Description of Winthrop Capital Management Winthrop Capital Management, LLC (“WCM”), offers investment advisory, investment sub-advisory and consulting services to pension and profit-sharing plans, corporations, insurance companies, Taft-Hartley plans, charitable organizations, foundations, endowments, trusts, other investment advisors and high net worth individuals. Clients retain WCM to manage and provide investment advice on their assets according to a specific investment strategy, or multiple strategies, based on their investment objectives and risk tolerance. WCM primarily serves individuals and institutional clients through financial intermediaries such as investment consultants and financial advisors (collectively, “Advisors”). WCM provides investment management services to clients of other advisors which are not affiliated with WCM. Those Advisors conduct their own independent due diligence of WCM. Advisors will offer all or some of WCM’s investment strategies to their clients. Some Advisors have entered into an advisory agreement with WCM, while others require WCM to enter into such agreements with the end client directly. In either agreement scenario in which an Advisor is involved, the Advisor typically remains WCM’s primary point of contact for related communications and updates to client or account information. When an Advisor is involved as an intermediary with a client of WCM, clients should be aware that WCM will not be provided with sufficient information from Advisors to perform an assessment as to the suitability of WCM’s services for their accounts. WCM relies on the Advisors who, within their fiduciary duty, must determine not only the suitability of WCM’s services for a client, but also the suitability of WCM. This also includes any assessment of whether a particular wrap platform is appropriate. WCM also has clients who have access to WCM’s investment advisory services directly. These clients may have designated authorized individuals to act on their behalf. Any such arrangements will have been designated in either the investment management agreement or in a separate written document. Types of Services Offered The services WCM provides include: 1. Investment Advisory Services – WCM continuously reviews client investment portfolios and implements changes based on WCM client's needs and objectives. WCM will assist certain qualified clients in selecting and investing in institutional quality, external investment managers for their portfolios. In addition, WCM may retain the use of an investment manager through a custodian’s “market place” designed to access investment managers for a specific engagement at a fixed fee. 2. Portfolio Models - WCM constructs and manages portfolio models for clients. Portfolio models are constructed utilizing a Risk Scoring methodology that combines various securities including mutual funds and ETFs, into an asset allocation based on an expected level of risk. The Risk Score incorporates the expected standard deviation of the specific securities as well as the correlation movement of the securities within the portfolio. Where appropriate to meet client goals, WCM may hire institutional quality external managers as sub-advisers as well as terminate the ongoing management of such firms as WCM deems necessary. 3. Sub-advisory Services - WCM offers its investment strategy and portfolio modeling services to other investment advisors on a sub-advisory basis. In such arrangements, WCM enters into a sub-advisory agreement with the investment advisor for WCM’s investment management services and the use of investment models and asset allocation strategies. WCM constructs an asset allocation and selects the underlying investments for each investment model portfolio based on client investment objectives provided by the investment advisor. Client accounts are generally managed via a third-party investment management platform (“Platforms”). Sub-advisory services may be on a discretionary or nondiscretionary basis depending on the sub- agreement. In a discretionary arrangement, WCM creates an investment model portfolio for a particular investment style, and based on that model, WCM exercises investment discretion over the transactions in the client accounts and is responsible for effecting

such transactions. In a nondiscretionary arrangement, the investment advisors receive WCM’s investment model portfolio for a particular investment style, and based on that model, the investment advisor exercises investment discretion over the transactions in the client accounts and WCM is responsible for affecting such transactions. WCM offers its investment services to registered investment companies on a sub-advisory basis. 4. Unified Management Account Programs - WCM offers its investment strategy and portfolio modeling services to Unified Management Account (“UMA”) programs. WCM constructs an asset allocation and selects the underlying investments for each investment model portfolio based on client investment objectives. The UMA program sponsor receives WCM’s investment model portfolio for a particular investment style and is responsible for effecting transactions in client accounts. WCM generally limits its portfolio modeling to mutual funds, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors) and non-U.S. securities. WCM may use other securities as well to help diversify a portfolio model when applicable. 5. Private Placements – Privately placed debt encompasses a wide variety of fixed income investments including corporate obligations, real estate related, project finance and asset-backed loans for midsize to large companies. It seeks to provide an enhanced yield over comparably rated public securities as well as access to issuers that are not available in the public market. Engaging WCM as a private placement investment manager is appropriate for sophisticated clients who can accept fluctuations in principal value and limited liquidity. 6. Specialty Services - WCM may provide independent investment advice, research and analysis that is outside of the traditional Investment Management Agreement and is designed to meet WCM’s client's goals and objectives. WCM’s investment consulting services are primarily focused on the insurance industry and assisting in risk examinations as an Investment Specialist for state Insurance Departments. In Addition, WCM offers customized specialty services including ERM Integration, Investment Policy Statement Review, Rating Agency Support, Peer Group Analysis, Tax Modeling, Liquidity Management, Insurance Regulatory Support, Income Forecasting, and Online Portfolio Reporting. WCM also offers its insurance clients access to structured securities, private credit, and commercial mortgage loans under investment management agreements separate from the management services described above. Through sub-advised relationships WCM offers a risk-controlled, actively managed approach to managing private placements and Commercial Mortgage Loans (1505 Capital Management & ACORE Capital, LP), and hedge funds (Indie Asset Management). Additional information about 1505 Capital, ACORE Capital, and Indie Asset Management is available on the Securities and Exchange Commission’s website at www.adviserinfo.sec.gov. How WCM Services are Tailored to Fit your Needs While many of WCM’s investment strategies are offered through Portfolio Models, many of WCM’s client’s portfolios are structured to meet their specific needs. WCM’s goal is to provide long-term investment performance results consistent with the risk tolerance and investment objectives of each client. Some of WCM’s clients impose restrictions on investing in certain securities or types of securities as outlined in their investment policy statement. In addition, some of WCM’s clients impose restrictions on the ability to realize gains or losses through the sale of securities within a certain period. Wrap Fee Programs As a money manager, WCM currently manages client portfolios through the wrap fee programs for Stifel Nicolaus (Horizon Program), Sanctuary Wealth (Separate Account Exchange), Morgan Stanley (Custom Solutions), and UBS Financial Services, Inc. (Managed Accounts Consulting Program). WCM is not a sponsor of a wrap fee program. Assets under Management As of December 31, 2023, WCM provides continuous management services for $3,796,348,151 in client assets on a discretionary basis, and $243,653 in client assets on a non-discretionary basis.