General Description of Advisory Firm Donaldson Capital Management (also referred to as “Donaldson”, “DCM”, or “Firm”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Limited Liability Company formed under the laws of the State of Indiana. DCM has been registered with the SEC since February 10, 1995. The Firm is principally owned by Gregory C. Donaldson and Michael D Hull. Neither has majority ownership of DCM, but together, they own approximately 60% of the Firm. The remaining interest in the firm is owned by various other Donaldson Capital Management employees. Through Donaldson Capital Management, we offer and consider ourselves to specialize in providing personalized Investment Management Services. We employ investment strategies using individual stocks, bonds, or a combination of both designed to best fulfill the needs of our clients, focusing on income and/or growth. We generally provide our services to individuals, pension and profit-sharing plans, trusts, estates, foundations, corporations, and other business entities. Clients are advised that the investment recommendations and advice offered by Donaldson Capital Management do not constitute legal or accounting advice. Therefore, you should coordinate and discuss the impact of financial advice with your attorney and/or accountant. Clients are advised that it is necessary to inform Donaldson Capital Management promptly with respect to any changes in their financial situation, investment goals and objectives. Failure to notify Donaldson Capital Management of any such changes could result in investment recommendations not meeting the needs of the client. General Description of Primary Advisory Services Investment Management Services - DCM provides advisory services in the form of Investment Management Services which involve providing clients with continuous and on-going supervision over client accounts. This means that Donaldson Capital Management will continuously monitor a client’s account and make trades in client accounts when necessary. The Firm may provide investment management services directly to clients (see One Fee – Investment Management Program) or through platforms sponsored by unaffiliated investment advisor firms and broker-dealers (see Independent Money Manager Services described in Item 4.B). Regardless of the platform, our investment portfolios, strategies, and recommendations are materially indifferent, Proprietary-retail clients may receive investment management, financial planning, and/or consulting services. Clients referred to DCM by unaffiliated investment advisers are not eligible to receive the Firm’s financial planning services and other services received by the Firm’s proprietary clients. A. One Fee - Investment Management Program DCM primarily provides investment management services to clients through its One Fee Program. Participation in the One Fee Program is primarily facilitated by affiliated investment advisor representatives. However, clients of unaffiliated independent investment advisors contractually engaged by Donaldson Capital Management are also eligible for the One Fee Program, as described below in Item 4(B). Through this program clients engage the Firm to design an investment portfolio and provide ongoing corresponding investment management services on a fee-only basis. This service is structured so that the Firm will serve as the sole investment advisor to the account. Donaldson Capital Management may allocate investment management assets of its client accounts, on a discretionary or non-discretionary basis, among one or more of its proprietary investment management portfolio strategies (i.e., Cornerstone, Capital Builder, Income Builder, Sectors, Endowment – Cornerstone, Endowment – Capital Builder, Endowment – Income Builder, and Preservation of Capital). Additional details and disclosures regarding the Firm’s investment management portfolio strategies (management styles) are provided to clients via separate documentation prior to or at the time a portfolio strategy is determined. Please also refer to Item 8 of this Disclosure Brochure for more information. Clients will be provided one or more of the following services:
• A detailed Discovery Process during the first meeting that is designed to gather important factors regarding each client’s particular situation;
• The presentation of an Investment Plan designed specifically for each client before becoming a client;
• A Retirement Income Plan designed to outline the income needs for a client during retirement;
• A Progress Review during the first sixty days to let the client understand how the strategies in the Investment Plan are being implemented;
• A daily reconciliation of every account to ensure that all transactions, positions, and prices have been properly updated;
• Portfolio Quality Assurance conducted, no less often than quarterly, adjusting every account, as needed, to Advisor’s model portfolios;
• Periodic review of account performance;
• Regularly scheduled personal portfolio reviews;
• Quarterly Reports that include; ▪ A detailed appraisal of assets under management; ▪ Estimated income being generated by each portfolio; and ▪ An advisory letter written by the Investment Policy Committee.
