Palisade Capital Management, LP, a Delaware limited partnership (“Palisade” or the “Firm”), is an investment adviser registered with the United States Securities and Exchange Commission (the “SEC”) with its principal place of business located in New Jersey. Palisade began conducting business in 1995. Please note that registration with the SEC does not imply a certain level of skill or training. A. General Description of Advisory Firm Our History Palisade was founded in 1995 by Martin L. Berman, Steven E. Berman, and Jack Feiler. Current Senior Partner and Chief Investment Officer Dennison “Dan” T. Veru worked with the team from 1986 to 1992 and joined Palisade in 2000. Alison A. Berman joined the team in 2011, holding various positions until her promotion to President and Chief Executive Officer upon Martin Berman’s death in 2018. Today, as a woman-led organization and WBENC-Certified Women’s Business Enterprise, Palisade’s Operating Committee and senior management team continue to emphasize our core investment approach as the Firm strives to think, invest, and treat its clients in a manner that is fundamentally different from other asset managers. Palisade’s investment philosophy of comprehensive, bottom-up, fundamental investing has remained constant for over 25 years. The Firm has managed small cap core equity and convertible securities portfolios for institutional investors and private wealth management portfolios for high net worth individuals since the company’s inception. Palisade’s offerings have also expanded and evolved to meet the changing needs of its clients, including the development of alternative investment strategies through private funds. Today, Palisade’s diverse lineup of specialized investment solutions seeks to deliver attractive results to corporations, public plans, financial institutions, family offices, and individuals. Firm Ownership 100% of Palisade’s voting equity interests are owned by the Firm’s senior management team (and their families, primarily for estate planning purposes). These membership interests are owned through entities. Alison Berman is a “principal owner” of Palisade because she owns 25% or more of the Firm through Palisade Capital Holdings, LP and Palisade Capital GP, LLC. B. Description of Advisory Services Palisade provides investment supervisory services on a discretionary basis (and offers such services on a non-discretionary basis) to various types of clients as described below. Please refer to Item 7 for further information on the types of clients to which we provide our investment management services. Specialized Investment Strategies Palisade provides investment management services in the following investment strategies: Small cap core equity. Palisade’s small cap core equity strategy seeks to provide attractive risk adjusted returns by utilizing a research-intensive investment process that integrates bottom-up fundamental stock research with a conviction-weighted approach to portfolio construction. We seek to identify high-quality, attractively priced companies that consistently grow revenues, earnings, and free cash flow, with capitalization ranges generally within that of the Russell 2000® Index. Small-mid (“SMID”) cap core equity. Palisade’s SMID cap core equity strategy seeks to provide attractive risk adjusted returns by utilizing a research-intensive investment process that integrates bottom-up fundamental stock research with a conviction-weighted approach to portfolio construction. We seek to identify high-quality, attractively priced companies that consistently grow revenues, earnings, and free cash flow, with capitalization ranges generally within that of the Russell 2500® Index. Focused equity. Palisade’s focused equity strategy seeks to deliver attractive returns by investing in a concentrated portfolio of companies that compound shareholder wealth consistently over time. Palisade focuses on companies’ leadership teams and is discerning with regard to the integrity, philosophies, processes, visions, and capabilities of company leadership. Furthermore, the focused equity strategy generally invests in companies that generate superior free cash flow and return on invested capital, and effectively deploy capital to compound shareholder returns. Convertible securities. Palisade’s long-only convertible securities portfolios invest in convertible bonds and convertible preferred equity securities with the objective of capturing a significant portion of the upside return of equities (approximately 70%) while seeking to limit the downside exposure to the underlying equities (approximately 50%). We attempt to achieve this objective by trying to take advantage of two inefficiencies in the marketplace: mispriced stocks and mispriced convertibles. Short duration bonds. Palisade’s short duration bonds strategy seeks to generate asymmetric returns by investing in short-term domestic convertible bonds (defined as having a maturity or put date within three years or less from the date of purchase) within select price parameters. Palisade believes these securities are an under-utilized asset class and that a portfolio composed of short- term convertible bonds may offer investors liquid, low beta, low volatility-type exposures. The investment team seeks to invest in bonds that have a strong likelihood of repayment at maturity or put date and craft portfolios having overall attractive upside/downside capture ratios, attractive yields, and strong cash flows. Investment returns are expected to be driven by yield and the optionality inherent in short-term, out-of-the-money convertibles while the structural benefits