O.N. Investment Management Company (ONIMCO) Firm Description Established in 1969, O.N. Investment Management Company (hereinafter “ONIMCO”) is a SEC Registered Investment Adviser and a subsidiary of The O.N. Equity Sales Company (hereinafter “ONESCO”), a full service broker/dealer registered with the SEC and FINRA. ONESCO is a wholly owned subsidiary of Constellation Insurance Holdings, Inc. Generally speaking, ONIMCO advisers (hereinafter "Investment Adviser Representatives" or "IARs") are required to maintain the FINRA Series 6 (Investment Company and Variable Contracts Registration) or the Series 7 (General Securities Registration), and must be authorized to act as an investment adviser under the state securities regulations for the states in which they conduct business. Generally, the state securities regulations require a representative to have a Series 65 (Uniform Investment Adviser Law), Series 66 (Uniform Combined State Law) or hold a certain professional designation. Description of Services IARs of ONIMCO provide Financial Planning Services and Investment Advisory Programs as described below. Financial Planning Services A financial plan is defined as an outline designed to help provide you with recommendations of how to efficiently invest or allocate the money you currently have and help provide you with ideas of how to increase the value of your funds for the future. Financial plans can sometimes be simple, but more often are comprehensive and involve various aspects of personal finance such as: cash flow management, education planning, retirement planning, investment planning, risk management, insurance planning, estate planning, etc. In developing a personalized financial plan for clients, ONIMCO IARs may provide: 1. Comprehensive Financial Planning – Using approved software programs, ONIMCO advisers will assist you in developing a detailed strategy for your financial situation. The plan will cover present and anticipated assets and liabilities, including but not limited to insurance, savings, investments, and anticipated retirement or other employee benefits. 2. Modular Planning – More limited than a comprehensive financial plan, a modular plan will focus on a specific need such as: retirement funding, college funding, or Estate Planning. Approved software will also be used when performing Modular Planning. 3. Specialized Financial Services – Refers to services performed by ONIMCO advisers based on a specific client need which is charged at an hourly fee or fixed fee for a specific time period (not to exceed one year). These services are limited to specific topics within the financial planning area. Examples include but are not limited to: Insurance Analysis, Investment Analysis, Cash Flow Analysis, Education Planning, Retirement Planning, and Special Needs Planning. The Comprehensive and Modular planning process often consists of two stages. In the first stage, your adviser will work with you as an objective adviser. He/she will help you determine your financial goals and objectives. Based on the information you provide, the investment adviser will create a plan tailored to your specific situation. The recommendations will be general in nature, in that they will not recommend any company’s specific products or ONIMCO ADV Part 2A: Version 3/28/2024 - 5 - securities, but will instead focus on strategies that you should consider in order to achieve the goals that you’ve identified as being most important to you. Once your adviser has completed the plan, he/she will then review the plan with you and may offer to help you implement the plan. Once created, you are under no obligation to implement the plan or to continue working with the same adviser. However, if you do decide to put the plan to work utilizing the same adviser who created the plan, then he/she will work with you in order to choose the specific products that may be necessary to help you achieve your goals. Investment Advisory Programs In order to assist you with the management of your accounts, IARs of ONIMCO may choose to utilize Third Party Investment Advisory Programs or act as Portfolio Manager through two IAR-Directed Programs available through Envestnet. Additionally, ONIMCO and its IARs may provide a variety of services for compensation to ERISA plan fiduciaries and plan participants. Third Party Investment Advisory Programs ONIMCO has agreements with the following non-affiliated investment advisory programs. For most programs, ONIMCO IARs act as a solicitor. ONIMCO IARs who recommend these programs are required to deliver to clients the Form ADV Part 2 of the non-affiliated adviser as well as the ONIMCO Form ADV Part 2. Each of these programs offers services to ONIMCO clients on a discretionary basis. Clients seeking more information about these programs should consult Form ADV Part 2 of the particular non-affiliated program. Third Party Programs
• AssetMark, Inc.
• Brinker Capital / Orion Portfolio Solutions, LLC

• City National Rochdale
• Envestnet, Inc
• BNY Mellon Advisors, Inc.
