Firm Description Covington Investment Advisors, Inc., a Pennsylvania corporation (“Covington”) was founded in 2003. Covington provides personalized confidential financial planning and investment management to individuals, trusts, estates, pension and profit-sharing plans, charitable organizations, partnerships, corporations and other small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Covington is strictly a fee-only financial planning and investment management firm. The firm does not directly sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. Investment advice is provided, with the client either (i) making the final decision on investment selection via a non-discretionary account; or (ii) an advisor making the decision on a discretionary account pursuant to the mechanisms and rights afforded with such account (pursuant to a limited power of attorney). Covington is not a broker-dealer, nor does it act as a custodian of client assets; and clients’ have full purview and transparency to their assets and positioning. A written evaluation of each client's initial situation is provided to the client, often, depending upon the client’s desires and needs, in the form of a net worth statement. Internal periodic reviews are also performed by the advisor supervising the specific client to review the client’s performance relative to his/her desires. Such reviews are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed as prudently possible to the client in the event they should occur. The initial meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. Principal Owners The Patrick R. Wallace Revocable Trust, DTD 8/8/2016, is the sole shareholder of Covington; of which Patrick R. Wallace is the trustee. Types of Advisory Services Covington provides fee-based investment management services. If requested, Covington furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation

issues, and trust services that often include estate planning. Presently, Covington is comprised of two (2) advisors, Patrick R. Wallace, the President and Lead Advisor, and Cindy Jones, Portfolio Manager; one (1) Research Analyst, Nick Allen; one (1) Client Services Administrator, Hannah Patton; and, one (1) Office Manager, Makenzie Maust. Tailored Relationships Our Advisors tailor their advisory services to the individual needs of the client by creating an asset allocation to reflect the stated goals, objectives, and/or risk tolerance of our clients. Clients may impose restrictions on investing in certain securities or types of securities. The goals, objectives, and risk tolerance are documented in the Client Investment Profile. The asset allocation and/or any restrictions are documented in the Investment Management Agreement. Most clients choose to have Covington manage their assets in order to obtain ongoing in-depth advice and life planning. Generally, all major aspects of the client’s financial affairs are reviewed, including those of their children. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. In order to evaluate the clients’ needs and desires properly, the following may be performed: net worth statement; cash flow management; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; insurance review; education planning; retirement planning; and estate planning, as well as the implementation of recommendations within each area. The scope of advisory services and fee is detailed in the Investment Management Agreement and provided to the client in writing prior to the start of the relationship. The Investment Management Agreement may not be assigned without client consent. Wrap-Fee Program Covington does not participate in a wrap-fee program. Assets Under Management As of December 31, 2022, Covington manages approximately $574.46 million in assets for 523 accounts. Approximately $550.02 million is managed on a discretionary basis, and $24.43 million is managed on a non-discretionary basis. Termination of Agreement A Client may terminate the Investment Management Agreement at any time by notifying Covington in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. Covington may terminate the Investment Management Agreement at any time and for any reason whatsoever by notifying the client in writing. Additionally, Covington reserves the right to stop work on any account where the investment management fee is greater than 10 days overdue.