i. General Description of the Firm Bristol Gate is an advisory firm that manages investment accounts of clients (“Clients”) with securities in separately managed accounts (including accounts in wrap fee programs), ETFs or private investment pooled funds. We have been in business since 2006 and have been organized under the laws of the Province of Ontario, Canada. Bristol Gate has been registered as a portfolio manager, exempt market dealer and investment fund manager under the Ontario Securities Commission (“OSC”) since 2006 and by the Autorité des marchés financiers (“AMF”- the Financial Markets Authority in the Canadian Province of Quebec) since 2014. The Firm has also been registered as a portfolio manager and exempt market dealer in the Canadian provinces of British Columbia, Alberta and Manitoba since 2014. Bristol Gate has been registered as an investment adviser with the United States Securities and Exchange Commission (“SEC”) since 2015. Bristol Gate is a privately held company, whose principal shareholder is Gerald (Richard) Hamm (who holds shares through a personal holding company, Cabot Ventures Ltd.). ii. Summary of Bristol Gate’s Advisory Services Bristol Gate specializes in dividend growth portfolios and has developed and manages strategies holding portfolios predominantly of United States equities (“US Strategy”) and, separately, predominantly Canadian equities (“Canadian Strategy”) (collectively the “Strategies”). It provides this expertise by managing Canadian domiciled private pooled investment funds and Canadian domiciled publicly traded ETFs for investors, acting as a subadvisor to other Canadian domiciled pooled investment vehicles (sponsored by third parties), offering portfolio management services to institutions and individual investors though separately managed accounts (“SMAs”) and by acting as portfolio manager to third party sponsored wrap fee programs in the United States. Bristol Gate also provides model portfolios for use by institutional clients (Bristol Gate is not responsible for arranging or effecting

the purchases or sales associated with such models). Our investment advice is currently limited to the investment strategies set forth above. iii. Client Tailored Services and Investment Restrictions Portfolio management services provided to Clients do not generally allow for Client-directed exceptions to the fundamental mandates we offer. Clients may be able to elect their own custodian and administrative services, subject to the account size being sufficient for Bristol Gate to manage its trading, settlement and reporting operations efficiently. In such instances, these restrictions would be fixed and agreed to prior to the execution of the investment management agreement and trading for the accounts. We do not manage Client’s accounts in securities other than those in our model portfolios. While we may accept client securities at time of initial account onboarding, any securities that do not form part of the Bristol Gate portfolio are subsequently sold. iv. Wrap Fee Programs Bristol Gate participates as a portfolio manager to four wrap fee managed account programs sponsored by two third-party financial institutions that are not affiliated with Bristol Gate. Participating clients pay a single fee covering the services rendered by both the unaffiliated investment advisor and Bristol Gate and Bristol Gate receives a portion of this fee for its services. Bristol Gate does not manage the accounts of clients participating in the program differently than accounts of other managed account clients as they invest in the same Strategies. Bristol Gate does not sponsor any wrap fee programs. v. Assets Under Management As disclosed in Bristol Gate’s Form ADV Part 1, Bristol Gate manages approximately $2,159,136,231 in Client regulatory assets under management on a discretionary basis. In addition, Bristol Gate also has approximately $212,557,086 in assets under advisement which represent model portfolio clients. These totals were calculated using the closing market prices, on March 31, 2024.