WhaleRock is an investment adviser. Its principal activity is the day-today management of its clients’ investment assets. These assets are held in individual (separated) client accounts. These accounts are held and maintained by a bank, broker dealer or other qualified custodian. Clients compensate WhaleRock for its investment management service through fees based on a clearly written fee schedule provided to each client. A specific discussion of these fees can be found in Item 5. WhaleRock was formed in May 2006. It occupied its offices on June 1, 2006, and began managing clients’ assets on July 1, 2006. It is owned by Bradley P. Dorman and Tyson C. Reed. Mr. Dorman is the majority shareholder and managing partner. As of December 31, 2023, WhaleRock managed approximately $624,783,378 in client assets, of which $624,783,378 was managed on a discretionary basis and $0 on a non- discretionary basis. Investment Management Services WhaleRock's advisory services are tailored to the individual needs of clients. In general, WhaleRock seeks maximum after-tax investment results for its clients while adhering to each client’s written investment policy. Each client account has a written Investment Policy Statement clearly stating the account’s objectives, asset allocation ranges and constraints. Clients have the option to include specific investment directions or restrictions in this statement, if desired. Please see Item 16, Investment Discretion, for further information. WhaleRock manages nearly all accounts on a discretionary basis. This means it has full authority to determine the securities bought and sold in each account. This authority is granted by each client for each account in a signed Investment Management Agreement. A client may terminate this agreement at any time without penalty. Please see Item 16, Investment Discretion, for further information. WhaleRock employs third party and proprietary software tools to screen accounts with daily regularity. These methods review accounts constantly from various perspectives. We believe our proprietary tools create competitive advantages in many aspects of our account management and service delivery capabilities. In particular, we are able to manage large amounts of fixed income securities across numerous accounts. This provides us an ability to offer clients portfolios including directly owned fixed income securities using highly tailored management techniques. Please see Item 13, Review of Accounts, for further information. In the course of interacting with its clients, WhaleRock will often provide other financial planning advice, information and counsel. Unless a client enters a special agreement, WhaleRock does not charge additional fees for this service. It is included in the investment advisory service and the client’s investment fee schedule. Since inception, WhaleRock has not entered any special service agreements. Please refer to Item 5 Fees and Compensation, for further information. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Retirement Plan Services A. Types of Retirement Plan Services Pursuant to our Investment Fiduciary & Retirement Plan Consulting Agreement (the “Consulting Agreement”), we deliver both discretionary and nondiscretionary investment fiduciary services. The Consulting Agreement allows the Sponsor to select the nature and scope of services it determines to be necessary for the operation of their particular plan. The Consulting Agreement describes the terms of our arrangement with the Sponsor, including a description of the investment fiduciary services

and the fees we charge. Sponsor must sign and submit the Consulting Agreement to us before we perform any investment fiduciary services. By signing the Consulting Agreement with us, Sponsor agrees that it has selected us as a fiduciary to the plan under ERISA Section 3(21)(A). When Sponsor signs an agreement with us, Sponsor also agrees that the services we provide are necessary for the operation of the plan and our fees are reasonable. B. Description of Investment Fiduciary Services As described in the Consulting Agreement, and as elected by Sponsor, we provide the following services: Nondiscretionary Investment Fiduciary Services: For each of the nondiscretionary fiduciary services described herein, we will solely be making recommendations to Sponsor, and Sponsor retains full discretionary authority to make the final decisions over the assets of the plan. We provide the following non-discretionary fiduciary services: 1. Investment Policy Statement: We will review with Sponsor the investment objectives, risk tolerance and goals of the plan. If the plan does not have an IPS, we will provide recommendations to Sponsor to assist with establishing an IPS. If the plan has an existing IPS, we will review it for consistency with the plan’s objectives. If the IPS does not represent the objectives of the plan, we will recommend to Sponsor revisions to align the IPS with the plan’s objectives. 2. Advice regarding Designated Investment Alternatives (“DIAs”): Based on the plan’s IPS or other guidelines established by the plan, we will review the investment options available to the plan and will make recommendations to assist Sponsor with selecting DIAs to be offered to plan participants. Once Sponsor selects the DIAs, we will, on a periodic basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the DIAs. If a DIA is required to be removed, we will provide recommendations to assist Sponsor with replacing the DIA(s). 3. Advice regarding Model Asset Allocation Portfolios (“Models”): Based on the plan’s IPS or other guidelines established by the plan, we will make recommendations to assist Sponsor with creating risk-based Models comprised solely among the plan’s DIAs. Once Sponsor approves the Models, we will provide reports, information and recommendations, on a periodic basis, designed to assist Sponsor with monitoring the Models. Upon reasonable request, and depending upon the capabilities of the record keeper, we will make recommendations to Sponsor to reallocate and/or rebalance the Models to maintain their desired allocations. Discretionary Investment Fiduciary Services: For each of the discretionary fiduciary services described below, we will exercise discretionary authority over the plan assets. Sponsor’s sole responsibility with respect to these services is to prudently select and monitor us, and we will select, monitor and replace the investments as described more thoroughly below. Section 402(c)(3) of ERISA allows Sponsor to delegate responsibility for selecting, monitoring and replacing plan assets to an “investment manager” that meets the requirements of Section 3(38) of ERISA. Section 405(d)(1) of ERISA provides that if an investment manager is properly appointed, then “no trustee shall be liable for the acts or omissions of such investment manager or managers, or be under an obligation to invest or otherwise manage any asset of the plan which is subject to the management of such investment manager.” We are registered as an investment adviser under the Investment Advisers Act of 1940 (the “Act”), and we have acknowledged our fiduciary status to the plan under ERISA. Therefore, we are qualified to serve as an investment manager under Section 3(38) of ERISA and we are doing so with respect to the following services: 1. Selection, Monitoring and Replacement of DIAs: We will review with Sponsor the investment objectives, risk tolerance and goals of the plan and provide to Sponsor an IPS that contains criteria from which we will select, monitor and replace the plan’s DIAs. Once approved by Sponsor, we will review the investment options available to the plan and will select the plan’s DIAs in accordance with the criteria set forth in the IPS. On a periodic basis, we will monitor and evaluate the DIAs and replace any DIA(s) that no longer meet the IPS criteria. Creation and Maintenance of Models: We will create a series of risk-based Models comprised solely among the plan’s DIAs; and, on a periodic basis and/or upon reasonable request, we will reallocate and rebalance the Models in accordance with the IPS or other guidelines approved by Sponsor.