A. Firm Description Founded in 1919, 1919 Investment Counsel, LLC ("1919") has been a wholly-owned subsidiary of Stifel Financial Corp. (“Stifel”), a publicly held company whose common stock trades under the symbol “SF”, since November 8, 2014, when it was acquired from Legg Mason, Inc. 1919 was originally founded as Scudder Stevens & Clark and later known as Scudder Private Investment Counsel while under the ownership of Zurich Insurance Co., from 1997 to 2001, and Deutsche Bank from 2002 to 2004.1 A group of senior 1919 management professionals are responsible for the management structures, and policies and procedures for the operation and development of the firm. Harry O’Mealia, Chief Executive Officer, Margaret M. Pasquarella, Chief Financial Officer and Director of Human Resources, Charles C. King, Chief Investment Officer, Brian Gallagher, Chief Administrative Officer, Reshma Ballie McGowan, Chief Compliance Officer and the firm’s Operating Committee, comprise this group of executives. 1919 is a Maryland limited liability company formed in 2004 and is registered with the SEC as an investment adviser. As of December 31, 2023, 1919 managed approximately $21 billion of both discretionary and non-discretionary assets. 1919 is a separately-registered investment adviser that generally operates independently of other Stifel-affiliated advisers and broker- dealers. Information about 1919’s qualifications, business practices, portfolio management techniques and affiliates is accessible on our website at www.1919ic.com. B. Advisory Services When we serve as investment adviser to clients, we are considered to have a fiduciary relationship with the client and are therefore held to the legal standards set forth in the Investment Advisers Act of 1940, certain state laws, and common law standards applicable to fiduciaries. These standards include the duty of care, including the obligation to have a reasonable basis for believing that our investment recommendations are suitable and consistent with each client’s stated objectives and goals, and the duty of loyalty, including the obligation to provide the client with full disclosure of material conflicts of interest. Our duties of care and loyalty differ depending on the authority that a client has granted us and the services that we have agreed to provide – for example, whether we have agreed to provide non-discretionary versus discretionary services or when we provide episodic (e.g., financial planning) versus continuous advice. 1919’s core business is providing comprehensive investment counsel services including, but not limited to, equity, fixed income, and private funds discretionary and non- discretionary investment advisory services to both individual and institutional clients, and financial planning, family office services, and estate and generational wealth planning services to individual clients. 1919 is also the investment manager to mutual funds. 1919 tailors investment advisory services to client needs according to investment guidelines based on the client’s investment

objectives that are captured on a client investment policy statement. 1919 then manages client accounts in accordance with these tailored investment policy statements. The firm’s investment professionals work directly with individual and institutional clients to develop these investment policy statements and tailor portfolios to reflect individual client considerations including time horizon, risk tolerance, liquidity needs, restrictions on investing in specific securities or types of securities, portfolio income and cash flow needs, and tax considerations. The investment policy statements are not static and periodically reviewed with clients, and modified to meet clients’ changing needs. Investment professionals primarily focus on, but are not limited 1 Unless otherwise stated, references to 1919 also includes Arthur Karafin Investment Advisors (“AKIA”), a department of 1919. AKIA is not a separately registered investment advisor. 5 | P a g e to, liquid mid- to large-cap stocks and investment grade fixed income securities and, using third-party managers to supplement with strategies they believe complement these core assets. For certain client accounts, 1919 directs the investment of client assets in mutual funds. From time to time, 1919 presents a variety of alternative investments including private equity, hedge funds and real estate investments to clients if appropriate. Clients have the ability to define investment restrictions with respect to any of their accounts (or specific assets within the accounts), such as restricting investments in specific securities, types of securities, industries, or sectors. The performance of accounts will differ (potentially significantly) from the performance of other accounts in the same strategy, without similar restrictions or different entry points. In addition to the core offering of tailored investment management, 1919 also manages a variety of investment strategies that can be made available to clients through direct accounts or certain wrap platforms. These strategies include the following: C. Non-Discretionary Investment Advice 1919 largely provides discretionary investment management services, which involve 1919 selecting investments for client accounts. However, 1919 also provides certain clients with non-discretionary investment advisory services. When 1919 provides non-discretionary investment advisory services, the client decides whether or not to approve 1919’s investment recommendations. If 1919 provides non-discretionary advice, then 1919 will implement the recommendations only after receiving the client’s approval. 1919’s non-discretionary investment advisory services include:  providing another financial firm (the client) with, and continuously monitoring and updating, a model investment portfolio that the client, in turn, can implement for accounts of its own clients;  monitoring and making investment recommendations for specific client accounts; or  reviewing and making investment recommendations for client accounts at periodic intervals.