Dividend Assets Capital, LLC (“DAC” or the “Firm”), a limited liability company incorporated under the laws of the State of South Carolina, has been a registered investment adviser with the U.S. Securities and Exchange Commission since January 2004. Registration does not imply any certain skill or training. DAC was founded in 2003 and was formerly named Dividend Growth Advisors, LLC. The name change was made effective February 27, 2012. DAC is 100% employee owned through an Employee Stock Ownership Plan (ESOP). GreatBanc Trust Company serves as the Firm’s ESOP trustee and owner of the Firm’s equity on behalf of DAC’s employees. Over time, the ESOP will allocate the shares of DAC that it owns to the employees of DAC. DAC believes the ESOP is the most effective and efficient strategy for achieving the succession planning objectives with respect to ownership of the Firm. As of December 31, 2023, DAC had client assets it managed of $619,594,124. Of that total amount, the firm has $566,240,855 in regulatory assets under management, consisting of $565,903,833 managed on a discretionary basis and $337,022 on a non-discretionary basis. Client assets DAC manages that are not included in its regulatory assets under management are $53,353,269. Regulatory assets under management are calculated consistent with the methodologies applied in DAC’s Form ADV Part 1. DAC does not have discretion for certain securities held by some of our clients; however, the securities are held in discretionary accounts and therefore the assets are included in the calculation of assets under management. The value of these securities as of December 31, 2023, was $11,669,507. Types of Advisory Services and Investments DAC is an investment advisory firm in which its primary business is providing discretionary advisory services to clients through private client services, sub-advisory services and dual contract private client services. DAC generally invests assets in client accounts in dividend-paying stocks that have shown consistent dividend increases in prior years and Master Limited Partnerships (“MLPs”) that have maintained or increased distributions. Where appropriate to meet specific client needs and/or risk preferences, DAC may also invest in Treasuries, Corporate and/or Municipal bonds, as well as mutual funds, and ETFs. Clients may direct specific investments that may not be in the DAC strategy and therefore are not followed by DAC’s team of portfolio managers and research analysts. Clients who wish to impose restrictions on certain securities, types of securities, or industries, etc., should notify DAC. Once agreed upon, it is the client’s responsibility to inform DAC in writing when a change is desired or made and/or the restriction(s) is (are) no longer valid. DAC clients include those with whom DAC has a direct contractual relationship through DAC’s Client Advisory Agreement, those who have enrolled in asset-based wrap fee programs sponsored by an unaffiliated dual-registrant broker-dealer/investment adviser, and clients where DAC acts as a sub- adviser. 4 | Dividend Assets Capital, LLC Separate Accounts DAC’s advisory services to separately managed accounts are customized based on each separate account client’s return expectations, tolerance for risk, tax situation, volatility, and the need for liquidity. During initial and on-going discussions with each client, DAC develops the personal investment profile that includes specific client information and a general profile of the client’s risk tolerance, recommended investment strategy, income requirements, distribution requirements and any account restrictions. As mentioned previously, clients may direct specific investments that may not be in the DAC strategy and therefore are not followed by DAC’s team of portfolio managers and research analysts. Sub-Advisory Services A Sub-Advisory relationship occurs when DAC contracts with another, unaffiliated Registered Investment Adviser, Broker Dealer, Registered Representative or Custodian to provide discretionary portfolio management services on a continuous basis to their advisory clients. DAC provides sub-adviser services to client portfolios consistent with the client's stated goals, objectives and risk tolerances provided by the client or the client’s financial representative. For such accounts, DAC will place, per the written agreement, orders for the execution of all investment transactions for clients with the specified broker-dealer or the sub-adviser’s platform(s). In sub-adviser arrangements with smaller custodian banks, DAC will trade these accounts with its trading brokers. The sponsor of these programs generally provides the clients with all servicing including, but not limited to, reporting. Wrap Fee Programs DAC acts as a portfolio manager for several wrap fee programs in which the client pays one fee to the wrap program sponsor for all services associated with the management and execution of their account. DAC does not sponsor any wrap fee program. There are several differences between how DAC manages wrap fee accounts and other accounts. One of the primary differences is that the trading of a wrap fee account is typically directed to the sponsor (or an affiliate of the sponsor) of the wrap program. DAC may not have, depending on the structure of the wrap program, primary responsibility for maintaining on- going relations with the clients within the wrap program. DAC receives a portion of the total wrap fee paid to the wrap program sponsor for its portfolio management services. DAC does not solicit these clients or provide client statements or reporting. Unified Managed Account Program (“UMA”) A number of institutional SMA advisor clients retain the Firm so that their underlying retail clients can access DAC’s model portfolios for their own investment accounts. DAC’s services to some of these separately managed account (“SMA”) programs include development and delivery of the model portfolio, research, updates and monitoring of the model portfolio, and 5 | Dividend Assets Capital, LLC trade executions on behalf of the underlying

