A. Description of Firm Albion Financial Group is a Registered Investment Advisory Firm founded in 1982 and is privately held by William T. Levitt, John Bird, and Doug Wells. B. Description of Services Asset Management Services Albion offers discretionary management of investment accounts and financial planning for individuals and institutions, specializing in equity and debt securities including but not limited to domestic and foreign common stocks, exchange traded funds, no‐load mutual funds, closed end mutual funds, convertible securities, corporate and municipal bonds, and U.S. Government securities. Retirement Plan Services Albion Financial Group offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Services Albion Financial Group provides the following Fiduciary Retirement Plan Services:
• Investment Policy Statement Preparation ‐ Albion Financial Group will help you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Investment Monitoring ‐ Albion Financial Group will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement
• Discretionary Investment Selection Services ‐ Albion Financial Group will monitor the investment options of the Plan and add or remove investment options for the Plan. Albion Financial Group will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants. If you elect to utilize any of Albion Financial Group’s Fiduciary Management Services, then Albion Financial Group will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and Albion Financial Group hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Albion Financial Group acknowledges that in performing the fiduciary services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing discretionary investment advice only. Advisor will act in a manner consistent with the requirements of a fiduciary under ERISA for all services for which Advisor is considered a fiduciary under ERISA. Albion Financial Group (a) has responsibility for and (i) will exercise discretionary authority respecting management of Client’s retirement plan’s assets, and (ii) will not have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is an “investment manager” as defined in Section 3(38) of ERISA and does have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined

in ERISA. Albion Financial Group will disclose, to the extent required by ERISA Regulation Section 2550.408b‐2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b‐2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b‐2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b‐2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learns of such error or omission. Private Fund Management Albion also manages Albion Fund I, LP, Albion Fund II, LP, and Albion Fund III, LP, private investment funds, according to the investment objectives and investment guidelines set forth in the funds’ offering memorandums. See Item 6 for further details of these funds and service. C. Client Tailored Services and Client Imposed Restrictions Albion offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation and may include information such as cash distribution requirements, time horizon, tax situation, and risk tolerance. The Investment Policy Statement serves as guidance in constructing a client specific investment portfolio appropriate for the client restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Albion from properly servicing the client account, or if the restrictions would require Albion to deviate from its standard suite of services, Albion reserves the right to end the relationship. D. Wrap Fee Programs Albion is an investment manager in the Wells Fargo Private Advisors Network Wrap program and in the RBC Dain Rauscher MAP program. Accounts in these programs are treated no differently than other Albion client accounts. Trades are pre‐allocated according to Investment Policy, and trades are placed in blocks so that all clients receive similar trade executions. Albion receives a portion of the wrap fee for our investment management services. E. Amounts Under Management Discretionary Amounts: $ 1,480,441,706 Non‐discretionary Amounts: $ 117,241,412 Date Calculated: December 31, 2023