Description of Your Advisory Firm Promus Capital, LLC (“Promus Capital” or the “firm”), an Illinois limited liability company, was founded in May 2008. Promus Capital is wholly owned by Promus Holdings, LLC (“Promus Holdings”), whose principal owner is the Code Family Partnership, LP. Description of Advisory Services Offered Promus Capital is an investment advisory firm primarily offering a variety of services to individuals, high net worth individuals, trusts, retirement plans, charitable organizations, pension and profit sharing plans, corporations, and partnerships (collectively, “clients”). The services provided by Promus Capital generally include portfolio management services, financial planning, and reporting and family office services. Clients may engage Promus Capital for one, some or all of its various services. Portfolio Management Services Promus Capital generally offers its portfolio management services to clients through custom asset allocations or pursuant to model portfolio strategies. Portfolio management services may be provided on a discretionary or non-discretionary basis. Custom Asset Allocation Through its strategic allocation process, Promus Capital selects and weighs the asset classes for each client based upon appropriate levels of risk and return. Promus Capital participates in the selection, purchase, and sale of specific securities and/or selects third- party separate account managers to manage client accounts as part of an overall asset allocation methodology. Accounts may include, but are not limited to, cash, equity securities, fixed income, hedge funds, managed futures, private credit, private equity, real estate and real assets consistent with a client’s suitability, overall investment strategy, and risk tolerance. Depending on a client’s needs and objectives, Promus Capital may recommend and utilize affiliated and unaffiliated money managers (for more information, see “Promus Capital Affiliate Entities and Conflicts of Interest” below) to manage a portion of the client’s portfolio. Such money managers will manage client assets in a discretionary capacity that will allow the money manager to determine the type and amount of securities to be purchased or sold for the client with respect to the client’s assets managed by that particular money manager. Promus Capital’s asset management services are predicated on the strategic allocation of client assets among different asset classes with different levels of risk and return. Promus Capital will analyze each client’s current investments, investment objectives, goals, financial circumstances, investment restrictions and limitations, and risk tolerance, among other factors, and implement a portfolio consistent with such investment objectives, goals, risk tolerance, and related financial circumstances. Recommendations are tailored to meet the specific needs, goals, and objectives of the client. Due to varying degrees of personal and financial circumstances among clients who otherwise share a common level of risk tolerance, clients may have materially different compositions of portfolio assets. In addition, Promus Capital may utilize third-party software (e.g., Bloomberg, Morningstar, Pitchbook) to analyze individual security holdings and separate account managers utilized within the client’s portfolio. For certain clients, Promus Capital may prepare an investment policy statement based on the client’s investment objectives, goals, tolerance for risk, and such other factors unique to the client, and provide appropriate recommendations and implementation decisions. Generally, investment policy statements are created for clients who have multiple accounts, including trusts and corporate entities, with different investment objectives and goals and varying degrees of risk tolerance and tax sensitivity. Promus Capital’s investment advisory services take into account a client’s personal financial circumstances, investment objectives, and risk tolerance, among other factors. Generally, Promus Capital’s engagement with a client will include, as appropriate, the following:  Providing assistance in reviewing the client’s current investment portfolio against the client’s personal and financial circumstances as disclosed to Promus Capital in response to a questionnaire and/or in discussions with the client and reviewed in meetings with the firm;  Analyzing the client’s financial circumstances, investment holdings and strategy, and goals;  Providing assistance in identifying a targeted asset allocation and portfolio design;  Recommending a variety of securities including, but not limited to, public equities, mutual funds, exchange-traded funds (“ETFs”), separate account managers and, for appropriately qualified clients, privately placed pooled investment vehicles (including affiliated investment vehicles);  Reporting to the client on a triannual basis, or at some other interval agreed to with the client, information on contributions and withdrawals in the client’s investment portfolio and the performance of the client’s portfolio measured against appropriate benchmarks (including benchmarks selected by the client); and  Proposing changes in the client’s investment policy statement and investment portfolio in consideration of changes in the client’s personal circumstances, investment objectives and tolerance for risk, and the performance record of the client’s investments. In addition to providing Promus Capital with information regarding their personal financial circumstances, investment objectives, and tolerance for risk, clients are required to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio and to promptly notify the firm of any changes in such restrictions or in their personal financial circumstances, investment objectives, goals, and tolerance for risk. On a triannual basis, Promus Capital’s reports to clients will remind them of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of their accounts. Promus Capital will also contact clients at least annually to determine whether there have been any changes in a client’s personal financial circumstances, investment objectives, and tolerance for risk. Subject to any written guidelines that a client may impose, Promus Capital may be granted discretion and authority to manage the client’s account. Accordingly, Promus Capital is authorized to perform various functions, at the client’s expense, without

