The Company R.V. Kuhns & Associates, Inc. (operating under the assumed business name RVK, Inc., "we,” "us," or "RVK”) is an SEC-registered investment adviser.1 Since we were founded in 1985, we have focused solely on providing investment consulting to institutions, including public and corporate pension plans, defined benefit and defined contribution plans, Taft-Hartley funds, endowments and foundations, insurance companies and other business entities, as well as select high-net-worth individuals and families. We are owned entirely by our employees. Our principal owners are Rebecca A. Gratsinger, our Chief Executive Officer, and Scott P. Gratsinger, our Chief Information Officer.2 Consulting Services Core Values of RVK Trust – We pride ourselves on being a business partner our clients can trust. RVK delivers objective, informed, and unbiased advice. We aim to provide advice that is free of conflicts of interest. We believe that the only way to deliver unbiased advice is to eliminate potential conflicts of interest in our business model:
• 100% of our revenues are from consulting fees paid by our clients in return for services rendered. We accept no payments from investment management firms or any service providers that would create a conflict of interest.
• Our policy is that employees will not accept business gifts from service providers in the investment industry including, but not limited to, host/thank-you gifts, holiday gifts, or travel expenses.
• We recommend investment managers on the merits of their investment products.
• Our firm maintains a comprehensive Code of Conduct and Ethics and a Compliance Manual to which all employees receive mandatory training, agree to in writing, and provide regular reporting to monitor compliance.
• We will not engage in business activities that compromise the firm’s commitment to conflict-free investment consulting.
• We are 100% independently owned and managed by our employees, and we have no outside investors or a parent company that can influence our business practices.
• Our primary purpose is to exceed the expectations of our clients. Credibility is fundamental to our continued success. Accountability is a core value at RVK, and our 33 principals each have an owner's point of view on client satisfaction. Copies of RVK’s Code of Conduct and Ethics, as well as our Compliance Manual and related documents are available upon request. 1 Registration as an investment adviser does not imply a certain level of skill or training. 2 The shares owned by Mr. and Mrs. Gratsinger are combined for this determination. SEC rules state that shares owned by one spouse are also beneficially owned by the other spouse. RVK • 5 March 20, 2024 Client Service – RVK's client service philosophy has four main tenets:
• We believe that our core value to clients lies in our analysis and interpretation of data leading to tailored recommendations to our clients. We provide guidance, not reports.
• We believe that our team approach to clients is the best way of ensuring that the right expertise is available when needed, especially given the complexity and volatility of current financial markets.
• We believe in continually renovating a portfolio rather than tearing it down. Manager and security transitions can be expensive, so we spend time evaluating what is working well in a portfolio and what needs improvement, and renovate where necessary.
• We believe in a client-specific work product that is individually tailored, comprehensive, and understandable. Professional Expertise3 – The RVK team has a deep well of experience and expertise to draw on. We have 17 CFA Charterholders, 10 MBAs, 2 CFA candidates, 3 CAIA Charterholders, 1 CAIA candidate, 18 other Master’s degrees, as well as numerous other designations including: FRM, CPA, JD, MAAA, and ASA. Our consulting professionals average nearly 18 years of investment industry experience, including investment and financial management, actuarial advisory services, and consulting to plan sponsors, as well as an average of 16 years of investment consulting experience. In a complex and volatile environment, success comes from having a solid understanding of market dynamics and the ability to anticipate and adapt. RVK prides itself in delivering our work product to clients in the most professional manner possible, and we invest heavily in developing internal tools, policies, and training for our team members so that we can deliver the very best to our clients. Description of Services Strategic investment consulting on a non-discretionary basis is our only business. We provide a wide range of general consulting services and products, including:
• investment policy development and monitoring
• asset allocation studies
• asset/liability studies
• investment manager search and recommendations, including traditional, alternative and real estate investment evaluation and consulting
• manager structure analysis
• trust/custody and third-party administrator evaluation and search
• defined contribution plan evaluation
• performance analysis and monitoring
• alternative assets reporting
• public pension fund universe analysis
• client education
• client-directed consulting support services
• investment program review
• special projects and enhanced reporting 3 Employee data as of March 20, 2024. RVK • 6 March 20, 2024
• ESG consultative services
• OCIO search, evaluation and monitoring services Investment Policy Development and Monitoring – The development of client-specific investment policies is a critical step in tailoring our services to meet specific client needs. See the discussion in this Item 4 under "Tailored Advisory Services" for further information on this service. Asset Allocation Studies – An asset allocation study is a strategic planning tool used to assist clients in optimizing the balance between portfolio risk and return. Through these studies, we provide our clients with portfolio configurations that help them balance their primary objectives of maximized return and low volatility. Asset/Liability Studies – By modeling a pension, endowment, or insurance portfolio in actuarial or mean variance optimization, Monte Carlo and other software and tools, we are able to test asset mixes for their ability to satisfy the client's liabilities. The product of an asset/liability study is the identification of investment risk levels and broad investment portfolios that are most likely to meet an institution's unique expected future liability

