Firm Description Our Firm, Agincourt Capital Management, LLC, was founded in 1999 by the entire fixed income investment team of what was Sovran Capital Management. We are an investment adviser registered under the Investment Advisers Act of 1940. On August 14, 2020, Agincourt entered into an agreement whereby Guardian Capital Group Limited (TSX: GCG) acquired a significant majority interest in Agincourt. The transaction closed on October 1, 2020. One of the previous shareholders sold his stake upon deal closing; the remaining 30% stake is held by all previous owners including all members of the current Management Team. Agincourt manages over $8 billion in institutional fixed income (bond) assets. Portfolios are managed on a team basis. The members of the Management Team (Patrick Kelly, Duncan Buoyer, and Patrick O’Hara) have worked together for well over 20 years. The Investment Team consists of the Management Team, the Corporate/Credit Markets Team, the MBS/Structured Portfolio Team, and the Portfolio Analytics and Trading Team. We provide customized fixed income investment advisory services to pension and profit-sharing plans, state or municipal government entities, charitable organizations, corporations or business entities, and insurance companies. We also have a small number of trusts, estates, or individuals as fixed income clients. We do act as a sub-adviser for fixed income commingled and mutual funds. From time to time, Agincourt manages portfolios that include securities other than fixed income to meet the specific needs of individual clients. These assignments would be considered on a case-by-case basis and would be ancillary to Agincourt’s primary fixed income advisory service. The term ‘fixed income’ is interchangeable with the word ‘bond’. Portfolio decisions are made according to the investment objectives sought by the client. We are strictly a fee-only investment management firm; our fees are based on a percentage of assets under management, and in a small number of cases, net outperformance of a predetermined benchmark. We do not charge wrap fees or commissions. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. We will occasionally utilize third-party solicitors and promoters (see “Incoming Referrals”). No commissions in any form are accepted. No finder’s fees are accepted. Additionally, all the firm’s strategies are managed in-house. The firm does not act as a custodian of client assets. The client always maintains asset control, through asset custodians selected by the client. For some clients, on request, we calculate and directly withdraw our management fees from the client’s custodial account. These clients or their designee receive detailed invoices which illustrate the fee and calculation details. The firm does not have custody of client assets or funds outside this practice. Under the Investment Advisers Act of 1940, we owe our clients certain fiduciary duties. Our clients give us discretionary authority to enter into trades in client accounts under a limited power of attorney. Portfolios are reviewed on an ongoing, continuous basis. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be engaged directly by the client on an as-needed basis. If there is a conflict of interest other than types disclosed in this brochure (See “Performance Based Fees”, “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”, and “Brokerage Practices”) it will be disclosed to the client in the unlikely event they should occur. Agincourt has adopted a Code of Ethics which is available to any

client or prospective client upon request by calling (804) 648-1111. Principal Owners Agincourt’s principal owner is Guardian Capital LLC (“Guardian”). Guardian acquired a 70% ownership interest in Agincourt; the transaction closed on October 1, 2020. One of the previous shareholders sold his stake upon deal closing; the remaining 30% stake is held by all previous owners including all members of the current Management Team. Guardian is 100% owned by Guardian Capital LP, which is 100% owned by Guardian Capital Group Limited (TSX: GCG). Guardian Capital Group Limited is a diversified financial services firm founded in 1962 and based in Toronto, Canada. Types of Advisory Services We provide investment advisory services, specializing in taxable fixed income portfolios. From time to time, Agincourt manages portfolios that include securities other than fixed income to meet the specific needs of individual clients. These assignments would be considered on a case-by-case basis and would be ancillary to Agincourt’s primary fixed income advisory services. As of December 31, 2023, we managed $8,988,905,427 in assets for 196 clients and 396 accounts (See “Types of Clients”). We calculate our assets under management under the method required under Item 5.F of Part 1.A. of Form ADV. All assets are managed on a discretionary basis. Tailored Relationships The goals and objectives for each client are documented in our client Investment Management Agreement (or similar agreement), or by subsequent communication from the client to us. Our clients are typically sophisticated or institutional investors and may provide their internally generated investment policy statements that reflect the client’s stated goals and objectives. Our clients may impose restrictions or limitations on investing in certain securities or types of securities. We provide investment advice specifically designed to meet the client’s investment objectives while adhering to the agreed upon investment restrictions. Investment Management Agreement Our clients execute an Investment Management Agreement, which defines our responsibilities and those of our clients. We seek to achieve our clients’ needs and objectives in managing portfolios through security research and portfolio management. A client’s Investment Management Agreement cannot be assigned without the client’s consent. Sub-Advisory Arrangements We have entered into various “sub-advisory” agreements whereby we provide our investment adviser services to other investment advisers for use with their clients. We strive to provide identical services to sub-advised clients and sub-advised client’s objectives and restrictions, and we charge the same or similar fees to our direct and sub-advised clients. The terms, conditions, and fees for our sub-advised client relationships do not differ in a material way from the terms, conditions, and fees for our other clients. Agincourt does not make use of sub-advisers in managing Agincourt client assets – all are managed directly by Agincourt. Termination of Agreement Either party, us or our client, may terminate an Investment Management Agreement by written notice to the other party. Clients can generally terminate upon 5 business days written notice. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed. Refunds are generally not required because compensation is typically paid after services are provided. Certain clients have arranged to prepay their compensation three months in advance. Any prepaid fees that are unearned at the date of termination will be refunded on a pro rata basis to the client.