Cozad Asset Management, Inc. (Cozad) was founded in 1972, and registered with the Securities and Exchange Commission as an investment adviser in 1982. Our investment philosophy is guided by diversification, a disciplined approach to the purchase and sale of securities, and the flexibility to make sure each portfolio is as unique as our clients. Our goal is to provide the highest quality, personalized services and advice. As of 12/31/2023, the firm is owned by 36 shareholders, with interests ranging from .09% to The George Shapland Estate’s 25.73% interest. Seventeen of the firm’s employees are also shareholders holding total ownership of 31.15%. Services offered include: a. Continuous advisory services based on an individual client’s goals and objectives. We advise individuals, corporations, partnerships, trusts, limited liability companies and investment companies on investments and offer recommendations on specific investments, the purchase and sale of securities, and the management of client resources. Our investment and security selections are subject to the stated objectives and strategies of each client. Clients may impose restrictions on investing in certain securities. b. Financial planning, consisting of a complete analysis and evaluation of a client’s investment goals, current financial condition and retirement plans. c. Consultation on life, disability, health, accident and/or long term care insurance needs. d. Subadvisor for other investment firms. Effective September 11, 2021 Cozad changed its recommended broker-dealer from M Holding Securities, Inc. to Pershing Advisor Solutions LLC (PAS). Pershing, LLC will remain as primary custodian for client assets. Unified Managed Accounts and Separately Managed Accounts: Cozad provides investment advisory services on a discretionary basis for Unified Managed Accounts (“UMAs”) and Separately Managed Accounts (“SMAs”). Cozad may provide one or more of its model portfolio strategies to a “Platform Provider” such as Schwab Marketplace, in which RIA has entered into an agreement as a model manager with the Platform Provider. Other financial advisers have or may, in the future, enter into agreements with Cozad. Cozad provides access to some or all of our model portfolio strategies via the Platform Provider’s model management system for which Advisors and Clients can then select for use in a Client Account. For UMA/SMA managed accounts, Cozad is solely responsible for the management of the model portfolio strategies provided to the Platform Provider which have been selected for use in a Client Account by Advisor and/or Client. By utilizing one or more of Cozad’s model portfolio strategies via a Platform Provider; the

services Cozad provides UMA/SMA managed accounts is as follows; portfolio design, asset allocation, risk management and security selection. UMA/SMAs accounts are managed based upon the selected portfolio's stated investment strategy, philosophy and objective, rather than on each Client’s individual needs. Discretionary Authority: Our clients may choose to grant us discretionary authority, but it is not required. As of 12/31/23, $1,861,301,623 (96.78%), of our clients’ assets were managed on a discretionary basis, and $62,010,360 (3.22%), were managed on a non-discretionary basis. 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. Sub-adviser/Money Manager Review: Cozad utilizes or recommends the services of sub-advisers or money managers for account/portfolio management services. Prior to referring clients to any such entity, Cozad will conduct a due diligence review of the adviser or money manager. The review may consist of a presentation by the sub-adviser to Cozad, additional gathering of materials regarding the sub-adviser, including its Form ADV, registration status of the firm, etc. Once all information has been collected, Cozad will review the materials and determine if the sub-adviser/money manager should be utilized for account management services. Records of the review and final decision will be maintained in Cozad’s compliance files. If Cozad determines to utilize the sub-adviser/money manager, then Cozad will periodically conduct a due diligence review to assess whether Cozad should continue to recommend or select the sub-adviser or money manager.