Highland Consulting Associates, Inc. ("Highland Consulting") is a registered investment adviser with the U.S. Securities and Exchange Commission under the Investment Advisers Act of 1940. Highland Consulting began conducting business in 1993. Highland Consulting Associates International, Inc. ("Highland International") is a wholly owned subsidiary of Highland Consulting. Highland Consulting and Highland International have the same principal office and place of business in Cleveland, Ohio. Highland International is a registered investment adviser with the U.S. Securities and Exchange Commission under the Investment Advisers Act of 1940 and registered as an adviser in the category of portfolio manager with the Ontario Securities Commission. Highland International was formed to provide investment consulting services to institutional clients located outside of the United States. Highland International began conducting business in 2016. Listed below are Highland Consulting's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Highland Consulting Associates, Inc. Employee Stock Ownership Plan Highland Consulting offers the following advisory services to our clients: INVESTMENT ADVISORY SERVICES Highland Consulting provides investment advisory services. We provide continuous advice to clients regarding investments based on the individual needs of each client. Through discussions in which goals and objectives based on each client's particular circumstances are established, we assist the client in developing an investment policy and base our services on that policy. During our data-gathering process, we help determine each client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, and, if applicable, a client's family composition and background. Highland Consulting has historically served its clients on a non-discretionary basis. This means that the firm had no discretion over the specific investments held in client portfolios. There are a few cases where Highland Consulting has discretion. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may place restrictions on investments related to certain securities, types of securities, or industry sectors. Our investment recommendations are generally limited to mutual funds, ETFs, hedge funds, private equity funds, venture capital funds, private placements and other money managers. Highland Consulting may use other securities as well to help diversify a portfolio when applicable and may include advice regarding the types of investments held by the various products mentioned. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. As part of the process, we will assist the client in reviewing and monitoring fees associated with investments as well as other related costs (e.g. custody). INSTITUTIONAL RETIREMENT PLAN CONSULTING SERVICES Highland Consulting provides institutional retirement plan consulting services. The primary clients for these services will be the plan sponsors of defined benefit and defined contribution plans, however, we may also offer these services, where appropriate, to other entities. Highland Consulting has historically served its clients on a non-discretionary basis. This means that the firm had no discretion over the specific investments held in client portfolios. There are a few cases where Highland Consulting has discretion. Institutional Retirement Plan Consulting Services are comprised of four distinct services. Clients may choose to use any or all of these services. Investment Policy Preparation: We will meet with the client to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then assists with the preparation of a written investment policy detailing those objectives, constraints, etc., including an encompassing policy under which these goals are to be achieved. The investment policy also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investments: We will assist the client, where appropriate, in developing an asset allocation or asset allocation model. We will also review various investment managers and available investment vehicles, including mutual funds (both passive/index

and active/managed) to determine which investments are appropriate to implement the client's investment policy. The number of investments to be recommended will be determined by the client, based on the investment policy. Monitoring of Investments: We monitor client investments continually, following the procedures and timing intervals delineated in the investment policy. We monitor the client's portfolio, including individual managers, and will make recommendations as market factors and the client's needs dictate. As part of the process, we will assist the client in reviewing and monitoring fees associated with investments as well as other related costs (e.g. recordkeeping, custody, etc.). Employee Communications: For retirement plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we may also provide educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA. The educational support and investment workshops will not provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. FAMILY WEALTH PLANNING We provide family wealth planning services. The primary clients for these services will be individuals, families, family offices, and business owners. Highland Consulting will obtain information regarding a client's current situation from interviews and questionnaires as well as from a review of other documentation. Based upon information obtained from the client, we will prepare a written plan that summarizes the client's current situation and provides recommendations. Should the client choose to implement the recommendations contained in the plan, we assist them by working with their attorney, accountant, insurance agent, and/or other adviser(s). Implementation of financial plan recommendations is entirely at the client's discretion. Depending on the client's situation, the plan may address any or all of the following areas: Personal: We review family records, budgeting, risk management, estate information, financial goals and family relationships. Tax and Cash Flow Analysis: We analyze the client’s income and spending for past, current, and future years. We then illustrate the impact of various scenarios on the client's ability to meet future goals. Investments: We analyze investment alternatives and their effect on the client's portfolio. Insurance: We review to ensure proper coverage for our client and identify areas that need to be addressed. Primarily we review life, health, disability, liability and long-term care. Retirement: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. Estate: We assist the client in assessing and developing strategies to be effective and efficient in the accumulation and transition of their wealth, their business and their values. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. We will provide an analysis to clarify options and choices for our clients. WRITTEN ACKNOWLEDGEMENT OF FIDUCIARY STATUS When we provide investment advice to a client regarding a 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 a client’s interests, so we operate under a special rule that requires us to act in a client’s best interest and not put our interest ahead of a client. 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 a client’s interests 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 a client’s best interest;
• Charge no more than is reasonable for our services; and • Give a client basic information about conflicts of interest. AMOUNT OF ASSETS UNDER MANAGEMENT As of 12/31/2023, we managed approximately $ 17,596,855,445 in client assets on a nondiscretionary basis plus $ 238,614,866 in client assets on a discretionary basis.