ThirtyNorth Investments, LLC (hereinafter referred to as “the Company”, “we”, “us” and “our”) was founded in 1997. The Company is organized under the laws of the state of Louisiana. Advisean Partners, LLC ("Advisean"), is 94% owner, TNI Holdings, LLC is a 5% owner, and Latitude Holdings LLC is a 1% owner. Suzanne T. Mestayer is majority owner of Advisean and is the Managing Principal of the Company. Fritz Gomila is a majority owner of TNI Holdings, LLC and is a Principal of the Company. Sarah Bomhoff is a majority owner of Latitude Holdings, LLC and is a Principal of the Company. Services Offered 1) Discretionary Investment Management - The Company provides discretionary investment management services for individuals, high net worth individuals, individual retirement accounts, trusts, estates, non-profit organizations, and qualified retirement plans. We believe in a disciplined approach to investing that includes a strategic, global asset allocation. Our investment committee determines the overall global allocation of our portfolios and selects professional money managers and/or index- linked securities to implement the allocation. We do not attempt to time short-term movements in the financial markets and believe that asset allocation is the primary determinant of investor returns over time. Most of our discretionary accounts are invested in mutual funds, exchange-traded funds (ETFs), individual stocks, cash or cash equivalents, and structured notes. We determine each client’s investment objectives, time horizon, and risk tolerance before selecting the appropriate investments for that client’s portfolio. The Company also manages the Women Impact Strategy, a portfolio of the stocks of companies that are leaders in gender representation within Boards of Directors and executive teams. The strategy is actively managed to maintain gender benchmarks, established positive economic indicators, and to mirror the sector weighting of the Russell 3000 Index. 2) Non-Discretionary Investment Management – The Company offers non-discretionary investment management services to a limited number of clients. Because there are potential limitations to our ability to manage non-discretionary accounts, the performance of these accounts may vary from the performance of our discretionary accounts. We evaluate non-discretionary arrangements on a case-by-case basis and prefer to limit the number of non-discretionary account relationships. 3) Participant Account Management (Discretionary) - We use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. 4) Qualified Retirement Plan Consultant – The Company provides consulting services to qualified retirement plans such as 401(k) and profit-sharing plans. Our services include record-keeper evaluation and selection, assistance with third-party administrator (TPA) selection, plan design and feature review, investment line-up review and recommendations, and, in some cases, consultation with plan participants individually. We provide both ERISA 3(21) consultative services and/or ERISA 3(38) investment advisory services to our clients depending upon their needs. We believe that with proper plan design and appropriate participant education retirement plans are an excellent benefit capable of playing the anchor role in an employee’s retirement planning. Further, we believe the proper measure of plan success lies in the retirement readiness of its participants. 5) Financial Planning Services - We offer financial planning services to our investment advisory clients, which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our Company for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also

use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. We may outsource the processing of the data for the plan. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our Company and the data derived from the financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our Company if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through the accounts for which we provide investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. 6) Institutional Consultant - The Company offers customized services to meet the diverse needs of institutional clients. The company offers review and recommendations on investment policies, asset allocation analysis, investment manager search and evaluation, ongoing performance measurement, and rebalancing analysis as well as ancillary services as needed by clients. 7) Retirement Plan Benchmarking – The Company provides independent assessment reports that can be used by plan sponsors to determine if plan costs, features, investment options, participation rates, and compliance procedures are comparable to plans of similar size. 8) Rollover Accounts – 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. We benefit financially from the rollover of your assets from an ERISA account to an account that we manage or provide investment advice, because the assets increase our assets under management and our advisory fees. In contrast, we receive less or no compensation if assets remain in the current plan or are rolled over to another Company plan in which you may participate. We manage the investments for our clients in the same manner our owners, advisors, and staff manage many of their own investments. Discretionary money manager role - Building and maintaining investment models starts and continues with research on global economics, markets, and historical information. The information comes from a variety of sources including books, periodicals, websites, blogs, wire-houses, mutual fund companies, conference calls, and in person meetings at conferences and due diligence meetings. There are many investment management styles that we do not use when managing client portfolios but which may be beneficial to the client individually. Assets Under Management The assets under management for ThirtyNorth Investments, LLC total approximately $279,173,000 (balances on accounts currently managed as of December 31, 2023). Most of these assets are held at Charles Schwab & Co., Inc. (“Schwab”), Voya Financial, Ascensus Trust, TIAA, Met Life, Principal, Fidelity and Vanguard. Discretionary accounts total $192,921,000, and non-discretionary total $86,252,000. Included in these numbers are 401(k) participant accounts. Asset totals are calculated using end of month figures downloaded from custodians' websites and quarterly paper statements for a few smaller custodial relationships. Discretionary accounts are those where the client has given specific written authorization to the Company to select securities and execute trades on behalf of that client without obtaining prior consent. Discretion is convenient for clients and enables the Company to more efficiently manage investments.