A. Description of the Advisory Firm Water Valley Investment Advisors, Inc. (hereinafter “WVIA”) is a corporation organized in the State of Illinois. The firm was formed in February 1998, and the principal owners are Kurt Henry Dorr and Philip Melvin Dorr. B. Types of Advisory Services Portfolio Management Services WVIA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. WVIA 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 WVIA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. WVIA 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. WVIA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of WVIA’s economic, investment or other financial interests. To meet its fiduciary obligations, WVIA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, WVIA’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 WVIA’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 WVIA generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs, although WVIA primarily recommends mutual funds. WVIA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions WVIA 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 WVIA on behalf of the client. WVIA 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 WVIA from properly servicing the client account, or if the restrictions would require WVIA to deviate from its standard suite of services, WVIA reserves the right to end the relationship. 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. WVIA does not participate in wrap fee programs. E. Assets Under Management WVIA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $125,470,000 $0 December 2023