Firm Description DLK Investment Management, (“DLK”) was founded in 2009 as a limited liability company. DLK provides personalized investment management services to individuals, trusts, estates, charitable organizations and small institutional investors. Advice is provided through consultation with the client and may include: determination of financial objectives, investment time horizon, cash flow requirements, tax considerations and estate planning. DLK is strictly a fee-only investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. Also, no finder’s fees are accepted. DLK does not act as a custodian of client assets. The client always maintains asset control. DLK places trades for clients under a limited power of attorney. Periodic reviews are conducted to provide clients with updates on the progress of their financial goals. More frequent reviews may occur but are not necessarily communicated to the client unless immediate changes are recommended. DLK can also create a financial plan when needed through its planning capabilities. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. An initial meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which investment management may be beneficial to the client. Principal Owners The firm is owned by Donald O. Dempster, Theodore J. Kay, and Peter J. Johnson Types of Advisory Services DLK provides investment supervisory services, also known as asset management services. As of December 31, 2023, DLK managed approximately $348,269,188 in assets for approximately 453 clients. Approximately $316,748,600 in assets are managed on a discretionary basis with the remaining $31,520,588 managed on a non-discretionary basis. Tailored Relationships Client accounts include customization as it pertains to their goals and risk tolerance. A key decision in the process is a client’s asset allocation, which is tailored accordingly. All these relevant issues are documented in DLK’s client relationship management system (“CRM”). Agreements may not be assigned without the client’s consent. Types of Agreements The following agreements define the typical client relationships. Asset Management Assets are invested primarily in stocks, bonds and under certain circumstances exchange- traded funds, usually through discount brokers or banks. The client has the ultimate decision on where their account is held for custody. This usually dictates where the transactions in their accounts will be executed. The brokerage firm charges a fee for stock and bond trades. DLK does not receive any compensation, in any form, from the brokerage firm or any fund companies. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (and mutual funds shares), U. S. government securities, and options contracts. Clients will not be charged a management fee on investments in mutual fund shares. Initial public offerings (IPOs) are not available through DLK and usually aren’t investments that meet the firm’s investment process discipline. Financial Planning In addition to its investment management services, DLK may provide financial planning services to its advisory clientele who desire such services. Depending on the needs of the client, and at the discretion of the Firm, a written financial plan may be generated and delivered to the client. The Firm gathers information from its clients through in-depth personal interviews, the review of various financial documents, and/or confidential questionnaires completed by the clients. Information gathered includes the client’s current financial status, tax situation, and future goals. The Firm reviews the information gathered and delivers advice and recommendations. Clients are free at all times to accept or reject any of DLK’s financial planning recommendations and retain the authority and discretion over whether or not to implement any such suggestions. Should the client decide to implement any financial planning recommendations, the Firm advises the client to work closely with their attorney, accountant, insurance agent, or other professional. Retirement

Plan Consulting Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company’s participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investments options, plan structure and participant education. Retirement Plan Consulting services typically include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will also provide investment education to and for the benefit of Plan Participants. Accordingly, our firm will coordinate Participant investment education meetings, on an annual or, upon request, a more frequent basis. In Providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly trades REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, or firm acknowledges it fiduciary standard withing the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where 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 a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, 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. WRAP Program The Adviser does not sponsor or provide investment management services to a wrap program. Termination of Agreement A Client may terminate any of the aforementioned agreements, with a 30-day notice, at any time by notifying DLK in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, DLK will refund any unearned portion of their advance fees. DLK may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, DLK will refund any unearned portion of the advance payment.