A. Describe your advisory firm, including how long it has been in business. Identify your principal owner(s). Founded in 1962, Guardian is an independent, institutional investment firm. Guardian is a subsidiary of Guardian Capital Group Limited, one of Canada's largest and most established independent publicly listed financial services companies. Guardian offers equity and fixed-income management services primarily to institutions including defined benefit and defined contribution pension funds, insurance companies, foundations, endowments, charitable organizations, and mutual funds. Guardian is registered as a Portfolio Manager in all provinces of Canada and is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). B. Describe the types of advisory services the firm offers. If the firm holds itself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis or market timing, explain the nature of that service in detail. If the firm provides investment advice only with respect to limited types of investments, explain the type of investment advice firm offers and disclose that the advice is limited to those types of investments. Advisory Services – General Guardian provides fee-based investment supervisory services to investment funds (pooled funds and mutual funds), pension and profit sharing plans, charitable organizations, and other Canadian institutional investors. Guardian offers similar services to U.S.-based clients. Guardian mainly uses exchange-listed securities, securities traded over-the-counter, foreign securities, warrants, corporate debt securities, commercial paper, municipal securities, mutual funds, exchange traded funds, U.S. government securities, options contracts on securities, futures contracts on intangibles, interests in partnerships investing in real estate and oil & gas interests to accomplish client objectives. Guardian offers balanced mandates, specialty Canadian equity, fixed-income expertise, and investment management for U.S., international and global mandates. Quantitative Analysis – Systematic Strategies In selecting securities, Guardian’s systematic strategies team utilizes a process that primarily relies on bottom-up analysis and seeks to identify companies that have the potential for dividend growth, sustainable income, and capital appreciation over time. The process uses a combination of relative, intrinsic and artificial intelligence models to rank companies within each economic sector. The relative analysis uses multiple factors including earnings growth, dividend growth, value, yield, momentum and quality. This intrinsic analysis projects future cash flow growth and uses customized discount rates to arrive at an intrinsic valuation target. The artificial intelligence component forecasts expected dividend growth rates and also the probability of a dividend cut. A team of portfolio managers then constructs the portfolio based upon the above stock selection process and concurrent assessment of the macro environment and portfolio risk constraints. The combination of a systematic stock selection process and a team refined portfolio construction process results in a diversified portfolio of dividend-paying equity securities that seeks to provide above average yield and dividend growth. Participating Affiliate In providing services to clients, Guardian may rely on the resources of a non-U.S. affiliate that supplies services pursuant to a participating affiliate arrangement (“Participating Affiliate”). This arrangement is further discussed under “Other Financial Industry Activities and Affiliations.” C. Explain whether (and, if so, how) the firm tailors advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. Separate Accounts: Guardian relies on a model portfolio to tailor its advisory services to a client’s individual needs. Our disciplined approach brings consistency in the development of the model portfolios. The clients’ stated policy and objectives are the primary guide for portfolio construction of constrained accounts. We monitor the implementation at different levels such as through our portfolio accounting team and through our compliance officers. Every client works directly with a dedicated client service executive. Clients may impose certain restrictions on investing in certain securities or types of securities. Those restrictions are normally outlined in writing within the client agreement. Investments in mutual funds sponsored by Guardian are managed in accordance with the respective mutual fund’s investment objectives,

strategies and restrictions as set forth in the prospectus and are not tailored to the individualized needs of any particular shareholder in the mutual fund. Therefore mutual fund shareholders should consider whether the mutual fund meets their investment objectives and risk tolerance prior to investing. U.S. Private Funds: Within a sponsored private fund vehicle, Guardian tailors its advisory services to the specific investment objectives and restrictions of each fund pursuant to the investment guidelines and restrictions set forth in each fund’s governing documents. Investment strategies and guidelines are not tailored to the individualized needs of any particular investor in a fund. Once invested in a fund, an investor cannot impose restrictions on the types of securities in which such fund may invest. Investors in a fund participate in the overall investment program for the relevant fund, but in certain circumstances may be excused from a particular investment due to legal, regulatory, or other agreed- upon circumstances pursuant to the governing documents; provided that such arrangements generally do not and will not create an adviser-client relationship between Guardian and any investor. A fund or the general partner may enter into a side letter with a particular fund investor in connection with its admission to a fund, which would have the effect of establishing rights under, altering, or supplementing the terms of, or confirming the interpretation of an applicable fund document with respect to such investor in a manner more favorable to such investor than those applicable to other fund investors. Under no such arrangement will Guardian abrogate its fiduciary duty to disclose and responsibly manage all known current and emergent conflicts of interest. D. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Guardian serves as an investment manager of wrap fee programs sponsored by third party wrap program sponsors (e.g. broker-dealers). A wrap fee program is a program where a client is charged a specified “bundled” fee (generally, a percentage of assets under management) for discretionary investment management services and trade execution costs and sometimes other services such as custody, recordkeeping and reporting. Sponsors pay us an investment management fee from a portion of the total wrap fee charged to the wrap program sponsor’s clients. We manage these accounts using strategy model portfolios (similarly to how we manage other separate accounts), but we generally accept fewer client-imposed investment restrictions for these accounts, and the accounts may be constrained to not include certain types of investments, such as IPOs, that would normally be available to institutional clients. Because we typically execute wrap account trades through each respective wrap program sponsor, these accounts usually are included in the second tier of our trade rotation process, as described more fully in Item 12. Guardian also provides model portfolios to certain wrap fee program sponsors (or their overlay managers) for unified managed accounts (“UMAs”). Each program sponsor (or overlay manager) retains investment discretion over the UMAs and may accept or reject our recommendations. The program sponsor also is responsible for effecting trades resulting from our recommendations. Guardian has no investment discretion over the program sponsor’s UMAs and has no specific knowledge of the program sponsor’s clients or their circumstances. As a model provider, we receive a negotiated fee from each program sponsor to which we provide model portfolios. As further described in Item 12, we provide our model portfolios during the third tier of our trade rotation process. Our compensation under a wrap program may be lower than our standard fee schedule; however, the overall cost of a wrap arrangement may be higher than a client otherwise would pay if the client paid our standard fee schedule and negotiated transaction costs through a broker-dealer outside the wrap arrangement. E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2022, Guardian’s Regulatory Assets Under Management totaled U.S. $11,646,070,728, all on a discretionary basis. In addition, Guardian has assets under administration or Unified Managed Account (“UMA”) program assets of U.S. $5,264,232,652.