Firm Description SFE Investment Counsel (SFE) is an independent investment advisory firm located in downtown Los Angeles. We have been providing investment advice and portfolio management services to individuals, families, trusts, charitable organizations, retirement plans, businesses, and institutional investors since 1977. SFE is a California corporation and operates as an SEC Registered Investment Advisor (RIA). Principal Owner Jon M. Kmett, president of SFE, is the only principal owner with more than 42 percent. Advisory Services SFE specializes in offering investment supervisory services with a personal touch. We provide investment advice to clients, and make investments for clients, based upon the individual needs of the client. These needs include the nature of other client assets and their personal and family obligations. We design and execute strategies to meet client financial objectives and actively manage the investment portfolio within those guidelines. We emphasize continuous and regular account supervision with some incidental planning and consultations. A successful financial strategy often requires a team of trusted advisors including accountants, attorneys, administrators, and consultants, working in concert on behalf of the client. Client priorities and relationships determine which of these leads the effort. SFE has extensive experience in this collaborative model. We often take the lead role – managing all of the client’s assets and coordinating with other trusted professionals. In the institutional market, SFE is comfortable in a supporting role – managing a portfolio in accordance with a specific mandate. SFE’s investment philosophy is founded upon our belief that asset allocation is the single most important determinant of portfolio performance. Accordingly, we adjust equities, fixed income, and cash positions in response to market and economic conditions to fulfill client objectives. Generally, we are not market timers and prefer to invest for the long term. Through our disciplined investment approach, . We strive to preserve capital and achieve long-term appreciation by employing an opportunistic, total return approach to managing client accounts. For equity investments, we seek companies of quality and value – the best in their fields. SFE focuses on companies that have established a competitive advantage in their industries, and/or have strong global franchises and generate significant revenue from their international operations. To aid in our selections, we subscribe to many sources of independent research and perform our own fundamental and technical security analysis. Many of our equity selections are chosen for their dividend yield to enhance total return. Fixed income allocations are primarily comprised of United States (US) government and agency securities, corporate bonds, exchange traded funds (ETFs), and tax-exempt municipal bonds (as appropriate), with maturities ranging from 2-10 years. These allocations typically reduce portfolio volatility and risk. Maturities are adjusted as needed to capture the sweet spot on the yield curve. Selected securities will be readily marketable and diversified by issuer. SFE’s core strength is the management of concentrated portfolios of US equities, frequently with a fixed income allocation. Portfolios are customized to meet specific client objectives. We typically construct a portfolio of 20-25 equity positions from our “Merit Monitor”. The Merit Monitor is a list of stocks that have been approved for purchase by the SFE Investment Committee. This committee, comprised of SFE investment-adviser owners, meets regularly to review, and update the list. As part of its asset allocation target, a portfolio may consist of individual stocks, bonds, ETFs, mutual funds, bank deposit programs and other public and private securities or investments. SFE provides four types of advisory services more fully described below: separately managed accounts; dual-contract relationships; model portfolio services; and third-party separate account manager programs. Separately Managed Account (SMA) SMAs are managed on an individualized basis according to the client’s investment objectives, financial condition and risk tolerance. A client’s investment strategy is tailored to their specific needs and may include some or all of the security

types mentioned above. Each portfolio will be initially designed to meet particular investment goals, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been created, our portfolio management team strives to review the portfolio twice each quarter, and if necessary, rebalances the portfolio based upon the client’s individual needs, stated goals and objectives. Dual-Contract Relationship SFE may also be retained by other RIAs to provide investment advisory services under a dual-contract relationship. These services primarily consist of portfolio management for assets of the clients of these RIAs and are not considered investment supervisory services. SFE will have exclusive authority to direct and manage the investment and reinvestment of all client assets on a fully discretionary basis, based upon client information and investment objectives as provided by the RIAs. Such discretionary authority shall include, without limitation, the right to purchase, sell, exchange and engage in other transactions with respect to all client assets under management. We will not have authority to select a custodian or negotiate commissions. These clients do not have access to the same level of personal service as clients who invest directly with SFE. Further description of the programs, fees and services available will be provided to clients upon receipt and review of the RIA’s disclosure brochures, investment management agreements, and account opening documents. Clients will sign an advisory agreement with the RIA and a discretionary portfolio management agreement with SFE. Model Portfolio Service SFE designs and manages model portfolios that are available to other advisor firms and investment professionals through select technology platforms. These model portfolios present specific investment strategies for turn-key use by subscribers on behalf of their clients. SFE is engaged and compensated through contractual agreements with the platform providers. Fees are calculated at a negotiated rate and remitted quarterly to SFE by the providers based upon their determination of the aggregate market value of assets utilizing the strategies through their platforms. These clients do not have access to the same level of personal service as clients who invest directly with SFE. Third Party Separate Account Manager Program Our firm participates as a separate account manager in various programs (“SAM Program”) offered by certain third-party retail and institutional advisers. Under such programs, the third-party adviser enters into an account agreement with the SAM Program client. As part of the account agreement, the SAM Program client authorizes SFE to provide investment portfolio management services to the client on a discretionary basis. Under the terms of a SAM Program, the third-party adviser representative determines the suitability of SFE’s investment strategies for the client. The adviser also provides custodial, brokerage, reporting, performance review and related services to SAM Program clients. Once we accept a SAM Program client, the third-party adviser will forward a copy of the program client’s account agreement to us. This agreement includes suitability information and client account information. The adviser provides us with electronic access to view the program client’s account holdings, values and transactions. We will manage such accounts according to the SFE investment strategies that have been approved by the adviser under the terms of the SAM Program. The third-party adviser pays SFE for the portfolio management services we provide to SAM Program clients. Our fees are calculated by the adviser and paid to us monthly in arrears. Fees are calculated as a percentage of the total assets managed by SFE under the program and vary depending upon the amount of assets. Our minimum client account size for third party separate account programs is $100,000. A SAM Program client may terminate our designation as separate account manager at any time by written notice to the third-party adviser. SFE may terminate our relationship with the client upon thirty (30) days’ notice to the adviser. Client Assets SFE manages $410,231,061 on a discretionary basis and $31,617,748 on a non- discretionary basis. Total assets under management are $441,848,809 as of September 30, 2023.