Fort Pitt Capital Group LLC (“Fort Pitt”) was formed in 2015 to carry on the traditions and values of its predecessor, Fort Pitt Capital Group, Inc., which was formed in 1995. Fort Pitt is managed by Michael Blehar, Theodore Bovard, J. Todd Douds, Jay Sommariva, Dan Eye and William Engel (“Fort Pitt Principals”), pursuant to a management agreement between FP Capital Management LLC and Fort Pitt. The Fort Pitt Principals serve as leaders and officers of Fort Pitt and are responsible for the management, supervision, and oversight of Fort Pitt, in perpetuity. Fort Pitt’s main office is in Pittsburgh, PA with locations in Harrisburg, PA and Bonita Springs, FL. Fort Pitt is part of the Focus Financial Partners LLC (“Focus LLC”) partnership. Specifically, Fort Pitt is a wholly owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Fort Pitt is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Fort Pitt. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Fort Pitt provides investment management services to clients on both a discretionary and non- discretionary basis. As of December 31, 2023: Discretionary Assets Under Management $5,146,228,824 Non-Discretionary Assets Under Management $ 9,797,377 Total $5,156,026,201 As a registered investment adviser subject to Section 206 of the Advisers Act, Fort Pitt acts as a fiduciary related to the conduct of its wealth management and advisory services. As such, Fort Pitt has obligations imposed by the federal and state securities laws. For example, clients have certain rights that cannot be waived or limited by contract. Nothing in Fort Pitt’s Investment Management Agreement should be interpreted as a limitation of the firm’s obligations under federal and state securities laws or as a waiver of any unwaivable rights that each client possesses. As a fiduciary, Fort Pitt must act in the best interest of its clients guided by the core duties of loyalty and care. In plain English, the duty of care means that Fort Pitt must provide advice that’s in clients’ best interest, seek the best possible execution of transactions and monitor clients’ investments over the course of their relationship with Fort Pitt. The duty of loyalty hinges on Fort Pitt making full and fair disclosure of any conflicts of interest so that clients can make an informed decision about whether to pay Fort Pitt to be their investment adviser. The rest of this document is designed to describe the firm’s policies and practices for adhering to the duty of care and the duty of loyalty. Fort Pitt’s first priority is protecting clients’ money by staying within the spectrum of acceptable risk based on each client’s specified risk tolerance – and doing so through highly personalized service. Fort Pitt believes that integrity, confidence, and respect are the cornerstones of any successful business relationship. Wealth management is a holistic set of services that includes Investment Management (described below) for both individuals and institutions and advice on matters such as asset accumulation, elder care costs, estate planning, education planning, business succession planning and/or insurance needs. When any person or entity engages Fort Pitt for wealth management, that client is assigned to a service team, led by a Financial Advisor. The service team is dedicated to the implementation of the firm’s investment philosophy in a manner consistent with the client’s investment objectives and risk tolerance. If/When a Financial Advisor leaves the firm, Fort Pitt will promptly contact all affected clients to provide new firm contact information and reassure them regarding the continuity of services provided by Fort Pitt. The management process begins with the Financial Advisor learning about the investment experience of the client and their goals for hiring Fort Pitt as their investment manager. Some clients want to engage the firm to provide the full investment planning experience while others may want Fort Pitt to manage only a portion of their overall investment portfolio. Taking into account the client’s wishes, Fort Pitt reviews the assets and investment accounts held by that client and provides recommendations on how to structure the client’s assets and accounts moving forward. The Financial Advisor looks at the client’s holdings as well as the type of accounts in which the securities are held. Fort Pitt’s recommendations regarding accounts/holdings to be maintained, opened, or closed will be documented as further described below. See also Rollover to IRA below. Fort Pitt has full discretionary authority over clients’ assets under management. The majority of client assets are contained in managed portfolios of securities that are actively invested by Fort Pitt. In addition, clients may hold certain non-managed accounts and/or segregated assets that are excluded from billing & reporting. Although not actively managed, these assets are included in the firm’s assets under management as they are considered by Fort Pitt as part of the overall financial condition of the client and they help to inform the recommendations made by Fort Pitt. Each service team periodically reviews clients’ non-managed positions and Fort Pitt will execute trades when deemed appropriate by the Financial Advisor and/or based on the wishes of the client. Non-managed assets can include real estate holdings, business equity, accrued retirement