Types of Advisory Services Available Through Stifel Independent Advisors Our services include discretionary and non-discretionary1 Advisory services, which generally involve account and/or portfolio management, asset allocation, and related services, and recommendation of, or assistance with the selection of, securities and/or other registered investment managers (“Managers”). Such Managers may include firms that are independent of our firm (“Independent Managers”) as well as firms owned by our parent company, Stifel Financial Corp., or one of its subsidiaries (“Affiliated Managers”). We enter into a written advisory agreement (“Advisory Agreement”) with each Client and our affiliate, Stifel, Nicolaus & Company, Incorporated (“Stifel”), acknowledging the Advisory relationship and disclosing our firm’s and Stifel’s obligations when acting in an Advisory capacity to clients. We provide Advisory services to a variety of Clients, including individuals, corporations, and other businesses, pension or profit sharing plans, employee benefit plans, trusts, estates, charitable organizations, state and municipal government entities, educational institutions, insurance companies, and banks and thrift institutions (“Clients”). We generally provide Advisory services through our investment advisory representatives, each of whom is an independent agent of the firm (“Financial Advisors”). These Financial Advisors determine the services that are most appropriate for Clients based on each Client’s stated individual investment goals, financial circumstances, and other information provided by the Client. We are able to fulfill a Client’s wealth management needs by acting as broker-dealer, investment adviser, or both. Our Advisory services cover many types of debt and equity or equity-related securities of domestic and foreign companies, as well as national, state and local government issuers, whether trading on an exchange or over-the- counter. In addition to stocks and fixed income securities, we (and/or Stifel) recommend or invest Client assets in other types of investments, such as rights and warrants, options, certificates Page 5 of 41 SIA1601-3/24 of deposit (“CDs”), mutual funds and other open and closed-end funds, exchange traded products (“ETPs”), including exchange traded funds (“ETFs”), unit investment trusts (“UITs”), real estate investment trusts (“REITs”), American Depositary Receipts (“ADRs”), foreign ordinary shares, publicly traded master limited partnerships (“MLPs”), private investment vehicles (including, but not limited to, hedge funds and private equity funds), and other investments deemed appropriate for our Clients. Assets Under Management As of December 31, 2023, we had approximately $2,099,723,673 of Client assets that were managed on a discretionary basis and $1,456,795,102 in non-discretionary assets. Our Responsibilities as an Investment Manager When serving as an investment adviser to Clients in the Advisory programs covered by this brochure, we are acting as a fiduciary with respect to the assets held in accounts covered by the Advisory Agreements. In our capacity as an investment adviser, we are held to the legal standards set forth in the Investment Advisers Act of 1940 (the “Advisers Act”), certain state laws, and common law standards applicable to fiduciaries, as well as, where applicable, obligations imposed under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) or other relevant regulations for Advisory retirement accounts. Such standards include the duty of care, including the obligation to have a reasonable basis for believing that our investment recommendations are suitable and consistent with a Client’s stated objectives and goals (including any investment restrictions placed on the account by the Client) and the duty of loyalty, including the obligation to provide Clients with full disclosure of material conflicts of interest. Our duties of care and loyalty differ depending on the terms of our relationship with the Client, the type and level of agreed services, and other factors, including whether we provide non-discretionary versus discretionary services or when we provide episodic (e.g., financial planning) versus continuous advice. Our duty of care may be defined in our Client agreement, and our duty of loyalty may be modified or limited through Client disclosure and affirmative or implied Client consent by receiving and not objecting to the disclosure. Additional information about our fiduciary obligations, including some of the policies and procedures that we undertake to fulfill those obligations, is available throughout this brochure, including under the section titled “Participation or Interest in Client Transactions.” SERVICES, FEES, AND COMPENSATION Our Relationship with Stifel, Nicolaus & Company, Incorporated Our affiliate, Stifel, supports the Advisory services described in this brochure by providing access to its research and Advisory programs, execution and clearing of Client transactions, and, in most cases, custody of client assets. Throughout this brochure and depending on the type of Program referenced, the term “portfolio manager” shall refer to, as applicable, i) Stifel Independent Advisors, where your Financial Advisor, as agent for our firm, provides discretionary portfolio management services (e.g., in connection with the Vantage Program discussed below), ii) Stifel where