of a short duration portfolio priced near par value seek to enhance capital preservation. Hedged convertibles. Palisade’s hedged convertibles strategy seeks to achieve attractive returns with lower volatility. Hedged convertibles portfolios generally seek to achieve capital appreciation predominantly by employing strategies that profit by extracting inefficiencies in the valuation of convertible securities. Palisade determines these inefficiencies based on fundamental views of the underlying equities and credits of convertible issuers. The hedged convertibles strategy typically entails the purchase of convertible bonds, preferred stocks, or warrants that are deemed to be undervalued in conjunction with the simultaneous short sale of the common stock and/or options into which they are convertible and, conversely, the short sale of convertible bonds, preferred stocks, or warrants that are deemed to be overvalued in conjunction with the simultaneous purchase of the common stock and/or options into which they are convertible. Portfolios seek to generate low correlated returns with low volatility and with an emphasis on risk management. Investment in Palisade’s hedged convertibles strategy is available only to certain accredited and/or qualified sophisticated investors. Types of Account Vehicles and Services Palisade offers to our clients the following types of advisory account vehicles. Please note that not all account vehicles are available to all investors: Separately Managed Accounts – Generally. Palisade provides continuous advice to institutional and individual private wealth management clients through separately managed accounts. We manage these accounts on a discretionary basis. Account supervision is guided by the client’s stated objectives, as well as tax considerations, if applicable. Clients can impose reasonable restrictions on investing in specific securities, types of securities, or industry sectors. Our investment recommendations generally include advice regarding the following types of investments (however not all investment strategies will incorporate all of the types of investments listed below):  Exchange-listed securities  Securities traded over-the-counter  Foreign issuers  Warrants  Corporate debt securities (other than commercial paper)  Municipal securities  Mutual fund shares  Exchange Traded Funds (“ETFs”)  United States governmental securities  Options contracts on securities  Options contracts on commodities  Cryptocurrencies, decentralized application tokens, protocol tokens, and other cryptofinance coins, tokens and digital assets and instruments that are based on blockchain, and distributed ledger or similar technologies (“Digital Assets”)  Separately managed accounts and private funds (including, but not limited to, hedge funds and private equity funds) managed by third-party advisers (such third-party managed investments being collectively referred to as “Underlying Investments” and such third- party advisers being collectively referred to as “Underlying Managers”). Because some types of investments involve certain additional degrees of risk, they will only be implemented and/or recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and suitability. Institutional Separately Managed Accounts. Palisade offers separately managed accounts on a discretionary basis to institutional clients in the following strategies, as described above:  Small cap core equity  Small-mid “SMID” cap core equity  Focused equity  Convertible securities  Short duration bonds  Hedged convertibles Private Wealth Management Individual Separately Managed Accounts. Palisade offers private wealth management services on a discretionary basis to high net worth individuals through separately managed accounts, based on the individual needs of the client. Through personal discussions that establish goals and objectives based on a client’s particular circumstances, we develop a client’s individual investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. Private wealth management separately managed account portfolios generally include the securities of individual issuers, however accounts may also utilize mutual funds, ETFs, Digital Assets, and/or investments in Underlying Investments (each of which may utilize a selection of the other asset classes described in Item 8 of this Brochure) to obtain an appropriate level of diversification. In some cases, private wealth management separately managed accounts may exclusively own mutual funds, ETFs, and/or investments in Underlying Investments. Based on the client’s goals and risk tolerance, the client will typically select one of the following investment objectives:  Growth – Palisade will seek to generate long-term capital appreciation. Portfolios will emphasize equity investments but may also utilize a selection of the other asset classes described in Item 8 of this Brochure, with a focus on those that provide the most potential for long-term capital appreciation.  Preservation of Principal / Income - Palisade will seek to preserve principal while generating current income. Portfolios will emphasize fixed income investments but may also utilize a selection of the other asset classes described in Item 8 of this Brochure, with a focus on investments that generate current yield.  Balanced / Conservative Growth - Palisade will seek long-term capital appreciation and the generation of current income. Portfolios may utilize a selection of the asset classes described in Item 8 of this Brochure to balance the opportunity for long-term growth with income generation. Additionally, certain private wealth management separately managed accounts may be invested in Palisade’s institutional investment strategies as described in Item 4 of this Brochure. Financial Planning. Palisade provides financial planning services through the Firm’s private wealth management program. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using known information and making certain assumptions to predict future cash flows, asset values, and withdrawal plans. Through the financial planning process, we consider various questions, information, and analyses that impact a client’s financial situation. Palisade gathers information through in-depth interviews and the collection of documentation, including (as appropriate) the client’s current financial status, tax status, future goals, return objectives, and attitudes toward risk. Palisade carefully reviews documents and information supplied by the client and typically prepares a detailed written report that includes our financial plan recommendations. Implementation of financial plan recommendations is at the client’s discretion. A financial plan typically addresses some or all of the following areas:  Personal – Palisade reviews household budgets, assets, liabilities, estate information, and financial goals.  Tax & Cash Flow – Palisade analyzes the client’s income tax and spending patterns (past, current, and future years) and illustrates the potential impact of various investment strategies on the client’s current and future income streams.  Investments – Palisade analyzes investment alternatives and their potential effect on the client’s portfolio.  Retirement – Palisade analyzes current strategies and investment plans to help the client achieve their retirement goals. Educational Seminars. Palisade provides complimentary investment-related educational seminars and workshops on various topics for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending upon the attendees’ needs and are purely educational and do not involve selling any investment products or securities. Palisade will only provide investment advice if engaged independently and only where the attendee’s individualized financial information, investment goals, and objectives are known. Materials provided are for general educational purposes and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Palisade or affiliates, or become a client. Palisade and its affiliates may share information from seminars and workshops consistent with the Firm’s privacy practices. Mutual Fund Management – Subadvisory Services. Our Firm, as a sub-adviser, provides discretionary portfolio management services to several mutual fund clients. Each portfolio is designed to meet a particular investment goal. Palisade currently provides these services to the following mutual funds (the “Mutual Funds”), all of which are registered under the Investment Company Act of 1940:  State Street Institutional Small-Cap Equity Fund  State Street Small-Cap Equity V.I.S. Fund As an investment sub-adviser to each of the Mutual Funds, Palisade is responsible for providing investment management services only for our allocated portion of assets for each Mutual Fund. Palisade’s investment teams utilize the institutional investment strategies described above (as applicable) when providing subadvisory services to Mutual Funds. Investors interested in investing in mutual funds subadvised by Palisade should refer to each Mutual Fund’s prospectus and Statement of Additional Information (“SAI”) for important information regarding objectives, investments, time-horizon, risks, fees, and additional disclosures. These documents are available as follows:  For the State Street Institutional Small-Cap Equity Fund: https://www.ssga.com/us/en/institutional/ic/funds/state-street-institutional-small-cap- equity-fund-service-class-ssqsx  For the State Street Small-Cap Equity V.I.S. Fund: https://www.ssga.com/us/en/institutional/ic/funds/state-street-small-cap-equity-vis-fund- class-1-sssex This portfolio is available only through variable products issued by unaffiliated entities. Prior to making an investment in any of the Mutual Funds, investors and prospective investors should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment in the Mutual Funds. Collective Investment Fund Management – Subadvisory Services. SEI Trust Company (the “SEI Trustee”) has retained the Firm to provide continuous investment advisory and administrative services to the SEI Trustee with respect to the management of the Palisade Capital Master Collective Investment Trust (the “Master Trust”). The Master Trust is a bank-maintained trust that holds the commingled assets of certain participating qualified corporate and governmental retirement plans, including certain defined benefit and defined contribution plans (“Eligible Plans”). Palisade presently serves as the investment adviser to the following separate investment portfolios of the Trust (each a “Collective Fund”) and may advise additional investment portfolios of the Trust in the future:  Palisade Capital Small Cap Core Collective Fund  Palisade Capital Small-Mid Cap Core Equity Collective Fund Palisade’s Small and Small-Mid Cap Core Equity investment team utilizes the institutional investment strategies described above when providing advisory services to the Collective Fund of the Master Trust. Eligible Plans

