Tortoise Investment Management, LLC (“Tortoise”) is a New York limited liability company formed in September 2004, and has been registered as an investment adviser with the United States Securities and Exchange Commission since January 13, 2006. Rochelle Yankwitt, a member of our Board of Managers, is Tortoise’s principal owner through a trust for which she serves as trustee. Tortoise’s management is vested in its three-member Board of Managers, currently comprised of: Chief Operating Officer, Riva Roloff; Managing Director, Justin Singer; and Rochelle Yankwitt. Michael Mattern serves as Tortoise’s Chief Compliance Officer. Tortoise provides customized, sophisticated investment management and financial advice. Portfolios are managed with an understanding of each client’s complete financial circumstances. We have structured our business to put your interests first in every aspect of our relationship: we are, and always have been, your fiduciary, independent, and fee-only. Every investor should have a strategic plan that coordinates investments into an integrated whole and incorporates the entirety of the investor’s financial circumstances. An integrated plan, properly implemented, leads to disciplined decision-making instead of making individual decisions in a vacuum or letting inertia govern and doing nothing. Our investment strategy emphasizes risk management, a conservative, long-term approach, and tax-efficiency. We believe that it is more important to maximize the probability of having enough money rather than taking the risk necessary to strive to have the most money. Risk and potential return are inextricably entwined. The key to successfully navigating the vagaries of the capital markets is having a more realistic assessment of the universe of possible outcomes, the uncertainty of the future, and the impact of potential losses on real life. A more fully developed understanding of your ability and willingness to bear risk enhances our ability to take the appropriate amount of risk on your behalf. This understanding can only come from on-going, open discussions with you, informed by our professional judgment. Tortoise provides discretionary investment management primarily to high net-worth individuals and trusts, both making and implementing the investment decisions. A substantial portion of our clientele consists of professionals in demanding careers who appreciate the combination of expertise, implementation and global advice from a trustworthy advisor. In addition to what is customarily referred to as investment management, upon specific client request Tortoise may advise clients on a variety of financial, non-investment issues. These issues may include among others: college and retirement planning, mortgage financing, general liabilities management, insurance, charitable giving, estate planning, and wealth transfer. In cases where we discuss estate planning, inter-generational gifting or related matters with a client, and some, but not all, other family members are clients, a potential conflict (or the appearance thereof) may arise. The client retains absolute discretion as to whether or not to implement any of Tortoise’s advice. While Tortoise believes that it is important for the client to address financial, non-investment issues on an ongoing basis, Tortoise’s fee, as set forth at Item 5 below, will remain the same regardless of whether the client decides to address financial, non-investment issues with Tortoise. The services that we provide vary in certain respects based on the needs and desires of individual clients. For example, some clients have more unresolved financial planning matters than others do. In addition, different clients prefer different formats and frequencies of communication. And, of course, each client’s investment portfolio is driven by the client’s particular circumstances. Clients may impose restrictions on certain investments as described in the Investment Discretion section. We do not provide a truncated, more limited version of our services. We do not serve as your attorney, accountant or insurance agent, and no portion of our services should be construed as same. Accordingly, Tortoise does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.). Clients are under no obligation to engage the services of any recommended professional, who shall be solely responsible for the quality and competency of the services they provide. If the client engages any unaffiliated recommended professional, and a dispute arises related to the engagement, the client should seek recourse exclusively from and against the engaged professional. Miscellaneous Retirement Plan Rollovers and Conflicts 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 Tortoise recommends that a client roll over retirement plan assets into an account to be managed by Tortoise, such a recommendation creates a conflict of interest if Tortoise will earn new (or increase its current) compensation as a result of the rollover. Of course, a similar conflict of interest arises any time a client contemplates putting additional assets (whether retirement plan assets or otherwise) under Tortoise’s management. If Tortoise provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Tortoise is acting as 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. No client is under any obligation to roll over retirement plan assets to an account managed by Tortoise. Portfolio Trading Activity. As part of its investment advisory services, Tortoise 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, additions, withdrawals, and/or a change in the client’s investment objectives. A review does not necessarily imply that some action will be taken. In fact, Tortoise often determines that taking no action, in the particular circumstances, is the best action. Clients remain subject to the fees described in Item 5 below during periods of account trading inactivity. Trustee Directed Plans. Tortoise can be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm will manage plan assets consistent with the investment objectives designated by the plan trustees. In these engagements, Tortoise will serve as a fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Tortoise will generally provide services on an “assets under

management” fee basis according to the terms and conditions of a written agreement between the plan and Tortoise. Client Retirement Plan Assets. Upon engagement to do so, Tortoise shall manage assets held in a client’s employer-sponsored 401(k), but their investment selections are limited to the options available on the applicable platform or accompanying brokerage link. Tortoise will not receive any communications from the plan sponsor or custodian, and those clients are exclusively obligated to notify Tortoise of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unaffiliated Private Investment Funds. Tortoise does not generally recommend private investment funds, However, when requested by a client, Tortoise may discuss investment in unaffiliated private investment funds (any corresponding purchase by the client shall be on a non-discretionary basis). If Tortoise determines to provide advisory services, Tortoise’s role shall be limited to its initial and ongoing investment review and monitoring services, and, unless determined by Tortoise to the contrary, in writing, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Tortoise calculating its investment advisory fee. Tortoise’s advisory fee shall be in addition to the fund’s fees. Tortoise clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that the client is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Interval Funds: Risks and Limitations. Where appropriate, Tortoise may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, interval funds are not listed on any securities exchange and are not publicly traded. Therefore, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct Tortoise, in writing, not to purchase interval funds for the client’s account. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield differential, Tortoise, within a reasonable period of time, will generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Tortoise reasonably anticipates that it will utilize the cash proceeds in the short-term to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of the difference between the sweep account and a money market fund, the size of the case balance, an indication from the client of a need for access to such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within Tortoise’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for cash balance decisions and corresponding transactions for cash balances maintained in any Tortoise unmanaged accounts. Client Obligations. In performing our services, Tortoise will not verify any information received from the client or from the client’s other professionals and, clients authorize Tortoise to rely on that information. Clients are responsible to promptly notify Tortoise if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous recommendations and services. Investment Risk. Investing in securities involves risk of loss that clients should be prepared to bear, including the loss of principal investment. Past performance does not guarantee future results. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Tortoise) will be profitable or equal any specific performance level. Investment strategies such as asset allocation, diversification, or rebalancing do not assure or guarantee better performance and cannot eliminate the risk of investment losses. There is no guarantee that a portfolio employing these or any other strategy will outperform a portfolio that does not engage in such strategies. While asset values may increase and client account values could benefit as a result, it is also possible that asset values may decrease and client account values could suffer a loss. Tortoise does not manage or sponsor a Wrap Fee Program. As of December 31, 2023, Tortoise managed $1,431,899,609 of client assets on a discretionary basis and $29,312,289 of client assets on a non-discretionary basis.