FIRM DESCRIPTION & OWNERSHIP KDP Asset Management, Inc. is registered as an investment adviser with the Securities and Exchange Commission ("SEC") specializing in the management of high yield bonds and leveraged loans. The investment advice provided is limited to fixed income directives with an emphasis on high yield bonds and leveraged loans. The firm was established in 1999 and is headquartered in Montpelier, Vermont. In 2003, a holding company, KDP, LLC, was created to further ensure alignment of interests between KDP Asset Management, Inc. and its research affiliate, KDP Investment Advisors, Inc. KDP, LLC is a holding company owned 72% by Kingman Penniman, CEO. KDP, LLC owns 98.2% of KDP Asset Management, Inc. The remaining 1.8% is owned by outside investors. KDP, LLC also owns 100% of KDP Investment Advisors Inc., the firm’s high yield investment research business. KDP Asset Management, Inc. manages separately managed accounts for institutional clients such as foundations, public plans, corporate pensions, insurance companies, endowments, banks, and high net worth individuals. KDP Asset Management, Inc. may agree, at its sole discretion, to manage separate accounts below the stated minimum account size. References in this brochure to "KDP" are intended to apply collectively to KDP Asset Management, Inc. and its research affiliate, KDP Investment Advisors, Inc. KDP Asset Management, Inc. provides investment management services to both institutional clients and high net worth individuals. KDP Investment Advisors, Inc. provides high yield and leveraged loan research to institutional clients. KDP Investment Advisors, Inc., through a Research and Database Service Agreement, provides KDP Asset Management, Inc. with access to: (i) the detailed industry knowledge possessed by its investment professionals; (ii) its significant proprietary database; and (iii) its analytical support

capabilities. The service agreement between KDP Asset Management, Inc. and KDP Investment Advisors, Inc. is reviewed for conflicts of interest and firewalls are erected and supervised, as necessary. TYPES OF SERVICES OFFERED The primary focus of KDP Asset Management, Inc. is on US Dollar denominated high yield bonds and leveraged loans, but under certain specific client guidelines may also own securities such as second lien loans, defaulted bonds, convertible bonds, convertible preferred securities, common stock, or distressed credit securities. KDP Asset Management, Inc. may invest in a broad array of securities and reserves the right to pursue other investment strategies. KDP Asset Management, Inc. provides investment management services based on the individual needs and objectives of its clients. Clients may impose restrictions on investing in certain securities, types of securities, credit ratings, industry sectors, or other restrictions. Select clients may elect to have socially responsible, environmental, religious, or other guidelines applied to their portfolios. In addition, KDP Asset Management, Inc. provides clients with the ability to set customized guidelines in terms of asset class weightings, sector weightings, industry emphasis, credit ratings, and other restrictions. There can be no assurances that investments or trading activities will be profitable. KDP Asset Management, Inc. does not currently participate in wrap fee programs. KDP also seeks to provide bank clients with a comprehensive suite of loan services via its KDP Bank Loan Services including analytical & regulatory loan support, existing loan portfolio surveillance, pricing, loan administration, and trade facilitation. As of December 31, 2022, KDP Asset Management, Inc. managed assets of $ 90,322,333 on a discretionary basis. As of December 31, 2022, KDP Asset Management, Inc. managed assets of $ 351,458,706 on a non-discretionary basis.