it provides discretionary portfolio management services, and/or iii) an Independent Manager or Affiliated Manager to whom Stifel has delegated discretionary authority as a sub-adviser, such as manager-traded Portfolios in the Opportunity Program, or to whom you have otherwise granted investment discretion, such as an Manager with whom you have entered into a separate investment advisory agreement within the Connect Program. Investment Restrictions Subject to Stifel’s review for reasonableness, if you have accounts in discretionary programs, you can impose investment restrictions on any of those accounts (or specific assets within the accounts), such as restricting investments in specific securities, types of securities, industries, or sectors. We generally require Clients to provide requests for investment restrictions in writing. If we, Stifel, and/or a Manager determine(s) that your proposed investment restrictions are reasonable and accept them, our Financial Advisor, Stifel, or the Manager you have selected (as appropriate) will be responsible for implementing and managing the account consistent with the restrictions that you have imposed. It is important for you to understand that if the restrictions are approved and imposed on your account, the performance of the account will differ (even significantly) from the performance of other accounts in the same portfolio without similar restrictions. You may request in writing that specific mutual funds or ETFs not be purchased in your discretionary Advisory account(s); however, we cannot accommodate requests to restrict the underlying securities that may be purchased or sold by mutual funds, ETFs, private funds, or other collective investment vehicles in Advisory accounts. For accounts in which the Firm or your FA have discretionary trading authority, where an investment restriction applies to prevent the purchase of a security, the funds that would have been invested in the restricted position will either be invested in cash equivalents (including short-term fixed income instruments), other substitute securities, or reallocated among other positions at our Financial Advisor’s or Stifel’s discretion, as appropriate. A higher than usual allocation to cash, cash equivalents, or other securities as a result of investment restrictions will impact the performance of the account relative to other accounts that are fully invested. Stifel defines and/or identifies certain permissible category restrictions (e.g., prohibiting investments in particular industries or based on social consciousness) by reference to information provided by a third-party service provider using the provider’s proprietary methodologies. If you elect to impose investment category restrictions on an account, Stifel will apply the restrictions based on its internal policies, by referencing the third-party service provider’s information. The service provider typically flags securities as violating specific category restrictions based on an issuer’s revenues or asset levels from the restricted activity(ies). The threshold or level at which revenue or assets are considered to have violated a particular restriction can change at any time, without notice to you. In addition, you Page 6 of 41 SIA1601-3/24 should note that Managers with trading responsibility over your account may use their own trading systems and, as a result, may use different reference points than Stifel in defining prohibited investments, activity, or revenue levels for category restrictions. As set forth above, we accept investment restrictions only if our firm, Stifel, and/or the Manager conclude(s) that those restrictions are reasonable and can be accommodated through current monitoring processes. We will reject any proposed investment restriction that does not meet this standard, in which case you have the option of (i) modifying your restrictions until acceptable to us or (ii) not opening or otherwise terminating your discretionary account(s). We generally do not accept the responsibility for monitoring investment restrictions in non-discretionary accounts. As a non- discretionary account, you must approve recommendations for your account before the related trades can be implemented. We expect you to consider your applicable investment restrictions when considering recommendations for your non-discretionary account(s), and to approve a trade only to the extent you conclude that the recommendation does not violate your investment restrictions. Investment Policy Statements We do not accept any responsibility for monitoring compliance with a Client’s investment policy statement (“IPS”) unless the Client account is in one of our discretionary programs and the Client is using either a Stifel-approved template for the IPS, or our home office personnel have reviewed the Client’s IPS and determine that the requirements and limitations of the IPS are reasonable and that we are capable of monitoring them, and we have confirmed in writing that we have accepted responsibility for monitoring compliance with the IPS. Clients may submit their IPS for review and will be notified in writing if and when their IPS has been accepted by Stifel. Please note that you are solely responsible for monitoring compliance with your own IPS, even where you have provided a copy of the IPS to your Financial Advisor(s) until you have received written notice from Stifel of