Firm Description Trinity Investment Management, LLC (“Trinity”) is an independent investment management firm that was founded and began managing assets in 2005. Trinity began with a commitment to faith and social responsibility. Trinity developed the FFV Scorecard® to screen investments to protect the dignity of human life, support and protect employees and their families, and to reasonably safeguard the environment. The firm is an SEC Registered Investment Adviser under the Investment Advisers Act of 1940. Trinity is a Texas Limited Liability Company and has a principal place of business in Fort Worth, Texas. Trinity’s current advisory activities consist of providing investment management services for separate account clients, private funds, investment advisers and consultants. Principal Owners Spiritus Enterprises, Inc, a Texas corporation, has purchased the interest of IWP Holdings, LLC and is now the principal owner of Trinity. The Advancement Foundation of the Catholic Diocese of Fort Worth is the sole owner of Spiritus. Four other individuals also have minority ownership interests in Trinity, each representing less than 25% of the firm’s ownership. Types of Advisory Services Trinity offers investment supervisory services to clients. Many of these clients share Trinity’s social, moral and religious concerns in investing. Trinity provides services to guide in investing with purpose. These services may include the following: 1. Interviews of potential clients to determine goals, assess tolerance for risk, and establish cash flow requirements. 2. Agreement upon and preparation of an Investment Policy Statement to address these goals and needs. 3. Investment portfolio management according to the guidelines contained in the Investment Policy Statement. Investment due diligence as defined in the Investment Policy Statement. All mutual fund strategies managed by Trinity also are available as separate account strategies. 4. The asset management may be on a discretionary or non-discretionary basis. 5. Quarterly performance reports by post to client portal, mail or email. 6. Annual service meeting to review accounts, and update client profiles. 7. Phone or e-mail communications throughout the year to answer questions regarding the client

accounts. In addition, Trinity offers consulting with individuals and businesses on a case by case fee-for-service basis. Clients open an investment account at a custodial firm and shall grant a limited power of attorney to Trinity which will permit us to effectively carry out our duties as described in the Investment Policy Statement. Trinity may choose to work with a custodian suggested by the client at Trinity’s discretion. Selection of Other Advisers Trinity may direct clients to third-party investment advisers. Before selecting other advisers for clients, Trinity will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where Trinity is recommending the adviser to clients. Written Acknowledgement of Fiduciary Status 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. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Trinity does participate in any wrap fee programs. Assets Under Management Trinity manages approximately $114,823,110 of client assets on a discretionary basis as well as $0 of non-discretionary funds based on calculations as of December 2023.