• Year-end tax reporting information; and
• Reconciliation and decision-making concerning: tenders, spin-offs, and mergers Prior to Donaldson Capital Management providing investment management services, the client will be required to enter into a formal Investment Advisory Services Agreement with DCM setting forth the terms and conditions under which we shall manage the client's assets, and a separate custodial/clearing agreement with the broker-dealer/custodian. Both the Firm’s investment advisory agreement and the broker-dealer/custodian’s custodial/clearing agreement may authorize the broker-dealer/custodian to debit the account for the amount of our investment management fee and to directly remit that management fee to Donaldson Capital Management. In performing its services, the Firm 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 the client’s responsibility to promptly notify DCM if there are ever any changes in the client’s financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Donaldson Capital Management generally recommends, and in some cases may require, clients establish accounts at Charles Schwab, Inc. as a result of the Firm’s participation in the Schwab Institutional program for advisors. We also recommend, and in some cases may require, clients establish accounts at National Financial Services LLC (NFS) through the Fidelity Institutional Wealth Services platform. Charles Schwab, Inc. (“Schwab”), member FINRA/SIPC. Schwab is an independent and unaffiliated SEC- registered broker-dealer. NFS is also an SEC-registered broker-dealer, member FINRA/SIPC. NFS is an affiliated company of Fidelity, but DCM is not affiliated with either NFS or Fidelity. Schwab and NFS serve as qualified custodians for the client’s funds and securities. In rare situations and upon approval of Donaldson Capital Management, a client may select a broker-dealer other than Schwab or NFS to serve as qualified custodian. For more details on the arrangement between Donaldson Capital Management, Schwab, Fidelity, and client-directed brokerage arrangements, see Item 12 of this Disclosure Brochure. Clients in the One Fee Program are charged an investment management fee based upon a percentage of the market value of the assets being managed by Donaldson Capital Management. The annual investment management fee rate charged shall vary (generally between 0.5% and 1.50%) depending upon the market value of assets under management and the specific type of investment management services to be rendered. Our firm’s investment adviser representatives (“IARs”) act as portfolio manager(s) for the One Fee Program. Other investment advisory firms may charge the same or lower fees than our Firm for similar services, although you will not have access to DCM strategies or portfolio managers. B. Donaldson Capital Management Independent Money Manager Services Donaldson Capital Management also provides its investment management services to clients through programs sponsored by unaffiliated investment advisors and/or broker-dealers. These programs may be general asset allocation programs. Through these programs, DCM will be available to clients for selection as an independent money manager. Under this program, Clients must establish an account directly with the program sponsor. All applicable contracts and account paperwork will be completed by the client with the assistance of the program sponsor representative. The program sponsor representative will obtain the necessary financial data from the client, assist the client in determining suitability, and help the client to set the appropriate investment objectives. The program sponsor will then provide all necessary information to Donaldson Capital Management. The program sponsor representative will meet periodically to review the client’s financial situation, investment objectives, and current portfolios and then make any necessary changes to the Firm portfolio strategy selection, notice of which will be sent to DCM. A representative of the program sponsor will be responsible for providing Donaldson Capital Management’s disclosure brochure. Depending on the money manager program, a DCM client agreement will also be provided to the client. Donaldson Capital Management will have the power and authority, as granted by the client through the program sponsor contract, to make investment decisions over the portion of the client’s assets delegated to the Firm. Depending on the specific program, clients may also be required to execute an investment management agreement directly with the Firm. Donaldson Capital Management will be responsible for executing transactions in the client’s account on a discretionary or non-discretionary basis as outlined in the agreement. Accounts established through a program sponsored by an unaffiliated investment advisor and/or broker- dealer will be held and cleared through a broker-dealer selected by the program sponsor, pursuant to a relationship between the sponsor and the clearing broker-dealer. The program sponsor reserves the right to designate alternative clearing and custody arrangements similar to those of its preferred clearing broker-dealer. Custody of funds and securities is maintained by the various clearing firms, not by Donaldson Capital Management. C. Investment Consulting Services We also provide investment consulting services in the form of oral advice and written recommendations. Investment consulting services may cover, but are not limited to, the following topics: portfolio analysis, asset allocation strategies, and specific investment recommendations. The Firm may provide consulting services on accounts and other investment holdings owned by the client but not included under the Firm’s investment management services. These are accounts for which trading authorization is not granted to DCM. Clients signing up for this service must understand that the Firm does not provide on-going reviews of accounts through this service and information about such accounts is limited to information provided exclusively by the client. Clients always have the sole discretion to accept or reject DCM’s advice. The client must implement all trades in such accounts because the Firm will have no access to the account.

