Oppenheimer Asset Management Inc. (“OAM”) has been in business since 1986. OAM is owned directly by Viner Finance Inc., a subsidiary of E.A. Viner International Co., a subsidiary of Oppenheimer Holdings Inc. which is a publicly held company. OAM offers a variety of advisory services including portfolio management of separate accounts, investment consulting services and research. This Brochure covers fixed income separate accounts managed by OIA, a division of OAM. The structure of our advisory programs entails certain conflicts of interest as discussed below. OAM as Fiduciary to You As a registered investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”), Oppenheimer has an obligation to act as a fiduciary in the way that we provide advisory services to you according to legal standards set forth under the Advisers Act., certain state laws and common law. What does it mean to act as a Fiduciary? – We need to act in your best interests. – We need to place your interests ahead of our own. – We must disclose material facts about our advisory programs. – We design our advisory programs to avoid conflicts of interest but if there is a potential for a conflict, we disclose the conflict to you. Our recommendations to you are based on our understanding of your investment goals and risk tolerance. – We will not engage in principal trading (trades between your accounts and our proprietary accounts) without your consent. – We will disclose the fees that you pay and compensation that we receive. – We must have a reasonable basis for believing our recommendations are suitable for you and are consistent with your objectives and goals. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: – Meet a professional standard of care when making investment recommendations (give prudent advice); – Never put our financial interests ahead of yours when making recommendations (give loyal advice); – Avoid misleading statements about conflicts of interest, fees,

and investments; – Follow policies and procedures designed to ensure that we give advice that is in your best interest; – Charge no more than is reasonable for our services; and – Give you basic information about conflicts of interest. Discretionary Fixed Income Accounts Fixed income accounts are managed on a discretionary basis and include the following strategies: – Short Duration Cash Management – Taxable and Tax Exempt – Insurance Fixed Income – Intermediate Fixed Income – Investment Grade Tax Exempt Fixed Income (Active and Laddered Portfolio Accounts) – Core Fixed Income – Core Plus Fixed Income – Corporate Core Plus Fixed Income – High Yield Fixed Income – High Yield Tax Exempt Fixed Income Fixed income separate accounts described in this Brochure are not part of a wrap fee program sponsored by OAM and are not custodied at Oppenheimer. The fixed income separate accounts described in this Brochure are custodied at a custodian chosen by the client. The fixed income separate accounts described in this Brochure are custodied at broker-dealers that are unaffiliated with Oppenheimer. The service provided by OAM for separate accounts is discretionary portfolio management only. Clients may impose reasonable restrictions on investing in certain securities or types of securities. High yield fixed income accounts are no longer being offered and are in the process of being liquidated. OAM manages separate accounts in accordance with the individual financial objectives of clients, taking into account client’s risk tolerance, need for liquidity, time horizon and investment restrictions. Oppenheimer Investment Advisers (“OIA”), a division of OAM, also provides portfolio management services in two wrap programs sponsored by OAM and in wrap programs sponsored by unaffiliated advisers. Consulting Services OAM provides investment consulting services to institutional clients. These services include the following: – Development or updating of an investment policy statement – Development of asset allocation strategy or model – Identification and monitoring of portfolio managers – Client reporting OAM’s consulting services do not include custodial services from Oppenheimer. OAM does not introduce portfolio managers affiliated with OAM to clients who enter into a consulting services agreement. Assets Under Management As of December 31, 2023, OAM managed $14,097,444,560 of client assets on a discretionary basis and $4,674,561,508 on a non-discretionary basis.