Frost Investment Advisors, LLC (the “Adviser”) is a registered investment adviser with the United States Securities and Exchange Commission (“SEC”), first registered in January of 2008. We are a wholly owned subsidiary of Frost Bank (“Frost”). Frost is a wholly owned subsidiary of Cullen/Frost Bankers, Inc., a financial services holding company offering insurance, brokerage and investment services through the subsidiaries of Frost Bank. Cullen/Frost Bankers, Inc. is publicly traded on the New York Stock Exchange (“NYSE”) under the symbol CFR. We provide investment advisory services to registered investment companies (mutual funds) through a range of style-based investment approaches including growth equity, taxable fixed income and tax-exempt fixed income. All mutual funds described above collectively make up the “Frost Funds”. Each mutual fund’s management style, objective, and constraints, among other things, are described in the prospectus and should be considered carefully before investing. All mutual funds are managed internally by the Adviser. Custody services for the mutual funds are provided by Brown Brothers Harriman & Co, 40 Water Street, Boston, Massachusetts. We also provide investment advisory services to separately managed accounts (“SMAs”), creating portfolio solutions to meet the specific purposes and/or needs of each client. We provide a range of style-based investment approaches to SMAs including taxable fixed income, tax-exempt fixed income and asset allocation. Guided by the investment policy statement (“IPS”) of the client, the Adviser will make every attempt to accommodate the client’s requests regarding the use of certain securities or types of securities, rating quality requirements, restraints on duration, tax exempt status and liquidity. For those clients who do not present us with an IPS, we will assist the client with constructing one by obtaining the necessary personal and financial information. Client’s may impose reasonable restrictions on investing in certain types of securities or industry sectors, if it does not impair our ability to manage their account. It is the client’s responsibility to notify us in writing of any changes to any information provided. We do not provide custody services for separately managed accounts. Our affiliate offers custody services; however, each client selects their custodian of choice. In addition to the investment advisory services provided to mutual funds and SMAs, we also provide asset allocation models and core models to financial institutions for use with their clients. The asset allocation models are risk-based and are primarily focused on diversification and minimizing volatility in a portfolio by distributing assets across a broad spectrum of asset classes, including, but not limited to, short-term bonds, intermediate-term bonds, high yield bonds, global bonds, large cap equity,

mid cap equity, small cap equity, international equity, emerging markets, real estate, natural resources, alternative investments, and cash equivalents. We provide financial institutions and other clients with the asset class weighting for each asset allocation model, and several options for each asset class. Options provided within each asset class are composed of proprietary mutual funds, third-party mutual funds and/or other appropriate securities. A conflict of interest arises when Frost Funds are recommended for purchase within the asset allocation models provided to our clients, as this would increase the amount of compensation we receive, based on the investment management fee that we receive on Frost Funds. This conflict is further addressed in the “Fees and Compensation” section. The core models are similar to the style-based investment approach provided to the mutual funds and SMAs, which include growth equity, dividend income equity, value equity, a blend of growth and value equity or growth and dividend income equity. We provide affiliated and non-affiliated financial institutions with notifications identifying our recommendations as to the securities to be bought, sold or held in each model, as well as the percentage of the model portfolio that would be invested in each underlying security within each respective portfolio. This information is provided to the client utilizing a trade rotation process described in the “Brokerage” section. Each institutional client utilizing our core models maintains discretion over all trading activity and implementation of any investment advice received from us. If a client determines to act on a recommendation to buy or sell a security, they may do so at the same time, prior to, or after we have bought or sold the security within our proprietary portfolio. The client’s activity could result in a positive or negative impact on our ability to execute trades for our own clients. A conflict of interest arises where pertinent information is not disseminated to institutional clients utilizing the core models in a timely fashion, or where one institutional client is continually notified before another. This conflict of interest is addressed by implementing a “trade notification rotation”, which is further discussed in the “Brokerage” section. 4 | P a g e Institutions utilizing our asset allocation models, and core models have the discretion to implement the models as provided or make adjustments as they wish. We do not facilitate any trading in a client’s use of our asset allocations models and core models in relation to the underlying accounts. As of December 31, 2023, we have $4,179,901,223.95 of discretionary assets under management and $0 non- discretionary assets under management.