D. Financial Planning Services DCM offers financial planning services a la carte or as an integrated component of our investment management services. Our clients may receive financial planning services on the following investment- related topics: retirement planning, tax planning, education funding, etc. Amongst others, investment management clients may receive a one-time written plan that is subject to updates as circumstances dictate. Normally, DCM will not charge a separate fee for these services unless specified in our signed Investment Advisory Agreement. If, at DCM’s sole discretion, DCM determines the client requires extraordinary planning and/or consultation services, DCM may assess a charge for additional services, the amount which shall be set forth in a separate written and signed agreement with the client. E. Participant Account Management DCM uses a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. DCM is not affiliated with the platform and receives no compensation from them for using their platform. A link is provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance. Client account(s) are reviewed on at least a quarterly basis and allocation changes will be made as deemed necessary. F. Types of Investments Used Donaldson Capital Management provides investment advice on the following types of investments.
• No-Load (i.e., no trading fee) and Load-Waived (i.e., trading fee waived) Mutual Fund Shares
• Exchange-listed securities (i.e., stocks)
• Securities traded over the counter (i.e., stocks)
• Fixed income securities (i.e., bonds)
• Closed-End Funds and Exchange Traded Funds (ETFs)
• Foreign Issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• United States government securities
• Options contracts on securities and commodities
• Interests in partnerships investing in real estate, oil and gas interests Donaldson Capital Management does not provide advice on futures contracts on tangibles or intangibles or hedge funds and other types of private (i.e., non-registered) securities. When providing Investment Management Services, DCM will typically construct each client’s account holdings using equities, fixed income, or a combination of both to build a diversified portfolio based on the client’s financial situation and investment objectives. It is not Donaldson Capital Management’s typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special considerations such as -- low basis stock, stock options, legacy holdings, inheritances, or special tax situations. If requested, a client may impose reasonable restrictions on investing in certain securities or certain types of securities. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. G. Retirement Plan Services DCM provides retirement plan services to employer plan sponsors on an ongoing basis. Generally, such services consist of assisting employer plan sponsors in establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment options, plan structure and participant education. Retirement plan services may include the following depending on whether the relationship is a 3(21) fiduciary relationship or a 3(38) fiduciary relationship:
• For 3(38) relationships, DCM will provide discretionary investment advice to clients about the investment alternatives available for the Plan in accordance with the Plan’s Investment Policy Statement. DCM will have final decision-making authority regarding the initial selection, retention, and removal of investment options. For 3(21) fiduciary relationships, DCM will provide similar services however the Plan trustees retain the final decision-making authority regarding the selection, retention, and removal of investment options.
• Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.
• Prepare periodic investment advisory reports that document consistency of fund management and performance to the guidelines set forth in the Investment Policy Statement and make recommendations and decision to maintain or remove and replace investment options.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation, and tolerance for risk.
• Meet with Client on a periodic basis to discuss reports, recommendations, and decisions.
