Johnson+Sterling, Inc. (JS) is an independent, fee-based investment adviser. Founded in 1976, JS serves clients throughout the United States. JS offers both discretionary and nondiscretionary investment advisory and management services. JS provides investment advice and pension consulting to persons or entities with various types of investment accounts, including, but not limited to, taxable, tax-deferred, tax- exempt, IRA and investment-only retirement accounts. JS consists of two divisions: (1) Johnson Sterling Asset Management, which provides investment advisory services to individuals, institutions, and entities other than Retirement Plan Sponsors and Participants; and (2) Johnson Sterling Retirement Services, which provides investment advice and fiduciary advisory services to Retirement Plans for both Plan Sponsor (employer) and Plan Participant (employee) levels. Plan Sponsors are employer entities that sponsor a Retirement Plan for the benefit of their employees. Plan Participants are employees who participate in an employer-sponsored Retirement Plan. JS primarily provides Investment advice related to investing in shares of U.S registered open-end investment companies (“mutual funds”) and advice concerning other U.S registered investment advisers who manage or provide advice about various classes of assets, including mutual funds, for investors. JS offers investment advice in three different service categories: - Discretionary Portfolio Advice (Advice and Portfolio Management) - Nondiscretionary Advisory Service (Periodic Point-in-Time Advice) - Investment Consultation Service (Single Point-in-Time Consultation) With Discretionary Portfolio Service, JS is authorized to exercise its discretion in the management of the client’s investment portfolio, and to act on behalf of the client for any action in the account, in accordance with the portfolio’s investment strategy and the client’s financial profile and objectives. Certain discretionary clients may be enrolled in a service known as 55ip, which is a registered investment advisor not affiliated with JS. 55ip provides advisory services pursuant to each Client’s investment advisory agreement, sub-advisory agreement, or trade list delivery services agreement with 55ip or its affiliates (each, an “Agreement”). 55ip provides an online investment strategy engine (“the “55ip Services Portal”) where JS can access model portfolios and select tax management services. JS directs 55ip to utilize one or more model portfolios comprised of mutual funds, exchange traded funds (“ETFs”), and/or stocks (“Models”) pursuant to their specifications. 55ip does not create the Models; instead, the Models are provided by JS. 55ip's services are offered through the use of 55ip's proprietary technology which incorporates a tax management technique referred to as "tax loss harvesting" that is primarily used in the following ways: "Tax-Smart Transitioning", "Ongoing Tax Management", and "Tax-Smart Withdrawals". 55ip's services also include ongoing trading and rebalancing services, which generally accommodate cash management, periodic rebalancing and investment changes at a frequency agreed upon by 55ip and the Client. Client- provided Models are assessed for rebalancing typically on

a semi-annual basis. Notwithstanding the rebalancing frequency, other trades may occur in accounts outside of the rebalancing frequency related to tax loss harvesting or to accommodate cash management withdrawal/deposits. 55ip is engaged to provide non-discretionary trade list delivery services, 55ip provides buy and sell recommendations to JS at the individual account level, pursuant to a Trade List Delivery Services Agreement. JS then chooses when and whether to execute such trades in their underlying investors’ accounts. 55ip does not maintain a direct relationship with, nor serve as an investment adviser to any underlying investor of JS. With Non-Discretionary Advisory Service, JS only provides the client periodic, point-in-time investment advice, JS is not authorized to act at its discretion on behalf of the client, and JS is not responsible for taking any action in the portfolio on behalf of the client. The Investment Consultation Service is a nondiscretionary, single point-in-time service, which assists clients seeking specific information on a one-time basis. JS is not authorized to act at its discretion on behalf of the client. JS is registered with the Securities and Exchange Commission as an Investment Advisory and Pension Consultancy. (Please be advised that registration does not imply a certain level of skill or training). The principal owners of JS are Samuel Paul Johnson and Elizabeth Lee Rutherford. JS primarily provides investment supervisory services, and JS also manages a small number of investment advisory accounts that do not include investment supervisory services. JS provides a range of specialized, research-driven, risk managed investment advisory and financial consulting services to both individual and institutional clients. These services include: investment advisory and portfolio management services, retirement plan consulting, fiduciary planning services, employee benefits consulting, and retirement transition services. JS’s investment process follows five basic steps, designed to build a diversified portfolio to meet our clients’ long-term goals. These steps are to: - Accurately assess the client’s financial profile and help develop appropriate objectives - Develop a financial/investment strategy tailored to the client’s needs - Implement the strategy - Monitor the strategy with regular reviews - Provide ongoing personal attention to the client and the client’s financial objectives. JS also works with institutional clients nationwide to optimize their benefits planning and retirement plan management systems. JS’s goal is to provide the following to retirement plan sponsor clients: - Fiduciary compliance and administrative services - A wide range of investment options for the plan sponsor to offer participants - Record keeping and plan administration assistance - Participant retirement planning guidance and information - Coordination of participants’ retirement plan and non-retirement plan investment portfolio. JS tailors advisory services to the individual needs of clients, and clients may impose restrictions on investing in certain types of securities. As of December 31, 2023, JS manages $480,800,000 in discretionary client assets and $2,503,900,000 in nondiscretionary assets.