NLG Capital, Inc., f/k/a Sentinel Asset Management, Inc. (“NLG Capital”) is an investment adviser registered with the SEC and has been in business since 1968. NLG Capital is wholly- owned by NLV Financial Corporation, which is a wholly-owned subsidiary of National Life Holding Company. National Life Holding Company is a Vermont mutual insurance holding company, meaning that it is owned by policyholders of National Life Insurance Company. NLG Capital offers discretionary investment advisory services to various types of affiliated institutional clients, focusing on fixed income investments. Although NLG Capital predominantly offers fixed income investment advice to its clients, NLG Capital also may provide advice to clients on issues related to other types of investments or strategies as necessary during the course of NLG Capital’s engagement with a client (e.g., NLG Capital may provide investment advice to a client on issues relating to other types of assets that the client may already own). NLG Capital generally does not offer non-discretionary investment advisory services to clients. NLG Capital is not actively seeking new clients. NLG Capital’s fixed income strategies incorporate sector allocation and security selection decisions to meet the income and capital preservation goals of the client. Based on an analysis of current market conditions and future expectations, NLG Capital allocates to the fixed income sectors, maturities, and securities it believes offer the best relative value and balance between return and risk control within a particular strategy. In conjunction with establishing top-down asset allocation, yield curve and duration positioning, the investment team applies disciplined fundamental analysis to security selection. More information regarding NLG Capital’s fixed income investment strategies, methods of analysis

and the risks associated with investments in any of these strategies is provided under the heading “Methods of Analysis, Investment Strategies and Risk of Loss” below. As part of its fixed income investment strategies, NLG Capital also invests in commercial mortgage loans, middle market loans, residential mortgage loans, and private credit (funds and direct investments). NLG Capital invests in private equity (funds and direct investments) and in equity securities on behalf of an affiliated charitable portfolio; however, no equity strategies are offered beyond this affiliate. NLG Capital offers tailored fixed income investment advisory services to clients and may offer other strategies to its clients in the future. Clients may impose restrictions on investing in certain securities or types of securities, most of which will be honored unless it is not feasible for NLG Capital to incorporate a requested restriction into the management of a client’s account, in which case the client will be notified of such an issue. NLG Capital consults with each of its clients initially and on an ongoing basis to ascertain and discuss the client’s investment objectives and any restrictions that the client may request. Client portfolios are monitored on an ongoing basis to ensure that any restrictions on a client’s portfolio are maintained. As of December 31, 2023, NLG Capital manages approximately $35 billion in client assets on a discretionary basis and does not manage any client assets on a non-discretionary basis. Individuals associated with NLG Capital may also have officer roles with its affiliated insurance company entities. Such personnel are subject to the NLG Capital’s compliance policies and procedures when acting on behalf of NLG Capital, and additionally, subject to the policies and procedures of the affiliate when acting on behalf of that affiliate.