• Provide investment advice to Client with respect to the selection of a qualified default investment alternative for participants who fail to make an investment election. If serving in a 3(38) fiduciary role, DCM will have the discretionary authority to make such decisions on the Plan’s behalf. All retirement plan services are provided in compliance with the applicable federal and state laws regulating retirement services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the agreement with respect to the provision of services described therein. Collective Investment Funds Services A collective investment fund (“CIF”) is a pooled investment vehicle that is exempt from registration as a mutual fund under the Investment Company Act of 1940 and only available to qualified retirement plans. Donaldson Capital Management offers investment advisory services by serving as subadvisor to multiple CIFs for participation solely by eligible employee benefit trusts pursuant to a Declaration of Trust that qualifies as a group trust (the “Trust”). Matrix Trust Company (“Matrix” or the “Trustee”) serves as the CIFs’ trustee and administrator, hires, and fires the investment adviser to the CIF, and selects the qualified custodian. As sub-adviser to the CIFs, DCM provides investment advice and management services to the Trustee. The only option available currently is the Donaldson Rising Dividend Cornerstone Fund (“the Fund”) and the Fund is available only to retirement plans as an investment option. Some retirement plans investing in the Fund could also be clients of DCM. Where such a plan is otherwise a client of DCM, DCM may perform Retirement Plan Services (including fiduciary consulting services), except for selecting, monitoring, or recommending the Fund, in which case it will receive a fee for such plan‐level service. The plan sponsor is responsible for selecting and monitoring the Fund. The investment management fee paid by the Fund to DCM may be at a rate that is higher or lower than the fee DCM typically receives from the plan for the plan‐level retirement plan services. Please refer to Item 5 of this Brochure for a description of our fees. Increases in Funds assets will result in increases in total management fees paid to DCM. In recognition of that incentive and to avoid any potential conflict of interest, any retirement plan utilizing DCM’s Retirement Plan Services will need to make its own independent investigation and evaluation of the Fund. The Fund currently comprises the sole collective investment fund client advised by DCM. DCM maintains limited power of attorney to act on a discretionary basis when managing the investments of the Fund. DCM is responsible for investment selection, asset allocation, and asset management decisions regarding the Funds. DCM does not have authority to disburse assets or securities from the Fund. Tailor Advisory Services to Individual Needs of Clients When managing client accounts through the Firm’s Investment Management Services program, DCM may allocate investment management assets of its client accounts, on a discretionary or non- discretionary basis, among one or more of its proprietary investment management portfolio strategies (management styles) developed and monitored by our Investment Policy Committee (IPC). When client accounts are managed using one or more of our proprietary portfolio strategies (management styles), investment selections are based on the underlying model(s) and we may not necessarily develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals and objectives. To determine which management style best suits the needs of a client, a DCM Portfolio Manager or a third-party investment advisor representative conducts an initial interview with the client during which time the Portfolio Manager or third-party investment advisor representative obtains from the client information sufficient to determine the client’s financial situation and investment goals and objectives. The Portfolio Manager or third-party investment advisor representative will describe the different management styles Donaldson Capital Management offers that might be most beneficial and appropriate in light of the client’s responses and objectives. Then, a portfolio strategy (management style) is chosen by agreement with the client for each account. Because Donaldson Capital Management specializes in generating income for clients, which investment management portfolio strategy (management style) and asset allocation are chosen depends in large part on how much income the client needs. Beyond that, personal risk tolerance and time horizon are factored into the decision. Each equity model is comprised of roughly thirty securities and each client account is uniquely tailored to that particular client as a result of the investment decisions the Portfolio Manager makes. The client’s account(s) is managed on the basis of the client’s financial situation and investment objectives. Different clients whose accounts are managed using the same portfolio strategy may not be invested in all of the securities included in the underlying model and different clients whose accounts are managed using the same portfolio strategy may not be invested in exactly the same securities. Clients are advised to promptly notify Donaldson Capital Management if there are ever any changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon the Firm’s management services. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. Client Assets Managed by Donaldson Capital Management As of December 31, 2023, Donaldson Capital Management managed a total of $ 2,677,442,196. The entire amount is managed on a discretionary basis.