IRONSHORE FINANCIAL, LLC (“IRONSHORE”) provides pension consulting services to qualified retirement plans. IRONSHORE is registered with the United States Securities and Exchange Commission, and the principal owner is Dean Speer. IRONSHORE provides investment services to sponsors of qualified retirement plans as a fiduciary advisor or fiduciary investment manager as those terms are defined by the Employee Retirement Income Security Act of 1974, as amended (“ERISA). Pension Consulting Services IRONSHORE provides investment and fiduciary consulting to qualified retirement plans and their sponsors. Generally, these plans will provide for participant-directed investments limiting the scope of IRONSHORE’s investment service to discretionary or non-discretionary actions related to the options made available for the participants’ selection. As of December 31, 2022, IRONSHORE was contracted to deliver pension consulting services to 23 clients covering plan assets of about $930 million. These services typically include:  Preparation and maintenance of an Investment Policy Statement (“IPS”)  Initial and ongoing comprehensive evaluation of the plan’s investment menu, including o Appropriateness and diversification of asset classes and representative investment options o Recommendation or selection of investment managers o Availability of asset allocation tools or strategies o Designation of a Qualified Default Investment Alternative (“QDIA”)  Quarterly documentation to evidence the fulfillment of these fiduciary duties  Periodic review & consultation with client designee(s) o Investment fiduciary responsibilities o Other Plan fiduciary governance matters, as appropriate Investment Policy Statement IRONSHORE provides an IPS that may be used by the client as a guide or template in the preparation of their unique policy statement or adopted in its current form as the basis for managing the investment aspects of the Plan. This IPS contains the standard provisions that should be present in a comprehensive investment policy: 1) roles and responsibilities, 2) investment guidelines and restrictions, 3) ERISA compliance matters, and 4) review and evaluation criteria. The process for conducting the ongoing review and evaluation of the investment options is detailed and specific to the proprietary methodology followed by IRONSHORE. Investment Evaluation Both the initial and ongoing evaluation processes involve consideration of menu construction and specific investment vehicles made available to participants. IRONSHORE designs an investment menu that offers a broad range of asset classes and/or investment styles to allow participants the opportunity to construct a diversified portfolio that is customized to their needs. Selection of the individual investment options is based upon IRONSHORE’s proprietary evaluation methodology. The foundation for this process is a quantitative scorecard that incorporates 9 measurement criteria over three distinct time horizons to rank an active manager’s performance relative to his peers using a cumulative total of 105 data points each month. Passively managed investments are evaluated based on their ability to achieve their stated objectives as opposed to being ranked against their

peers. However, the passive scorecard also is a robust quantitative methodology that evaluates 6 criteria over three distinct time horizons to critique 96 data points monthly. Each of these evaluation processes is fully documented and completed by batch-process execution in a third-party software application using data exclusively provided by a recognized leader in the industry who is independent of IRONSHORE. The evaluation criteria were chosen to address performance (return and risk) and process (consistency and efficiency) characteristics of each investment strategy. IRONSHORE considers the persistence of a manager’s ranking (outperformance or underperformance) over a reasonable time period as the primary factor in the decision-making process for either retaining or replacing that particular investment option. However, the quantitative scoring is not the only evaluation factor given consideration. IRONSHORE includes qualitative aspects of manager evaluation (people, process, firm culture or philosophy, etc.) and other third-party evaluation tools (i.e. asset allocation or Target Date Fund analysis software) in the comprehensive review upon which its recommendations or decisions are based. Periodic Review IRONSHORE prepares and delivers to clients an Evaluation & Monitoring of Plan Investments report on a quarterly basis. The report communicates the results of the ongoing evaluation process and documents the use of a prudent process for fulfilling the investment fiduciary responsibilities required by ERISA. Generally, and sometimes on a less-frequent basis (either semi-annually or annually), IRONSHORE conducts a detailed review of this report with the client designee(s). Such review may be completed in person or via telephonic conference depending on the client needs or desires and the specific arrangements defined by the service agreement. Investment Management IRONSHORE may provide discretionary investment management services to certain clients. These services are in accordance with a written agreement with the client authorizing IRONSHORE to exercise discretionary authority as an “investment manager” to the named fiduciaries of the plan as this term is defined by §3(38) of ERISA. Twenty-one clients with aggregate plan assets of more than $76 million as of December 31, 2022, have chosen this level of fiduciary service. At a minimum, IRONSHORE’s discretionary authority involves selection of investment options for the retirement plan “menu” from which participants may choose how to allocate their account balance. Frequently, this service also includes the construction of model portfolios that present diversified asset allocation strategies designed to alleviate the participant’s burden of making a less-informed allocation decision. In these circumstances, IRONSHORE exercises complete discretion in portfolio management decisions, including asset allocation and security selection. One or more of these model portfolios may also be chosen as the QDIA for the plan. IRONSHORE asserts that its selection of a QDIA will comply with the Department of Labor’s guidance for such a choice. The summation of participant account balances invested in these model portfolios amounts to almost $16 million as of December 31, 2022.