment adviser to a mutual fund named the Advisor’s Inner Circle Fund, also known as the Sarofim Equity Fund. The fund and Fayez Sarofim & Co. have entered into an investment advisory agreement pursuant to which we serve as the investment adviser and make investment decisions for the fund and continuously review, supervise and administer the investment program of the fund, subject to the supervision of and policies established by the trustees of the fund. For our services as investment adviser, Fayez Sarofim & Co. is paid a monthly fee by the fund. Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 12 of 42 Sarofim Global Equity Fund The Sarofim Global Equity Fund, is a sub-fund of the Sarofim ICAV, an Irish collective asset- management vehicle constituted as an umbrella fund and authorised by the Central Bank of Ireland pursuant to the European Communities Undertakings for Collective Investment in Transferable Securities Regulations 2011, as amended. The fund and Fayez Sarofim & Co. have entered into an investment advisory agreement pursuant to which we serve as the investment adviser and make investment decisions for the fund and continuously review, supervise and administer the investment program of the fund, subject to the supervision of and policies established by Carne Global Fund Managers (Ireland) Limited, the fund’s manager, and the fund’s Board of Directors. For our services as investment adviser, Fayez Sarofim & Co. is paid a monthly fee by the fund. Other Services In a few instances, Fayez Sarofim & Co. has agreed to provide advisory services to clients who wish to invest in a portfolio of securities issued by the United States government or its agencies through margin transactions. The firm is not currently seeking new accounts of this type. Fayez Sarofim & Co. Part 2A of Form ADV: Firm Brochure Page 13 of 42