Loudon Investment Management, LLC is a SEC-registered investment adviser with its principal place of business located in New Hampshire. Loudon Investment Management, LLC began conducting business in 2003. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 10% or more of this company).  Douglas M. Loudon, Chief Investment Officer  Emily L. Sands, President  John J. Sands, Principal Loudon Investment Management, LLC 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 in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. 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 or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), 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  Corporate debt securities (other than commercial paper)  Certificates of deposit  Municipal securities  Mutual fund shares  United States governmental securities 5 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. INVESTMENT SUPERVISORY SERVICES ("ISS") MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. EQIS Capital Management - Loudon Investment Management, LLC provides a model portfolio for EQIS Capital Management that consists of equity securities, cash equivalent securities, and a percentage allocation for each holding. The purpose of the portfolio is to reflect Loudon Investment Management, LLC's value and income investment style. Unlike individually managed accounts, the percentages held in the model portfolio are static and do not change as the prices of the underlying securities fluctuate. Both the securities and percentages held are adjusted periodically by Loudon Investment Management, LLC, as appropriate. As a result, the model portfolio looks similar, but not identical to, a typical unrestricted equity portfolio. Changes to the model portfolio generally reflect changes to Loudon Investment Management, LLC's individually managed accounts. Loudon Investment Management, LLC has no contact with the underlying investors, no operational authority in the model portfolio, and does not have discretion over these assets. EQIS Capital Management is responsible for obtaining stated objectives and determining suitability of the Loudon Investment Management, LLC Large Cap Value model portfolio for clients. Assets that are invested in the model are not counted as "assets under management" for Loudon Investment Management, LLC. 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 AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $199,509,203 of clients' assets on a discretionary basis plus $952,913 of clients' assets on a non-discretionary basis.