Our Advisory Business USI Advisors is registered as an investment advisor with the United States Securities and Exchange Commission, and has been in business since 1994. The Firm is an employee benefits service provider, pension consultant, third-party administrator/record keeper and licensed insurance agency. Assets considered to be under USI Advisors management are categorized as discretionary or non- discretionary. Discretionary assets are associated with a plan sponsor client for which the client has provided authorization to the Firm to select and monitor the investment lineup without pre- authorization, including each change to the lineup or subsequent transaction. Accounts established as non-discretionary require that the plan sponsor client make the final decision regarding the investment lineup, changes to the lineup and all required transactions – the Firm will assist in placing all requested securities transactions, but will not act unilaterally to make changes without the direction and consent of the non-discretionary client. As of December 31, 2023 the client assets under management for the Firm were as follows:
• Discretionary Assets Under Management = $1,176,137,305
• Non-discretionary Assets Under Management = $40,441,924,072
• Total Assets Under Advisement = $41,618,061,377 USI Advisors is a wholly-owned subsidiary of USIC Investment Group, Inc. (“USIC IG”). USIC IG is controlled through ownership of all voting shares by USIR Management LLC, an entity owned and controlled by certain executive officers of USI, Inc. USI Inc. is a Delaware corporation engaged, through multiple subsidiaries, in a range of insurance brokerage, group benefits, and consulting businesses. USIA offers the following investment advisory services to clients (Note - the term “client” typically represents an institutional investor or retirement plan): I. INVESTMENT SUPERVISORY SERVICES USIA provides Investment Supervisory Services to clients on either a discretionary or a non-discretionary basis. Discretionary services are associated with; 1) plan-level advice, such as a plan sponsor client which has provided authorization for the Firm to select and monitor the investment lineup without pre- authorization, including each change to the lineup or subsequent transaction, and 2) discretionary model portfolio advice, where the Firm will create and designate Model Portfolios as specific investments to be offered as investment options under the Plan. Accounts established as non- discretionary require that the plan sponsor client make the final decision regarding the investment lineup, changes to the lineup and all required transactions - USIA will assist in placing all requested securities transactions, but will not act unilaterally to make changes without the direction and consent of the non-discretionary client. USIA’s Investment Supervisory Services are provided on an on-going basis. II. INVESTMENT ADVISORY CONSULTATION SERVICES USIA will generally provide Investment Advisory Consultation Services to clients on a short-term or point-in-time project basis (although “Ongoing Performance Evaluation and Monitoring” may be done on a long-term basis). Any recommendation(s) made to the client, as to the advisability of purchasing/holding/selling an investment, are made on a non-discretionary basis (i.e., the client will make the final decision regarding all transactions). Additionally, the client will be responsible for implementing all transactions. Investment Services The Supervisory and Consultation services include some or all of the following, depending upon the needs of the client and the elections made by the client when executing an Investment Advisory Agreement: a. Investment Policy Statement - USIA consults with the client in order to assist in the development of an Investment Policy Statement. This process involves the review of current assets, future funding levels, future cash needs, investment expectations, risk tolerance, financial goals, etc. This enables USIA to help outline the appropriate investment guidelines and assists in defining the criteria upon which USIA will base suitable account investment recommendations. b. Asset Allocation - USIA develops an investment profile for the client and implements 3(38) discretionary or recommends a 3(21) non-discretionary asset allocation model based upon the profile. USIA periodically monitors the appropriateness of the asset allocation model relative to the client’s current assets, investment expectations, risk tolerance, financial goals, and various environmental factors. For defined benefit pension plans, OPEB plans, foundations, and endowments periodic rebalancing of the client account will be performed if elected by the client. c. Manager Search - USIA performs due diligence on multiple money managers prior to implementing/recommending a manager or managers to manage assets for the client. This process involves the use of both proprietary and third-party databases and software, supplemented by data provided by various third parties, to perform qualitative as well as quantitative analysis of the prospective money managers. On-site visits and conference calls with money managers may also be conducted. d. Initial Investment and Management Selection - USIA typically uses mutual funds (both index and managed)/variable annuity products/managed accounts/subaccounts/GICs/collective trusts/cash equivalents to structure portfolios designed to meet client objectives and risk profiles. USIA performs due diligence on multiple money managers prior to implementing/recommending any investment(s). This process involves