Howard Capital Management Group LLC (“HCM”) acquired the business of Howard Capital Management, Inc., which was founded in 1974. HCM is managed by David A. Robinson and Jason D. Kaplan (“HCM Principals”) pursuant to a management agreement (the “DRJK Management Agreement”) among DRJK, LLC (“DRJK”), the HCM Principals and KSFB Management, LLC (“KSFB”). The HCM Principals serve as officers of HCM and are responsible for the management, supervision and oversight of HCM. KSFB entered into the DRJK Management Agreement in furtherance of a separate management agreement among KSFB, the Principals of KSFB, Focus Financial Partners, LLC, NKSFB, LLC and HCM. Pursuant to the DRJK Management Agreement, certain decisions relating to the ongoing management and operation of HCM will be subject to KSFB’s approval, including significant expenditures and other budgetary matters. HCM does not believe that KSFB’s approval rights for such matters will materially affect the day-to-day advisory relationship between HCM and its clients. FOCUS FINANCIAL PARTNERS, LLC HCM is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, HCM is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is a majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R"). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because HCM is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of HCM. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. FIDUCIARY As a fiduciary, we have duties of care and loyalty to you and are subject to obligations

imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. ADVISORY SERVICES HCM generally provides personalized, ongoing investment supervisory services to clients relating to publicly traded equity and debt securities and will from time to time issue analyses or reports to clients concerning the above-described activities. HCM implements investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party Howard Capital Management Group LLC 2 custodians. These held-away accounts are often retirement accounts and other assets that are not held at our primary custodians. When deemed appropriate by HCM, HCM may employ the use of Exchange Traded Funds (ETFs) in the management of client accounts. Certain accounts may use ETFs exclusively. HCM is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. HCM is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants (collectively, “Retirement Account Clients”). As such, HCM is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption. HCM provides discretionary services for certain ERISA plans. HCM exercises discretionary authority to select investments in accordance with the plan’s goals and objectives. ASSETS UNDER MANAGEMENT As of December 31, 2023, HCM had $1,975,090,345 in assets under management on a discretionary basis. Howard Capital Management Group LLC 3