its acceptance of your IPS. In the event that you update your IPS, you are responsible for providing Stifel with the updated document for review and approval. If we agree that we can continue to monitor your IPS with the new guidelines, we will notify you in writing of our acceptance. Stifel will not be responsible for monitoring any new guidelines until we have notified you of our acceptance. Stifel’s goal is to follow your IPS. However, market, economic, or geopolitical conditions may impact our ability to do so and in those cases, Stifel’s policy is to do what it deems to be in the client’s best interest. ADVISORY PROGRAMS AVAILABLE AT STIFEL INDEPENDENT ADVISORS Through our affiliation with Stifel, we offer a number of different Advisory options (each a “Program” and collectively, the “Programs”). Clients may select from the following Programs as appropriate for their needs: Stifel Wrap Fee Programs As set forth on the cover page, we offer our Clients access to a number of different wrap fee (“Wrap”) Programs sponsored by Stifel. A “wrap fee” is an annual fee paid by the Client that is intended to cover applicable services to the account, including our investment advice and, where applicable, may include portfolio management, trade execution, clearing, settlements, custody, administrative, and account reporting services provided by Stifel, as well as investment advice and/or portfolio management provided by an Manager to the investment portfolio (“Portfolio(s)”). For these Programs, Stifel (not Stifel Independent Advisors) is the sponsor and, in certain Programs, both the sponsor of the Program and portfolio manager for Portfolios within the Program. Our Financial Advisors serve as portfolio managers only in connection with one Program, the Solutions Program. To the extent that portfolio management or similar services for a Portfolio are provided by Managers, Stifel pays a portion of the Client’s wrap fee to such Managers for their services – please refer to the section “Fees and Compensation” below for additional details about our fees (also called Advisory Account Fees). We offer Clients access to the Stifel Opportunity Program, under which Managers act as discretionary portfolio managers, or provide their model portfolios to Stifel, which Stifel implements. Clients may also grant our Financial Advisors (as agents for our firm) discretionary investment authority to manage the Clients’ accounts through the Stifel Solutions Program. Clients may also access discretionary investment advisory services through the Stifel Fundamentals Program. Finally, Clients can access non- discretionary investment advisory services through the Horizon Program or the Connect Program (where Stifel recommends a Manager with which you enter into a separate advisory agreement). Finally, under the Custom Advisory Portfolio (“CAP”), Stifel offers clients investment management services utilizing various investment products within a single

account, whose Portfolios may be a combination of any of internal and/or external model Portfolios, mutual funds, and/or ETFs. Clients determine their selection of either a Client-Directed option or the Financial Advisor-Directed option. Each of these wrap Programs is further described in the Stifel Wrap Fee Programs Brochure, which is available to you free, upon request. Other Advisory Programs We also offer Advisory services to Clients under non-wrap fee Programs. You may select from the following other non-wrap fee Advisory Programs as appropriate for your needs: Page 7 of 41 SIA1601-3/24 Stifel Vantage Program Under the Stifel Vantage Program (“Vantage”), your Financial Advisors who are approved to participate in the Vantage Program offer discretionary account management services to participating Clients. If you choose to enroll in the Vantage Program, your Financial Advisor will assist you in selecting an appropriate strategy for your Vantage account once you have established your investment objectives, goals, risk tolerance, and an overall asset allocation. To implement your investment objectives for the account and based on your risk tolerance, your Financial Advisor may utilize fundamental, qualitative, quantitative, and/or technical research published by Stifel or another source. Your Financial Advisor may also employ short-term purchases and/or limited options trading in your Vantage account, provided such strategies are suitable and appropriate for you and, as applicable, approved for the account. Our Financial Advisors use different strategies to manage their discretionary Client accounts; your Financial Advisor may utilize multiple strategies and/or may customize a strategy to fit your particular situations in ways that are different from other Clients. As such, the performance of your Vantage account will differ (at times, materially) from the accounts of similarly situated Clients for your Financial Advisor and/or other Stifel Financial Advisors. Subject to such limitations as we may impose from time to time, our Financial Advisors invest in various kinds of equity and fixed income securities in Vantage accounts. You are encouraged to discuss with your Financial Advisor and review how your Vantage account will be managed, the types of investments to be made, as well as the risks that will be applicable to your Vantage account. As with our other discretionary Programs, you may impose reasonable