A. Description of the Advisory Firm Clarion Advisors Inc. (hereinafter “CAI”) is a Corporation organized in the State of California. The firm was formed in January 2009, and the principal owner is Marshall Goins. B. Types of Advisory Services Portfolio Management Services CAI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CAI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring CAI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CAI will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CAI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CAI’s economic, investment or other financial interests. To meet its fiduciary obligations, CAI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CAI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CAI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments CAI generally limits its investment advice to mutual funds, real estate funds, equities, ETFs (including ETFs in the gold and

precious metal sectors) and treasury inflation protected/inflation linked bonds. CAI may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status 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. C. Client Tailored Services and Client Imposed Restrictions CAI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. CAI does not participate in wrap fee programs. E. Assets Under Management CAI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $105,492,000 $0 March 2024