Copeland Capital Management, LLC (“Copeland” or “CCM”) is headquartered in Conshohocken, Pennsylvania. Copeland was initially founded in 2005, as a Massachusetts limited liability company and state-registered investment adviser with an office in Wellesley, Massachusetts. Copeland changed its registration from a Massachusetts-registered investment adviser to a SEC- registered investment adviser in 2007. The inception of Copeland’s “dividend growth” strategy was in 2006. In 2009, Copeland became a Delaware limited liability company and moved its headquarters to Conshohocken, Pennsylvania as the firm brought on additional partners and expanded its investment capabilities. Copeland is 100% employee-owned, and ownership is shared broadly among employees. As of January 31, 2024, Copeland managed $4.77 billion of assets on a discretionary basis. (“Assets Under Management” or “AUM”). As of January 31, 2024, Copeland provided services for $3.34 billion in assets in a “non- discretionary” capacity. These assets are generally referred to as “Assets Under Advisement” or “AUA” and represent assets for which Copeland serves as a model portfolio provider, as described in Item 4. Copeland does not have discretion or trading authority over these assets. Advisory Services and Tailoring Services to Client Needs Copeland provides investment management services to individuals, investment companies registered under the Investment Company Act of 1940, as amended (“1940 Act”), pension and profit-sharing plans, trusts, estates, charitable organizations, state and municipal government entities, corporations and business entities, pooled investment vehicles, as well as others (see Item 7 for additional information). Copeland offers its services for a fee based upon assets under management. Prior to engaging Copeland to provide investment advisory services, the client will be required to enter one or more written investment management agreements (“IMA”) with Copeland setting forth the terms and conditions under which Copeland shall render its services. We typically manage accounts on a discretionary basis; however, we will manage client accounts on a non-discretionary basis subject to client instruction. Individual client investment constraints, if any, shall be set forth by the client in the IMA. Investment advisory services are provided to clients based on the objectives of the client and mutually agreed upon written investment guidelines submitted by the client or client’s representative. Clients can impose restrictions on investing in certain securities or types of securities at any time. Copeland’s clients are advised to promptly notify Copeland if there are ever any changes in their investment objectives or if they wish to impose or remove any reasonable restrictions upon Copeland’s investment management services. For clients that participate in Copeland’s discretionary investment management services, Copeland requires such clients to grant our firm discretionary authority to manage the account. Discretionary authorization will allow Copeland to, among other things, execute transactions on behalf of the account, allocate, and rebalance the account portfolio(s) without client approval prior to each transaction. Discretionary authority is typically granted by the IMA. Clients may limit Copeland’s discretionary authority (for example, limiting the types of securities that can be purchased for the account) by providing Copeland with account restrictions and guidelines in writing. For clients that enter non-discretionary arrangements with Copeland, written approval is required by clients prior to executing any transactions on behalf of the account, including allocating, rebalancing and/or withdrawing account assets on behalf of the client. Copeland employs a conservative and disciplined investment philosophy and approach, which is consistently implemented across all strategies, as described below. Copeland’s Domestic Strategies Large Cap Dividend Growth – the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. Mid Cap Dividend Growth - the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. Smid Cap Dividend Growth - the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. Small Cap Dividend Growth - the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. Micro Cap Dividend Growth - the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. All Cap Dividend Growth - the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. Large Cap Dividend Growth Stop Loss - the strategy invests in stocks with market cap range that reflects its benchmark, focused on companies demonstrating the strongest dividend growth and relative valuation. In addition, the strategy has a relative stop loss feature to attempt to minimize losses in individual stocks. Fixed Income / Balanced - the strategy invests in issues of high-quality securities with an intermediate term focus. Balanced allocation flexible based on market activity and client objectives. Copeland’s International Strategies International All Cap Dividend Growth - the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. International Small Cap Diversified Dividend Growth - the strategy invests in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. Global Equity Dividend Growth (Global All Cap and Global Small Cap Dividend Growth) - the strategies invest in stocks with a market cap range that reflects its benchmark, focused on companies with consistent dividend growth. International All Cap Dividend Growth ADR – the strategy invests in domestically traded American Depository Receipts (ADRs) of international equities, focused on companies with consistent dividend growth. Investment