Description of Services Verity and Verity, LLC d/b/a Verity Investment Partners and Verity Investment Management is a registered investment adviser based in Beaufort, South Carolina with offices in Bluffton, South Carolina, Edwards, Colorado and San Antonio, Texas. We are organized as a limited liability company under the laws of the State of South Carolina. We have been providing investment advisory services since 2002. William W. Verity is our firm's principal owner. The following paragraphs describe our services. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Verity Investment Partners and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. We offer discretionary investment management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you ongoing and focused investment advice and/or to make investments on your behalf. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. We request you grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Financial Planning We offer financial planning services but do not charge separately for this service. Our financial planning services may be general in nature or focused on particular areas of interest or request, depending on each client's unique circumstances and goals. Financial planning advice is offered in the areas of goal setting, cash flow and debt management, retirement planning, investment planning, college education funding, tax planning and estate planning as applicable. We offer such services as requested by the client and the client is responsible for implementing, accepting or rejecting any plans we may present. We do not serve as an attorney, accountant, insurance agent and no portion of our services should be construed as same. Limitations of Financial Planning To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purposes. You are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation that we make. Please note: If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such March 2024 5 engagement, the client agrees to resolve the dispute directly with the engaged professional. Advisory Services to Retirement Plans and Plan Participants As disclosed above, we offer investment advisory and financial planning services. For Plans that allow participants to have self-directed accounts, we provide our services to employee benefit plan participants (“Participants”) or pooled accounts. The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan and the compensation we receive for these services are described above, and in the service agreement that you have previously signed. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation,

the services rendered for such compensation and the payer of such compensation to you. IRA Rollover Considerations and Recommendations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account (IRA) that we will manage on your behalf. We comply with the Department of Labor (“DOL”) Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable. Our firm is providing the following additional acknowledgment: When we provide investment advice to individuals regarding a retirement plan account or individual retirement account, the firm is deemed a fiduciary 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. The way we make money creates potential conflicts with a client’s interest. Therefore, we, operate under a special rule which requires the firm to act in a client’s best interest and not put our interests ahead of the client. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of a client when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure advice given is in the client’s best interest;
• Charge no more than is reasonable for services; and
• Provide basic information about conflicts of interest. We benefit financially from the rollover of a client’s assets from a retirement account to an account managed by the firm. This is a primary conflict of interest because when we provide investment advice, the assets increase the firm assets under management and, in turn, advisory fees. To meet the fiduciary responsibility we only recommend a rollover when it is deemed in the client’s best interest. March 2024 6 Sub-Advisory Services to Registered Investment Advisers We may also serve as a sub-adviser to unaffiliated registered investment advisers per the terms and conditions of a written agreement. With respect to its sub-advisory services, the unaffiliated investment advisers that engage our sub-advisory services maintain both the initial and ongoing day- to-day relationship with the underlying client, including initial and ongoing determination of client suitability for our designated investment strategies. If the custodian/broker-dealer is determined by the unaffiliated investment adviser, we will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, underlying accounts may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by us. Higher transaction costs adversely impact account performance. Investment Strategy and Research Services to Registered Investment Advisers We may provide model portfolios to unaffiliated registered investment advisers (third party) for their use in managing their underlying clients’ accounts. Per the terms of the written agreement, with the unaffiliated registered investment adviser we do not have an advisory, fiduciary or other relationship with any of the third party’s underlying client(s). The unaffiliated registered investment adviser is exclusively responsible for determining the suitability of the model portfolio for their underlying client(s) and whether to implement any of the model portfolios. Status In providing services to the Plan and Participants, our status is that of an investment adviser registered under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as a discretionary fiduciary of the plan as defined in Section 3(38) under ERISA. Types of Investments In general, we offer advice on equity securities, ETFs, corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual funds, U.S. Government securities, interests in partnerships investing in real estate and oil and gas interests and other investments. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Client Obligation In performing our services, Verity Investment Partners 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. Each client is advised that it remains his/her responsibility to promptly notify us in writing if there is ever any change in his/her financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. We also request that you keep us advised of any changes of address, phone, email and the like. Assets Under Management As of December 31, 2023, we provide continuous management services for $930,833,366 in client assets on a discretionary basis as well as $7,900,558 on a non-discretionary basis. March 2024 7