A. Cardinal is a corporation formed on August 14, 1992 in Manitoba, Canada. Cardinal became registered as an Investment Adviser Firm on December 12, 2002. Cardinal is 100% principally owned by Cardinal’s employees. Tim Burt and Emily Burt are the firm’s largest shareholders, respectively. B. As discussed below, Cardinal offers to its clients (individuals, business entities, investment companies, pension and profit sharing plans, trusts, estates and charitable organizations, etc.) investment advisory services. Cardinal also provides financial planning, estate planning, insurance planning, investment and non-investment related consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage Cardinal to provide discretionary and/or non- discretionary investment advisory services on a fee basis as discussed at Item 5 below. Cardinal’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Cardinal’s management. To commence the investment advisory process, an investment adviser representative will first ascertain each client’s investment objectives and then allocate or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, Cardinal provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives, and may periodically execute or recommend execution of account transactions based upon such reviews. Before engaging Cardinal to provide investment advisory services, clients are required to enter into an investment advisory agreement with Cardinal setting forth the terms and conditions of the engagement, including termination, describing the scope of services to be provided, and the fee that is due from the client. Once allocated, Cardinal provides ongoing supervision of the accounts. To the extent specifically requested by a client, Cardinal may provide consultation services to its investment advisory clients on investment and non-investment related matters. Any such consultation services, to the extent rendered, shall not be subject to any separate or additional fee. MISCELLANEOUS Limited Consulting/Implementation Services. To the extent requested and engaged by the client to do so. Cardinal provides financial and non-financial planning services to its Canadian investment management clients on investment and non-investment related matters. Financial planning services are generally not made available to clients located in the United States. Services include: estate planning, tax planning, risk management, insurance products and services, and so forth. Cardinal shall not receive any separate or additional fee for any such consultation services. Please Note: Cardinal believes that it is important for the client to address financial planning issues on an ongoing basis. Cardinal’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Cardinal. Neither Cardinal, nor any of its representatives, serves as an attorney or accountant, and no portion of Cardinal’s services should be construed as same. Accordingly, Cardinal does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, Cardinal may suggest the services of other professionals for certain non- investment implementation purposes (i.e. attorneys, accountants, insurance agent, etc.), including representatives of Cardinal in their separate censed capacities as discussed below. The client is under no obligation to engage the services of any such professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendations from the Cardinal and or its representatives. Please Note: If the client engages any such professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse from and against the engaged professional. At all times, the engaged licensed professional(s), (i.e., attorney, accountant, insurance agent, etc.), and not Cardinal, shall be responsible for the quality and competency of the services provided. Please Also Note: It remains the client’s responsibility to promptly notify Cardinal if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Cardinal’s previous recommendations and/or services. Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If the Cardinal recommends that a client roll over their retirement plan assets into an account to be managed by the Cardinal, such a recommendation creates a conflict of interest if the Cardinal will earn a new (or increase its current) advisory fee as a result of the rollover. To the extent that Cardinal recommends that clients roll over assets from their retirement plan (or an existing IRA) to an IRA managed by Cardinal, then Cardinal represents that it and its investment adviser representatives are fiduciaries under the Employment Retirement Income Security Act of 1974 (“ERISA”), or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Cardinal whether it is from an employer’s plan or an existing IRA. Non-Discretionary Service Limitations. Clients that determine to engage Cardinal on a non-discretionary investment advisory basis must be willing to accept that Cardinal cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Cardinal would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Cardinal will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Limitations of Sub-Advisor / Separate Account Manager Services. Cardinal also serves as a: (1) sub-adviser to unaffiliated registered investment advisers and (2) privately pooled investment funds. Cardinal also furnishes sub-advisory services as a Trust Bank portfolio manager. Specifically, Cardinal provides portfolio models which are implemented by the Trust Bank. Cardinal also provides subadvisory support to another investment manager through which its pooled investment fund products are made available. With respect to these three types of engagements, the unaffiliated investment advisers that engage Cardinal’s sub-advisory services and/or assist their clients in selecting Cardinal as a separate account manager, maintain both the initial and ongoing day-to-day relationship with the underlying client, including the initial and ongoing determination of client suitability for Cardinal’s investment strategies. Cardinal’s obligation shall be to manage the client’s account consistent with the investment strategy designated by the unaffiliated investment adviser. In addition, for all such engagements, Cardinal does not generally have the ability to choose and/or determine: (1) the custodian and/or broker-dealer for the client’s account; (2) whether the services are part of a wrap program or provided on an unbundled basis; or (3) program and/or transaction cost pricing. Therefore, Cardinal is unable to control or confirm best execution for account transactions. Higher fees and transaction costs adversely impact account performance. Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by Cardinal independent of engaging Cardinal as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Cardinal’s initial and ongoing investment advisory services. In addition to Cardinal’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Cardinal generally recommends that Charles Schwab & Company, Inc.(“Schwab”) serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian While certain custodians, including Schwab, do not currently charge fees on individual equity transactions (including ETFs), others do. When beneficial to the client, individual fixed‐ income and/or equity transactions may be effected through broker‐dealers with whom Cardinal and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which

event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab). These fees/charges are in addition to Cardinal’s investment advisory fee at Item 5 below. Cardinal does not receive any portion of these fees/charges. Please note: Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Please also note: there can be no assurance that Schwab will not change its transaction fee pricing in the future. ANY QUESTIONS: Cardinal’s Chief Compliance Officer, DeWayne Osborn, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity. Cardinal has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Cardinal will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Cardinal determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Cardinal will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note: Cash Positions. Cardinal continues to treat cash as an asset class. As such, unless determined to the contrary by Cardinal, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Cardinal’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Cardinal may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Cardinal’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Cardinal’s Chief Compliance Officer, DeWayne Osborn, remains available to address any questions that a client or prospective may have regarding the above fee billing practice Please Note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Cardinal ), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Wrap/Account program services: Cardinal neither sponsors, nor recommends, wrap account programs. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. In the event that Cardinal is engaged to provide investment advisory services as part of an unaffiliated wrap-fee program, Cardinal will be unable to negotiate commissions and/or transaction costs. The program sponsor will determine the broker-dealer though which transactions must be effected, and the amount of transaction fees and/or commissions to be charged to the participant investor accounts. Participation in a wrap program may cost the participant more or less than purchasing such services separately. Higher transaction costs adversely impact account performance. Cybersecurity Risk. The information technology systems and networks that Cardinal and its third-party service providers use to provide services to Cardinal’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Cardinal’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Cardinal are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Cardinal has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Cardinal does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e. custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Cardinal does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). Cardinal does not recommend such borrowing for investment purposes (i.e. to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Cardinal:
• by taking the loan rather than liquidating assets in the client’s account, Cardinal continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by Cardinal, Cardinal will receive an advisory fee on the invested amount; and,
• if Cardinal’s advisory fee is based upon the higher margined account value, Cardinal will earn a correspondingly higher advisory fee. This could provide Cardinal with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Client Obligations. In performing its services, Cardinal shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Cardinal if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Cardinal’s previous recommendations and/or services. Disclosure Statement. A copy of Cardinal’s written Brochure as set forth on Part 2A of Form ADV and Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Management Agreement. C. Cardinal shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Cardinal shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Cardinal’s services. Moreover, it remains each client’s responsibility to promptly notify Cardinal if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. D. Cardinal licenses a model to a wrap fee manager, but has no other relationship with a wrap fee program. E. As of September 30, 2023, Cardinal had $2,771,092,229 (USD) in assets under management on a discretionary basis and $42,122,482 in assets under management on a non-discretionary basis.