Firm Description Pinnacle West Asset Management, Inc. a Wyoming Corporation is an investment management and research firm located in Casper Wyoming. The firm was founded October 1, 1991 and is a successor to a business started by Tom R. Creager in 1988. The firm was founded to fulfill the needs of long-term investors. The firm is a regulated investment advisory firm subject to the rules and regulation of the Investment Advisors Act of 1940, administered by the Securities and Exchange Commission. Principal Owners Its principal owners are Tom R. Creager and Roger W. Wesnitzer. Types of Advisory Services Pinnacle West Asset Management, Inc’s. commitment is to provide a disciplined and systematic approach toward the investment process to achieve the highest risk adjusted return possible within defined investment objectives. The firm creates custom designed investment portfolios to meet specific client investment goals and objectives. Client portfolios are individually managed in keeping with each client’s stated investment goals, objectives, and income tax strategies within the overall parameters of our investment philosophy. The basis for which we manage each of our client’s investment portfolios begins with an asset allocation model. We believe proper asset allocation is critical to the investment process and the effective management of portfolio risk. We are available to assist with the development of an asset allocation model if requested. Many times, we are provided with a predetermined asset allocation model from the client’s financial advisor. We firmly believe once the asset allocation is determined and agreed upon it should stay constant over the short-term but evolve over the long-term. The asset allocation model should not change to respond to the market environment in the short-term, but rather evolve over the long- term as client’s needs and risk tolerance changes. Generally, the asset allocation model will broadly require that a certain percentage or range of the investment assets be allocated among cash and cash equivalents, fixed income securities, equity income securities and equity securities. Cash and cash equivalents are often readily liquid money market or bank deposit accounts. Fixed income securities often include corporate debt securities, government debt securities, and municipal debt securities. Equity income securities often include preferred stock, index securities, real estate investment trusts and publicly traded partnerships. Equity securities often include large capitalization stocks, small capitalization stock index securities, mid capitalization stock index securities, developed foreign country index securities, and foreign emerging market index securities. Pinnacle West Asset Management, Inc. does not utilize leverage or margin for the management of our portfolios. However, a client may utilize margin (client directed) to borrow against their account. If so, Pinnacle will bill on managed portfolio assets without regard to the amount borrowed. Pinnacle West Asset Management, Inc. has full

discretionary trading authority over each client’s account. Clients are not allowed to impose any restrictions on investing in certain securities or types of securities. Our investment philosophy is the disciplined long-term management of risk to preserve and grow investment capital. We believe superior risk adjusted returns can be achieved over the long-term with proper diversification. Our philosophy is grounded on the basis of buying and holding investment securities over the long-term. Our definition of long-term for equity securities is often measured in a lifetime. We do not believe market timing can be a successful long-term approach to the investment process. Our philosophy does not include short-term trading or thinking. The fixed income portion of the portfolio will often consist of a laddered portfolio not exceeding ten years in maturity. We do not select fixed income securities for trading purposes we tend toward holding them until they mature and collecting the interest income. At the outset of our relationship with each client in consultation with the client we develop and agree on a memorandum of understanding that outlines the assumptions and understandings governing the management of the investment portfolio. Wrap Fee Programs Pinnacle West Asset Management, Inc. does not participate in wrap fee programs of any type. Client Assets As of December 31, 2022, Client assets under management were approximately $168.3 million, all of which it managed on a discretionary basis. Fees & Compensation Description All fees charged by Pinnacle West Asset Management, Inc. are calculated on an annual basis. The fees are billed quarterly in arrears. The fee is calculated based on the end of quarter valuation. Fees are prorated for any period less than a full quarter. Minimum fee charged per household $100.00 Cash and cash equivalents .25% Fixed income securities .25% Equity securities 1.00% Equity income securities 1.00% Exchange traded index shares .50% Mutual funds .50% Other Fees The fees charged for mutual funds and exchange traded index shares do not include any fees charged directly by the fund or index shares. The fees charged do not include any transaction costs, or handling fees charged by the custodial firm handling the account. The fees do not include any charges by trustees if the assets are held by a corporate trustee. Fees may be negotiable on larger accounts. Fee Billing Fees are deducted directly from client assets after the end of each quarter unless other arrangements are agreed to. A copy of the invoice showing the calculation of the fees is included with our quarterly reporting to clients. Fees Paid in Advance Fees for our services are not charged in advance. Additional Compensation Pinnacle West Asset Management, Inc. does not receive any other forms of compensation related to client assets. Performance-Based Fees & Side-by-Side Management Pinnacle West Asset Management, Inc. does not receive performance-based fees of any type.