Goelzer Investment Management, Inc. (“Goelzer”) is an investment advisory firm registered with the SEC, whose Principal Officers include Gregory W. Goelzer, Chief Executive Officer and Brett D. McKamey, President. Goelzer is an employee-owned company, with a controlling interest held by the Goelzer family. Founded in 1969, Goelzer provides services to private and institutional clients, which include Investment Advisory Services and discretionary and non-discretionary Asset Management Services. In addition, the firm may provide Consulting Services to clients that wish to have Goelzer monitor and report on investments held at a third-party asset manager, adviser, custodian, or trust company. These services are more fully described below, as well as in the advisory contract applicable to each account. As of 12/31/2023, the firm advises on a total of $3,159,426,779 in assets under management, and $208,675,208 in consulting assets for a total of $3,368,101,987 in assets under advisement. Goelzer’s Investment Advisory Services are divided into three separate teams that provide distinct aspects of Goelzer’s advisory offerings. These include Goelzer’s Institutional Advisory Services team, which provides services tailored for institutional clients, Goelzer’s Private Client team, which offers comprehensive wealth management services specific to private clients, and Goelzer’s Investment Management team, which provides research and analysis to support the other teams. Institutional Advisory Services Goelzer’s Institutional Advisory Services Team offers investment consulting and custom-tailored portfolios to institutions, including pension and profit-sharing plans, foundations, and endowments, primary, educational institutions, corporate accounts, and other institutional accounts. Goelzer has served the institutional marketplace for over 30 years, offering comprehensive investment advice. Goelzer offers a customized approach, tailored to each client’s needs and objectives, not a mass generated solution. OCIO Discretionary Services Goelzer can serve as an Outsourced Chief Investment Officer (“OCIO”) for institutions where we serve as a co-fiduciary next to the client, saving the client’s time by allowing it to focus on more important priorities. Goelzer serves as a close partner with its institutional clients by providing OCIO services that help to alleviate the burdens that clients face. OCIO Services include:
• Development of the Investment Policy Statement
• Asset Allocation Study and Liability Analysis Goelzer Investment Management, Inc. – Form ADV Part 2A Brochure 5
• Investment Manager Searches, Monitoring, and Supervision
• Portfolio Implementation and Rebalancing and Tactical Shifts
• Customized Portfolio Construction
• Research and Education
• Portfolio Compliance and Risk Management
• Performance Reporting and Monitoring
• Spending Policy Analysis
• Annual Fee Analysis The average client size for OCIO Discretionary Services is $7.6 million. Traditional Consulting Services Goelzer also offers any of the above services individually or in a group as part of a consulting relationship. For instance, Goelzer can provide assistance with the Investment Policy Statement, Investment Manager Monitoring, and Performance Reporting. Goelzer can contract to provide any and all of these services according to the needs of the client. The average client size for Traditional Consulting Services is $73.1 million. Private Client Services Goelzer’s Private Client Team provides comprehensive wealth management services to high net worth individuals, which includes individualized investment and financial planning advice tailored to each client’s needs. Each portfolio is structured to conform to the client’s investment objectives and risk tolerances. This service is typically available to persons wishing to invest a minimum of $1,000,000, but this amount can be waived. The investment objectives and risk tolerances may differ from client to client, and portfolios may differ among clients. Goelzer’s private client services include:
• Development of Personal Investment Plan
• Plan updates and Revisions
• Asset Allocation
• Custom Portfolio Creation
• Performance Reporting Financial Planning Goelzer also provides wholistic financial planning services to help the client evaluate their current income, financial condition, and spending by using current known variables and the client’s financial goals to assess potential future income, asset values, and withdrawal plans. Goelzer works with the client to understand and identify his or her current financial situation and specific goals. The adviser then analyzes the current course of action and potential alternative courses of action to develop an appropriate and mutually

agreed upon financial plan. Throughout the Goelzer Investment Management, Inc. – Form ADV Part 2A Brochure 6 relationship, Goelzer’s advisers will monitor the plan, updating it as necessary. As part of its financial planning services, Goelzer may provide clients advice on various subjects including: education savings, debt management, funding retirement plans, estate planning concepts, charitable giving, business exit strategies, and other relevant subjects. Goelzer Private Office For clients with more complex financial estates, Goelzer provides specialized Private Office services to meet the needs of these clients. These services include some or all of the following: generational wealth planning, philanthropic legacy, consolidated reporting, institutional investing consulting, alternative investments, business advisory, custom wealth solutions, and Goelzer Wealth Vision, a planning tool that provides clients a wholistic view of their personal finances. Goelzer Private Office is a tailored approach focusing on the needs of these complex situations. G•PRO Goelzer markets itself specifically to professional athletes under the name G•PRO. G•PRO offers financial planning, investment advisory, and asset management services that are tailored to the needs and financial situations of professional athletes. Investment Management Goelzer offers investment management services in support of the Institutional Advisory Services and Private Client Teams in which Goelzer provides research and portfolio management to Goelzer clients. Goelzer’s Investment Management Team maintains Goelzer’s proprietary investment strategies, which include core equity strategies, government, corporate, and municipal fixed income, mutual funds, and private investments. Please see Items 8 and 13 below for more information on Goelzer’s Investment Management Team and its investment process. Unmanaged Assets From time to time, clients may ask Goelzer to include assets for which Goelzer does not provide ongoing management or advisory services (“unsupervised assets”) in client reports. As Goelzer may include these unsupervised assets in its reports to clients and may consider these unsupervised assets in making asset allocation decisions or recommendations for clients, Goelzer may, but typically does not, include these unsupervised assets when determining the total assets under management upon which the client’s fee is based, depending on the complexity of including the assets in the report. However, Goelzer does not regularly research, review, or otherwise evaluate a client’s unsupervised assets. Clients holding unsupervised assets should recognize that Goelzer may be unaware of factors that could lead an unsupervised asset to rapidly decline in value and that Goelzer Investment Management, Inc. – Form ADV Part 2A Brochure 7 Goelzer should not be expected to alert the client should such a decline be in progress. The client has the sole responsibility to monitor and request trades in unsupervised assets. Miscellaneous Sub-Adviser Relationships For a number of accounts, Goelzer serves as a sub-adviser to another investment adviser. Co-Adviser Relationships For a specific number of clients, Goelzer contracts to work as a co-adviser with another registered investment adviser. With these clients, Goelzer provides investment management services, and the other investment adviser provides investment advisory services. Other Goelzer may be engaged to recommend one or more investment advisers to the client. If authorized by the client, Goelzer may recommend itself as an investment adviser, if that recommendation is in the client’s best interest, and Goelzer may earn an additional advisory fee for those relationships. The option of recommending itself among other advisers is a conflict of interest because there is an incentive to choose itself instead of the other advisers. Goelzer discloses the potential of additional fees in this Brochure and again to affected clients prior to entering the relationship. Fiduciary Duty Related to Retirement Accounts We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Similarly, any recommendation to open an account with Goelzer that results in the client paying fees to Goelzer is an inherent conflict of interest.