the use of both proprietary and third-party databases and software, supplemented by data provided by various third parties, to perform qualitative as well as quantitative analysis of prospective money managers. On-site visits and conference calls with money managers may also be conducted. e. Ongoing Performance Evaluation and Monitoring - USIA will periodically monitor existing portfolios and/or money managers, evaluate them relative to the client’s goals and various environmental factors, and make, or recommend, changes when deemed necessary. USIA will also furnish quarterly, semi-annual, and/or annual performance reports to the client. These reports are intended to inform clients as to the performance of their investments for the selected period. This process involves the use of both proprietary and third-party databases and software in order to obtain specific plan information such as transactional history, market values, and investment/benchmarking statistics. f. Investment Vehicles - USIA typically uses mutual funds, managed accounts, subaccounts, GICs, collective trusts, US Treasuries, and cash equivalents to structure portfolios designed to meet client objectives and risk profiles. USIA performs due diligence on multiple money managers and investment vehicles prior to implementing/recommending any investment(s). This process involves the use of both proprietary and third-party databases and software, supplemented by data provided by various third parties, to perform qualitative as well as quantitative analysis of the prospective money managers and/or investments. On-site visits with money managers may also be conducted. g. Investment Program Review - USIA provides a written analysis of existing investments, portfolios, and/or money managers as they relate to the needs of the client. The process includes the verification and evaluation of investment objectives and client expectations. It also includes an assessment of the number of investments and the type of managers represented in each asset class, as well as identification of asset classes that are over or underrepresented within the existing program. The investment analysis addresses various issues, such as - risk vs. potential reward characteristics, style consistency, correlation of investments within the portfolio, management stability, relative performance with peers and benchmarks, and overall suitability in relation to the client’s stated needs and goals. Recommendations for changes may be made when deemed necessary. h. Defined Benefit Plan Asset Liability Analysis - USIA will utilize an asset/liability study (incorporating such factors as cash flow, cost, investment risk vs. return, asset allocation strategy, etc.) to help the client arrive at an individualized strategy for the funding of and selection

of investments for their defined benefit pension plan. i. Retirement Plan Services Analysis - USIA will conduct an analysis of a client’s retirement plan to evaluate the services currently provided to the client by third parties. After identifying and confirming the project objectives and service standards, the areas of analysis may include asset management services, record keeping, administration, customer service, participant education, etc. These services may also include a cost/benefit analysis, recommendation of alternative vendors, facilitation of the RFP process for solicitation of a new vendor, and/or assistance in fee negotiations with proposed vendors. III. PLAN CONSULTING SERVICES In certain instances, the Defined Contribution Consulting Group (“DCCG”) division of USI Consulting Group, Inc. (“USI Consulting Group”) will offer a suite of pension related services that include non- investment services primarily related to plan administration (i.e., Plan Consulting Services). The fees and nature of the services to be provided are negotiated on a case-by-case basis. Although the business objective of the DCCG is to provide both Investment and Plan Consulting services, it is possible that the DCCG will only be engaged to provide Plan Consulting Services. All arrangements will be documented through an Investment Advisory Agreement and non-investment-related consulting agreements, as applicable, and services may be provided on a one-time basis or ongoing. These services include some or all of the following, depending upon the needs of the client and their elections made in writing when executing the Investment Advisory Agreement: a. Plan Management Services – DCCG will assign a dedicated account manager who will support the client and provide information and guidance on issues related to overall plan management and administration of the plan. The account manager will review annually the priorities and goals of the plan and will serve as the liaison between the service provider and the client. b. Regulatory and Compliance Services - DCCG will provide information and guidance related to regulatory compliance with ERISA, the Internal Revenue Code, relevant regulations, and other guidance pertaining to industry trends. c. Fiduciary Training Consulting Services – DCCG will provide a fiduciary education training session with the Plan Fiduciaries to explain ERISA’s fiduciary responsibility provisions and discuss common misconceptions, industry trends and best practices. DCCG will also provide Fiduciary Process and Governance Training, which will include conducting a discovery session consisting of interviews with relevant personnel and a document request to learn about the current procedures in order to identify gaps and recommend action steps to address those gaps. DCCG will