A. Description of the Advisory Firm Pacific Asset Management (hereinafter “PAM”) is a Limited Liability Company organized in the State of Washington. The firm was formed in November 1998, and the principal owners are Joshua A. Morin, Donald F. Cox and Brian W. Cox. B. Types of Advisory Services Portfolio Management Services PAM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. PAM creates an Investment Policy Statement for each client, which outlines the client’s current situation (which may include income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring PAM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. PAM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. PAM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of PAM’s economic, investment or other financial interests. To meet its fiduciary obligations, PAM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, PAM ’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is PAM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Pension Consulting Services PAM provide pension consulting services to employer plan sponsors in the capacity of a 3(21) and 3(38) advisor. Generally, such pension consulting services consist of assisting employer plan sponsors in establishing, selection and/or monitoring of investment alternatives (generally open-end mutual funds) and reviewing their company’s participant-directed retirement plan. To the extent requested by the plan sponsor, PAM may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and the conditions of the engagement shall generally be set forth in the advisory agreement between the plan sponsor and PAM. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments PAM generally limits its investment advice

to mutual funds, fixed income securities, equities and ETFs, although PAM primarily recommends asset class investing via mutual funds and ETFs. PAM may use other securities as well to help diversify a portfolio when applicable. Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If PAM recommends that a client roll over their retirement plan assets into an account to be managed by the PAM, such a recommendation creates a conflict of interest if PAM will earn an advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by PAM. Portfolio Activity PAM has a fiduciary duty to provide services consistent with our client’s best interest. As part of its investment advisory services, PAM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when PAM determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. C. Client Tailored Services and Client Imposed Restrictions PAM will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by PAM on behalf of the client. PAM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent PAM from properly servicing the client account, or if the restrictions would require PAM to deviate from its standard suite of services, PAM reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. PAM does not participate in wrap fee programs. E. Assets Under Management PAM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 236,200,000.00 $0.00 December 31, 2022