A. Description of the Advisory Firm KG&L Capital Management, LLC is a Limited Liability Company organized in the State of Louisiana. The firm was formed in May of 2012, and the principal owners are Andrew A. Grezaffi III, Gabriel S. Kora III, and Christophe Francis Levasseur. B. Types of Advisory Services KG&L Capital Management, LLC (hereinafter “KG&L”) offers the following services to advisory clients: Investment Supervisory Services KG&L offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KG&L will offer both discretionary and non-discretionary portfolio management. Where KG&L has discretionary authority to place trade orders, it will select securities and execute transactions without permission from the client prior to each transaction. Where KG&L does not have discretionary authority to place trade orders, KG&L will secure client permission prior to effecting securities transactions for the client’s account. KG&L creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring KG&L evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Selection of Other Advisers KG&L will direct certain clients to third party money managers, specifically Farr, Miller & Washington. [Alabama and Mississippi clients, however, will not be directed to third- party advisers.] KG&L will be compensated via a fee share from the advisors to which it directs

those clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisors for clients, KG&L will always ensure those other advisors are properly licensed or registered as investment advisor. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services are based on hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. Services Limited to Specific Types of Investments KG&L generally limits its investment advice and money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, hedge funds, REITs, insurance products including annuities, private placements, and government securities. KG&L may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions KG&L offers the same suite of services to all of its clients. However, specific client financial plans 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) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. 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, transaction costs, fund expenses, and any other administrative fees. KG&L does not participate in any wrap fee programs. E. Amounts Under Management KG&L has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 349,222,805 $0 December 2023