EM 4 Who We Are Sawgrass Asset Management, LLC (hereinafter referred to as “Sawgrass”, “the Company”, “we”, “us” and “our”), is a 100% employee-owned registered investment advisor1 that was founded in January of 1998 by a group of investment professionals that formerly comprised the core part of the institutional investment arm of Barnett Capital Advisors. We feel that being employee-owned plays to our strength by providing institutional clients2, with a group of talented investment professionals that have learned to work together to achieve consistent, repeatable investment returns. Being employee-owned there is: stability in structure of each asset-class management team; individual talent retention that leads to increased team knowledge; ownership of purpose that focuses the team on their investment pursuits; and, most of all, a vested interest in our clients’ long-term success. Owners Since Sawgrass is employee-owned, no single individual has ownership control of more than 50%. The Company is a wholly-owned subsidiary of Sawgrass Asset Management, Inc. (“SAM”) and the following individuals including certain core founders, are the majority shareholders who also direct our day-to-day management operations. Name Title CRD# Dean E. McQuiddy Shareholder of SAM/Principal/CCO/CIO/Director of Equity 4373760 Brian K. Monroe Shareholder of SAM/Principal/Director of Marketing & Client Services 2147305 Martin E. LaPrade Shareholder of SAM/Equity Portfolio Manager 4726831 David A. Furfine Shareholder of SAM/Director of Fixed Income 2790329 Patrick A. Riley Shareholder of SAM/Equity Portfolio Manager 4726836 Assets Under Management As of December 31, 2023, our assets managed totaled: Client Discretionary Assets .............................................. $2,283,307,039 Client Non-Discretionary3 ................................................ $ 0 Total Assets Under Advisement (AUA) is $2.8 billion. 1 The term “registered investment advisor” is not intended to imply that Sawgrass Asset Management, LLC has attained a certain level of skill or training. It is used strictly to reference the fact that we are “Registered” as a licensed “Investment Advisor” with the United States Securities & Exchange Commission – and “Notice Filed” with such other State Regulatory Agencies that may have limited regulatory jurisdiction over our business practices. 2 A client could also be a high net worth individual and their family members, a family office, a foundation or endowment, a corporation and/or small business, a trust, a guardianship, an estate, another fiduciary, or any other type of entity to which we choose to give investment advice. We also sub-advise a Collective Investment Trust. 3 The non-discretionary assets listed represent assets in which we have neither discretionary authority nor responsibility for arranging or effecting the purchase or sale of recommendations provided to and accepted by the ultimate client. Inclusion of these assets will make our total assets number different from assets under management disclosed in Item 5.F of our Form ADV Part 1A due to specific calculation instructions for Regulatory Assets Under Management. Our Mission Our mission is to provide our clientele with the highest level of professional asset management services in a totally objective, prudent and cost-effective manner using a disciplined investment process to achieve the desired investment goal. What We Do Active Investment Management Stratagies We specialize in active investment management using multiple Investment Products with different risk/reward characteristics. Our firm provides active growth equity and fixed income investment management services primarily to institutional investors, and our products include large and small cap growth equity portfolios as well as core, intermediate and short-term fixed income portfolios. We can tailor portfolios that match a range of risk tolerances and time-frames. We believe that our approach can best: ❖ Take advantage of the changing economic environment. ❖ Implement the investment strategies best suited to attain the client’s investment goals. ❖ Reduce the volatility of investment returns based on the client’s risk tolerance. ❖ Provide liquidity and access to principal in a long-term investment. ❖ Review client portfolios to assure adherence to restrictions and/or mandates. For more information on our investment strategies, see Item 8, “Methods of Analysis, Investment Strategies and Risk of Loss” below. Pooled Investment Vehicles In July 2011, Sawgrass Asset Management, LLC completed a private offering of securities through a Private Placement (Rule 501 Reg. D) offering to fund Sawgrass Diversified Income Fund, LLC, a Delaware Limited Liability Company (the “Fund”). The Fund was formed for the purpose of managing a well-diversified portfolio of securities from among various asset classes including debt, equity, and preferred stock with the objective of generating income through dividends and interest payments. Sawgrass will serve as the exclusive Manager responsible for operational oversight and management of the Fund. Our fiduciary duty binds us to an ethical standard of complete care and loyalty to our clients and to avoid circumstances that might affect, or