Johnson Wealth Inc. (“Johnson Wealth”, “we”, “our”, or “us”) is an investment advisory firm registered with the SEC under the Investment Advisers Act of 1940 (“Advisers Act”). Johnson Wealth is a wholly owned subsidiary of Johnson Financial Group, a privately held financial services company and marketing name for its subsidiaries, Johnson Bank and Johnson Wealth Inc. We provide investment advisory and consulting services to high-net-worth individuals, families, trusts, not- for-profit and senior living organizations, public and private foundations and endowments, business entities, government entities, and other investment advisers, including our affiliate Johnson Bank. Although we were formed in 2003, our predecessor firms have served clients since 1987. Investment Advisory Services We believe the investment advisory business should be approached with an underlying sense of purpose. Our advisory services are tailored to the individual needs of each client based on the client’s short and long-term goals, including the client’s financial objectives, income tax status, and size of the account. These factors and others help form the basis of a client’s investment strategy. While solutions may have wide applicability, each client's situation is unique. Our investment advisory services typically include, but are not limited to:
• Analysis of objectives
• Asset allocation and portfolio construction
• Investment policy development
• Investment research
• Evaluation and selection of funds and separate account managers (Managers)
• Responsible investing, where requested
• Trustee and Board education When engaging Johnson Wealth, clients enter into a written agreement that sets the terms and conditions under which we render our services. A client may negotiate for specific advisory services designed to achieve the client's goals and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities. We also work with clients’ other professional advisors, including other Managers clients separately engage, to provide clients with an integrated approach. Discretionary and Non-Discretionary Advisory Services Johnson Wealth typically manages client accounts on a discretionary basis; however, non-discretionary advisory services are also available. Investment decisions are guided by the client’s investment policy statement. If a client’s account is managed on a discretionary basis, Johnson Wealth will generally execute all investment selections that are determined to be appropriate to implement the client’s policy without further consultation with the client. Johnson Wealth provides discretionary investment advice primarily with respect to mutual funds, exchange traded funds (ETFs) (collectively, a “fund” or “funds”), common stocks, fixed income securities, and alternative investment vehicles. Alternatives include, but are not limited to, registered mutual funds and ETFs that have alternative strategies, real estate investment trusts, master limited partnerships, commodities, natural resources, derivative instruments, and currencies. Johnson Wealth’s discretionary authority also includes the ability to retain and terminate Managers to perform subadvisory services for client accounts. Johnson Wealth generally selects Managers that are on a platform administered by a third- party service provider (a “Program Administrator”). Such Managers enter into a subadvisory agreement directly with the Program Administrator. Accounts managed on a discretionary basis are generally assigned to an appropriate model portfolio; in which case, trades are typically executed in mass when

a strategy change is implemented. Accounts may be excluded from the model reallocation or the timing may be delayed at the discretion of the portfolio management team. Accounts that are not traded in mass when a strategy change is implemented may receive different execution prices (higher or lower). All members of the portfolio management team are subject to the Code of Ethics and must act in the best interest of the client. If a client’s account is managed on a non-discretionary basis, the client may receive different execution prices (higher or lower) on securities bought or sold and may receive different transaction charges than if the account was managed on a discretionary basis. Johnson Wealth has also partnered with a third-party service provider to access due diligence and the online subscription process for certain private investments, including, but not limited to, private equity, private credit and hedge funds. For these investments, we perform due diligence and curate a menu of options, offering the investments on a managed, non-discretionary basis for clients who meet certain accredited investor or qualified purchaser investor qualifications. Other Services Johnson Wealth provides pre-retirement planning services to airline pilots and their families under the firm’s Pilot Program that include, among other things, risk tolerance profiling, asset allocation design, pension benefits review, retirement timing and transition consultation. As part of these services, Johnson Wealth provides discretionary account management through the participant’s 401(k) self- directed brokerage account. Investments are limited to the investments available through the 401(k) plan’s self-directed brokerage account option. Johnson Wealth also offers similar pre-retirement services to other individuals through their employer’s 401(k) plan. Important Note: If Johnson Wealth recommends that a client roll assets out of an employer sponsored plan into an Individual Retirement Arrangement (“IRA”) to be managed by Johnson Wealth, such recommendation creates a conflict of interest because we earn ongoing investment management fees when managing the IRA. Our policies require each Wealth Advisor who recommends a plan rollover to evaluate the recommended transaction in the client's best interest. Johnson Wealth offers financial planning services designed to help clients evaluate the potential of attaining their financial goals. When we create a financial plan for a client, we use industry standard technology and methods to perform calculations based on information provided by the client or prospect as well as various market assumptions and scenarios. The results are hypothetical in nature and are intended to be reviewed at least annually. It is recommended that individuals also consult with their legal and tax advisers regarding their financial plan. Our affiliate, Johnson Bank, retains Johnson Wealth to perform discretionary or non-discretionary subadvisory services for nearly all of its wealth management clients, including its retirement plan services clients. These services typically include discretionary investment management, trading, broad investment trends analysis, investment policy direction, asset allocation modeling, Manager selection and fund due diligence, construction of plan fund line-ups, fixed income and equity strategy and analysis, portfolio construction advice, and model portfolios. Assets Under Management As of December 31, 2023, Johnson Wealth advised on approximately $6.8 billion of client assets on a discretionary basis and approximately $1.6 billion of client assets on a non-discretionary basis. Discretionary and non-discretionary assets include those subadvised for our affiliate, Johnson Bank.