Advisory Business Robert Harrell Incorporated (RHI, Adviser) is a privately owned independent SEC-Registered Investment Adviser. In 1991, Robert L. Harrell founded RHI as President and Chief Executive Officer, and in 2009, Sandra Larsen-Harrell became President and majority shareholder. RHI is headquartered in Austin, Texas. Advisory Services Offered RHI provides a full range of services for its individual and institutional clients, including high-net worth individuals; family limited partnerships; family offices; banks; public, corporate and Taft-Hartley employee benefit plans; endowments, foundations, charitable trusts. RHI’s services are broadly defined as Supervisory Investment Services and Investment Consulting Services. In 1988, the former research department of Lowry, Raclin, Harrell and Howerdd, Inc (LRHH), including Dr. James MacBeth and Dr. Dave Emanuel evolved into a research and technology firm, Empirical Modeling and Analytics, Inc. (EMA Softech). EMA Softech provided analytical and performance data to RHI until 2013. Currently, RHI receives performance data from Zephyr Associates, Inc and has brought performance analysis in-house. RHI continues to provide 4-factor performance analysis to its clients as it has since inception of the firm. Since its inception, RHI has taken a highly proactive approach to portfolio risk monitoring, risk control, and manager communication. However, the firm’s position is that quarterly reporting is not always sufficient for all clients. For this reason, RHI has adopted information systems which monitor investment management activity as frequently as on a daily basis. This allows RHI, as a fiduciary-level consultant, to stay abreast of changes which have an impact on the ability of an institution to meet its financial obligations. In providing Investment Consulting Services, RHI works with the client to analyze and educate regarding Portfolio manager selection and retention, determining appropriate asset allocation mix, development of investment objectives and funding medium, performance evaluation, and record keeper evaluation and selection. Also, RHI provides quarterly portfolio evaluation reports to clients that include analysis of the comparative risk and return of each of their portfolio managers. In providing Supervisory Investment Services to the client, RHI represents that it is a registered investment adviser under the Investment Advisers Act of 1940, and it qualifies as an investment manager under Section 3(38) of ERISA, as that it is a fiduciary to the client within the meaning of ERISA. RHI is authorized by the client to exercise its best judgment in investing, selling, and reinvesting the cash and securities in an account in its discretion. The client further authorizes RHI, through any of its officers or employees, to perform the following on a discretionary or non-discretionary basis. 1. To invest and reinvest in shares, stocks, bonds, notes and any other types of securities and/or obligations of every description issued or incurred by governmental bodies, corporations, mutual funds, trusts, associations, firms or other types of entities; 2. To take such action, or direct the custodian to take such action, as may be necessary or desirable to carry out the purposes and intents of the foregoing authorizations; provided, however, that RHI is not authorized to take custody of any assets, to borrow money, to pledge or hypothecate property in an account, to direct the delivery of securities by the custodian of payment, or to direct the payment of funds by the custodian other than against receipt by the custodian of payment, or to direct the payment of funds by the custodian other than against receipt by the custodian of securities therefore, except by direct authorization of the client in which RHI takes no custodianship. RHI provides the following services to the client in the execution of its role as an Adviser.

➢ Investment Policy Review ➢ Custodian Evaluation and Selection ➢ Public and Private Investment Manager Evaluation and Selection ➢ Establish Investment Guidelines for Managers ➢ Alternative Asset Class Due Diligence ➢ Daily Monitoring of the Total Portfolio ➢ Quarterly Meetings with the Account Holders, Trustees, or Board Members (minimum) ➢ Quarterly Performance Analysis ➢ Portfolio Rebalancing to: o Maintain the allocation among managers and o Provide for distributions or benefit payments Upon election by the client, RHI may provide the following Additional Services. Alternative Asset Consulting As a complement to its general consulting business, RHI also maintains a dedicated alternative asset consulting practice that performs hands-on advisory services regarding real estate, private equity and other non-traditional asset classes. RHI focuses on providing its clients a combination of on-going education on the dynamic alternative market, fund manager selection, due diligence on real estate fund managers and real estate direct deal investments, as well as monitoring and reporting on all facets of the clients’ alternative holdings. RHI is also poised to perform special project assignments on a one-off basis including specialized due diligence projects and alternative asset portfolio reviews. Daily Monitoring of Investment Activity RHI worked with its clients to develop a daily monitoring system. The system includes a performance analyst downloading all of the holdings and trades from the prior trading day, running specific accounting rules against the data to identify any misallocation, breach of investment policy, and cash levels in each of the investment accounts and the funding account. For instance, the system verifies that adequate, not excessive, cash is held in the funding account ensuring that the client’s available assets are traded by the professional managers. We monitor all activity on a daily basis which has proactively reduced past inefficiencies and dislocations. Individual Customization The clients of RHI receive fully customized information regarding their specific needs as a family or organization. Each client’s specific information is weighed and examined as part of their experience with RHI. While working with RHI, clients operate with an Investment Policy Statement that is unique to their needs and identifies their security objectives and restrictions. Written Acknowledgement of Fiduciary Status When we provide investment advice to clients regarding their 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. Wrap Fee Programs RHI does not participate in wrap fee programs. Discretionary versus Non-Discretionary Asset Management and Assets under Advisement As of December 31, 2023, RHI advised $4,139,078 on a discretionary basis and $836,804,482 on a non- discretionary basis totaling $840,943,560 in Assets under Management. The firm does not manage Assets under Advisement.