cash outflows or spending needs while minimizing the risk that those needs will not be met. Investment Manager Search and Recommendations – We seek to match client objectives with appropriate investment managers. We have extensive experience in evaluating the vast universe of traditional and alternative asset investment managers. Our process combines rigorous quantitative evaluations, which are complemented by an experienced perspective of qualitative factors and includes specialized consulting services specifically focused on direct investments in hedge funds and primary real estate investments across all investment instruments and property types. In addition, our real estate team offers real estate portfolio assessments on a project basis, advisory assistance in secondary real estate sales, and project-based due diligence on real estate and related real asset investments. Manager Structure Analysis – We provide clients with analysis explaining how selections and weightings of different types of investment strategies collectively tilt a portfolio toward particular investment styles, sectors or capitalization biases. Trust/Custody and Third-Party Administrator Evaluation and Search – We evaluate custodians and third-party administrators based on the services required by a client and effective costs available for providing those services. We work with clients to develop monitoring criteria and have created a service-delivery tracking tool to objectively assess custodian performance. Defined Contribution Plan Evaluation and Fee Reviews – We evaluate participant-directed defined contribution plans to determine whether the plan utilizes an array of return/risk differentiated and appropriate investment fund (asset class) choices and has adequate record- keeping services and communication plans. Portfolio Performance Analysis and Monitoring – Our clients receive Investment Performance Analysis reports that describe and analyze the performance of the client's total assets, asset class exposures, and investment managers. These reports aggregate data from multiple managers into a single report, supply analytical depth not found in quarterly reports provided by RVK • 7 March 20, 2024 managers or custodians, place manager and total-portfolio returns in the context of peer universes and broad-market benchmarks, and provide an independent evaluation of manager performance. Further information on these reports can be found in Item 13 below. Alternative Assets Reporting – We developed a proprietary performance monitoring and reporting tool that provides our clients with customizable analyses of their exposure to alternative investments such as private equity and real estate. Public Pension Fund Universe Analysis – We produce a comprehensive analysis of public funds pension semiannually. The analysis compares asset allocation, performance, fees and actuarial comparative data from a broad universe of public pension plans and other sovereign funds in the U.S. We have the ability to customize this report to include any subset of the universe in order to provide the most appropriate peer comparison available. We also produce a survey of investment professionals' compensation at large public funds. This analysis compares average base salary and ranges, total potential compensation, years at fund/experience required as well as fund assets under management, internal vs. external management for each asset class, allocation of staff by asset class and title, professional certifications and turnover rate, and cost of living by geographic area. Client Education – Our consultants have experience developing and conducting educational sessions/seminars for clients with varying levels of investment knowledge. Sessions range in length from half an hour to two days and have been presented to investment staff, retirement- plan participants, and the boards overseeing investment pools. These seminars have covered topics such as fiduciary responsibility, asset allocation concepts, appropriate manager structure, the benefits of active vs. passive management, the benefits and risks of financial investing, investments in alternative asset classes, and other topics. Client-Directed Consulting Services – Additional support for clients in their management of the nuts and bolts of fund administration includes the drafting, transmitting, and confirming activities relating to client-directed cash movement, whether due to the termination or funding of new managers, meeting capital calls for alternative investments, investing incoming cash flows, portfolio rebalancing or raising and transferring cash for spending/benefit requirements. Our clients maintain full discretion over all investment decisions while RVK’s consulting team provides timely execution, planning, and support. Investment Program Review – Our firm conducts full or targeted reviews of the investment programs of institutional investors on behalf of fiduciaries and oversight bodies. These reviews may cover any or all facets of the investment program including, but not limited to, board and investment staff organization, governance, operations and resources, investment policy and overall governance, asset allocation and risk management, mandate creation, manager selection and monitoring, and internal investment staffing, job functions, performance reviews, and compensation policies. Special Projects and Enhanced Reporting – Our special projects team actively focuses on the next generation of client reporting and on investment operations efficiencies. Our customized reports allow clients to access and more fully understand the information central to their decisions and operations, even in situations with unique characteristics. Within this activity is RVK • 8 March 20, 2024 our customized risk reporting conducted for clients with varying frequency depending on their needs. We welcome specialized and challenging projects that help our clients better understand their portfolios and the general investment climate. ESG Consultative Services – RVK, as part of our Investment Manager Research services, also offers clients comprehensive, updated information, industry knowledge and general education related to the incorporation of environmental, social and governance factors (ESG) into investment decisions. This includes research on outcomes related to ESG factor incorporation, such as impact outcomes, by money managers and other entities. OCIO Search, Evaluation and Monitoring Services – RVK offers a suite of services to clients seeking assistance in searching for, evaluating and monitoring a category of discretionary asset managers normally referred to as outsourced chief investment officer (OCIO) providers.