Clifford Swan Investment Counselors provides investment supervisory services and manages investment advisory accounts on behalf of clients within the greater context of our clients’ wealth management needs. Clifford Swan Investment Counselors and its predecessor firms have been in business since 1915. The firm is wholly owned by its employees. Clifford Swan provides both investment supervisory services and the management of investment advisory accounts as continuous investment counseling services. Investment advisory agreements for these services continue indefinitely but are subject to cancellation at any time by either party. Typically provided to clients who are in need of advice on an ongoing basis, investment counseling services include advice on structuring clients' portfolios given their unique objectives (return requirements and risk tolerance) and circumstances (time horizons, liquidity needs, and tax and legal considerations). Our firm keeps a record of our clients’ investment holdings, and places transactions for clients’ portfolios. Our clients also have the privilege of conferring with us on any financial subject whenever they feel our judgment would be of assistance, including financial planning services such as reviewing retirement cash flow, intergenerational wealth transfer, insurance needs, tax planning, funding college education, and philanthropy. We also publish an educational newsletter for our clients and other interested parties, with general advice about investing, market commentary, and other financial matters. From time to time, at our discretion, we accept an assignment to be performed on other than a continuous basis. Our services are available on a discrete assignment basis to review investment portfolios and make recommendations thereon as we deem advisable. Our responsibility ends when the results of the review are presented to the client. Although we are available to support and coordinate action by the client on these recommendations, implementation of the appropriate financial strategies is performed by the client and is entirely at the client's discretion. Clifford Swan provides

investment counseling and/or administrative services to charitable institutions and individuals for specialized deferred gifts (e.g., charitable remainder trusts, gift annuity funds, and pooled income funds). These administrative services include effecting periodic benefit distributions, tax reporting, management reporting and other ancillary requirements designed to provide a full-service arrangement. All our advisory services are offered in the context of the client’s unique circumstances, and tailored to address target returns, income needs, tax concerns, risk tolerances, etc., as described above. We generally work with our clients to establish broad policy guidelines for investments, suitable or unsuitable, for their portfolios. Any limitations on discretionary authority are discussed with clients and documented in our client files and/or databases. Both discretionary and non-discretionary clients can impose restrictions on investing in certain securities or types of securities or indicate that a particular held security is not to be sold. Some of our clients have limited our discretionary authority on purchases by specifying certain companies or industries in which we may not invest their funds. Other clients have specified a maximum percentage of their total portfolio to be invested in any one company, security type, industry or asset class. In some cases, it has been the client’s expectation that purchases or sales of securities will be discussed with the client prior to placing the trade, even though Clifford Swan has been granted investment discretion and trading authorization. Wherever practical, trades for these clients will be aggregated with fully discretionary trades to obtain more favorable execution. However, it is possible that trades for these clients will be executed separately from trades for other purely discretionary clients, which could result in the trades being completed at a higher or lower price from other accounts. Assets Under Management as of 12/31/2023 $3.33 Billion Discretionary Basis $519 Million Non-Discretionary Basis $3.85 Billion Total Assets Under Management