General Crawford Investment Counsel, Inc. (the “Advisor”) is an independent investment advisor registered with the U.S. Securities and Exchange Commission since its inception in 1980. The owners of Advisor are John H. Crawford III, John H. Crawford IV, David B. Crawford, and the Crawford Investment Counsel, Inc. Employee Stock Ownership Plan. Advisor generally provides investment advice on a discretionary basis to individuals, including high net worth, investment companies, pension and profit sharing plans, trusts, estates, charitable organizations, municipalities, Taft-Hartley plans, corporations, and other business entities. Advisor’s services are always provided based on the specific needs of the individual client. Clients are given the ability to impose restrictions on their accounts, including specific investment selections and sectors. However, Advisor will not enter into an investment advisor relationship with a client whose investment objectives may be considered incompatible with Advisor's investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Advisor typically limits its investment advice to the following types of investments:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issues
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States government securities Asset management services are generally offered on a discretionary basis through a variety of channels, including: (1) our traditional asset management services, (2) wrap fee programs sponsored by third party financial services firms, (3) registered investment companies, and (4) model-based programs. Asset management services involve continuous and on-going supervision of client accounts, which means client accounts are monitored, and trades are made when necessary. See Item 12, Brokerage Practices, for additional discussion on selection of client custodians. The total amount of clients’ assets managed by Advisor was $7,729,583,314.43 as of December 31, 2023. Of that total, $7,729,583,314.43 were assets managed on a discretionary basis and $0 were assets managed on a non-discretionary basis. Traditional Asset Management Services Advisor offers portfolio management services that include giving continuous investment advice and/or making investments for the client based on the individual needs, goals and objectives, and risk tolerance of the client. Advisor provides management services on a discretionary basis. This means that Advisor makes all decisions to buy, sell or hold securities, cash or other investments in the managed account in Advisor’s sole discretion without consulting with the client before making any transactions. Clients must provide Advisor with written authorization to exercise this discretionary authority, and they can place reasonable restrictions and limitations on the discretionary authority. See Item 16, Investment Discretion, for additional discussion on discretionary authority. Crawford Investment Counsel, Inc. – 4 – Disclosure Brochure Wrap Fee Programs Advisor also

manages client accounts using wrap-fee programs sponsored by unaffiliated brokers/dealers. Advisor provides both traditional investment advisory and sub-advisory services to wrap fee sponsors and other registered investment advisors. In traditional portfolio management programs, advisory services are provided for a fee. In wrap-fee programs, the sponsor negotiates a management fee with the advisor and the client is charged a wrap fee which includes a transaction fee and a management fee. Wrap and sub-advised accounts are managed to a specific investment strategy, and the sponsor determines the appropriateness of the strategy for their client. Traditional accounts have a more complete process which considers the goals and objectives and relationship with the end client. Advisor receives a portion of the wrap fee charged to the client’s account. Registered Investment Companies Advisor also provides investment management services to investment companies such as mutual funds. Specifically, Advisor serves as investment advisor to the Crawford Large Cap Dividend Fund (CDGIX, CDGCX), the Crawford Small Cap Dividend Fund (CDOFX), and the Crawford Multi-Asset Income Fund (CMALX). The Crawford Large Cap Dividend Fund (CDGIX, CDGCX) invests primarily in common stocks of large capitalization companies that demonstrate a consistent pattern of earnings and dividend growth. The Crawford Small Cap Dividend Fund (CDOFX) typically invests in common stocks of small capitalization companies and seeks to maximize total return through long term stock ownership of those companies determined to possess attractive fundamentals and consistent dividends. The Crawford Multi-Asset Income Fund (CMALX) pursues a multi-asset income strategy with the primary objective of generating current income. Model-Based Programs Certain Unified Managed Account (UMA) or Model Program Sponsors receive Advisor’s model securities portfolio for selected investment styles. The Advisor also provides updates to the model, but is not responsible for actual implementation in client accounts. The Advisor does not have any contact with the underlying clients utilizing the model and the Advisor does not perform any trading on behalf of the underlying clients. Retirement Plan Rollovers – No Obligation / Conflict of Interest A client or prospective client leaving an employer has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Advisor recommends that a client roll over their retirement plan assets into an account to be managed by the Advisor, such a recommendation creates a conflict of interest in that Advisor will earn new (or increases its current) compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Advisor. Please see Item 5, Fees and Compensation, for a detailed description of fees charged.