Kellogg Asset Management, LLC (Kellogg) has been an investment adviser registered with the Securities and Exchange Commission since 2009. It was organized to focus on the unique needs of institutional clients. Kellogg is a wholly owned subsidiary of Associated Trust Company, N.A. (ATC), an affiliated banking institution with trust powers. ATC is a wholly owned subsidiary of Associated Bank, N.A. (AB). AB is a wholly owned subsidiary of Associated Banc-Corp (AB-C). AB-C is a diversified bank/financial services holding company headquartered in Green Bay, Wisconsin. Kellogg provides advisory services to its affiliates and to third parties. Fixed Income Management Services Kellogg provides fixed income investment management solutions to serve the financial needs of institutional investors and high net worth investors. Kellogg’s goal is to deliver competitive investment performance in a risk-controlled framework to a variety of clients, such as, corporations, foundations, insurance companies, municipalities, as well as high net worth individuals. Kellogg provides investment analysis, security selection and trade execution for each portfolio it manages. Safety, liquidity and yield are Kellogg’s primary considerations when making investments in bonds. Yield curve positioning, duration management and sector rotation are tools Kellogg utilizes to minimize risk while seeking to maximize return. The relative attractiveness of various sectors and a bottom-up analysis of specific securities are key factors in portfolio construction. Kellogg uses the following types of investments in carrying out its various fixed income investment strategies: corporate debt securities, United States government securities, mortgage-backed securities, asset-backed securities, municipal securities and other types of investment grade securities. Clients are responsible for informing Kellogg, in advance and in writing, of any restrictions on investing in certain securities or types of securities. Kellogg may implement strategies and invest in types of investments other than those listed above for client accounts, depending on a particular client’s investment objectives and financial needs. Equity Management Services Kellogg provides equity investment management solutions to serve the financial needs of institutional and high net worth investors. Kellogg’s goal is to deliver competitive investment performance in a risk-controlled framework to a variety of clients, such as corporations, foundations, insurance companies, as well as high net worth individuals. Kellogg provides investment analysis, security selection and trade execution for each portfolio it manages. Regular meetings are held with clients or their advisors to review the investment objectives and constraints. Kellogg’s goal in managing equities is to provide growth of capital in a risk-controlled framework. We assemble a portfolio of companies where our positive fundamental view differs from consensus, with the belief that subsequent events will validate our investment thesis and the stock price will move toward our assessed value. Kellogg uses the following types of investments in carrying out its various equity investment strategies: common stocks, ADRs, and ETFs, as well as options strategies to enhance income or provide downside protection. Clients are responsible for informing Kellogg, in advance and in writing, of any restrictions on investing in certain securities or types of securities. Kellogg may implement strategies and invest in types of investments other than those listed above for clients’ accounts, depending on a particular client’s investment objectives and financial needs. Actively Managed Outside Manager Investment Services Kellogg’s actively managed outside manager investment services includes the Associated

Select Advisor Portfolio (ASAP) program, the Associated LifeStage collective funds, and Health Savings Accounts. The services offered by Kellogg include the selection, analysis and monitoring of outside investment managers used in various model portfolios and recommended lists. Selection of third-party mutual funds is based in part, but not limited to, management style, manager experience, consistent application of a philosophy, and long-term performance. Associated Select Advisor Portfolio Program Kellogg uses third-party mutual funds to build diversified portfolios that can meet a wide variety of investment objectives and risk tolerances. Kellogg’s ASAP program offers six investment strategies that range from Aggressive Growth to Conservative Balanced, each of which is described in more detail herein. Kellogg uses third-party mutual funds when developing these strategies. Kellogg has entered into a license agreement with Envestnet Asset Management, Inc. and its legal affiliates (Envestnet) pursuant to which Kellogg licenses the ASAP models to Envestnet for inclusion on Envestnet’s Third Party Models Program. In the future, Kellogg may enter into similar arrangements with other third-party platform providers (Third-Party Platforms). As a result, advisors and other financial institutions (Third-Party Advisors) may engage Third-Party Platforms to directly trade their assets pursuant to the ASAP models. Kellogg will act as a manager of the ASAP program, and will be responsible for providing the ASAP models, including periodic updates, to the Third-Party Platforms. In return for these services, Kellogg receives a portion of the wrap fee charged to clients. Clients with ASAP program accounts will be advisory clients of those Third-Party Advisors who access the ASAP models through a Third-Party Platform. Associated Investment Services, Inc. (AIS), an affiliated registered investment adviser and indirect wholly-owned subsidiary of AB-C, provides its advisory clients access to the ASAP program through Envestnet’s Third Party Models Program as a Third-Party Advisor. In addition to providing the ASAP program through Third Party Platforms, the ASAP program is also available to clients of ATC directly. Associated LifeStage Collective Funds Kellogg is the manager of the Associated LifeStage collective funds of Associated Trust Company, N.A. (ATC), an affiliated banking institution with trust powers. Associated LifeStage collective funds are available solely to clients of ATC. LifeStage collective funds sponsored by ATC are only used in ATC products. Health Savings Accounts Kellogg provides investment advice to AB in connection with the Health Savings Accounts (HSAs) for which AB serves as custodian. In this role, Kellogg is responsible for recommending and monitoring the mutual funds available for investment in an HSA. In return for these services, Kellogg receives a portion of the fee charged by AB to its clients. Asset Allocation and Portfolio/Model Management Services Kellogg also offers custom asset allocation strategies. These strategies use a diversified portfolio of bond and/or stock mutual funds to create a mix of assets targeted to a specific risk tolerance. Each strategy varies in its degree of risk and potential return. To maintain a particular asset allocation strategy, portfolios must be periodically rebalanced. In addition to providing various asset classes (stocks, bonds, cash) and market capitalization (large, mid, and small company stock funds), the strategies also provide diversification by blending growth and value investment styles. Assets Under Management As of December 31, 2023, Kellogg had discretionary assets under management of $2,508,796,355 and non-discretionary assets under management of $6,750,121.