A. Description of the Advisory Firm The Windmill Group, Inc. (hereinafter “TWGI”) is a Corporation organized in the State of New York. The firm was formed in July 1970, and the principal owners are Gregory Capozzi and John Maceranka. B. Types of Advisory Services Portfolio Management Services TWGI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. TWGI 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. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring TWGI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. TWGI will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. TWGI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of TWGI’s economic, investment or other financial interests. To meet its fiduciary obligations, TWGI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, TWGI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is TWGI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments TWGI generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs and treasury inflation protected/inflation linked bonds. TWGI may use other securities as well to help diversify a portfolio

when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions TWGI will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by TWGI on behalf of the client. TWGI may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent TWGI from properly servicing the client account, or if the restrictions would require TWGI to deviate from its standard suite of services, TWGI reserves the right to end the relationship. TWGI selects investments in client portfolios only after applying its internal due diligence process. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. TWGI does not participate in wrap fee programs. E. Assets Under Management TWGI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 32.101.709 $0 December 2023