Colbert Investment Management Co (“Colbert”, the “Adviser”, “we”, “our” or “us) is a Florida corporation established in 1997 by Mr. Karim Armand, its principal owner, and Chief Compliance Officer. Colbert offers discretionary or non-discretionary portfolio management services primarily to high net worth domestic and international clients and financial institutions. Colbert provides active asset management to its clients. We manage individual accounts for clients utilizing a value-oriented strategy comprising of both fixed income (such as investment grade, and high yield corporate or government bonds) and equity (common stocks, exchange traded funds (“ETFs”)) portfolios. While we focus on this value-oriented strategy, we custom tailor portfolios to the individual needs of clients depending on the client’s individual situation. In particular, we custom tailor a client’s fixed income portfolio while clients’ equity portfolios tend to be more uniform among our clients. At the start of the relationship, we will gather information regarding your investment goals, risk profile current financial situation and prior investment experience. You may impose reasonable investment restrictions, including restrictions on particular securities or types of investments, subject to our agreement. Colbert requires that any requests for investment limitations or restrictions be made in writing. You should be aware that performance of restricted portfolios may differ from performance of portfolios without such restrictions, which may affect overall returns. Clients that fund their accounts by depositing securities, authorize us to liquidate their securities and invest the proceeds in accordance with the strategy selected. Colbert does not provide advice regarding the securities being liquidated and is not responsible for any losses incurred in securities positions transferred into your advisory account. Depending on the securities involved, the holding period and other factors, liquidations may result in redemption charges and a taxable event. You should review the potential tax consequences of these liquidations with their tax advisor. Clients funding

their accounts with mutual fund shares may pay redemption fees in addition to any charges incurred on the initial purchase. Clients that hold mutual funds in their advisory account(s) incur our advisory fees in addition to the mutual fund’s operating and management fees and expenses. You should review these costs carefully before transferring mutual fund shares into your advisory account(s). Certain products may not be held in the account or used to fund the account. These include insurance, annuities, private placements, certain limited partnership interests, hedge funds, commodities, and futures. You should consult with your investment advisor representative prior to attempting to transfer such assets. The advisory fee on transferred assets is assessed as of the day you execute our advisory agreement. You should review these costs carefully before transferring assets into your advisory accounts Retirement Accounts (For U.S. Clients Only) When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title 1 of ERISA 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 the 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, investments;
• Have in place 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
• Provide you with basic information about conflicts of interest As of December 31, 2023, Colbert had discretionary assets under management of $177,714,069. Colbert is not managing any non-discretionary portfolios at this time.