Oarsman Capital, Inc. (“OCI”) is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) that provides investment-management services, mutual fund/exchange-traded fund portfolios, separate accounts managed by independent investment managers (“Independent Managers”), financial-planning services and retirement plan advisory services to a variety of retail and institutional clients. OCI began providing advisory services in 2000. Registration does not imply a certain level of skill or training. OCI is majority owned by Robert W. Phelps and Benjamin Kebbekus. OCI does not control any other firm; its only business is providing investment advice. In January 2023, OCI launched LRC Aviation Advisors (“LRC”), a division of OCI. This division has a unique market niche that is focused on airline pilot retirement plans and financial planning. LRC’s target market is airline pilots and their families to provide the knowledge and services specific to the different retirement requirements in the airline industry. The advisory services of OCI are described below. Investment-Management Services OCI provides Investment Management Services to individual, trust and institutional clients seeking to implement long-term investment programs. OCI also serves as a sub-advisor to other investment advisory entities. OCI constructs and manages portfolios for its clients that comprise one or more of the following investment asset classes, among others: common stocks, debt securities (U.S. Treasury, U.S. Government Agency, corporate and municipal), mutual funds, exchange-traded funds/notes, stock options, and cash equivalents. OCI emphasizes the use of securities it believes are of fundamental quality and, in the case of common stocks and stock-based mutual- and exchange-traded funds, offer capital-appreciation potential. Investment programs for taxable individual and trust clients emphasize a long-term perspective, tax- efficient strategies and the control of investment risk. Programs for tax-exempt/-deferred clients seek to achieve risk-adjusted returns superior to an appropriate benchmark over multi-year periods that encompass both ‘bull’ and ‘bear’ market phases. OCI focuses on customized portfolios to meet client needs by analyzing multiple factors, including but not limited to, risk preference, investment horizon, cash flows and tax consequences. Based on discussions of a client's particular circumstances and objectives, OCI establishes goals and objectives. OCI will use proprietary modeling tools or other financial tools to develop a client's personal investment policy and creates and manages a portfolio based on that policy. OCI generally manages advisory accounts on a discretionary basis. This means that after obtaining discretionary authority in writing from a client, OCI will make purchases and sales as it deems necessary. Account supervision is guided by the stated objectives of each client (i.e., maximum capital appreciation, growth, income, or growth and income). Clients are permitted to place reasonable restrictions (e.g. sector, asset class, company specific) on the types of investments which OCI utilizes in their accounts. In identifying potentially attractive common stocks to purchase, OCI favors well established companies that possess, among other desirable attributes, proprietary products and/or services, track records of consistent earnings growth, financial strength, experienced management, and well articulated strategies for future growth. Many, though not all such companies, are global industry leaders with large market capitalizations. OCI also seeks to invest in stocks with reasonable valuations. In assessing valuation, OCI typically analyzes current and historical data regarding a stock’s price/earnings, enterprise value/cash flow, price/sales, and/or price/book ratios. Discounted-cash-flow analysis is also utilized where appropriate. OCI constructs portfolio for its clients with common stock holdings that are broadly diversified among several economic/industry sectors, while at the same time may include strategic concentrations intended to benefit from cyclical and/or longer-term trends. To broaden portfolio holdings to include investments that fall outside OCI’s core-equity discipline, OCI will invest a portion of client assets in equity mutual funds and/or exchange-traded funds/notes whose managers employ an investment approach that differs from that of OCI (e.g., small-company stocks, non-U.S. stocks, high-yield income investments, real-estate- and commodity-related investments, among others). OCI invests client assets in stocks with the intention of holding them for an extended period of time; accordingly, portfolio turnover is expected to be relatively low. A stock is eliminated from a client’s portfolio (sold) if OCI believes the company has lost its fundamental quality or growth potential. A stock position is reduced (trimmed) in a portfolio if OCI believes the stock’s valuation more than adequately reflects the company’s assessed quality and growth potential. Short-term market-timing strategies are generally avoided. However, a major change in OCI’s market outlook can result in a reallocation of assets among security classes (if consistent with client-established guidelines). OCI invests a portion of most clients’ assets in U.S. dollar-denominated debt securities primarily to provide a reliable source of portfolio income and to enhance stability of principal. In most cases, investment-grade notes and bonds are used, and the average maturity of portfolio holdings generally does not exceed 10 years. Tax-exempt (municipal) securities are diversified geographically and corporate debt securities are diversified by industry. OCI generally holds debt securities for an extended period (e.g., maturity) and portfolio turnover is expected to be relatively low. A debt security may be sold if OCI believes there has been a major reduction in the creditworthiness of the issuer, if OCI identifies a security deemed more attractive in terms of yield and/or quality, or if a change in OCI’s interest rate and/or economic forecast necessitates