investment restrictions on your Vantage account. Vantage Commission Schedule: If you enroll an account in the Vantage Program, you will pay transaction-based charges (commissions) for the services provided by your Financial Advisor and Stifel. Commissions are charged based on our standard commission schedule (subject to negotiation in certain circumstances) for brokerage transactions. The Vantage Program is generally not available to IRAs and is not available to retirement accounts subject to ERISA. Conflicts of Interest It is important that you understand that, due to the commission-based structure of the Vantage Program, Stifel and your Financial Advisor have a conflict of interest with respect to transactions implemented in your Vantage account due to the fact that your Financial Advisor’s compensation rises as more transactions are implemented in the account (conversely, the Financial Advisor is not paid if no transactions are implemented in the account). You should carefully consider whether a Vantage account is appropriate for your investment objectives, risk tolerance, time horizon, and investment experience. While we do not consider the appropriateness of the Vantage Program for a Client solely based on a comparison to wrap-fee programs, the Vantage Program may not be suitable for you if you (and/or your Financial Advisor) anticipate a high level of trading activity where the transaction costs could potentially exceed those that would otherwise be charged under a discretionary wrap Program. We highly encourage you to review all available options at Stifel with your Financial Advisor(s). Stifel Summit Program The Stifel Summit Program (“Summit”) allows our Financial Advisors the ability to serve Clients who are seeking investment advice for assets held and traded through other custodians or other broker-dealer firms. Clients that may benefit from a Summit relationship include (but are not limited to): municipalities, endowments, foundations, corporations, high- net-worth individuals, and sponsors and/or trustees of qualified retirement plans subject to ERISA. We typically offer non-discretionary advice under the Summit Program. Our services may include, for example: advice regarding use of third-party investment managers; evaluation of investment risk and performance; and recommendations on the purchase and sale of individual investment vehicles including stocks, bonds, mutual funds, UITs, ETFs, closed-end funds, and options. Our Financial Advisors provide investment advice to Clients in accordance with each Client’s stated investment objectives, risk tolerance, time horizon, and investment experience. If you sign up for such an arrangement, you will be solely responsible for implementing any non-discretionary advice provided by the Financial Advisor(s). In all cases, you will be solely responsible for all brokerage and custodial charges imposed by your independent qualified custodian. If you elect to enroll in the Summit Program in connection with your assets at other institutions, you should be aware that, through our wrap Programs, you could pay a wrap fee for investment management, execution, and custodial services through Stifel. These wrap Programs may be a cheaper alternative than using the Summit Program and paying separate fees to different institutions for advice, custody, trade execution, and clearing; we highly encourage you to review all available options at Stifel with your Financial Advisor(s). Summit Fee Schedule: For our services under a Summit arrangement, we charge a fee at an annual rate of up to 1.00% of the total value of investments under the arrangement. You can typically negotiate the fee for your specific arrangement with your Financial Advisor. In certain circumstances, we may agree to a flat dollar fee arrangement, which may payable at once or in installments (e.g., monthly, quarterly, or other agreed frequency). In general, the initial fee for any Summit arrangement is calculated based on the account’s most recent account statement, quarterly or otherwise. The fee is typically billed quarterly in advance, although some relationships may bill in arrears and/or at a frequency that is not quarterly. Page 8 of 41 SIA1601-3/24 Benefit Plans: We provide investment advice, education, and other services to various kinds of retirement and benefit plans, including defined contribution plans (e.g., 401(k) plans), defined benefit plans, nonqualified retirement plans, deferred compensation plans, and others. Our services to plans typically include one or more of the following non-discretionary services:
• Assisting plan fiduciaries in reviewing the plan design to improve efficiency and/or reduce costs. This may include an analysis of plan terms, as well as an evaluation of service providers;
• Assisting plan fiduciaries in creating, reviewing, and/or updating investment policy statements;
• Asset allocation and creating an investment menu, including diligence of potential investments and/or periodic monitoring of the selected investments (other than any securities that are specifically excluded pursuant to the agreement with the plan); and