Adviser to Copeland Trust Copeland serves as the investment adviser to the Copeland Trust, an investment company registered with the SEC under the 1940 Act. There are currently three (3) funds in the Trust - the Copeland Dividend Growth Fund (the “Dividend Growth Fund”), the Copeland SMID Cap Dividend Growth Fund (the “SMID Cap Fund”), and the Copeland International Small Cap Fund (the “International Fund”) (collectively, the “Funds” or “Copeland Funds”). Services provided by Copeland include the selection of investments per the Funds’ investment objectives, policies, and restrictions. The Dividend Growth Fund is available in Class A, C and I shares; the SMID Cap and International Funds are available in Class A and I shares. Other Types of Investments If appropriate, Copeland will provide advice about exchange traded funds (ETFs) and any type of investment held in a client’s portfolio at the beginning of the advisory relationship. If a client requests a security in their account at the start of our investment advisory relationship continue to be held in their account, even though Copeland would not purchase and hold that security in the strategy selected, Copeland would mark the security as “unsupervised”. We would not include the “unsupervised” asset(s) in Copeland’s assets under management and advisory fee calculations or performance, and Copeland would generally not offer investment advice on the “unsupervised” asset(s). Generally, clients will receive written quarterly evaluations of their account(s) accompanied by an analysis of performance. However, clients are urged to refer to their custodian statements for current valuations, as custodians utilize settlement date for trades versus our valuations, which are based on trade date. Any information about an “unsupervised” security would also be included in the custodian statement. Copeland is also available for periodic meetings at the request of the client. Sponsored Advisory Accounts - Wrap Fee Programs Copeland offers investment supervisory services on a discretionary basis to clients under wrap fee programs (the “Program(s)” or “Wrap Fee Program(s)”) sponsored by third party investment advisers, broker-dealers or other financial services firms (the “Sponsor(s)”). Depending on the structure of each Program, a client may enter into a contract with Copeland and/or the Sponsor. In most Programs, the Sponsor is responsible for establishing the financial circumstances, investment objectives and investment restrictions applicable to each client. The client’s Program agreement with

the Sponsor generally sets forth the services to be provided to the client by or on behalf of the Sponsor, which can include, among other things: (i) asset manager selection; (ii) trade execution, often without a transaction-specific commission or charge; (iii) custodial services; (iv) periodic monitoring of investment manager; and (v) performance reporting. Clients are generally charged by the Sponsor a comprehensive “wrap fee” based upon a percentage of the value of the assets under management to cover the Program’s services. The wrap fee often, but not always, includes the advisory fees charged by Copeland (or other managers) through the Program. Where the services are included in the wrap fee, the Sponsor typically collects the wrap fee from the client and remits the advisory fee to Copeland (or other participating managers). In certain Programs, clients also may be required to execute a separate agreement directly with each investment manager, such as Copeland, or the investment manager may be made party to the client/Sponsor agreement (“Dual Contract Programs”). In Dual Contract Programs, Copeland’s fee is typically paid directly by the client pursuant to a separate agreement between Copeland and the client. Clients participating in Programs may also be subject to additional fees, expenses and charges (e.g., commissions on transactions executed by a broker-dealer other than the Sponsor or the Program’s designated broker-dealer(s), expenses with respect to investment in pooled vehicles (such as ETFs and money market and other registered investment companies), dealer mark-ups or mark-downs on principal transactions, and certain costs or charges imposed by the Sponsor or a third-party, such as odd-lot differentials, exchange fees and transfer taxes mandated by law). Participants in the Programs may pay a higher aggregate fee than if investment management, brokerage, custodial, and other services are paid for separately. The complete schedule of the wrap fees is set forth in each Sponsor’s brochure related to the Program. The Sponsors’ brochures and this brochure are generally provided by the Sponsors to clients of the Programs prior to or concurrent with their engagement in the Programs. Generally, the client may terminate their agreement with Sponsors and Copeland at will. Termination clauses vary, and clients are advised to read each Program’s’ brochure thoroughly prior to investing. The Program brochure for each Sponsor is available through the SEC’s website at https://www.adviserinfo.sec.gov. The Programs in which Copeland participates are identified in Copeland’s ADV Part 1. Aside from differences such as fees and the ability to select broker-dealers to execute trades, the accounts are managed in the same manner as other accounts at Copeland. The Sponsors are responsible for client interaction. Model Delivery Arrangements Copeland provides investment recommendations in the form of a model portfolio to a Sponsor or third-party firms such as Unified Managed Account (“UMA”) platforms and other registered investment advisers, who then utilize all or part of the model in managing