• Morningstar Investment Services, LLC
• SEI Investment Management Corp
• Symmetry Partners, LLC ONIMCO ADV Part 2A: Version 3/28/2024 - 6 - IAR-Directed Programs There are two IAR-Directed Programs available to ONIMCO advisers and their clients: Adviser as Portfolio Manager Program and an IAR-Directed Unified Managed Account Program both available through Envestnet Portfolio Solutions. These programs are unique because in lieu of having a third party professional money manager select and monitor which specific investments should be utilized, the ONIMCO Investment Adviser Representative will have the discretion to select the investments on the client’s behalf based upon several factors, including but not limited to: investment time horizon, risk tolerance, financial situation, net worth, investment experience, and investment objectives. The Adviser as Portfolio Manager Program allows the IAR to construct a portfolio by utilizing a combination of individual stocks, bonds, mutual funds, and certain exchange-traded funds (“ETFs”). Additionally, IARs may use certain fee or commission-based Variable Annuities alone or in combination with managed portfolios for clients. The compliance rules and oversight under the Adviser as Portfolio Manager also apply to the variable annuity sub-accounts. The IAR-Directed Unified Managed Account Program also allows the IAR the ability to construct a portfolio utilizing individual securities, mutual funds, certain ETFs, as well as Fund Strategist Portfolios, Separately Managed Accounts (“SMAs”), and Adviser Constructed Sleeves. These portfolios are constructed by the IAR based upon the client’s specific investment objectives and risk tolerance, and the accounts are monitored and rebalanced by the IAR for the Advisor as Portfolio Manager or rebalanced by Envestnet for the Unified Managed Account Program. With both of the IAR-Directed Programs described above, ONIMCO IARs will assist with the client’s initial asset allocation and monitor the accounts to provide reallocation of the assets as needed. IARs periodically review accounts and will consult with clients, at least annually, in order help ensure that the account holdings are appropriate given the client’s time horizon, risk tolerance, investment experience, and goals. You, as a client, are responsible for contacting the Investment Adviser Representative in order to provide updates to any material changes that may occur to your circumstances which may impact your goals and objectives for your accounts. In seeking investment advice, you are responsible for providing accurate information about your financial status, goals, and risk tolerance to help ensure that appropriate recommendations are provided. Retirement Plan Advisory Services ONIMCO and its IARs provide a variety of services for compensation to ERISA plan fiduciaries and plan participants. ONIMCO and its IARs may provide education and enrollment services to ERISA plan fiduciaries and plan participants. ONIMCO IARs may provide non-fiduciary consulting services to plan sponsors. The IAR will generally establish the plan sponsor’s needs and objective through an initial meeting to collect data and review plan information to assist the sponsor in developing or updating a plan. IARs may provide general investment-related guidance, investment education and information about plan design, investment options and rollovers to a retirement plan fiduciary and its participants without being considered a fiduciary. ONIMCO guidelines regarding retirement plan advisory services require the plan to adopt third party professional investment fiduciary services to provide ERISA 3(16), 3(21) and/or 3(38) plan and investment services for the plan sponsor. ONIMCO IARs are not authorized to have discretionary authority (3(38)) over an ERISA plan account, but may in some pre-approved cases provide non-discretionary investment services (3(21)) by providing recommendations regarding the selection and review of investment options for the plan sponsor. Plan sponsors are under no obligation to follow the recommendations of the IARs in these instances. ONIMCO IARs providing services to retirement plan sponsors must enter into either a fee-for-plan consulting agreement or non-fiduciary services agreement with the plan sponsor. ONIMCO does not provide recordkeeping or TPA services for plans and relies on several sponsors to provide these services to plan sponsors and ONIMCO IARs. ONIMCO IARs work with many strategic partners who provide retirement plan services. Your ONIMCO IAR will work with you to help determine which strategic partner may be the best fit for your specific situation. ONIMCO ADV Part 2A: Version 3/28/2024 - 7 - Assets Under Management: (as of December 31, 2023) Discretionary: $654,726,293 Non-Discretionary: $1,540,721,448 Total: $2,195,447,741 ONIMCO ADV Part 2A: Version 3/28/2024 - 8 -