• Participant education services on investment-related topics (under limited circumstances, note that these services may include provision of investment advice to participants). We may also provide such other agreed-upon services as are set forth in our agreement with the plan. For example, from time to time, we may agree to provide discretionary investment services to plans, including in selecting and implementing a plan investment menu, creating and managing default investment options, and/or creating and managing risk-based model portfolios for the plan. It is important to note that, in our arrangements with plans under the Summit Program, our agreement is with the plan and our Client is the plan (not any individual participant with whom we may interact). In these arrangements, we may provide fiduciary advice to participants, but will not assume any discretionary or other authority over a participant’s selection of any investment option or product on the plan’s investment menu. In limited circumstances, we may agree to provide individualized advisory services to participants in a plan; in those cases, we may require the participant to, among other things, complete and execute agreements, certifications, or other documents. OTHER INFORMATION ABOUT THE PROGRAMS As discussed above, we enter into written Advisory Agreements with you acknowledging our (and Stifel’s) Advisory relationship, disclosing our obligations when acting in an Advisory capacity, and describing the roles and responsibilities of each party. Processing Guidelines for Advisory Accounts New Account Processing As set forth in our Advisory Agreement, our Advisory relationship with you begins after Stifel has accepted a fully executed Advisory Agreement (referred to as the “effective date” in the Advisory Agreements). In general, this occurs after (i) your Financial Advisor has submitted all required account opening documentation through the appropriate channels (typically through our account opening systems); (ii) all required internal approvals have been documented and submitted; (iii) Stifel’s processing personnel have confirmed that the account documentation is in good form (for example, Client signatures are generally required to be dated within 90 days of submission); (iv) your account is funded with no less than the minimum amount required for the particular Program or Portfolio in which you are seeking to invest; and (v) the account has been coded as an Advisory account in Stifel’s and our recordkeeping systems. Processing times may vary due to a number of factors, including (but not limited to) the volume of new Advisory accounts being processed, whether additional verification activities are needed, etc. In general, you should note that the turnaround time for processing new Advisory accounts or conversions between Programs or Portfolios may take several business days to complete, even under normal market conditions. Neither Stifel Independent Advisors nor Stifel (or any Manager, if applicable) is responsible for changes in market prices that occur between the time you execute Advisory account documentation (or otherwise authorize enrollment into a Program or Portfolio) and the eventual investment of the account in the selected strategy. Prior to enrolling into any Program, you should talk to your Financial Advisor about the expected processing period for that Program. Processing Ongoing Account Maintenance Requests Availability of Funds/Securities Added to Discretionary Accounts for Trading – When you add funds or securities to your discretionary accounts at Stifel, those funds and/or securities are generally available for trading no earlier than the next business day. Processing Partial Liquidation/Withdrawal Requests in Firm Discretion and Manager Portfolios – To the extent possible, Stifel will process liquidation requests promptly after its trading and/or processing staff receive those instructions from your Financial Advisor. If a Manager has trading discretion over your account, Stifel will then relay those instructions to the Manager for implementation. You should note that, in periods of unusually high volumes (which may occur, for example, during highly volatile market conditions), it can take more than one business day to implement these requests. In each case, please note that frequent withdrawals from your account will affect your account’s performance. Stifel has reserved the right to terminate any account that falls below the minimum account value for the applicable Program due to partial liquidations/withdrawal requests. You should refer to the section “Terminations; Refund of Fees Upon Terminations” below for a discussion of the processing guidelines relating to account terminations from the Advisory Programs. Other Maintenance Requests – You may also experience delays in connection with other ongoing account maintenance requests. During times of unusually high volumes of requests from Clients, it can take multiple business days to process and implement ongoing maintenance requests. Page 9 of 41 SIA1601-3/24 In each case, we recommend that you communicate your maintenance requests to your Financial Advisor as early as possible. You should note that, for certain securities (such as mutual funds), we are not able to process trade instructions received after 3:00 p.m. Eastern Standard Time. Neither Stifel Independent Advisors, Stifel, nor any Manager is responsible for changes in market prices that occur between the time you communicate an account maintenance request for any discretionary account to your Financial Advisor and the eventual implementation of that request by the appropriate team.