Probity Advisors, Inc. is an SEC‐registered investment adviser with its principal place of business located in Texas. Probity Advisors, Inc. began conducting business in 2002. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). *The Probity Advisors Shareholders Trust, DTD 07/06/2005 *The Porter L. Ozanne, III & Linda M. Ozanne Joint Living Trust DTD 10/30/84, Beneficiary Probity Advisors, Inc. offers the following advisory services to our clients: Investment Supervisory Services ("ISS") ‐ Individual Portfolio Management Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions and/or questionnaires in which goals and objectives based on a client's particular circumstances are established, we develop a client's investment profile and create and manage a portfolio based on that profile. During our data‐gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., retirement income, ultra conservative, conservative, moderate conservative, moderate, moderate aggressive, aggressive), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker‐dealer or insurance company and will generally include advice regarding the following securities:  Exchange‐listed securities  Securities traded over‐the‐counter  Foreign issuers  Warrants  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Variable life insurance Variable annuities  Mutual fund shares United States governmental securities  Options contracts on securities Futures contracts on intangibles Interests in partnerships investing in real estate Interests in partnerships investing in oil and gas interests Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Probity Advisors, Inc. provides clients with professional, discretionary portfolio management services through one of four investment platforms: The Advantage Platform, The Tactical Allocation Platform, The Diversified Income Platform, and The Fixed Income Platform. Advantage Platform: The Probity Advantage Platform is designed for investors who prefer an active portfolio approach. Our in‐house research staff will select individual stocks, fixed income and other exchanged traded securities to create a portfolio tailored to satisfy the client’s risk profile, time horizon, tax budget, short‐term and long‐term tax rates, transaction costs, and/or any ESG requirements. Qualifying accounts start at $250,000. Tactical Allocation Program: Probity's Tactical Allocation Platform is designed for investors who seek a professionally managed, dynamically rebalanced portfolio that utilizes exchange traded securities. Like the Advantage Platform, the individual investor’s buy and sell constraints, transaction costs, short‐term and long‐term tax rates, tax budget, time horizon and risk profile are all taken into consideration in building the portfolio. Qualifying accounts start at $10,000. Diversified Income Platform: Probity Diversified Income Platform is designed to provide a growing stream of income from a diverse set of securities types, ranging from dividend paying, large cap domestic equities to emerging market bond funds. Unlike a typical fixed income strategy, this platform takes an active approach towards income replacement, balancing a client’s current income need against their growing spending requirements over time. The portfolio may be more volatile than more traditional income strategies, making it suitable for investors who are comfortable balancing growth and income. Qualifying accounts start at $250,000. Fixed Income Platform: Probity Advisors’ Fixed Income Platform is a discretionary fixed income program designed for investors seeking current income and/or capital appreciation through investments in debt securities. Our portfolio managers work with the client to design strategies tailored to meet their specific spending needs, safety of principal requirements and asset allocation demands. Fixed Income strategies may include, but are not limited to, laddered, bullet, barbell, cash flow matching or liability immunization and the resulting portfolio may hold underlying securities that include, but are not limited to, US treasuries, agencies, foreign government obligations, domestic corporate bonds, commercial paper, high yield bonds, ETFs and/or closed end funds. Qualifying accounts start at $100,000. Asset Builder Platform: Probity Advisors’ Asset Builder Platform is our entry level product for the investor seeking to begin building their savings. This platform may invest in ETFs, mutual funds or other assets to efficiently achieve the investor’s selected risk tolerance. This portfolio is rebalanced using quantitative metrics to adhere to the designed allocation and anticipated drift parameters established for each risk level. The Asset Builder Platform has no minimum, but does not provide customization or regular, individualized review. Annuity Allocation Services Client may grant Probity Advisors discretion to: (a) select investment strategy allocations for client’s existing or new annuity products; and (b) allocate among the investment strategy allocations available from the specific annuity sponsor (collectively (a) and (b) are referred to as the “Annuity Allocation Services”). In performing Annuity Allocation Services, Probity Advisors will only consider the options available within the specific annuity purchased by the client. If an annuity was purchased with retirement account assets, Probity Advisors does not exercise discretionary control with respect to the purchase of the annuity for the client. Any changes in client’s annuity investments (reallocations among investment strategy allocations) are subject to the terms and conditions imposed by the applicable annuity sponsor. Retirement Plan Advisory Services Probity Advisors provides consulting and advisory services for employer‐sponsored retirement plans in accordance