interested in investing in the Master Trust should refer to the Master Trust’s Declaration of Trust and Disclosure Memorandum for important information regarding objectives, investments, time-horizon, risks, fees, and additional disclosures. Prior to making an investment in a Collective Fund, investors and prospective investors should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment in a Collective Fund. Private Funds: Hedge Fund Portfolio Management. Palisade provides continuous advice on a discretionary basis to Palisade Strategic Master Fund (Cayman) Limited and its affiliated feeder entities Palisade Strategic Fund (Cayman) Limited and Palisade Strategic Fund (Domestic) LLC (collectively, the “Strategic Fund”), a private hedge fund utilizing the hedged convertibles investment strategy described above and described in the Strategic Fund’s private placement offering memorandum. Investments in the Strategic Fund are available only to accredited and/or qualified sophisticated investors and certain Palisade employees. Investment in the Strategic Fund involves a higher degree of risk than investments in the separately managed accounts (other than hedged convertibles separately managed accounts), the Collective Funds, or the Mutual Funds described above. For example, client investments in the Strategic Fund are less liquid. The Strategic Fund utilizes leverage and employs trading strategies involving a higher degree of risk, such as short selling and options. Though the Strategic Fund’s performance is intended to be less volatile because of the hedging strategies employed by the fund’s portfolio manager, there can be no guarantee the hedging strategies will work as intended. Please see Item 8 below for an additional description of the risks associated with investing in the Strategic Fund. Proprietary Accounts. Palisade may from time to time provide investment management services for proprietary accounts funded with seed capital of Palisade’s equity holders and/or other Palisade employees. Such accounts are utilized by the Firm to investigate and/or develop investment strategies that may be offered to Palisade’s clients in the future. Certain of Palisade’s employees, consultants, temporary workers, and interns retained/employed by the Firm having access to confidential client portfolio holdings information (or securities under consideration for client purchase) (all of whom are considered “Supervised Persons”) also invest in the Strategic Fund, if qualified to do so. Additionally, Palisade has established the Axe-Houghton® Associate Investment Fund, LLC (“AAIF”, and together with the Strategic Fund, the “Private Funds”) as a private fund to serve as an investment vehicle for Palisade’s Supervised Persons to invest in the Firm’s small cap core equity, small-mid (“SMID”) cap core equity, and focused equity investment strategies (each as described in Item 4 of this Brochure). Palisade may also incubate new investment strategies in AAIF that are not yet made available to the public. AAIF may trade alongside Palisade client accounts utilizing the “Bunch Trade” procedures described in Section B in Item 12 of this Brochure. Investment in AAIF is available solely to certain qualified Palisade Supervised Persons (or former employees) and their respective household family members (or entities owned or controlled exclusively by such Supervised Persons (or former employees) and/or their household family members). For purposes of the foregoing, “household family members” means the spouse (or the equivalent, e.g., domestic partner) and children of a Palisade Supervised Person who live in the same residence as the Supervised Person. Palisade serves as the Managing Member of, and investment manager to, AAIF, and receives no management or performance fee in connection for providing such services. Please see Item 5 of this Brochure for more information. Palisade’s management of a proprietary account, like AAIF, alongside client accounts creates numerous conflicts of interest. Please see Section F in Item 4, Item 10, and Section B in Item 11 of this Brochure for further information. C. Availability of Tailored Services for Individual Clients Palisade provides advice to client accounts based on specific investment objectives and strategies. Under certain circumstances, Palisade may agree to tailor advisory services for separately managed accounts to the individual needs of its clients. For example, separately managed account clients have the option to impose restrictions on investing in specific securities or certain types of securities. D. Wrap Fee Programs Our Firm provides investment management services as a portfolio manager to sponsored programs (and may provide such services to additional sponsored programs in the future) under which a client (i) enters into an agreement with a bank, a registered broker/dealer, or a financial service organization (each, a “Wrap Fee Sponsor”) that may also be registered as an investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) or (ii) enters into an agreement with both a Wrap Fee Sponsor and Palisade (an arrangement commonly referred to as “dual contract”). Such Wrap Fee Sponsors are not affiliated with Palisade. Under some programs, the Wrap Fee Sponsor charges clients a bundled fee (a “wrap fee”) based on a percentage of the market value of the account, which generally covers portions of or all services for: (i) selection or assistance in the selection of one or more investment advisers participating in the program, (ii) the investment adviser’s fee to manage the client’s portfolio on a discretionary basis, (iii) brokerage commissions, (iv) acting as custodian for the assets in the client’s portfolio which also includes providing the client with trade confirmations and regular statements, (v) periodic evaluation and comparison of account performance, and (vi) continuing consultation on investment objectives. These programs