their clients’ accounts (collectively, “Model Programs”). With regards to Model Programs, Copeland provides model portfolios and any updates to the model portfolios to Model Programs in exchange for a fee. The Model Programs will then utilize the model to invest their clients’ accounts. Copeland does not receive client-level information in the majority of these relationships and any client information which passes through to Copeland is not used by Copeland in the model delivery process. Copeland’s obligation in these relationships is to provide updated model allocations in a timely manner for the strategy or strategies outlined in a written arrangement. While an account can be formatted as a separately managed account within these model delivery relationships, Copeland does not have trading authority over these accounts as it does for the discretionary accounts described above. Another common account structure in model delivery arrangements is the UMA. The UMA structure has a single account consisting of multiple strategies instead of a single strategy. The strategies will be a combination of Copeland’s strategies and other investment managers’ strategies. The implementation of the strategy and continual servicing of your account in these relationships is handled by the platform or adviser. Copeland will send notification to the Model Programs when their placement in the Copeland trading rotation arrives but may not wait for the Model Programs to complete their trading (as further detailed below) before moving on in the rotation. We do not offer any additional services to Model Programs; the Sponsor is responsible for all trading and client interaction. Model Programs accounts’ assets are not included in Copeland’s regulatory assets under management. The assets are considered “assets under advisement”, which, as of January 31, 2024, totaled approximately $3.34 billion. These assets are not considered discretionary or non-discretionary assets under management. The recommendations implicit in the model portfolios provided to the Sponsor may reflect recommendations being made by Copeland contemporaneously to, or investment advisory decisions made contemporaneously for, similarly situated discretionary clients of Copeland. Thus, Copeland may have already commenced trading for its discretionary client accounts before the Sponsor has received or had the opportunity to evaluate or act on Copeland’s recommendations. In this circumstance, trades ultimately placed by the Sponsor for its clients will be subject to price movements, particularly with large orders or where the securities are thinly traded, that may result in Model Program clients receiving prices that are more or less favorable than the prices obtained by Copeland for its discretionary client accounts. On the other hand, the Model Program Sponsor may initiate trading based on Copeland’s recommendations before or at the same time Copeland is also trading for its discretionary client accounts. Particularly with large orders or where the securities are thinly traded, this could result in Copeland’s discretionary clients receiving prices that are less favorable than prices that might otherwise have been obtained absent a Model Program Sponsor’s trading activity. Because Copeland does not control the Sponsor’s execution of transactions for the Sponsor’s client accounts, Copeland cannot control the market impact of such transactions to the same extent that it would for its discretionary client accounts. Where Copeland participates in Model Programs, the Model Program Sponsor is responsible for investment decisions and performing many other services and functions typically handled by Copeland in a traditional discretionary managed account program. Depending on the facts and circumstances, Copeland may or may not have an advisory relationship with model-based program clients. To the extent that this Form ADV Part 2A is delivered to program clients with whom Copeland has no advisory relationship, or under circumstances where it is not legally required to be delivered, it is provided for informational purposes only. Furthermore, because a Model Program Sponsor generally exercises investment discretion and, in many cases, brokerage discretion, performance and other information relating to Copeland’s services for which it exercises investment and/or brokerage discretion is generally provided for informational purposes only and may not be representative of model-based program client results or experience. Copeland is not responsible for overseeing the provision of services by a Model Program Sponsor and cannot assure the quality of its services. Multi-Asset Manager Strategies Copeland does not offer or provide customized portfolios to Model Program participants. However, on occasion Copeland may offer or provide to certain multi-asset managers customized analysis, portfolio development and investment management services focused on achieving specific strategy objectives. The customized multi-asset strategy draws from Copeland’s Small cap, Smid cap, Large cap and International investment opportunities, using our domestic and international research coverage. The custom strategies focus on strategic and tactical asset allocation and fundamental security selection. Potential conflicts of interest can arise because favorable portfolio decisions regarding the custom strategy may benefit these client(s) over other clients. To overcome these conflicts, Copeland will devote as much time to each investment strategy, investment product or advisory account as Copeland deems appropriate to perform its duties in accordance with its management agreements and fiduciary duties.