The Firm has been in business since 1976. Michael Perlow is the majority owner of the Firm. ADVISORY SERVICES General Policy Michael Perlow, the Firm’s primary Portfolio Manager, makes recommendations designed for certain categories of Firm Clients, and generally implements these recommendations, where appropriate, for particular Clients. Mr. Perlow is assisted in this role by Peter Goldman, the Firm’s associate portfolio manager. Mr. Goldman joined the Firm in May, 2014. Together, Mr. Perlow and Mr. Goldman serve as the Firm’s Portfolio Management team and they review client portfolios and analyze securities for possible inclusion (or removal) from client portfolios. Generally speaking, the final determination regarding contemplated actions or recommendations will be made by Mr. Perlow. In some instances, the Portfolio Management team will make recommendations directly to certain Clients for those Clients to implement independently directly with their custodians. The Firm tailors its advisory services to the individual needs of clients, in that the Firm considers the investment objectives of individual clients when it constructs portfolios for its clients. The Firm generally uses a growth style strategy in investing client funds. There is no model portfolio for clients but, by design, there is substantial overlap across client portfolios in the stocks that are held. In constructing such portfolios, the Firm may use equity securities, preferred stocks, municipal bonds, government bonds and/or corporate bonds but the Firm’s growth style strategy will generally mean that client portfolios are primarily invested in equity securities. While the Firm generally seeks to follow the companies that are among the leaders in their specific industries, the specific securities that the Firm follows varies over time and there is no specific criteria or formula that determines which companies the Firm follows closely. While the Firm tailors allocations among stocks held in client portfolios according to individual client investment objectives, the Firm’s growth style strategy may have the effect of limiting the extent to which a portfolio may be tailored. The Firm provides advice to certain clients on a non-discretionary basis. The Portfolio Management team will generally implement recommendations or selection of securities for investment for an individual account as soon as reasonably possible for that account and prior to reviewing other accounts. Notwithstanding the above, the Portfolio Management team may implement such recommendations or selections in a different order of priority due to the timing and nature of its investment decisions. Clients may impose restrictions on investing in certain securities or types of securities by actively identifying such restrictions in writing for the Portfolio Management team. IPOs and Private Offerings The Firm does not recommend or purchase initial public offerings (IPOs) in common stock for its Clients, but may recommend or purchase IPOs with respect to bonds or preferred stock. The Firm does not recommend or purchase private offerings for its Clients. Publicly Traded Clients Westwood’s clients may include publicly traded companies. In such instances, Westwood will not purchase shares of such publicly-traded companies within its client portfolios. However, there are no restrictions on Westwood’s ability to purchase shares of those publicly-traded companies for Mr. Perlow’s portfolio or for Westwood’s profit sharing plan. Westwood does not believe such policies have a material impact on the Firm’s ability to manage client assets. Client Instructions The Firm does not accept investment directions, including purchase or sale orders, by e-mail, voice mail or other telephonic voice messaging. The Firm’s

authority over client accounts does not include the authority to transfer assets and, accordingly, clients must contact their custodians directly to transfer assets. Cross Trading The Firm does not effect cross trades between Client accounts. BUSINESS CONTINUITY – SUCCESSION PLAN Michael Perlow is the Firm’s majority owner and acts as the Firm’s Chief Executive. In his role as the head of the Portfolio Management team, Mr. Perlow generally makes final determinations regarding the management of client portfolios. However, Mr. Perlow is assisted in the portfolio management process by Peter Goldman, an experienced securities analyst. The Firm believes that, if Mr. Perlow was incapacitated for a period of time or unable to continue at the Firm for any reason, Mr. Goldman has the experience to successfully continue to manage client portfolios and to otherwise operate the Firm. BUSINESS CONTINUITY – EMERGENCY CONTACT INFORMATION In the event of a disruption, we can be contacted by e-mail at: info@westwood-management.com (Please note this email address is not regularly monitored except during times of disruption) Westwood maintains a website and email address solely for disaster recovery purposes: You can obtain information regarding a disruption by checking our disaster recovery web site at: www.westwood-management.com MICHAEL PERLOW’S MULTIPLE ROLES Mr. Perlow serves as Chief Compliance Officer (CCO), President and majority owner. He also serves as the Firm’s primary portfolio manager, assisted in this role by Peter Goldman. As such, he may at times face inherent conflicts of interest in serving the interests of the Firm’s clients as well as the financial and other interests of the Firm. Westwood maintains policies, procedures and controls which it believes are reasonably designed to ensure such conflicts are satisfactorily addressed. Westwood routinely monitors this conflict, and does not believe it results in unfair treatment by Westwood of its clients. CHARITABLE CONTRIBUTIONS The Firm, or Michael Perlow individually, periodically receives requests from clients to make contributions to charitable organizations selected by such clients. Generally, Michael Perlow has made any such contribution individually. Mr. Perlow will consider any request from a client to make a charitable contribution; however, he has sole discretion to determine whether a contribution is made and the amount of any such contribution. NO WRAP FEE ACCOUNTS The Firm does not sponsor or participate in wrap fee account arrangements. On occasion, clients separately set up wrap fee account arrangements for accounts managed by the Firm. The Firm does not endorse or recommend such arrangements and does not participate in the wrap fee charged by the sponsor of the wrap fee arrangement. DISCRETIONARY MANAGEMENT As of December 31, 2022, the Firm manages approximately $799,271,165 in regulatory assets under management on a discretionary basis. CONFLICTS OF INTEREST A “conflict of interest” exists when the interests of the client and the Firm diverge. As a fiduciary to its clients, the Firm has an obligation to eliminate or make full and fair disclosure of all conflicts of interest that might cause it to render advice which is not disinterested such that a client can provide informed consent to the conflict. As a general matter, Westwood personnel meet with outside counsel at least annually to discuss and identify potential conflicts of interest and to determine ways to eliminate, disclose or mitigate any potential conflicts that are found.