with the Employee Retirement Income Security Act (“ERISA”). The services provided are ERISA 3(21) and 3(38) fiduciary services depending on the desires of the plan sponsor. Both 3(21) and 3(38) advisors accept fiduciary responsibility and adhere to ERISA 404(a)’s duty to act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. Plan sponsors retain the responsibility to select and monitor the advisor, regardless of their advisor’s fiduciary status. These services are provided on a discretionary basis for ERISA 3(38) services and a non‐discretionary basis for ERISA 3(21) services. Under a 3(21) fiduciary advisory arrangement we will assist in the drafting of the investment policy statement (IPS), help design initial fund menu, monitor the selected investments, provide participant education, and provide guidance throughout the fiduciary process. As an ERISA Section 3(21) fiduciary, we do not have authority to make and implement fiduciary decisions for the plan. The plan sponsor is responsible for the selection and monitoring of the 3(21) investment manager and implementation of any of the 3(21) investment manager’s investment recommendations, and assumes responsibility and liability for any overriding decisions made by the plan sponsor. Plan Sponsors or trustees may also elect to appoint Probity as a 3(38) fiduciary investment manager. Under this arrangement, we draft the IPS, accept discretion over plan assets, and assume responsibility for the fiduciary functions related to the investment options available to plan participants and the ongoing monitoring and documentation requirements under ERISA. Financial Planning Probity Advisors provides financial planning services. Financial planning is an evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. Through the financial planning process, questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a tailored financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:  PERSONAL: We may review family records, budgeting, personal liability, estate information and financial goals.  TAX & CASH FLOW: We may analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.  INVESTMENTS: We may analyze investment alternatives and their effect on the client's portfolio.  INSURANCE: We may review existing policies to ensure proper coverage for life, health, disability, long‐term care, liability, home and automobile.  RETIREMENT: We may analyze current strategies and investment plans to help the client achieve his or her retirement goals.  DEATH & DISABILITY: We may review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.  ESTATE: We may assist the client in assessing and developing long‐term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in‐depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We review documents supplied by the client, including a questionnaire completed by the client, and prepare a report tailored to the client’s requirements. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or asset manager. As a convenience, Probity Advisors or affiliated companies may offer many of the recommended services, but the implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non‐securities advice on topics that may include: Tax and budgetary planning, estate planning and business planning  Exchange‐listed securities Securities traded over‐the‐counter  Foreign issuers Warrants  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Variable life insurance  Variable annuities  Mutual fund shares  United States governmental securities  Options contracts on securities  Futures contracts on intangibles  Interests in partnerships investing in real estate  Interests in partnerships investing in oil and gas interests Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker‐dealer or insurance company. Publication of Periodicals Probity Advisors, Inc. publishes a weekly commentary providing general information on various financial topics including, but not limited to, estate and retirement planning, market trends, etc. No specific investment recommendations are provided in this newsletter and the information provided does not purport to meet the objectives or needs of any individual. In addition, Probity Advisors, Inc. may periodically release white papers and research papers designed to educate clients on various topics. These newsletters and research papers are distributed free of charge to our advisory clients, industry associates, personal contacts, friends, and family. Consulting Services Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker‐dealer or insurance company. All recommendations are of a generic nature. Wrap Fee Programs Probity does not participate in wrap fee programs. Amount of Managed Assets As of 01/01/2024, our firm managed $628,834,149.00 of assets on a discretionary basis and an additional $1,347,576.00 on a non‐discretionary basis.