A. Description of the Advisory Firm Kroon & Mitchell Asset Management, LLC. (hereinafter “K&M”) is a Limited Liability Company organized in the State of Michigan. The firm was formed in July 2013, and the principal owner is Phillip Mitchell. B. Types of Advisory Services K&M offers the following services to advisory clients: Portfolio Management Services K&M offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. K&M creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). 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 K&M evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. K&M 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. K&M seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of K&M’s economic, investment or other financial interests. To meet its fiduciary obligations, K&M attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, K&M’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 K&M’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities

that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services K&M offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. 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. K&M provides one-off and ongoing financial planning, depending on the client's needs. Services Limited to Specific Types of Investments K&M generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs), commodities, and non-U.S. securities. K&M may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions K&M offers the same suite of services to all of its clients. However, specific client investment strategies 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). 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. K&M does not participate in any wrap fee programs. E. Assets Under Management Discretionary assets under our firm’s management were approximately $164,051,761.00. Non-discretionary assets under management were approximately $ 1,225,824.00 as of December 2023.