Firm Description Francis LLC is 100% employee owned and was founded over two decades ago to provide conflict-free investment advice to qualified retirement plan sponsors and their employees. Our business structure is specifically designed with ERISA compliance in mind and eliminates the conflicts of interest plaguing today’s financial services industry. 100% of Firm revenue is derived from the fully transparent, fixed- dollar fees we negotiate with clients. We help our clients’ employees save money by avoiding unnecessary asset management fees, because the financial wellness and investment advice we offer is not tainted by conflicts. Our Firm offers no wealth management products or services, so our clients can be confident the rollover advice we provide their employees is always based solely on their best interest. Our investment consulting clients enjoy recommendations solely focused on improving their results, not someone else’s bottom line, because we offer no proprietary products, or self-serving managed account program. We accept no remuneration of any kind from anyone in the asset management industry. Our services have consistently been recognized by national third-party organizations for their quality and objectivity.* *2018 Plan Sponsor Magazine’s “Large Team” Retirement Plan Advisor of the Year, 17-time recipient of Pension & Investment Magazine’s Eddy Award for excellence in employee education. Services We Offer Francis LLC offers two services in the institutional financial services marketplace: 1) employee education, advisory, and financial wellness services, and 2) qualified retirement plan investment consulting and plan management services. Types of Advisory Services Employee Education, Advisory, and Financial Wellness Services Francis LLC contracts with employers to provide the following employee education and advisory services. a) Employee Education and Advice. We custom design our participant education and advisory services which are delivered by experts in adult learning principles. Our award-winning education services are custom designed for the participant population being presented to and delivered on an ongoing basis by a consistent team of dedicated professionals. Francis LLC has earned multiple Eddy Awards for excellence in the field of employee financial education. Eddy Awards are national defined contribution education awards sponsored by Pension & Investments Magazine.* *2023 Eddy Award recognition received based on Pensions & Investments annual evaluation process. Winners demonstrated program effectiveness and creativity, as well as completion of the entry form, which included a $150 fee per entry. Number of entries varies annually but averages 130-150. Selection criteria weighted differently based upon the category, but in general, creativity and the ease of understanding complex topics was key in determining award-winning entries. 2024 Eddy Award represents the seventeenth time Francis LLC has received such recognition, having previously received Eddy Awards in 2011, 2012, 2014, 2016, 2018, 2019, 2020, 2021, 2022, and 2023. Francis LLC is not affiliated with and does not provide remuneration to Pensions & Investments. Receipt of this award should not be construed as a guarantee of future performance or results. b) Participant Advice. Through a contract with their employer, we provide a full range of personalized financial wellness advice designed to meet the needs of all types of employees. Advice is delivered through face-to-face consultation, accessed online, and by phone. We acknowledge our status as an ERISA fiduciary in writing to qualified plan participants. Francis LLC advisors do not implement transactions on behalf of our clients or their employees, and our advisors do not actively manage the investments of the individuals we advise. The employee has the sole responsibility to determine whether to and how to implement the financial planning recommendations we provide. Financial advisory services do not include any specific recommendations of individual stocks or bonds. Francis LLC and its advisors do not actively monitor employees’ financial situation or investments. Employees have the sole responsibility to monitor their own financial situation and to seek input from an advisor if circumstances change or merit additional analysis and planning. Francis LLC’s financial wellness services and any recommendations are free from conflicts of interest and are dependent on receiving accurate information from the employee. Francis LLC sets forth in its Services Agreement that its financial wellness services do not include any highly detailed tax or legal advice. c) Francis LLC Mobile Application. In order to facilitate

remote access to our participant advisory services, Francis LLC offers the Francis LLC mobile application. This technology provides employees convenient messaging access to Francis LLC advisors, real-time financial planning software, and a personalized financial wellness assessment which provides tasks for improving financial wellness. d) Group Workshops. Francis LLC develops and delivers workshops specifically designed by adult learning experts to be educational, yet fun and actively engage the employee. Curriculum and materials are customized based on the specific education goals and the employee demographics. The workshops are conducted on an ongoing basis. Qualified Retirement Plan Investment Consulting and Plan Management Service Francis LLC provides the following non-discretionary investment consulting services to qualified sponsors: a) Investment Policy Statement. Francis LLC assists its clients with the development of an investment policy statement that establishes the objectives and guidelines for the management of a plan’s investments. This statement clearly defines who is responsible for fiduciary decisions regarding plan assets, how the plan’s assets are allocated (defined benefit plans), how the plan’s investment managers/funds are selected, how their ongoing performance is evaluated, and when they should be replaced/eliminated. b) Investment Manager/Fund Search(es). We conduct investment manager/ fund searches in accordance with the provisions set forth in the investment policy statement. Our database encompasses virtually all established public mutual funds and thousands of institutional money managers. Francis LLC utilizes a rigorous, multi-step screening process which incorporates both qualitative and quantitative evaluations to satisfy the “prudent expert” requirements of ERISA. c) Retirement Plan Cost Analysis. Francis LLC annually prepares for its defined contribution plan clients a detailed analysis of each component of plan costs. The analysis uncovers the individual sources of revenue sharing and details where these revenues are directed. Francis LLC’s extensive proprietary database of client and industry plan cost information allows us to provide clients with an independent benchmarking of their plan’s total cost and the identification of the true revenue earned by each of the plan’s service providers. d) Portfolio Management and Asset Allocation Optimization. A means-variance methodology is used to develop client asset allocation recommendations. Testing of these outcomes can be developed with Monte Carlo simulation software, while proprietary research is used to generate the inputs. Asset allocation optimization studies are conducted upon client request and completed informally on an ongoing basis. Any tactical allocation changes are discussed with clients during quarterly meetings or as requested. Francis LLC utilizes risk measures such as beta and standard deviation calculated from historical data. Capital market expectations are reviewed monthly and any revisions are recommended quarterly. e) Plan Operational Review. The executed plan documents govern the legal requirements plan sponsors must follow in the administration of their plans. Failure to comply with the plan document could result in penalties or a disqualification of the plan’s tax-favored status. Over time it is not uncommon for there to be discrepancies between the provisions of the formal plan document and the actual day-to-day operation of the benefit. We can assist clients in the performance of an operational review of their daily administrative activities and verify they comply with the formal plan document. f) Recordkeeper/Trustee Search. Francis LLC works with plan committees to identify their needs, priorities, and to establish the necessary capabilities of recordkeeper/trustee candidates. We prepare a customized request for proposal and collect and evaluate all recordkeeper/trustee responses. Francis LLC organizes interviews to help determine the final selection and assists with the contract negotiation. g) Annual Fiduciary Review (AFR). Francis LLC provides an annual assessment of ERISA compliance activities and plan results. With the help of Francis’ proprietary benchmarking tools, the AFR helps identify employee groups underutilizing the benefit and offers recommendations for improvement. The AFR provides a comprehensive review of the year’s employee education / advisory activities as well as a thorough analysis and benchmarking of plan costs. This report contains the information necessary to respond to participant or governmental inquiry. Principal Owners Michael J. Francis is the principal stockholder and managing member. Kelli B. Send and Clifford H. Dunteman, Jr., Joseph J. Topp, Edward C. McIlveen and Susan L. Salmon are minority stockholders. The Firm is 100% employee owned.