include separately managed wrap fee accounts and non-discretionary model portfolios. Each wrap fee and model portfolio is designed to meet a particular investment strategy. Depending on the structure of the program, wrap fee programs can be referred to as separately managed account (SMA), dual contract, or unified managed account (UMA) programs. Palisade manages wrap fee accounts on a discretionary basis and “model” portfolios on a non- discretionary basis. Model portfolios are typically associated with UMAs, where Palisade is responsible for sending portfolio holdings and transactions to the UMA sponsor (but where Palisade is not responsible for effectuating any trades for clients). Account management is generally pursuant to each Wrap Fee Sponsor’s stated investment strategy rather than on each client’s individual needs. However, some wrap account and dual contract clients can place reasonable restrictions on the types of investments to be held in their account. Such restrictions are agreed to between the wrap fee client and the Wrap Fee Sponsor. For providing its services in connection with most wrap fee programs, Palisade receives a portion of the wrap fee charged by the Wrap Fee Sponsor to wrap fee program clients. In the case of dual contract arrangements, clients may pay the investment management fee directly to Palisade. Palisade’s investment recommendations for wrap accounts and model portfolios are generally consistent with our recommendations for separately managed accounts utilizing the same strategy (as described above). One significant exception, however, is with regard to investors in wrap fee programs utilizing Palisade’s convertible securities investment strategy (none of which are currently active). Because of regulatory restrictions, such investors will not be eligible to accept allocations of “Rule 144A” securities, which are unregistered securities offerings that are available for purchase only by Qualified Institutional Buyers (“QIBs”). A QIB is an institution that manages at least $100 million in securities including banks, savings and loans institutions, insurance companies, investment companies, employee benefit plans, or an entity owned entirely by qualified investors. As a result of this restriction, wrap accounts utilizing our convertible securities investment strategy may have a higher concentration of non-Rule 144A securities (and less diversification in the account generally), which results in additional risk to the portfolio. Information on the wrap-fee program(s) for which Palisade provides investment management services can be found in Schedule D to Palisade’s Form ADV, Part 1A, which is periodically updated and available on the SEC’s website at https://adviserinfo.sec.gov. E. Client Assets Under Management As of December 31, 2023, Palisade had approximately $4.243 billion of regulatory assets under management, $4.241 billion of which was managed on a discretionary basis and $2.196 million of which was managed on a non-discretionary basis. F. Important Information Regarding Conflicts of Interest Like every investment adviser, Palisade and our Supervised Persons are confronted with various actual or potential conflicts of interest when we provide our investment management services. For example, as noted below in Item 5 of this Brochure, Palisade receives both asset-based and incentive compensation (i.e., performance-based) fees for managing different types of client accounts. The side-by-side management of accounts that are charged asset-based and/or incentive- based fees could create an opportunity for Palisade or its Supervised Persons to receive greater fees or compensation from accounts or funds that have an incentive fee structure over accounts or funds that have an asset-based fee structure. As a result, Palisade or its Supervised Persons have an incentive to direct the best investment ideas to, or to allocate, aggregate or sequence trades in favor of, or to otherwise favor (whether in terms of better execution, brokerage commissions, directed brokerage, or otherwise), the account or fund that pays an incentive fee. Please note that performance-based fees could create an incentive for Palisade to recommend investments which are likely to be riskier or more speculative than those which would be recommended under a different fee arrangement. Additionally, conflicts of interest can arise from different investment strategies taking varying positions. For example, a concurrent long/short position in the Strategic Fund, on one hand, and another client account, on the other hand, could result in a loss to one client based on a decision to take a gain for the other. Client accounts also could be invested in different components of an issuer’s capital structure (e.g., different classes of securities of the same issuer, debt securities versus equity interests, senior versus subordinated debt, or privately versus publicly offered investments). Taking concurrent conflicting positions in certain derivative instruments also may result in a loss to one client and a gain for another client. Uncovered option strategies and significant positions in illiquid securities will also result in conflicts of interest for Palisade and its Supervised Persons when managing incentive-fee accounts and funds side-by-side with asset- based fee accounts and funds. Similar potential conflicts of interest to those described above regarding incentive fee accounts and funds arise when Palisade is managing proprietary accounts or funds for Palisade or its Supervised Persons. Such proprietary accounts or funds include, but are not limited to, AAIF, in