A. Description of Firm, History and Ownership McDonald Capital Investors, Inc. (MCI) is an independent, privately owned corporation. The firm has been in continuous operation since 1981. The firm has one office (Orinda, CA), no subsidiaries and no affiliates. Every employee of the firm is considered a “supervised” person and has contact with clients. Only the firm principals, Andrew (Drew) and Trent McDonald, provide investment advice and portfolio management to clients. Drew McDonald founded the firm in 1981. Drew was born in 1955. He received a bachelor’s degree in Psychology and a graduate degree in Industrial Engineering from Stanford University in 1977 and 1980, respectively. His brother, Trent McDonald, joined the firm in 1986. Trent was born in 1958. He received a bachelor’s degree in Economics from Stanford University in 1980 and a graduate degree from the Stanford Graduate School of Business in 1982. He worked as a management consultant on strategic planning and financial management matters before joining McDonald Capital. When Trent joined the firm, he and Drew divided the equity ownership of the business: 50% each. Subsequently, another individual acquired a minority financial interest in the firm of 16.5% and Drew and Trent now own 41.75% each. The individual who owns 16.5% of the business is a passive investor and has no role in the shaping of investment policy, portfolio management, or the operations of the firm. Drew and Trent McDonald are the firm principals, investors, analysts and portfolio managers. Linda Udall, the Chief Compliance Officer, has been with the firm since 1991 and supervises administration, operations, client service and compliance. Linda was born in 1957, received a bachelor’s degree from Stanford University in 1979 and a graduate degree from the University of California, Los Angeles, School of Public Health in 1982. Prior to joining the firm, she worked in public health program planning and administration. Two additional employees currently support back-office operations including trade clearing, settlement, and client service. B. Services Provided Discretionary Advisory Services to Clients with Equity-only and Balanced Portfolios The firm provides investment management services for client portfolios with either an equity- only or balanced approach. The equity-only product is open to new clients, while the balanced product has been closed to new clients since 1995. Equity-only accounts represent 95% of the firm’s total assets. McDonald Capital has complete discretion over the investment decisions (selection and amount of securities to be bought or sold) for the accounts of clients receiving either equity-only or balanced management. The firm’s equity investment philosophy and approach are consistent for the equity-only accounts and for the equity portion of its balanced accounts. Our fundamental objective is to acquire interests in well capitalized, well managed, growing businesses when the market understates their economic value. Companies selected for investment meet certain financial and operating criteria. These criteria include: low debt, high return on equity, substantial free cash flow, superior management and evidence of a competitive advantage in their business or industry. Companies meeting these criteria are then purchased when they can be found in the market at a discount to our estimate of their intrinsic or fair value. In order to find attractive businesses that fit our criteria, our research process begins with screening U.S. publicly traded companies for the financial and operating characteristics just described. Of these, approximately 200 are selected to research in-depth and are followed on an ongoing basis. We acquire ownership interests in 10-20 of these businesses, regardless of their industry group

or size (market capitalization), when we believe they are selling at a discount to their intrinsic value. We expect to hold investments over three to five years, over which time we expect to benefit from price appreciation - as the market price better reflects intrinsic value - and also from the underlying growth of each company over the holding period. These securities are either U.S. publicly traded stocks or the convertible bonds of domestic companies. Convertible bonds may or may not be investment grade. Drew and Trent McDonald both participate in the research and stock selection process. Their buy/sell discipline may be simply stated as a process which leads to buying the stocks of certain companies when they can be purchased at discounts to “fair” value (their appraised value) and sold when they reach that value. Over our projected holding period, business results may deviate from our expectations or other circumstances may arise which cause us to believe that our original appraisal was incorrect. As new information becomes available, we adjust appraisals and sell if appropriate. Balanced accounts hold a combination of equity securities, fixed income securities and cash or money market funds. Bonds selected for balanced clients are typically investment grade. Bond maturities range from one to fifteen years. Government, corporate, and municipal bonds, bills or notes may be selected as appropriate for balanced clients. Investments in money market funds may be considered fixed income investments. Bonds are typically purchased for yield and not as a vehicle to profit from interest rate changes. Drew and Trent McDonald have personal accounts that they invest alongside their McDonald Capital clients. They each have IRA and non-IRA accounts that are invested and managed in the same manner as those of our clients. Drew and Trent McDonald believe that investing their assets alongside those of our clients aligns the interests of both the advisor and the clients and avoids the potential for conflict. C. Tailoring Services to the Individual Client Generally the firm does not tailor its investment services to an individual client’s needs. The investment philosophy, strategy and process are the same for all equity and balanced clients. On occasion, the firm will modify the asset allocation of a balanced portfolio based on the specific needs of a particular client, adjusting the weighting between equities and fixed income securities accordingly. Accounts in both strategies generally will hold the same equity securities in approximately the same percentage allocations relative to the total account size. The firm does tailor its management (non-investment) services to clients. Examples of this include: we will hold cash in reserve for a client who needs a routine quarterly distribution of a certain amount; from time to time, the firm will agree to retain legacy securities in an account as an accommodation for a client; at the client’s direction, we may affect a sale of unsupervised securities in order to assist the client in obtaining reasonable execution. These are not advertised services and the firm does not charge additional fees for holding or selling unsupervised assets. MCI will occasionally accept an account where the client imposes as specific security restriction (e.g., “do not buy XYZ company”) or a broader mandate such as “no tobacco stocks”. The firm agrees to manage these accounts on a case-by-case basis and only when we conclude that the requested restriction will not have a significant impact on our ability to execute our stated investment approach. D. Wrap Fee Programs The firm does not participate in any wrap fee programs. E. Client Assets Under Management as of December 31, 2023 Assets Under Management (all discretionary): $1,617,535,770.