Thomas White International, Ltd. is an SEC-registered investment adviser with its principal place of business located in Illinois. TWI began conducting its investment advisory business in June 1992. No shareholder of TWI is classified as a principal owner as no individual or entity owns 25% or more of the firm. TWI offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES SEPARATE ACCOUNT PORTFOLIO MANAGEMENT The firm manages six primary equity strategies designed for institutional relationships: International Equity (ADRs), Global Equity (domestic and ADRs), Emerging Market Equity (ADRs), US Large Cap, US Mid Cap and Global Dividend (domestic and ADRs). Each equity discipline adheres to the firm’s bottom-up, value investment philosophy. Although TWI does not currently manage any International, Emerging Market or Global Equity strategy accounts that utilize foreign ordinary shares, TWI has extensive experience managing ordinary share strategy accounts and expects to do so in the future, consistent with client objectives. TWI also includes fixed-income investments in certain portfolios based on client investment objectives and risk tolerance. An account that utilizes one or more of the primary equity strategies will generally be classified as a Balanced Account. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through direct discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's investment policy objectives and manage their portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Foreign issuers  Warrants  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Mutual fund shares  United States governmental securities  Options contracts on securities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, and desired liquidity. WRAP FEE PROGRAM PORTFOLIO MANAGEMENT TWI has been retained as an investment manager under wrap-around fee arrangements. These arrangements are customarily sponsored by broker-dealers who are neither affiliates nor related persons of TWI (each, a “Program Sponsor”). Under a wrap-fee arrangement, Program Sponsors may recommend that a client retain TWI as an investment adviser (or allocate a portion of assets under management to TWI), pay TWI's investment advisory fee on behalf of the client, and monitor and evaluate the performance of TWI or any other investment adviser. In these cases, TWI is acting as a sub-adviser to the Program Sponsor. When the Program Sponsor is a broker-dealer, it may execute the client's portfolio transactions without additional commission charge, and provide custodial services for the client's assets, all for a single fee paid by the client to the Program Sponsor. Certain wrap programs may include some or all of these features. Program Sponsors generally are responsible for providing wrap fee clients with this brochure as well as the Program Sponsor’s own wrap fee brochure (the “Wrap Brochure”). A Program Sponsor’s Wrap Brochure may also be available on the SEC’s website at www.adviserinfo.sec.gov, as Appendix 1 to the Program Sponsor’s Form ADV, Part 2A. In determining the suitability of TWI's investment management

style to the individual needs and financial situation of the client, TWI relies on the Program Sponsor's extensive information on the prospective client. This information may come from, among other things, a personal interview of the client, a written questionnaire completed by the client that provides certain financial and other relevant data, including the client's investment objectives, risk tolerances and any investment restrictions. Once the account has been established, TWI may communicate directly with the client; however ultimate responsibility for client communications is with the Program Sponsor. TWI manages wrap fee accounts and other accounts in the same manner. As compensation for its investment advisory services, TWI receives a portion of the overall wrap fee paid by the client to the Program Sponsor. Wrap fee clients should review a Program Sponsor’s Wrap Brochure for further details about the relevant wrap fee program. TWI is not responsible for, and does not attempt to determine, whether, in the first instance, a particular wrap fee program is suitable or advisable for any given client. Rather, TWI is responsible for and will determine whether each wrap fee client referred to TWI is reasonably suitable for discretionary management by TWI based on the information provided by the Sponsor. TWI reserves the right, in its sole discretion, to reject any wrap fee client referred to TWI for any reason, including, but not limited to, the wrap fee client’s investment goals and restrictions. UNIFIED MANAGED ACCOUNT (“UMA”) PROGRAMS TWI provides model portfolios to certain UMA program sponsors for various TWI strategies. We are responsible for periodically updating these model portfolios. TWI does not execute any trades on behalf of UMA program clients and has no relationship or agreement with these UMA clients. Each UMA program sponsor retains sole authority and responsibility for the management of the UMA client account and determines whether or not to invest assets of their clients based on the model portfolio provided by TWI. We provide the current model portfolio to each UMA program sponsor promptly upon changes to the model portfolio, consistent with our equitable trade rotation policy. A UMA program sponsor may purchase and sell the recommended investments in the model portfolio at the same time, prior to or after TWI executes similar trades within the corresponding TWI strategy for non-UMA accounts where we are responsible for initiating trading activity. This trading activity undertaken by a UMA program sponsor could impact our ability to execute trades for our clients by affecting the liquidity and market price of securities in the model portfolios. PERSONAL AND PROPRIETARY INVESTMENTS BY TWI, OUR AFFILIATES AND THEIR RESPECTIVE EMPLOYEES TWI, our affiliates and their respective employees typically, directly or indirectly, invest in one or more separately managed accounts managed by TWI. This generally includes persons who serve on TWI's Investment Committee, act as portfolio managers to various separately managed accounts, or are otherwise in a position to determine or influence advice provided to the separately managed accounts. Accordingly, such persons may have differing pecuniary interests with respect to different separately managed accounts. This creates a potential incentive for such persons to allocate or recommend limited investments which they believe are more likely to be profitable to those separately managed accounts in which such persons are allowed to invest. TWI has instituted policies and procedures that it believes are reasonably designed to mitigate such conflicts of interest. AMOUNT OF MANAGED ASSETS As of February 28, 2023 we were actively managing $461,054,100 of clients' assets on a discretionary basis. This amount does not include $123,202,200 in UMA assets that utilize TWI’s model portfolios, which are described above and which do not constitute “regulatory assets under management” as defined by the SEC. The total assets invested in our strategies, as of February 28, 2023 and including both discretionary and model account assets, was $584,256,300 and is described by us as the total TWI “assets under advisement.”