which Supervised Persons and certain of their respective family members invest (as described in Section B in Item 4 above). For example, Palisade and its Supervised Persons have an incentive to favor their proprietary accounts and funds over client accounts because of the financial interests that Palisade or its Supervised Persons have in such proprietary accounts. Examples of other actual or potential conflicts of interest can include, for example:  Conflicts relating to allocating time and resources between client accounts, and allocation of brokerage commissions, soft dollars, and investment opportunities generally. We have an incentive to favor proprietary accounts or client accounts with performance-based fees or other beneficial compensation arrangements. For further information on our brokerage and allocation policies, and related conflicts of interest, please refer to Item 12 of this Brochure;  Conflicts relating to investing client assets (including uninvested cash) in investment vehicles in which we, or our related persons, have an interest or serve as adviser or another service provider. We have an incentive to recommend these products. Please refer to Item 10 and Section B in Item 11 of this Brochure for further information;  Conflicts relating to receipt of compensation or benefits, other than advisory fees. We have an incentive to favor clients or non-clients that provide compensation (including, but not limited to, gifts and entertainment) to us over the interests of our clients who do not provide such compensation. Please refer to Item 14 of this Brochure for further information;  Conflicts relating to investing in securities recommended to clients and contemporaneous trading of securities (i.e., personal trading) by Palisade and our related persons. We have an incentive to invest or trade in ways that benefit us, or our related persons, over the interests of our clients. Please refer to Item 11 of this Brochure for further information;  Conflicts relating to cross trades between clients (where Palisade effects a purchase and sale of securities between client portfolios). We have an incentive to favor larger clients over smaller clients because of increased fees paid to Palisade by larger clients. For further information on our brokerage and allocation policies, and related conflicts of interest, please refer to Item 12 of this Brochure;  Conflicts relating to voting securities held in client accounts when we are delegated the authority to vote proxies. Conflicts may arise from time to time between the interests of Palisade, or our related persons, and our clients. Please refer to Item 17 of this Brochure for further information; and  Conflicts of interest relating to entertainment, gifts, sitting on boards of directors/trustees, charitable contributions, political contributions, and other relationships with third parties. We have an incentive to favor those with whom we have these relationships. See Section A of Item 11 of this Brochure for further information on our Code of Ethics. Actual or potential conflicts of interest generally can be addressed in a number of ways, such as one or more of the following, for example:  Prohibition – we prohibit the conduct that gives rise to the conflict of interest (e.g., insider trading is prohibited under our Compliance Manual);  Waiver – we give a benefit received to a client (e.g., when we advise a private fund and invest private wealth management separately managed account client assets in that fund, we do not charge the client two advisory fees);  Delegation – we engage a third-party to act or make a decision (e.g., we engage a proxy voting service);  Isolation – we construct information barriers to prevent a person from gaining knowledge that gives rise to a conflict (e.g., from time to time we isolate Supervised Persons from certain material non-public information);  Validation – we establish a benchmark for conduct that is designed to protect client interests or limit the benefit that creates the conflict of interest (e.g., if two Palisade clients engage in a cross transaction, a third-party broker-dealer may be utilized to determine a fair price for the trade);  Disclosure/Consent – we disclose the conflict of interest to our clients (e.g., we require solicitors to provide disclosure regarding solicitation fees paid to them by Palisade); or  Setting a De Minimis Threshold – we set a threshold for a benefit that is considered too small to influence conduct, and is therefore permitted (e.g., we set limits on entertainment, gifts, and political contributions under our Compliance Manual). Palisade has adopted a Code of Ethics as required under SEC rules (please refer to Section A of Item 11 of this Brochure for further information on our Code of Ethics). Palisade also has policies and procedures in place to mitigate and address the above-referenced conflicts of interest. Palisade’s policy is to manage incentive-based fee accounts and funds, as well as its proprietary accounts, consistent with applicable law, the client’s investment management agreement, and Palisade’s management of other client accounts and funds. Palisade has policies and procedures in place which it believes are reasonably designed to treat clients fairly and seek to prevent clients from being systematically favored or disadvantaged. Our compliance policies provide for review and testing of our policies and procedures no less frequently than annually as required by SEC rules. Clients should refer to the other sections of this Brochure noted above for more specific information on conflicts of interest and how they are addressed.