A. Cardinal Capital is a corporation formed on January 2, 1992, in the state of North Carolina. Cardinal Capital became registered as an Investment Adviser Firm in January 1992. Cardinal Capital is principally owned by Glenn C. Andrews, who serves as Cardinal Capital’s President and Chief Investment Officer. B. As discussed below, Cardinal Capital provides its clients (currently: individuals, high net worth individuals, trusts, estates, charitable organizations, insurance companies, and corporations or other business entities) with investment advisory services and investment related consulting services. Cardinal Capital does not hold itself out as providing financial planning or related consulting services. INVESTMENT ADVISORY SERVICES Cardinal Capital provides discretionary and/or non-discretionary investment advisory services on a fee-only basis. Cardinal Capital’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Cardinal Capital’s management. Before engaging Cardinal Capital to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Cardinal Capital setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Cardinal Capital provides investment advisory services specific to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, Cardinal Capital will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, Cardinal Capital provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives, and may periodically rebalance and execute transactions for the account based upon such reviews. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Although Cardinal Capital does not hold itself out as providing financial planning, estate planning or accounting services, to the extent specifically requested by the client, Cardinal Capital may provide limited consultation services to its investment management clients on investment and non-investment related matters, such as estate planning, tax planning, insurance, etc. Cardinal Capital shall not receive any separate or additional fee for any such consultation services. Neither Cardinal Capital nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Cardinal Capital does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Cardinal Capital, if desired. Cardinal Capital does not serve as a law firm, accounting firm, or insurance agency, and no portion of its services should be construed as legal, accounting, or insurance implementation services. Accordingly, Cardinal Capital does not prepare estate planning documents, tax returns, or sell commissioned insurance products. To the extent requested by a client, Cardinal Capital may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). The client is under no obligation to engage those services. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Cardinal Capital and/or its representatives. If the client engages any recommended unaffiliated professional on a separate and individual basis, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Cardinal Capital, shall be responsible for the quality and competency of the services provided Non-Discretionary Service Limitations. Clients that determine to engage Cardinal Capital on a non-discretionary investment advisory basis must be willing to accept that Cardinal Capital cannot effect any account transactions without obtaining prior consent to such transactions from the client. Therefore, in the event that Cardinal Capital would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Cardinal Capital will be unable to effect the account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Cardinal Capital recommends that a client roll over their retirement plan assets into an account to be managed by Cardinal Capital, such a recommendation creates a conflict of interest if Cardinal Capital will earn new (or increase its current) compensation as a result of the rollover. If Cardinal Capital provides a recommendation as to whether a client should engage in a rollover or not, Cardinal Capital is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Cardinal Capital, whether it is from an employer’s plan or an existing IRA. Use of Exchange Traded Funds: Many exchange traded funds are available directly to the public. A prospective client can obtain many of the funds that may be used by Cardinal Capital independent of engaging Cardinal Capital as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Cardinal Capital’s initial and ongoing investment advisory services. In addition to Cardinal

Capital’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Portfolio Activity. Cardinal Capital has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Cardinal Capital will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when Cardinal Capital determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Cash Positions. Cardinal Capital continues to treat cash as an asset class. As such, unless determined to the contrary by Cardinal Capital, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Cardinal Capital’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Cardinal Capital may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Cardinal Capital’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Cardinal Capital shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Cardinal Capital reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a Cardinal Capital actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Cardinal Capital unmanaged accounts. Client Obligations. In performing its services, Cardinal Capital shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Cardinal Capital if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Cardinal Capital’s previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that Cardinal Capital and its third-party service providers use to provide services to Cardinal Capital’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Cardinal Capital’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Cardinal Capital are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Cardinal Capital has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Cardinal Capital does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Statement. A copy of Cardinal Capital’s written Brochure as set forth on Part 2 of Form ADV and a Client Relationship Summary as set forth on Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. C. Cardinal Capital provides investment advisory services tailored to the specific needs of each client. Before providing investment management services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, Cardinal Capital will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on Cardinal Capital’s services. D. Cardinal Capital does not offer a wrap-fee program for its investment advisory services E. As of March 22, 2024, Cardinal Capital had $785,131,336 in assets under management on a discretionary basis and $20,011,095 in assets under management on a non- discretionary basis.