Advisory Firm Parsons Capital Management, Inc. (PCM) is an SEC registered investment adviser, which is principally owned by PCM Holdings Inc. The firm was founded in 1993 and is headquartered in Providence, Rhode Island. The firm maintains a satellite office in Hobe Sound, Florida and a small satellite office in Denver, Colorado. PCM also has two residential satellite offices in Fishers Island, New York. John H. Mullen, President, joined the firm in 2008. John B. Trevor IV, Secretary, joined the firm in 2011, and, C. Bateman Parsons, Treasurer, joined the firm in 2016. Stacey L. Sternberg is the Chief Compliance Officer and has been with the firm since 2007. Investment Management and Advisory Services Parsons Capital Management, Inc. provides investment advisory and investment management services, consulting services and financial planning services to its clients. In investment management services, PCM consults with each client to define the client’s financial and investment objectives. When necessary, PCM will consult with a client’s outside advisers, such as attorneys and accountants, to assist in defining these objectives. During this process, PCM will assist the client in determining their income or principal needs, investment time horizon, specific investment limitations, tax circumstances and tolerance for risk. After the objectives are determined, PCM will work with clients to plan and implement a specific investment program and strategy tailored to that individual client. PCM manages investment portfolios that may comprise of domestic and international stocks, preferred stocks, convertible securities, government and agency bonds, tax-exempt bonds, corporate bonds, exchange traded funds, mutual funds, master limited partnerships, limited partnerships and money market funds. Upon the request of a client, assets managed by PCM may be coordinated with assets not managed by PCM. These assets may include but are not limited to: 401(k) plans, 529 plans, trust accounts, defined benefit plans and deferred compensation plans. By monitoring the outside assets of a client, PCM helps maintain consistent and productive strategies for investment portfolios, helping to achieve the client’s long-term goals and objectives. In addition, PCM sometimes provides advice to clients not specifically related to investments. This advice may include matters relating to financial planning, tax issues or estate planning. PCM will generally provide such consulting services inclusive of its advisory fee, although exceptions could occur based upon assets under management, special projects or stand- alone planning engagements for which PCM may charge a separate or additional fee. PCM does not serve as an attorney, accountant or insurance agent, and no portion of our services should be construed as such. PCM does not prepare legal documents, tax returns or sell insurance products. If requested by a client, PCM may recommend other professionals for non-investment related services (i.e., attorneys, accountants or insurance agents). The client is free to accept or reject any recommendation from PCM or any of its representatives. The engaged licensed professional and not PCM shall be responsible for the quality and competency of their services provided. Further, PCM may engage in consulting services related to portfolio asset allocation, portfolio evaluation or security analysis. On occasion, PCM has been asked to provide services as expert witnesses in a legal action. Finally, PCM offers financial planning services with an in-depth evaluation and analysis

of clients’ current financial picture. As of December 31, 2023, PCM managed 1,821 discretionary accounts with a market value of $1,863,225,613, and 12 non-discretionary accounts with a market value of $16,368,442 for a total of 1,833 accounts and a total market value of $1,879,594,055. Written Acknowledgment of Fiduciary Status We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title 1 of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We are required to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must give prudent and loyal advice, avoid misleading statements regarding fees, investments, and conflicts of interest, give advice that is in your best interest, and charge a reasonable fee for our service. Retirement Rollovers & Potential Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan. A client or prospective client may choose one or a combination of the options below: 1. Leave the money in the former employer’s plan, if permitted; 2. Roll over the assets to the new employer’s plan, if one is available and rollovers are permitted; 3. Roll over to an Individual Retirement Account (“IRA”); 4. Cash out the account value, which could, depending upon the client’s age, result in adverse tax consequences. If PCM recommends that a client roll over their retirement plan assets into an account to be managed by PCM, such a recommendation creates a conflict of interest if PCM will earn new, or increase its current, compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by PCM. Investment Advisory Services for Held Away Accounts PCM uses a third-party platform to facilitate discretionary management of held away assets such as, but not limited to, 401(k) plans or 529 plans. The platform allows PCM to avoid being considered to have custody of client funds since the firm has no direct access to client log-in credentials. PCM is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided directly to the client allowing them to connect the account(s) to the platform. This allows the adviser to review the current account allocations, rebalance the account according to the client’s investment goals and objectives and tailor the account to the specific needs of the client. These accounts will be regularly monitored and rebalanced as needed. Security Claims Class Action Litigation PCM has engaged a third‐party service provider, Chicago Clearing Corporation (CCC), to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of the Firm’s clients. When a claim is settled and payments are awarded to PCM clients, it may be necessary to share client information, such as name and account number, with CCC in connection with this service. Clients may opt out of this service at any time. If a client opts out, PCM does not have an obligation to advise or take any action on behalf of a client with regard to class action litigation involving investments held in or formerly held in a clientʹs account.