appear to affect, this standard unless we act transparently and provide full and fair disclosure of any potential conflict. Therefore, as part of our good faith efforts, we are disclosing that operating a private investment fund creates potential conflicts of interest relating to: ❖ Economic benefits Sawgrass can receive for owning and operating the Fund; and, ❖ Custody situations that can adversely affect the client unless proper safeguards are adopted. For disclosure of our potential conflicts of interest, see “Private Investment Fund Affiliation” under Item 10, “Other Financial Industry Activities & Affiliations.” For information on how operating a private fund creates a custody situation and the safeguards we have adopted to protect clients, see “Pooled Investments” under Item 15, “Custody.” In addition to the Fund, Sawgrass also services as sub-adviser to a and manages Employee Retirement Income Security Act of 1974, as amended, (“ERISA”) assets in the Collective Investment Trust (“CIT”) to which Alta Trust Company serves as trustee and custodian. A CIT is a bank maintained fund that is exempt from registration as a mutual fund under the Investment Company Act of 1940, as amended, (“1940 Act”) or other applicable law, and unit holders are not entitled to the protections of the 1940 Act. The regulations applicable to the CIT are different from those applicable to a mutual fund. The CIT’s units are not securities registered under the Securities Act of 1933, as amended or applicable securities laws of any state or other jurisdiction. It is not registered with the SEC and only available to qualified retirement plans. Alta will serve as the CIT’s trustee and administrator, has the ability to hire and fire Sawgrass as the sub-advisor, and selects or acts as the Custodian. Sawgrass will not act as the custodian and will not have direct access to the CIT funds and securities. A CIT is only available to retirement plans and their participants as an investment option. Individual Wealth Management Services We also offer discretionary investment advisory services to individuals utilizing our stable of investment strategies discussed in this brochure, but that are tailored to client individual financial profiles and requested restrictions. These services emphasize continuous personal client contact and interaction by a dedicated Investment Adviser Representative (“IAR”). Your IAR will work with you to help identify your investment goals and objectives as well as risk tolerance, in order to create a portfolio allocation designed to complement your goals and objectives. i.IRA Rollover Recommendations For the purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under an exemption that requires us to act in your best interest and not put our interest ahead of yours. Under this exemption, we must: ❖ Meet a professional standard of care when making investment recommendations (give prudent advice), ❖ Never put our financial interests ahead of yours when making recommendations (give loyal advice), ❖ Avoid misleading statements about conflicts of interest, fees, and investments, ❖ Follow policies and procedures designed to ensure that we give advice that is in your best interest, ❖ Charge no more than is reasonable for our services, and ❖ Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. FEES & COMPENSATION IT 5 Investment Products Matching a client’s investment parameters with an investment strategy designed to meet their goals and objectives, risk tolerances and time frames is the focus of our Products. For our Equity products our philosophy is to emphasize growth stocks with a consistent and stable earnings pattern, accelerating earnings estimates and companies with greater earnings potential than the market and their peer group. For our fixed income products, our philosophy incorporates an emphasis on issuers with strong measures of creditworthiness within a well- diversified portfolio Duration and sector allocation are actively managed within defined ranges of that of the appropriate benchmark. Managed account(s) may include a combination of the following Investment Products. Diversified Large Growth Equity INVESTMENT OBJECTIVE – We combine quantitative models with qualitative research into a consistent and structured investment discipline. We believe that in combination, these elements allow us to identify companies early in their cycle of positive earnings and estimates changes, which can offer our clients above average stock appreciation potential. MANAGEMENT FEE Style: Large company stocks of high quality companies with strong earnings potential Product Minimum: $3,000,000 Annual Fees: Key Benefits: Growth returns with risk control Focused Growth Equity INVESTMENT OBJECTIVE – We seek to add value over time by uniquely combining proprietary quantitative models with qualitative research in a consistent and structured investment discipline. Our process identifies companies with high quality balance sheets, consistent earnings streams, rising earnings estimates, and reasonable valuations relative to the Russell 1000 Growth Index. The firm believes that in combination, these four elements allow us to identify companies early in their cycle of positive change, capitalizing on above average appreciation potential. This strategy tends to use fewer more concentrated positions than does our Diversified Large Growth Equity product described above. MANAGEMENT FEE Style: Large company stocks of high quality companies with strong earnings potential Product Minimum: $3,000,000 Annual Fees: Key Benefits: Growth returns with risk control Account Value Annual Fee Rate First $10,000,000 ....................................... 