also work with the client to develop and implement a “fiduciary structure” with appropriate documentation and will also provide tools to help the client follow established processes and maintain consistency in carrying out fiduciary responsibilities. d. Plan Operations and Document Review Services – DCCG will review the plan document to determine whether it is in compliance with recent regulations and will also evaluate if the fiduciaries have been operating the plan according to the provisions stipulated in the plan document. e. Plan Design Consulting Services – DCCG will provide plan feasibility studies which will include information about the different plan design options and the calculation of projected contributions for different plan design options (i.e., employer matching or non-elective contributions.) f. Employee Communication, Education and Advice Services - DCCG will review and assess the plan’s current communication and education program and review the service provider engaged to conduct the investment education and enrollment services. DCCG can also prepare a custom education strategy as well as customized material and conduct general investment education and enrollment seminars for employees of the client. If the client elects to have DCCG provide enrollment and educational services, the content of the program will be generic in nature and will not contain participant level investment advice or recommendations to invest in a particular security. The Firm may provide, upon request, enrolled participants of certain legacy clients advice on their retirement plan assets if contractually obligated. g. Retirement Plan Provider Search and Periodic Review - DCCG will initially undertake analysis of the current plan, develop criteria used in selecting a plan service provider, assist in the search and selection of a plan service provider and assist with the transition and conversion to the new plan service provider. h. Fee Benchmarking Services – DCCG will provide a benchmarking of the plan’s fees being paid by the plan sponsor and the participant by comparing it to other similar plans across the country and/or within DCCG’s client base in order to determine whether they are fair and competitive i. Merger & Acquisition Support – DCCG will Review the current retirement plan of a target company being considered for acquisition with respect to plan documents, non-discrimination testing, 5500 filings, employer contribution costs, plan fees and investment related expenses. DCCG will provide recommendations regarding post-closing integration including coordination regarding the transition and communications to the plan’s recordkeeper. In addition, DCCG will provide assistance negotiating recordkeeping and investment fund fees in order to provide favorable plan and participant- level pricing and maintain the same or similar level of plan sponsor and participant- level services. Pension Consultant Referral Service When USI Advisors services are not appropriate for a client, or upon client request, USI Advisors may provide the client with a referral to another Pension Consultant, based on a client’s individual circumstances and needs. USI Advisors is not compensated directly or indirectly by the referred firm for providing this service to our client. Related Information USIA, including its agents and employees, will provide investment advisory services on either a discretionary or a non-discretionary basis. Discretionary services are associated with; 1) plan-level advice, such as a plan sponsor client which has provided authorization for the Firm to select and monitor the investment lineup without pre-authorization, including each change to the lineup or subsequent transaction, and/or 2) discretionary model portfolio advice, where the Firm will create and designate Model Portfolios as specific investments to be offered as investment options under the Plan. Accounts established as non-discretionary require that the plan sponsor client make the final decision regarding the investments. USIA will not act to make changes or execute transactions without the written consent of the non-discretionary client. The non-discretionary client at all times shall elect unilaterally to follow or ignore completely or in part any information, recommendation, and/or counsel given by USIA. USIA may provide both the above services mentioned to plan sponsors, financial institutions, and individuals with respect to various types of retirement plans. In this capacity, USIA acts as a pension consultant, as defined, pursuant to Rule 203A-2(b) of the Investment Advisers Act of 1940. USIA, in its efforts to assist the client in areas applicable to the needs of the client, may suggest that a client review the services of particular trust companies (e.g., for the purpose of serving as a directed trustee and/or payment agent). USIA’s suggestion to consider any party in this regard is merely to provide the client with a starting point in their selection process and does not represent any form of endorsement, recommendation, or advice. Dependent upon client retirement plan specifics, certain 3(38)/discretionary services may only be available through USIA from a limited number of trust companies. It is a fiduciary duty and responsibility of the client to properly investigate and interview qualified candidates prior to making any decision to appoint a party to serve as a directed trustee and/or paying agent for their employer sponsored retirement plan. The client expressly retains the responsibility and authority for both the selection and contracting of any party in this regard.