Aurora Investment Counsel, Inc. is a separate account manager providing primarily US Equity investment strategies. Aurora utilizes a “bottom-up”, fundamentals based approach for its “Growth At the Right Price” discipline to equity investing. Ancillary services may include asset allocation, fixed income services and general investment guidance. The securities we use in our investment strategies and investment advice include equity securities, such as exchange listed securities, securities traded over the counter and foreign issues; preferred stock of public corporations, debt securities of corporations and similar entities; listed options securities, certificates of deposit; municipal and government securities; investment company securities such as mutual fund shares and exchange traded funds. Aurora Investment Counsel, Inc. was incorporated and became a Registered Investment Advisor on January 4, 2001, after previously doing business as Randy Seckman and Associates. In December, 2014, Lebenthal Asset Management, an SEC Registered Investment Advisor (SEC File # 801- 68831) and a 100% owned subsidiary of Lebenthal Holdings, LLC, consummated a transaction to purchase the assets of Aurora Investment Counsel. On September 1, 2017, Aurora Investment Counsel, an SEC Registered Investment Advisor (SEC File # 801- 00000) and Lebenthal Asset Management signed a Termination Agreement, which combined with other related documents separated all business connections as of August 31, 2017. Remaining stockholders of Aurora Investment Counsel are David J. Yucius, Jr. (majority owner), and Michael T. Doyle. David J. Yucius, Jr., CFA acts as Portfolio Manager for all accounts and clients, and serves as President and CCO of the firm. Types of Services Offered by Aurora Investment Counsel: Aurora Investment Counsel provides discretionary investment counseling for its clients. Typical elements of that service include:  A review of each client’s financial status and inquiry to their investment goals.  The drafting of an Investment Policy Statement which incorporates among other things: Return Objectives, Risk Tolerance, Time Horizon, Liquidity Needs, Tax Considerations and Special Constraints.  Setting of Asset Allocation targets and acceptable ranges for investment in various asset classes. Also, outlines general parameters for security selection within asset classes.  Policy implementation includes security selection across asset classes including common equities, government & corporate fixed income, municipal fixed income, mutual funds, money market mutual funds, convertible securities and closed end funds.  Constant review of recommended securities for all accounts. Ongoing client communications through written research updates, investment proposals and regularly scheduled client meetings.  Quarterly performance and status updates including account appraisals quarterly and annual performance information, and market environment commentary. When engaged to provide investment advice for separate accounts (i.e. not commingled with other portfolios), Aurora Investment Counsel, Inc. does provide clients with customized advice and recommendations. Client or Sub-Advisor consultations and Investment Policy statements are used to allow for client input regarding unique characteristics in the client’s profile that requires attention or limitation. Examples of such characteristics include the ability

to restrict Aurora from purchasing particular securities and/or to restrict ownership of certain types of securities or sectors. Aurora also works with referring Advisor firms and representatives to communicate the special and individual needs of their clients, which can account for tax considerations, liquidity needs or other portfolio structure requests. 2 of 7 Financial Planning Services When directly engaged, without acting as Sub-Advisor, Aurora may offer broad based Financial Planning services. These services entail questions as to a Client’s financial details including insurance, wills, income/expenses, assets/indebtedness and retirement planning. These services are delivered in personalized settings, and do not involve the sale or use of any products with remuneration for Aurora or Aurora personnel. Fees are inclusive with the Asset Management fees and schedule otherwise mentioned in this form. Assets Under Management As of December 31, 2023, Aurora Investment Counsel, Inc. managed $220 million, with $215 million being Discretionary Assets Under Management and $4.6 million being Non-Discretionary Assets. We serve in a Sub- Advisory capacity to 12 Registered Investment Advisory firms, where clients contract for services with these intermediaries directly. Aurora then serves as a Sub-Advisor with regards to its more specialized investment services. Aurora serves clients directly as Investment Advisor for roughly 48 relationships. Wrap-Fee Programs Aurora has entered into a “wrap fee” arrangements with unaffiliated companies. In addition, some of our clients may be involved in other wrap fee arrangements with certain brokerage firms or other companies which sponsor such arrangements. Under a wrap fee arrangement, a brokerage firm or other company may recommend retention of a particular investment advisory firm, such as Aurora, to manage all or a portion of your assets; pay us a fee for our services; monitor and evaluate our services in managing your assets; execute securities transactions which we implement on your behalf; and provide you with custodial services for your assets. Additionally, the brokerage firm or other company may provide any combination of these services, for a set fee to be paid by you to the brokerage firm or other company. Under a wrap fee arrangement, your assets would be managed by us in the same manner as assets managed by us for our clients not in a wrap fee arrangement, although this would be subject to your particular investment needs and objectives, and we may have limited or minimal contact with you where the brokerage firm or other company maintains the direct and primary relationship with you. You should understand that, depending upon the amount of the wrap fee the brokerage firm or other company charges you, the number of securities transactions in your account, the value of custodial or other services you will receive under the arrangement, the amount of the wrap fee may or may not be less than the total cost for such services added together if you obtained them separately. Therefore, such arrangement may not be suitable for all clients based on the client’s individual financial circumstances and investment goals. You can find more specific information on each wrap fee arrangement in the Wrap Fee Program Brochure which should be available to you from the wrap fee arrangement sponsor. Aurora does not act as a sponsor of any wrap fee arrangements.