0.70% Next $20,000,000 ....................................... 0.60% Over $30,000,000 ....................................... 0.50% Account Value Annual Fee Rate First $10,000,000 ....................................... 0.70% Next $20,000,000 ....................................... 0.60% Over $30,000,000 ....................................... 0.50% Small Cap Growth Equity INVESTMENT OBJECTIVE – The small cap portfolio process identifies domestic stocks with greater earnings potential than the market. We believe it is possible to add value over time by combining quantitative models with qualitative research in a consistent and structured investment discipline. Our process identifies small companies with strong earnings momentum, rising earnings estimates, and reasonable valuation relative to the Russell 2000 Growth Index. MANAGEMENT FEE Style: Small company stocks (30-50) with strong earnings potential Product Minimum: $100,000 Annual Fees: Key Benefits: Growth potential with controlled risk Genesis Small Growth Equity INVESTMENT OBJECTIVE – Seeks to add value over time using quantitative and qualitative research which is applied in a consistent and structured investment discipline. Our process identifies profitable, less volatile small companies that exhibit solid sales and earnings growth, stable margins, and reasonable valuations relative to the Russell 2000 Growth Index. MANAGEMENT FEE Style: Small company stocks (80-100) with strong earnings potential Product Minimum: $100,000 Annual Fees: Key Benefits: Growth potential with controlled risk SMID Core INVESTMENT OBJECTIVE – Seeks to add value over time using quantitative and qualitative research which is applied in a consistent and structured investment discipline. Our process identifies profitable, less volatile SMID companies that exhibit solid sales and earnings growth, Account Value Annual Fee Rate First $25,000,000 ....................................... 0.80% Next $25,000,000 ....................................... 0.70% Over $50,000,000 ....................................... 0.60% Account Value Annual

Fee Rate First $25,000,000 0.80% Next $25,000,000 0.70% Over $50,000,000 0.60% stable margins, and reasonable valuations relative to the Russell 2500 Growth Index. MANAGEMENT FEE Style: SMID company stocks with strong earnings potential Product Minimum: $1,000,000 Annual Fees: Key Benefits: Growth returns with risk control Diversified Large Value Equity INVESTMENT OBJECTIVE – We combine quantitative models with qualitative research into a consistent and structured investment discipline. We believe that in combination, these elements allow us to identify companies early in their cycle of positive earnings and estimates changes, which can offer our clients above average stock appreciation potential. MANAGEMENT FEE Style: Large company stocks of high quality companies with strong earnings potential Product Minimum: $1,000,000 Annual Fees: Key Benefits: Value bias returns with risk control High Quality Core Fixed Income INVESTMENT OBJECTIVE – The core fixed income strategy focuses primarily on controlled duration management of investment grade securities and secondarily on strategic sector valuations and specific security analysis. This portfolio typically has an effective duration that ranges from 3-6 years and an average maturity that ranges from 6-12 years. There currently are no sector constraints. The investable universe consists of U.S. dollar-denominated government, corporate and mortgage-backed securities. The investment approach is managed to the Bloomberg Barclays US Aggregate Index. MANAGEMENT FEE Style: Duration controlled – Investment Grade Bonds Product Minimum: $3,000,000 Account Value Annual Fee Rate First $10,000,000 ....................................... 0.70% Next $20,000,000 ....................................... 0.60% Over $30,000,000 ...................................... 0.50% Account Value Annual Fee Rate First $25,000,000 0.75% Next $25,000,000 0.65% Over $50,000,000 0.50% Annual Fees: Key Benefits: Active management with risk control Intermediate Fixed Income INVESTMENT OBJECTIVE – The intermediate fixed income strategy focuses primarily on controlled duration management of investment grade securities and secondarily on strategic sector valuations and specific security analysis. This portfolio typically has an effective duration that ranges from 2-5 years and an average maturity that ranges from 4-8 years. There are currently no sector constraints. The investable universe consists of U.S. dollar- denominated government, corporate and mortgage-backed securities. The investment approach is managed to the Bloomberg Barclays US Intermediate Aggregate Index. MANAGEMENT FEE Style: Limited Duration – Investment Grade Product Minimum: $3,000,000 Annual Fees: Key