Cumberland Investment Counsel Inc. (“CIC”) (formerly called Wirth Associates Inc.) was founded in 1991 to provide investment advisory services to high-net-worth clients. The company was acquired in January 2007 and became a wholly owned subsidiary of Cumberland Partners Ltd. (“CPL”). On May 1, 2018, Cumberland Partners Limited (“CPL”; parent company of Cumberland Associates Investment Counsel Inc. (“CAIC”) and Cumberland Private Wealth Management Inc. (“CPWM”)), Norrep Investment Management Group Inc. (“NIMGI”; parent company of Norrep Capital Management Ltd (“NCM”)), Perron & Partners Wealth Management Corp. (“PPWM”), Perron Asset Management Inc. (“PAM”), amalgamated their related entities (the “Combination”). Under the Combination, PAM amalgamated with CAIC and will continue under the name Cumberland Investment Counsel Inc. (“CIC”), PPWM amalgamated with CPWM and will continue under the name CPWM, and Norrep Capital Management Ltd. (“NCM”) will remain a separate entity. NCM subsequently changed its name to NCM Asset Management Ltd. in August 2018. As a result of the Combination, CIC, CPWM, NIMGI and NCM are wholly owned subsidiaries of CPL, and CPWM, NIMGI and NCM are related persons of CIC. CIC’s related persons are Canadian entities and are not registered under US securities legislation. NIMGI amalgamated with NCM on September 30, 2022. CIC provides discretionary investment management services primarily to high-net-worth individuals, their families, and foundations through separately managed accounts generally with $1 million or more in investible assets. As well, CIC provides sub-advisory services to certain Canadian individual portfolios within CPWM’s discretionary management program, and certain Canadian affiliated funds where CPWM or NCM is the Canadian Investment Fund Manager. CIC invests primarily in exchange traded equity securities, corporate and government bonds, and we may invest in pooled funds and exchange traded funds (ETF). Certain ETFs will incur other costs in addition to management fees. CIC provides continuous investment advice on a fully discretionary basis. Clients may impose restrictions relating to, amongst other things, directorships, controlling interests in publicly traded securities or specific preferences. The Investment Management Agreement may be terminated by either party

per the terms outlined under the Agreement. CIC will gather information about a client’s investment profile in an Investment Policy Statement and Account Application including information pertaining to a client’s personal and financial circumstances, risk tolerance, risk capacity, time horizon, investment needs and objectives. This information will be used to develop a client profile and will serve as the basis for the formulation of an investment strategy to help meet a client’s investment goals. CIC does not participate in Wrap Fee programs. IRA Rollover Recommendations For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. As of September 30, 2023, CIC managed ~U$1 billion in AUM on a fully discretionary basis, primarily for Canadian resident clients and Canadian affiliated funds, and ~U$25 million AUM for US resident clients.