A. Business Description and Principal Owners 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. We manage equity and fixed-income portfolios for institutions, including 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. Advisory Services Advisory Services – General We manage portfolios for institutional, wrap and model-based clients. The main types of securities we manage include domestic and foreign securities, warrants, corporate debt securities, commercial paper, municipal securities, mutual funds, exchange traded funds, U.S. government securities, options and money market securities. We also manage futures contracts on intangibles, interests in partnerships investing in real estate, and oil & gas interests. Participating Affiliate For certain strategies, we team up with the investment team of our London-based affiliate to manage your portfolio (“Participating Affiliate”). This arrangement is further discussed in Brochure Item 10C. C. Tailored Advisory Services You choose how you want us to manage your investments, either through separately managed accounts, private funds, and/or registered mutual funds. Separate Accounts In a separate account, we follow a model portfolio, although you may provide us with guidelines and restrictions to meet your unique needs. An example would be to avoid certain market sectors or securities. Client guidelines and restrictions are agreed in writing within the Investment Advisory Agreement. Each separate account client works directly with a dedicated client service executive. All client portfolios are monitored by our portfolio accounting and compliance teams. U.S. Private Funds: When we manage our own private funds, we tailor our advisory services to the specific investment objectives and restrictions of each fund pursuant to the investment guidelines and restrictions found in each fund’s governing documents. Private funds are not customized to meet an investor’s individualized needs. Private fund investors have no say in portfolio decisions but may in some cases ask to be excused from a particular investment due to legal or regulatory reasons, as explained in the

fund’s governing documents. A private fund is permitted to sign a side letter with a particular fund investor to grant special rights to the investor which are not granted to other fund investors. We will notify all fund investors of the general categories of side letter terms. Guardian-Sponsored Mutual Funds We manage each Guardian mutual fund in accordance with the fund’s prospectus which explains investment objectives, strategies and restrictions. Mutual funds are not tailored to meet the individualized needs of any particular shareholder. D. Wrap Fee Programs We serve as an investment manager within wrap fee programs sponsored by certain third-party broker- dealers. Wrap account clients pay a single fee, generally a percentage of the account size, which covers investment management fees, trading costs, and other operational fees such as custody, recordkeeping and reporting. The wrap sponsor pays Guardian a portion of the investment management fee it earns. We manage wrap accounts similar to how we manage other separate accounts. However, the wrap sponsor sets the guidelines and restrictions, not the wrap account client. Clients considering a wrap account should ask the wrap sponsor for information about guidelines and restrictions before investing. Please see Brochure Item 12 for more information about how we trade wrap accounts compared to other accounts we manage. We also provide model portfolios to certain wrap fee program sponsors (or their “overlay” managers) for unified managed accounts (“UMAs”). In a UMA account, we share investment recommendations with the program sponsor who decides whether to accept or reject them. The program sponsor executes UMA trades, so Guardian does not know whether our recommendations are accepted, nor do we have any information about the identity of UMA clients. We are paid a fee directly by the program sponsor. Please see Brochure Item 12 for more information about the timing of our investment recommendations to UMA sponsors. The fees we receive from wrap sponsors may be lower than the fees we charge to clients who hire us directly. However, the overall cost to the client of a wrap arrangement may be higher than if the client hired us directly, when considering all the elements of the wrap fee paid to the program sponsor, such as trading, custody, recordkeeping, and reporting costs. E. Regulatory Assets under Management As of December 31, 2023, Guardian’s Regulatory Assets Under Management totaled U.S. $11,647,004,242, all on a discretionary basis. In addition, Guardian had assets under administration of U.S. $5,793,115,704.