Benefits: Reduced interest rate sensitivity Short-Term Fixed Income INVESTMENT OBJECTIVE – The short-term fixed income strategy focuses primarily on controlled duration management of investment grade securities and secondarily on strategic sector valuations and specific security analysis. This portfolio typically has an effective duration that ranges from 1-3 years and an average maturity that ranges from 2-4 years. There are currently no sector constraints. The investable universe consists of U.S. dollar- denominated government, high quality corporate and mortgage-backed securities. The goal of this product is to generate investment returns which exceed 1-year Treasury Bills by 100 basis points over a market cycle. The current benchmark is the ICE BofAML 1-5 Year Gov’t/Corp Index. We also manage this product to a customized short-term index when appropriate. MANAGEMENT FEE Style: Short Duration – Investment Grade Product Minimum: $3,000,000 Account Value Annual Fee Rate First $30,000,000 ....................................... 0.35% Next $50,000,000 ....................................... 0.25% Over $80,000,000 ....................................... 0.15% Account Value Annual Fee Rate First $30,000,000 0.35% Next $50,000,000 0.25% Over $80,000,000 0.15% Annual Fees: Key Benefits: Low expected interest rate sensitivity Core Total Return Fixed Income INVESTMENT OBJECTIVE – The core fixed income strategy focuses primarily on controlled duration management of investment grade securities and secondarily on strategic sector valuations and specific security analysis. This portfolio typically has an effective duration that ranges within 30% of the benchmark and an average maturity that ranges from 6-12 years. There currently are no sector constraints. The investable universe consists of U.S. dollar- denominated government, corporate and mortgage-backed securities. The investment approach is managed to the Bloomberg Barclays US Aggregate Index. MANAGEMENT FEE Style: Duration controlled – Investment Grade Bonds Product Minimum: $1,000,000 Annual Fees: Key Benefits: Active management with risk control Customized Balanced INVESTMENT OBJECTIVE – Our balanced portfolio is a diversified portfolio stocks and bonds structured to satisfy our clients unique investment needs. We will work with the client, or if a Retirement Plan, with the Trustees' investment committee members (consultant, attorney, etc.) to review the current investment policy, assets, liabilities, and future contribution/distribution needs of the Fund. Once these factors are taken into consideration, an optimal asset allocation is developed and implemented, based on current capital market assumptions. MANAGEMENT FEE Style: A blend of growth equity and investment grade bonds Product Minimum: $3,000,000 Account Value Annual Fee Rate First $20,000,000 ....................................... 0.25% Next $20,000,000 ....................................... 0.15% Over $40,000,000 ....................................... 0.10% Account Value Annual Fee Rate First $30,000,000 ....................................... 0.35% Next $50,000,000 ....................................... 0.25% Over $80,000,000 ....................................... 0.15% Annual Fees: Key Benefits: Stock and high quality fixed income Private Investment Fund Our annual management fee is an amount equal to 0.65% of the aggregate Net Asset Value of all units of membership interests. The management fee shall be paid quarterly (0.1625%) in arrears and shall be charged pro rata against the Net Asset Value of each Member’s units of membership interests. Additional information on fund fees and expenses paid by the fund are contained in the offering documents provided to prospective investors. Protocols for the Investment Products The following protocols establish how we handle our Investment Product accounts and what clients should expect when it comes to: (i) managing their account(s); (ii) their bill for investment services; (iv) withdrawing funds; and (v) other fees charged to your account(s). Discretion We accept discretionary authority to manage accounts on behalf of our clients. Customarily, this authority is granted by an Investment Management Agreement or Investment Policy Statement (IPS) that is provided at the inception of our relationship. Limitations to our discretionary authority are generally described in the IPS. Typically, the IPS is furnished by the client or an independent third party; however, upon request, we will assist our clients in developing an IPS consistent with client circumstances. Billing The fees indicated above under each Product represent the annual percentage charged for portfolio management provided on an asset-based fee arrangement. Clients will be billed quarterly (or monthly) in arrears or advance at their request, based on the fair market value of the assets held in their portfolio management account. Advance fees are pro-rated and refunded when a termination occurs. For the first billing quarter, if the management account was not opened at the beginning/end of the quarter, the fee will be based upon a pro-rata calculation of the fair market value of the client’s assets managed for the period. For most accounts the fee for a quarter