Twele Capital Management, Inc. (“Twele Capital”) is an SEC-registered investment adviser with its principal place of business located in Minnetonka, Minnesota. Twele Capital began conducting business in 2004. Listed below are the firm's shareholders as of May 10, 2024: Shareholder Name Position Percent Ownership John A. Twele, CFA President & Chief Executive Officer 30% Maressia A. Twele Chief Financial Officer 30% Gregory I. Baranivsky, CFA Principal 20% Justin D. Henne, CFA Chief Investment Officer 20% Twele Capital offers the following advisory services to our clients: Individual Portfolio Management Through personal discussions, in which goals and objectives based on a client's particular circumstances are established, we develop a client's Investment Policy Statement, and create and manage a portfolio based on that policy. During our data-gathering process, we detail the client’s overall investment objective, time horizons, risk tolerance, liquidity needs and any other special considerations. Within the Investment Policy Statement, we also state the return objectives and identify risk management elements of our investment process. Investment Supervisory Services Our firm provides continuous advice to a client regarding the investment of funds based on the individual needs of the client. We manage these advisory accounts on a discretionary basis meaning a client authorizes us to buy and sell securities within their account(s) without needing the client’s consent for each trade. Account supervision is guided by the client's stated investment objectives and tax considerations. Clients can impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any

specific product or service offered by a broker-dealer, asset management firm or insurance company, but generally we use Exchange- Traded Funds (ETFs) as the core investment building blocks for client portfolios. Because all investments involve varying degrees of risk, the investments will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. Retirement Planning Our firm offers Retirement Planning to its clients typically near or at retirement at no additional costs. Retirement Planning will typically involve preparing a retirement plan based on a client’s unique goals, resources (income sources, savings, and investment assets) and risk and return tolerances. Information is gathered through in-depth personal interviews, a written questionnaire and additional supporting documentation from the client. Our firm utilizes tools, including third-party retirement software, to produce a personalized retirement lifestyle plan which is reviewed and discussed with the client. Retirement Planning may include recommendations for a course of activity, including a proper savings and spending strategy, or other specific actions to be taken by the client. Implementation of any recommendations are at the sole discretion of the client. The projections or other information generated by the third- party retirement planning software includes investment outcomes that are hypothetical in nature, do not reflect actual investment results, and are not guarantees of future results or success in retirement. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $636,129,571 of clients' assets on a discretionary basis plus $398,931 of clients' assets on a non-discretionary basis.