ITEM 5—ADDITIONAL COMPENSATION ............................................................................................ 22 ITEM 6—SUPERVISION ..................................................................................................................... 22 Bolthouse Investment Management Services Page 1 Description of Advisory Firm Bolthouse Investments, LLC dba Bolthouse Investment Management Services (“Bolthouse Investments,” “we,” “our,” “the firm” or “us”) is a privately-owned limited liability company headquartered in Bakersfield, California. Bolthouse Investments is registered as an investment advisor with the U.S. Securities and Exchange Commission (the “SEC”). Bolthouse Investments was established in March 2008, in anticipation of registration with the SEC, to carry on the investment advisory business previously conducted by Bolthouse Properties, LLC (“Bolthouse Properties”). Registered with the SEC in March 2012, Bolthouse Investments is wholly owned by Bolthouse Properties, which in turn is primarily owned by members of the Bolthouse family. Advisory Services Offered Bolthouse Investments offers the following services to advisory clients: Investment Management Services Bolthouse Investments offers advice to clients regarding asset allocation and the selection of investments. Investment management services are provided primarily through two private partnerships (equity and fixed income) organized by Bolthouse Investments (each a “Fund”). Assets in the Funds are invested either with third-party advisors or in mutual funds, Exchange-Traded Funds (“ETFs”), and individual securities selected by us. We provide continuous and regular investment supervisory services on a fully discretionary basis. The Funds are available only to accredited investors, as the term is defined by rule 501 of Regulation D under the Securities Act of 1933. Additional information on each Fund is provided in its offering documents. This brochure is not an offer to sell, or a solicitation of an offer to purchase, interests in the Funds. Such an offer only occurs when a prospective investor receives the offering documents. The third-party advisors and mutual funds selected by Bolthouse Investments primarily utilize the following investment types when making investment purchases for the Funds: Equity securities, including U.S. securities and foreign securities listed on U.S. exchanges using American depositary receipts or listed on foreign exchanges Fixed-income securities, including corporate bonds, commercial paper, and certificates of deposit Securities with equity and debt characteristics, including convertible bonds, preferred stocks or other preferred securities Municipal securities U.S. government securities Mutual funds Exchange-traded funds (each an “ETF”) Money-market funds and cash Bolthouse Investment Management Services Page 2 Depending on the individual investment objectives and needs of individual clients, our investment selections may include the securities held by the Funds and: Real estate investment trusts (each a “REIT”) Promissory notes Closed-end funds Variable annuities Deeds of trust Interests in partnerships and other entities investing in real estate, oil and gas interests, and leases Master limited partnerships Private funds Unit investment trusts Warrants and rights Insurance products, including variable life insurance Viaticals Options contracts on securities and commodities Futures contracts Managed futures accounts Limited liability company interests Treasury inflation-protected securities Inflation-indexed bonds Other investments Bolthouse Investments may also occasionally utilize additional types of investments if to address the individual needs, goals, and objectives of a client or in response to a client inquiry. Bolthouse Investments may offer investment advice on any investment held by the client. We describe the material investment risks for many of the securities that we utilize in Item 8—Methods of Analysis, Investment Strategies, and Risk of Loss—Specific Security Risks. We may also offer non-discretionary services depending on client circumstances. We discuss our discretionary authority in Item 16—Investment Discretion. For more information about the restrictions clients may put on their accounts, see Tailored Services and Client-Imposed Restrictions in this item. We describe the fees that we charge for investment management services in Item 5—Fees and Compensation. Consulting Services From time to time, Bolthouse Investments may offer financial consulting as requested by the client. We describe the fees charged for consulting services in Item 5—Fees and Compensation. Bill Pay Services Bolthouse Investments provides non-investment advisory services to advisory clients where the firm has direct access to client bank account(s) and other asset(s), often referred to as bill paying services. Fees for these

services are separate and distinct from the advisory fees and negotiated and billed separately to the client. Bolthouse Investment Management Services Page 3 Limitations on Investments In the following circumstances, our advice may be limited to certain types of securities: Limitation by Plan Sponsor or Employer When we provide services to a retirement plan, such as a 401(k), 403(b), or other employer plan, we are limited to those investment providers and investment options chosen by the plan sponsor. Similarly, when we provide services to participants in an employer-sponsored plan, the participant may be limited to investing in securities included in the plan’s investment options. Therefore, Bolthouse Investments can only select investments for or make recommendations to the client from among the available options. We will not recommend or invest the client’s account in other securities, even if we perceive that other options are more attractive. Limitation by Issuer When we manage assets within an annuity, we are limited to those investment options made available by the annuity provider. Limitation by Custodian There may be limitations imposed by the custodian holding the account on the securities that Bolthouse Investments may utilize in a client’s account based on limitations. Bolthouse Investments encourages clients to establish brokerage accounts with Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”), which is a broker-dealer registered with the SEC and a member of the Securities Investor Protection Corporation. Schwab offers a broad range of investment products, but we may occasionally recommend a security for the client that Schwab does not have available. We typically purchase the security from another firm, and have it transferred to the client’s Schwab account. Schwab may charge the client additional fees. Bolthouse Investments considers these fees when we recommend outside securities. Limitation by Client Bolthouse Investments may limit advice based on client-imposed restrictions. For more information about the restrictions that clients may put on their accounts, see Tailored Services and Client-Imposed Restrictions in this item. Non-Managed Assets With respect to investment management services, Bolthouse Investments will only be responsible for the supervision and management of securities and other investments that we recommend or select. Bolthouse Investments is not responsible for the supervision or management of non-managed assets. Non-managed assets may include securities held in a client’s account that were (1) delivered into the account by the client, (2) purchased by the client, (3) purchased by Bolthouse Investments at the request of the client as an accommodation, or (4) designated by the client to be non-managed securities by written notification. Bolthouse Investment Management Services Page 4 We do not provide investment advice regarding that portion of the client’s account designated as non- managed assets, nor do we provide opinions as to the merits of any non-managed asset held in the account. We also do not make any judgments as to the appropriateness of assumed risk or the suitability of any non-managed investment. Bolthouse Investments monitors and reports on non- managed assets at no charge and at our discretion, in consideration of other assets that we manage for the client. Tailored Services and Client-Imposed Restrictions Bolthouse Investments applies a customized investment strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on information that the client supplies about his or her financial situation, goals, and risk tolerance. Our investment selections may not be suitable if the client does not provide us with accurate and complete information. Clients should keep Bolthouse Investments informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account. For example, a client may need to keep a minimum level of cash in the account or may not want Bolthouse Investments to buy or sell specific securities or security types in the account. Bolthouse Investments reserves the right not to accept or to terminate management of a client’s account if we feel that client-imposed restrictions would limit or prevent us from achieving or maintaining the client’s investment strategy. Clients may not impose restrictions on the investments selected for the Funds. Assets Under Management Bolthouse Investments manages client assets in both discretionary and non-discretionary accounts on a continuous and regular basis. As of December 31, 2022, we managed approximately $348,412,000 assets on a discretionary basis and approximately $5,010,000 assets on a non-discretionary basis. Our total assets under management as of that date were approximately $353,422,000.