benefits, potential inheritances, illiquid securities, securities that have sentimental value and/or holdings of the children and grandchildren of the same family. Coordinating a client’s broad-based asset mix ensuring appropriate wealth preservation and liquidity while also optimizing growth, limiting risk and maintaining tax efficiency is a critical and ongoing wealth management function. Fort Pitt often works closely with a client’s extended family to set priorities and expectations regarding current and future wealth transfers to family members, charities, etc. Although Fort Pitt does not provide investment recommendations regarding options within the firm’s managed account strategies, the firm may utilize options on a limited basis for clients who hold concentrated positions in a single security. The purpose is to allow Fort Pitt to sell out of the position over time while limiting the tax impact of the transactions. Fort Pitt may also refer clients to other industry professionals (i.e., tax professionals, insurance professionals, attorneys, financial institutions) when expertise outside of that provided by Fort Pitt is needed. Such referrals can be made through UPTIQ Treasury & Credit Solutions and/or Focus Risk Solutions LLC (“FRS”). Please see Items 5 and 10 below for a fuller discussion of these services and other important information. Referrals may also be made to other individuals who are long-time industry professionals that Fort Pitt has worked with before and that have proven themselves to be knowledgeable in their field(s). When an introduction is made to an outside entity or individual, including any Fort Pitt affiliate, the client is not obligated in any way to retain the services of that service provider. Protection from Financial Exploitation: Fort Pitt strives to protect client assets from financial exploitation by educating employees (and clients) regarding red flags that indicate that an account (or a client) is being taken advantage of or targeted by an outside party, even if that party is a relative of the client. Fort Pitt encourages all clients to designate a Trusted Contact through their custodian for protection from financial exploitation. A Trusted Contact can be a trusted friend or family member that the custodian or Fort Pitt can contact in the event that financial exploitation is suspected. A Trusted Contact cannot place trades and doesn’t have any control over the account. Fort Pitt will not reach out to a Trusted Contact with basic questions about the account. Additional information can be provided upon request. Investment Management Services: Fort Pitt primarily manages client assets by utilizing one (or more) of three types of investments:
• Individual Equity Securities;
• Fixed Income Securities (taxable and tax free);
• Mutual Funds/Exchange Traded Funds (“ETF”); As described above, through discussions and the completion of a client questionnaire, Fort Pitt will assist clients in developing an Investment Plan based on their investment objectives and risk tolerance and then pursuing investment strategies and individual securities taking into account their investment timeline and anticipated distribution needs. Clients should expect to be fully engaged and periodically meet with or talk to their Financial Advisor regarding their holdings and the firm’s recommendations. Clients are also encouraged to keep Fort Pitt informed of any changes to their investment objectives and risk tolerance. Open, honest and ongoing communication among all parties is critical to a successful working relationship. Fort Pitt can also provide management services for a particular portfolio of securities as designated by the client. In these cases, a discussion typically occurs between the Financial Advisor and the client regarding the goals of the client for that particular portfolio and an investment strategy is selected. The firm’s recommendations and the strategy selected will be documented in writing by Fort Pitt and provided to the client. Whether an Investment Plan is created, or a strategy is selected for a particular portfolio, Fort Pitt will monitor the assets and provide ongoing management services to the client. Fort Pitt designs each client’s individual equity and fixed income portfolio (using different combination(s) of stocks, bonds, mutual funds and ETFs) to achieve performance results that will allow them to address their day-to-day needs while still pursuing their short-term and long- term goals. As further described in Item 12 below, Fort Pitt establishes, trims and/or eliminates positions on a pro rata basis across all like managed accounts. With respect to mutual fund/ETF investing, Fort Pitt engages in discussions with clients regarding their anticipated account balances and distribution needs and a good faith selection is made. Disclosures are provided at the time of investment to help clients understand the recommended investments and share classes being presented. Prior to making any mutual fund investment, clients and prospective clients should review the prospectus for a comprehensive understanding of the terms and conditions applicable to that fund. Fort Pitt uses its best efforts to select the share class that is the most cost effective for each client at the

