Martin Capital Partners, LLC (MCP), a wholly owned subsidiary of WCM Investment Management, LLC (“WCM”), is an Oregon based financial services firm offering investment advisory services to its clients since June of 2010. The principal owners of WCM are Kurt Winrich and Paul Black through the entity Thalia Street Partners LLC. Martin Capital Partners (MCP) offers investment advisory services to its clients. Advice and services are tailored to the stated objectives of the client(s). Except as otherwise instructed, clients grant MCP ongoing and continuous discretionary authority to execute its investment recommendations in accordance with established client objectives and suitability, without the client’s prior approval of each specific transaction. Under this authority, clients shall allow MCP to purchase and sell securities and instruments in this account, arrange for delivery and payment in connection with the foregoing, and act on behalf of the client in most matters necessary or incidental to the handling of the account, including monitoring certain assets. Clients have the opportunity to place reasonable restrictions on the types of investments that MCP will make on their behalf. All transactions in the account shall be made in accordance with the directions provided to MCP by the client. Clients will execute instructions regarding MCP’s trading authority as required by each custodian. MCP may also provide sub-advisory services to other registered investment advisors who continue to act as their client’s primary advisor. In this role as a sub-advisor MCP provides additional expertise and services for the benefit of the primary advisor’s client. The primary advisor will maintain the advisory relationship with the client and will manage MCP in an advocacy role for the client. Sub-advisory fees charged by MCP are based on a percentage of assets managed by MCP and are set-forth in a sub-advisor agreement entered into by MCP and the primary advisor or the primary advisor’s client. Accounts managed on a sub-advised basis will be managed in the same manner as direct clients of MCP. We follow internal Trade Rotation policies to ensure all clients, including sub-advised, are provided services fairly. MCP participates in certain wrap

programs where a client enters into an agreement with MCP and a registered broker/dealer either directly or indirectly through an affiliate. The client is charged a combined fee (referred to as a “wrap fee”) based upon a percentage of the market value of the account, which generally covers all services for:
• selection of program;
• the investment advisers’ fee to manage the client’s portfolio on a fully discretionary basis;
• brokerage commissions and, in some instances, dealer mark-ups or mark-downs for the execution of trades by the designated broker;
• acting as custodian for the assets in the client’s portfolio which also includes providing the client with trade confirmations and monthly statements;
• periodic evaluation and comparison of account performance; and
• continuing consultations on investment objectives. However, there are some programs where some of these fees are not covered but are charged separately. MCP receives a portion of this “wrap fee” for providing investment supervisory services. In some cases, MCP’s advisory fee is a separate fee. All wrap accounts are traded with non-wrap accounts; please refer to the section entitled Item 12 – Brokerage Practices for information on blocking transactions. Generally, MCP has discretionary investment authority over its client accounts. In some circumstances, client grants MCP only non-discretionary authority to execute its investment recommendations in accordance with MCP’s Statement of Investment Policy (or similar document used to establish client’s objectives and suitability). Non-discretionary authority requires MCP to obtain the client’s prior approval of each specific transaction prior to executing investment recommendations, as well as for the selection and retention of sub- advisors to the account. (Please see Item 16 for additional information). As of December 31, 2023, Martin Capital Partners, LLC provided continuous and regular discretionary management services to approximatley $332.97 million worth of client assets and had zero non-discretionary assets or account. These assets include those managed through sub-advised accounts of other advisors, wrap programs of other advisors as well as direct client assets.