further approval from the client. Such functions can include the authority to manage client portfolios in accordance with and in securities as described in Item 8 of this Brochure. This authority would include the determination of the price of securities to be purchased or sold and the amount of securities to be purchased or sold. Once the portfolio is constructed, Promus Capital provides ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Promus Capital will obtain client approval prior to executing any transaction for non-discretionary accounts. Promus Capital may also recommend other advisers to manage a portion of a client’s account, including advisers affiliated with Promus Capital. Model Portfolio Strategies Promus Capital offers various model portfolio strategies. Promus Capital may provide the model portfolio strategies on a non-discretionary basis or manage a client’s account on a discretionary basis pursuant to a model portfolio strategy. The current model portfolio strategies are as follows:  Promus Core Equity - The Promus Core Equity strategy is designed to give clients low cost, tax efficient exposure to the global equity markets. By utilizing ETFs, this strategy has the flexibility to tilt the equity allocation to segments of the market that Promus Capital believes are relatively undervalued and away from segments that the firm believes are relatively overvalued. The investment team meets on a regular basis to discuss the strategies. If the investment team believes the equity market is overvalued as a whole, it may raise cash to deploy at more attractive prices.  Promus Large Cap Quality Growth - The Promus Large Cap Quality growth strategy seeks to produce attractive returns by investing in large capitalization companies which Promus Capital believes have superior business models, excellent financials, outstanding management teams and durable franchises.  Promus Core Income - The Promus Core Income strategy is designed to give clients efficient exposure to the global fixed income markets. There are two iterations of the global fixed income portfolio: one for taxable accounts and one for tax-exempt accounts. These portfolios will generally reflect the same convictions. Promus Capital has chosen to use tactical fixed income managers to tilt the portfolio to attractive sectors of the fixed income market while maintaining discipline around credit and interest rate risk. Financial Planning Services To the extent specifically requested by a client, Promus Capital will provide financial planning services (including investment and non-investment related matters). Financial planning services are typically provided as part of Promus Capital’s portfolio management services; however, Promus Capital may charge an additional fee for such services depending on the level of service provided and other considerations deemed relevant by Promus Capital in its sole discretion. Prior to engaging Promus Capital to provide these services and to the extent a client has not entered into an investment advisory agreement (also referred to as an investment management agreement) with Promus Capital, clients are generally required to enter into an agreement setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Promus Capital commencing services if applicable. Family Office Services Promus Capital also offers certain reporting and family office services designed to help family office clients organize their financial situation. The services provided will vary on a client-by- client basis and may include, for example, the following:  Financial planning and investment consulting;  Risk management;  Investment monitoring and/or reporting;  Legacy services; and  Cash flow management. Investment Advisory Services to Retirement Plans and Plan Participants Promus Capital may also provide investment advisory services to retirement plans (“Plan”) or retirement plan participants (“Participants”). Promus Capital may prepare personal asset allocation targets after obtaining and evaluating information concerning their individual client circumstances provided by each Participant in response to a risk profiling questionnaire. Promus Capital may provide recommendations as to an appropriate asset class structure and/or securities from a list of securities approved by the plan sponsor (“Sponsor”). The asset allocation and mutual fund recommendations made to such clients may differ from those made by Promus Capital to high net worth and affluent individuals and institutions for one or more of the following reasons:  A Participant’s asset allocation target typically consists of a smaller number of asset categories to reflect the relatively smaller size of the Participant’s investment assets.  The Sponsor has constrained the investment alternatives from which Promus Capital may make recommendations. In such cases, Promus Capital may be required to observe quantitative criteria established by the Sponsor in preparing Participant-oriented lists of mutual funds, or to confine the advice given to choices among a relatively narrow set of investment alternatives established by the Sponsor. Participants are informed when the Sponsor of the group imposes constraints on Promus Capital’s ability to recommend mutual funds or other securities. Client-Tailored Services and Client-Imposed Restrictions Where Promus Capital has investment discretion over a client account, the account will be managed in accordance with the client’s financial situation, investment objectives, and any reasonable client restrictions. Promus Capital will remind clients to inform the firm of any changes to their personal financial circumstances, investment objectives, or risk tolerance, and any modifications or restrictions that should be imposed on the management of their accounts. Promus Capital will also contact clients at least annually to determine whether there have been any changes in a client’s personal financial circumstances, investment objectives, and tolerance for risk. Client Assets Under Management As of December 31, 2023, Promus Capital advises $1,410,633,377 of regulatory assets under management, which includes approximately $369,416,408 of discretionary assets under management and approximately $1,041,216,969 of non-discretionary assets under management.