Windward Capital Management Company (“Windward”) is a wholly owned subsidiary of Windward Capital Group, Inc. (“WCG”), and an affiliate of S.L. Reed & Company (SLR), a FINRA registered broker/dealer. WCG is a wholly owned subsidiary of Windward Group Holding Co. LLC. Windward was incorporated on October 10, 1995, and has been in operation since January 1996. The sole business of Windward is to provide fee-based investment supervisory services to all of its clients. Investment advisory fees are calculated as a percentage of assets under management. All clients’ portfolios are managed on a discretionary basis, and Windward offers equity, balanced, options, and fixed income management services. Windward offers advice on the following: equity securities, including exchange-listed securities, securities traded over-the-counter and convertible bonds; foreign issues; warrants; corporate debt securities (other than commercial paper); commercial paper; certificates of deposit; municipal securities; investment company securities, including mutual fund shares; United States government securities; and option contracts on securities. Windward does specific analysis of each client’s individual investment experience, sophistication, and needs to determine which investment strategy would be in the client’s best interest. If desired, clients may also impose restrictions on investment, including requesting to have equities selected that reflect a social or environmentally sensitive investment strategy. The primary product offered by Windward is called “Risk Averse Asset Management,” referred to as RAAM. RAAM is available to clients as an all-equity product, or as part of a balanced account containing stocks and bonds. In the world of investment management, there are a number of different investment styles that can be employed in the management of a client’s portfolio. The two most common styles are Growth and Value, and many investment managers adhere strictly to one or the other of these styles in the belief that one is superior to the other. We disagree with this approach. Historic performance comparisons between growth and value stocks tend to suggest that neither style, if used to the exclusion of the other, is more likely to produce better performance results. For this reason, Windward’s Risk Averse Asset Management (RAAM) portfolios are often constructed using both growth and value securities. In addition to RAAM, Windward also offers other investment strategies: Capital Appreciation (CapApp): Our Capital Appreciation (CapApp) strategy is a Large Cap Growth strategy focusing primarily on the growth characteristics of the companies within our economic and sector themes. The portfolios nonetheless are constructed to mitigate risk and experience less volatility than a traditional Growth portfolio, while achieving superior results. Equity Income: This strategy is designed for clients who are seeking moderate income with the potential for moderate growth. Dividend paying equities, exchange traded funds (ETFs), Master Limited Partnerships (MLPs) and fixed income securities are used with differing asset allocations, depending on a number of economic factors. Equities, however, will normally be over-weighted in the portfolio. Balanced Growth: Many investors do not feel that they can accept the risk of an all-equity portfolio. Windward offers the Balanced Growth strategy to address this issue by incorporating the potential added stability of bonds to the portfolio RAAM or CapApp equity portfolio. While the size of the

bond allocation can be tailored for the client’s individual investment goal, a 30% to 35% allocation to fixed income securities, including Fixed Income ETF’s is quite common among our clients. Balanced Income: With a typical asset allocation with 65% fixed income and only 35% equities, the Balanced Income accounts are among the most conservative that Windward manages. Many clients with a need for high current income (combined with an opportunity to offset inflation) have found these accounts offer the potential income they need, even as they seek to protect their consumer buying power from inflation. Again, the size and characteristics of the fixed income securities, including fixed income ETF’s used can be tailored to fit the individual client. Balanced Equity Income: clients who want a balanced strategy, but prefer not to incorporate growth stocks, may choose this strategy which combines features from two of the above strategies. Fixed income securities as used in the Balanced strategies are combined with dividend producing equities used in the Equity Income strategy. Fixed Income: In addition to the above balanced strategies, clients may choose to have a portfolio constructed entirely of fixed income products. Generally, our fixed income philosophy centers on our belief that bonds with intermediate maturities can capture the majority of the yield available from bonds with long maturities. By dollar-weighting our fixed income investments to reflect this belief, we feel that we are better able to control both interest rate and credit risk. Technical analysis may also be used to fine tune exit or entry points for each investment. The Windward fixed income process incorporates client objectives, tax considerations, investment alternatives, average maturity and duration targets. Windward generally purchases fixed income securities with a 10-year maximum maturity, and prefers a 5-year average maturity for the fixed income portion of these portfolios. Windward does not normally use the strategy known as “laddering” wherein specific bonds are bought so that each will mature at a different date in the future. Unless directed by the client, Windward may use high yield bonds in the fixed income portion of a client portfolio. Such bonds generally carry a Standard & Poor’s rating of BB, which is one grade or more below what most investors and rating agencies consider “investment grade” and, therefore, carry a greater risk that the issuer will not be able to meet the interest payment obligation. Focus: Windward offers a concentrated equity investment strategy called Focus. The investment objective of this strategy is to achieve long-term capital appreciation by investing in the equities of a limited number of companies with enhanced growth potential, typically in the stocks of 10 companies. As a result of this focus on a smaller number of companies, industries, and/or economic sectors, the portfolio may be volatile and/or experience high turnover. Windward acts as sub-advisor on certain wrap fee program accounts introduced to Windward by outside broker/dealers, for which Windward receives a management fee as a percentage of portfolio assets. In all such cases, all trades are conducted at the custodial brokerage firms; in all other ways, wrap-fee accounts are managed in the same manner as other accounts with the same strategy. As of December 31, 2023, Windward managed $1,184,914,609.44 of client assets on a discretionary basis. Windward does not hold assets under management on a non-discretionary basis.