client accounts in response to model updates. DAC does not enter into a direct relationship with the underlying clients of the SMA programs and does not provide account-specific performance reporting services to those underlying program participant clients. In these relationships, DAC does not have investment discretion over the investment adviser’s client accounts nor does DAC communicate directly with the investment adviser’s clients. DAC receives an investment management fee directly from the adviser. Different institutional SMA advisors and its UMA advisor clients also retain DAC in order that their underlying retail clients can access the model portfolio for their investment accounts. However, DAC’s services to these other SMA and UMA programs include only development of the model portfolio, research, updates and monitoring of the model portfolio, and notice only of model updates. For these program clients, the Firm does not provide trade execution services in response to model updates and does not provide account-specific performance reporting services. DAC does not enter into a direct relationship with the underlying clients of the UMA and SMA programs. Dual Contract Arrangements DAC acts as a portfolio manager for several dual contract programs in which the client hires both a financial advisor and DAC to manage their assets. Generally, the client’s investment objective is provided by the financial advisor to DAC. These clients sign DAC’s Client Advisory Agreement, have the same obligations under the DAC agreement as would a direct client of the Firm, and may pay fees less than our separate account clients due to fewer servicing requirements as these are fulfilled by the other financial adviser. All trades for these accounts are directed to the financial advisor’s trading platform and may be aggregated alongside DAC’s other clients. Under the dual contract arrangement, DAC will generally meet with or have discussions with the client’s financial advisor, rather than the client, on a regular basis. In the course of managing the separate accounts, sub-advised, UMA programs, dual contract and wrap accounts, DAC may take different positions in the same or related securities for different clients. It is possible that DAC could sell certain securities in one client account, while another client account will continue to hold the same security. In addition, clients may have investment objectives, strategies, time horizons, tax considerations, and risks that differ from one another. The portfolio managers’ investment decisions for each client are based on these factors, and other relevant investment considerations applicable to that particular client. Consequently, the portfolio managers may purchase or sell securities for one client, but not all clients, and the performance of securities purchased for one client may vary from the performance of securities purchased for other clients. Real, potential, or apparent conflicts of interest may arise when a portfolio manager has day- to-day investment responsibilities with respect to more than one of its types of clients (e.g., separate accounts, sub-adviser accounts, dual contract or wrap). For example, a portfolio manager may have conflicts of interest in allocating management time and resources among the different clients s/he advises. Financial Planning Services 6 | Dividend Assets Capital, LLC DAC offers financial planning services for a fee ranging from $200 to $300 per hour. DAC does not provide legal, accounting, or insurance services. The financial plans are for budgeting and retirement planning purposes and are provided only as a guideline. Clients or prospects are not obligated to accept or follow the advice resulting from the plan provided by DAC, and they may take the plan to another investment manager if they so choose. Our policy does not allow the financial plans to include health or long-term care recommendations, insurance recommendations, tax or estate planning. The primary focus of the plan is to analyze retirement income goals, budget/spending analysis and to establish retirement income expectations. The financial planning service does not involve implementing transactions on the client’s behalf or the active and ongoing management of the client’s investments. It is the sole responsibility of the client or prospective client to determine whether to implement the financial plan. To the extent that the client or prospective client would like to implement the investment strategy of the plan with DAC, an investment advisory agreement must be executed with the Firm. Our financial planning service offering is not mandatory for all clients and prospects. We believe there will be one- off cases where financial plans will be developed for clients and some portfolio managers will not use the tool at all. The financial plan is developed based on information that is provided to us by the client or prospective client. This information may include, but is not limited to, the client’s financial objectives, risk tolerance, financial resources, family situation and future financial goals. Documents requested by DAC to develop the plan could include tax returns, financial statements, bank statements, list of investments, insurance policies, etc. It is important that the information provided to DAC is accurate and complete. DAC is not responsible for verifying the accuracy of the information provided by the client or prospective client. Cash Management Services DAC makes available to clients the Cantor Fitzgerald Cash management program offered by StoneCastle Network, LLC (“StoneCastle”). This program allows customers to place funds in deposit accounts at banks, savings institutions and credit unions (collectively, “Insured Depositories”) where such accounts are insured by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration, whichever is applicable. Funds are deposited within StoneCastle’s network of Insured Depositories. DAC earns a fee from StoneCastle if clients participate in this program, which gives us an incentive to recommend that you participate in the program.