an adjustment to the portfolio’s asset allocation, average maturity, sector allocation (e.g., government vs. corporate), or industry exposure. Mutual Fund/Exchange-Traded Fund Portfolios For clients whose investment needs or preferences do not call for a fully customized portfolio comprising primarily of individual common stocks and fixed-income securities, OCI offers a program that utilizes model asset-allocation strategies, each targeting a specific investment objective/risk tolerance, and implemented using mutual funds and exchange-traded funds (MFs, ETFs). In OCI’s MF/ETF program, the Firm offers several model asset allocations, with initial portfolio composition and ongoing management driven by the firm’s economic and financial-market outlook. OCI makes recommendations regarding a particular model/strategy based on factors including, but not limited to, the client’s financial situation, long-term goals, investment objectives and attitude toward risk. Specific mutual funds/ETFs are selected based on their ability to provide desired asset exposure, historical investment performance, and cost-efficiency. Use of Independent Managers For clients whose investment needs require additional diversification, OCI recommends that clients engage certain Independent Managers through Charles Schwab & Co., Inc.’s Managed Account Marketplace program (“Schwab Marketplace”) to actively manage a portion of some clients’ assets by investing in a variety of investments and employing various investment techniques. OCI recommends Independent Managers only when it is in the client’s best interest and reviews suitability at least annually. OCI evaluates a variety of information about Independent Managers, which generally includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses that OCI believes are reputable. Independent Managers are selected based on their ability to provide desired asset exposure, historical investment performance, and cost efficiency. On an ongoing basis, OCI monitors the performance of those accounts being managed by Independent Managers. OCI seeks to ensure the Independent Managers’ strategies remain aligned with its clients’ investment objectives and overall best interests. Refer to Item 10 for additional information on conflicts of interest created by OCI’s recommendation of Independent Managers on Schwab Marketplace. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients should also review the written disclosure brochures of the respective Independent Managers engaged to manage their assets. Financial-Planning Services OCI provides financial-planning services that include, among other things, household/business cash-flow analysis; retirement-income planning; risk-tolerance profiling; asset-allocation design; pension- and health- care benefits analysis; tax planning; and family-survivorship guidance. Financial-planning services are generally provided at no additional cost to clients who have retained OCI for Investment Management and/or Mutual Fund/Exchange-Traded Fund Portfolio services. OCI generally does not provide financial planning services to clients as a standalone service. Financial-planning services assist clients in evaluating the appropriateness of existing and/or potential financial arrangements, with the aim of enhancing the probability of attaining various financial goals. In providing these services, OCI uses industry-standard methods and technology-based tools to perform calculations based on information provided by the client or prospect and informed by capital-market assumptions and alternative planning scenarios. Results are hypothetical and intended to be reviewed and updated regularly. Individuals should consult with their legal and/or tax advisers regarding the appropriateness of any financial plan. Clients and prospects are to notify OCI immediately if there have been any material changes in their financial situation. In conjunction with financial-planning services, OCI may provide clients with discretionary investment- advisory services for their self-directed employer-sponsored retirement-plan (e.g., 401(k), 403(b), PRAP) accounts and/or Individual Retirement Accounts (IRAs). If OCI recommends that a client retain OCI to provide investment-advisory services for retirement-plan assets not previously overseen by OCI, that recommendation creates a conflict of interest, as OCI will earn incremental fees if the client follows the recommendation. OCI policies require that all such recommendations be in the client’s best interest. Retirement-Plan Advisory Services OCI offers educational and/or advisory services to retirement plans and their participants. OCI’s services are designed to complement the services of unaffiliated third-party retirement plan administrators in assisting plan sponsors, plan trustees, and investment committees in meeting their management and fiduciary obligations to plan participants under the Employee Retirement Income and Securities Act (“ERISA”). OCI supplements the services provided by the plan administer – who assists the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed – by providing education services to plan participants and monitoring the performance of the plan’s investment vehicles. OCI assists with participant enrollment meetings and provides investment-related educational seminars to plan participants on topics including, but not limited to, diversification, asset allocation, risk tolerance, time horizon as well as other topics specific to a particular plan. Plan participants are responsible for all individual investment decisions and allocations made within the plan. As of December 31, 2023, OCI had assets of $698,050,258 under discretionary management and $5,254,948 under non-discretionary management.