Richmond Capital Management is a fixed income investment adviser located in Richmond, Virginia. The firm originally registered as an investment adviser in 1982. The principals, believing that Richmond Capital Management could better serve its clients as an independent firm, purchased the firm from then parent company, AON Corporation, in 1987 and the firm has remained independent since that time. The firm is 100% owned by thirteen current employee shareholders. No one individual owns 25% or more of the firm. The current owners are: Howard K. Bos, Patton H. Roark, Jr., R. Wheatley McDowell, Elizabeth M. Harris, Beth L. Baron, Paul H. Lundmark, Geoffrey B. Sale, John R. Sides, David W. Schultz, Tammie A. Burks, O. Gregory Glatt, III, Lori G. Little and Linda A. Crocker. Richmond Capital Management offers fixed income investment management services to a broad range of institutional and high net worth clients. While our ongoing services primarily involve the investment management of our clients’ portfolios, the firm may also assist clients in other areas such as the review of investment objectives and guidelines, performance reviews and education of new market opportunities that might fit our clients’ investment needs. Investment management of client portfolios involves developing and implementing an investment program to meet each client’s fixed income needs. The process begins with each client establishing a portfolio benchmark and investment guidelines. The benchmark, which is typically a publicly available benchmark index such as the Bloomberg Aggregate Index, sets the appropriate duration and maturity risk range for that portfolio. The investment guidelines serve as a “roadmap” detailing allowable investments and establishing client-imposed limitations. These limitations typically include items such as the percentage of the portfolio that can be invested in one credit name, market sector, or rating category and an allowable range of duration deviation from

the benchmark index. Additionally, clients may impose socially responsible requirements, such as ESG (Environmental, Social and Governance) or other guidelines on the management of their assets. Investment management of the portfolios is performed by the firm’s investment professionals. All of the investment professionals are specialists in fixed income investing and come from a broad diversity of investment backgrounds, such as banking, brokerage and insurance. This experience allows them to understand the investment and client servicing needs of a broad array of clients. The investment professionals develop an investment strategy that is then implemented by executing trades with non-affiliated brokerage firms. Portfolios are monitored on an ongoing basis to ensure compliance with both the investment guidelines and current firm investment strategy. Occasionally, new clients transfer management of securities already owned. In some cases, the client does not give us discretion to liquidate these legacy securities. In other cases, it may be undesirable to liquidate these securities. As a result, these securities are included in the overall asset allocation analysis, advisory fee calculation and quarterly reports sent to clients. The firm participates in one wrap fee program. Portfolios in this program are managed in the same manner as non-wrap fee portfolios. Richmond Capital Management does not receive a portion of the wrap fee. Consistent with all clients except sub-advisory clients, the firm executes a contract directly with each wrap-fee client. As of December 31, 2023, the firm managed $5,536,768,000 on a discretionary basis and $48,493,000 on a nondiscretionary basis. The firm has a diverse client base, which includes public entities, corporations, insurance companies, endowments and foundations, Taft-Hartley plans, educational institutions, healthcare and faith-based organizations, high net worth individuals, and a number of pooled investment vehicles.