will be one-fourth of the annual percentage (i.e., 1.00%  4 = 0.25%) multiplied by the corresponding market value of the assets held within each tier on the last business day of the previous calendar quarter. Fee breaks will occur for the portion of assets in the client’s portfolio that increase into the next indicated tier(s). However, certain accounts may be billed based on the average daily balance of the account for the quarter. Clients should reference their investment management agreement for their specific fee billing methodology. We retain discretion to negotiate the management fee indicated under each of the Investment Products on a client-by-client basis. Therefore, clients with similar assets under management and investment objectives may pay significantly higher or lower fees than other clients. Account Value Annual Fee Rate First $20,000,000 ....................................... 0.65% Over $20,000,000 ....................................... 0.50% Generally, we will bill the client directly our quarterly management fee. However, under certain arrangements, clients can choose to have our fees deducted from their custodial account. If we bill the client’s managed account, advisory fees will be taken first from any money market funds or balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. Such liquidation can affect the relative balances of the account. Account Discrepancies To minimize the likelihood of discrepancies, we will remit invoices to clients after we have reconciled cash flow movements with custodian provided information. Any discrepancies of $100 or more are corrected via an adjustment entry to the invoice on the next billing cycle. Certain client portfolios, due to their nature, may be subject to significant cash flows relative to the portfolio size. Such cash flows can result in quarter end balances that might not be representative of the portfolio during the billing period. In such instances, subject to consultation with our client, we may calculate fees based on an average market value during the period. Fee Exclusions The above fees for all our management services are exclusive of any charges imposed by the custodial firm including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, including, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lost differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in the client’s managed account (see Item 12 for further information on commissions and execution costs). There can also be other fees charged to the client’s account that are unaffiliated with our management services. However, at the request of a client, Sawgrass may offset and/or subsidize custodial fees. In addition, all fees paid to us for management services are separate from any fees and expenses charged on mutual fund shares by the investment company or by the investment advisor managing the mutual fund portfolios. These expenses generally include management fees and various fund expense, such as: 12b-1 fees, Redemption fees, account fees, purchase fees, contingent deferred sales charges, and other sales load charges may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. Clients are encouraged to carefully read the fund prospectus. Termination of Investment Product Services To terminate investment advisory services, either party (the client or Sawgrass) by written notification to the other party, may terminate the Investment Advisory Agreement at any time, provided such written notification is received at least 30 days prior to the date of termination. Such notification should include the date the termination will go into effect along with any final instructions on the account (i.e., liquidate the account, finalize all transactions and/or cease all investment activity). In the event termination does not fall on the last/first day of a calendar quarter, we will send the client a pro-rated bill for the number of days in the quarter the account was managed. Once the termination of investment advisory services has been implemented, neither party has any obligation to the other – we no longer earn management fees or give investment advice and the client becomes responsible for making their own investment decisions. PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT 6 We do not publish or promote performance-based fees or fees based on a share of capital gains or capital appreciation of client assets. However, at the request of a client, we will consider a performance-based fee based on individual circumstances3. There are inherent conflicts of interest in the side-by-side management of performance fee and non-performance-fee accounts. Performance-fee arrangements may create an incentive for an adviser to take risks in managing assets that would not otherwise be taken in the absence of such arrangements. Similarly, we may have an incentive to favor larger or higher fee-paying accounts because they may generate more revenue for Sawgrass. However, insofar as client accounts within a specific investment discipline are managed consistently with trades allocated proportionately, we give no priority of investment opportunities to client’s portfolios with performance-based fees when managed with other accounts whose fees are asset–based.