time of investment unless otherwise instructed by the client. Please refer to Item 5 for more information. Clients have the ability to purchase/sell securities (including shares of any mutual fund) without retaining Fort Pitt as their investment adviser. Retaining Fort Pitt to provide investment management services costs more than clients doing independent research and investing on their own. Fort Pitt is committed to the “value add” that it provides and believes that the increased costs related to the management of client assets are justified. Fort Pitt encourages any prospective client to speak to an industry professional (at Fort Pitt or otherwise) about investment advisory and/or wealth management services in general and the costs and benefits associated with investing independently or through an investment adviser. At any time, clients may impose reasonable restrictions on their accounts. Examples of reasonable restrictions include the segregation of assets within an account so that the firm cannot buy or sell those securities or the setting of a capital gains budget. Although not recommended, a client may also wish to utilize margin within their account(s) and/or take out a loan using the securities within the portfolio as collateral. If, in the opinion of the Financial Advisor and/or Portfolio Managers, a restriction or client directed trade would subject the client’s portfolio to risks that are contrary to the investment strategy selected by them, the Financial Advisor will request additional information from the client and provide guidance regarding what Fort Pitt believes to be in the client’s best interest. If a mutual understanding cannot be reached as to the best way to invest the client’s assets, Fort Pitt may be forced to terminate the firm’s engagement with that client. Fort Pitt is not responsible for any gains or losses incurred by clients as a result of any restrictions and/or trades directed by them. Fort Pitt recommends that client assets be held in custodial accounts at Charles Schwab & Co., Inc. or Fidelity Investments. Retirement Investors: Fort Pitt is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and under Section 4975 of the Internal Revenue Code (“IRC”) with respect to investment management services and investment advice provided to ERISA plan clients (“Plan Sponsor”) including ERISA plan participants, IRAs and IRA owners (collectively “Retirement Investors”). The way that Fort Pitt makes money creates a conflict of interest so Fort Pitt must operate under a special rule that requires the firm to act in clients’ best interest and not put the firm’s interests ahead of its clients. As such, Fort Pitt is subject to specific duties and obligations under ERISA and IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid or eliminate conflicts of interest or rely upon an applicable Prohibited Transaction Exemption (“PTE”). Fort Pitt has chosen to rely on the PTE (2020-02) as provided by the Department of Labor. Rollover to IRA: When Fort Pitt recommends a rollover of Retirement Assets into an IRA or Roth IRA, the firm believes that the “value add” that it can provide with respect to those assets (described herein), justifies any increased costs related to the management of the Retirement Assets. Clients are required to sign a separate disclosure document when they wish for Fort Pitt to manage their retirement assets. Like any other advice provided by Fort Pitt, a rollover recommendation is based on the individual client’s needs and circumstances, including the risks and potential rewards associated with that recommendation. It should be noted; however, that a conflict of interest arises when Fort Pitt recommends to clients that they roll over their Retirement Assets into an IRA or Roth IRA that is managed by Fort Pitt. By recommending that a client roll over retirement plan assets to an IRA, even if there are no costs associated with the IRA rollover itself, Fort Pitt is entitled to earn investment management fees on the IRA account. Investing in a managed IRA with any investment adviser, including Fort Pitt, will typically be more expensive than investing through your retirement plan. Opening a new IRA as a brokerage account will also result in additional charges such as commission charges and fees charged by the underlying investments (i.e., equity, fixed income, mutual fund, ETF, etc.). Custodial and trading fees also apply. See Item 5: Fees and Compensation. In contrast, leaving assets in a retirement plan or rolling the assets to a plan sponsored by a new employer will likely result in little or no compensation to Fort Pitt. Therefore, Fort Pitt has an incentive to encourage investors to rollover retirement plan assets into an IRA managed by Fort Pitt. Investors considering rolling over assets from a qualified employer-sponsored retirement plan to an IRA should review and consider the advantages and disadvantages. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover retirement plan assets to an IRA; or (4) Cash out the retirement plan assets and pay the required taxes on the distribution. At a minimum, Retirement Investors must consider the factors regarding the fees and expenses, available investment options, management and/or advisory services to be provided, availability of penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and the ability to place transactions in employer stock. Fort Pitt encourages clients to discuss their options and review the above-listed considerations with an accountant, third-party administrator, investment advisor to their Employer Plan (if available), or legal counsel. If a client chooses to move forward with a rollover of Retirement Assets into an account managed by Fort Pitt, that client must acknowledge the conflicts described above before any such rollover occurs. Retirement Plan Assets Under Section 3(21) of ERISA, Fort Pitt provides Plan Level Non-Discretionary Investment Advisory Services regarding the asset classes and investment alternatives available within a retirement plan. Fort Pitt will provide recommendations to the Plan Sponsor who will retain the final decision-making authority regarding the selection, retention addition and removal of investment options. Fort Pitt provides educational resources and can provide individualized investment advice to plan participants regarding the allocation of their investments among the investment options. Under Section 3(38) of ERISA, Fort Pitt, through an agreement with a Plan Sponsor, provides model portfolios as options within the plan and has full discretionary authority over the management of the assets within those model portfolios. Fort Pitt can also be engaged to have full discretionary authority over the assets of the plan itself. Fort Pitt manages the investments within the plan and each model portfolio. Investment selections are made by the plan participants. Fort Pitt may provide investment advice on behalf of certain clients’ assets in held-away accounts (i.e., retirement assets) that are maintained at independent third party custodians. These held-away accounts are often 401K accounts, 529 plans and other assets that are not held by our primary custodians. In such cases, Fort Pitt’s advisory services are usually limited to providing advice to an individual retirement plan participant regarding the allocation of assets within their employer sponsored retirement plan using only the investment options (i.e., mutual funds) that are available to them. The plan participants retain the final decision-making authority regarding the recommendations provided by Fort Pitt. If accepted, the plan participate must generally place their own trades and/or reallocate their investments. Non-Fiduciary Services: Fort Pitt provides certain non-fiduciary services to Plan Sponsors and/or may arrange for the retirement plan’s service providers to offer services. Fort Pitt helps educate the Plan Sponsor regarding its fiduciary responsibilities and assists the Plan Sponsor in selecting and supervising the plan’s service providers. In addition, Fort Pitt provides services directly to retirement plan participants through group enrollment/educational meetings designed to increase plan participation and provide information regarding general investment principles. Fort Pitt Capital Total Return Fund: Fort Pitt serves as adviser to the Fort Pitt Capital Total Return Fund (the “Fund”) and makes the investment management decisions for the Fund’s portfolio. Although the assets of the Fund are managed in a manner similar to that of the firm’s managed stock portfolios, the specific guidelines that Fort Pitt uses on behalf of the Fund are described in the Fund’s prospectus. Fort Pitt will include the Fund in a client’s portfolio in accordance with its fiduciary duty and only if that investment is consistent with the investment objectives and risk tolerance of that client. Management of Annuities: On a limited basis, Fort Pitt provides investment advice with respect to annuities that are custodied at Charles Schwab and Fidelity. Although Fort Pitt can be designated as having full trading authority for these types of assets, the firm’s management is limited to allocating client assets among the investment options (i.e., sub-accounts) that are available to the annuity holder. UPTIQ Treasury & Credit Solutions: Fort Pitt offers clients the option of obtaining certain financial solutions from unaffiliated third- party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. Focus Risk Solutions: Fort Pitt offers clients the option of obtaining certain insurance solutions from unaffiliated third-party insurance brokers by introducing clients to our affiliate Focus Risk Solutions, LLC, a wholly owned subsidiary of Fort Pitt’s parent company, Focus Financial Partners LLC. Please see Items 5 and 10 for a fuller discussion of these services and other information. Community Involvement: Fort Pitt takes great pride in its ability to support and sponsor charitable organizations within the City of Pittsburgh and throughout the United States. In addition, Fort Pitt employees pride themselves on taking advantage of educational opportunities and being active within their communities by supporting local businesses. Fort Pitt employees have been asked to hold positions of control (i.e., board positions) with outside organizations that have a direct client relationship with Fort Pitt. When this has occurred, the conflict of interest has been disclosed to compliance and acknowledged/addressed as necessary by the employee and the outside organization. In addition, there are a handful of client relationships with non-profit organizations that Fort Pitt supports through charitable contributions/sponsorships. Such relationships are not material to the business of Fort Pitt and any such clients are not provided with favorable treatment by Fort Pitt.