Claret Asset Management Corp: investment adviser

Claret is a single purpose organization which provides investment management services only. We create portfolios consisting of bonds/fixed income securities as well as North American and international equities/stocks. The objective is to add value through security selection. Portfolio volatility or risk is managed by diversification. We do trade in options and derivatives if it is in the clients’ best interest. Our style primarily emphasizes buying securities that are trading at low valuations that have sound businesses and strong balance sheets. Further information is available upon request. C. EXPLANATION OF HOW WE TAILOR OUR SERVICES TO THE INDIVIDUAL NEEDS OF CLIENTS

We spend time to get to know you, our client, to review and discuss your current financial situation. Areas of review will focus on, but are not be limited to, your: (i) goals and objectives; (ii) asset and liabilities; (iii) liquidity needs; (iv) risk tolerance; (v) tax status; (vi) legal constraints (such as being a corporate insider, officer or director) and (vii) other variables relevant to understanding your unique investment circumstances including any unique preferences. This approach is based on the CFA Institute (Chartered Financial Analyst Institute) guidelines to portfolio management. We also spend time explaining our investment style to ensure that your expectations will be met. Together we develop the investment guidelines and establish the asset mix and ranges we will follow when managing your portfolio. This information can be found in our investment policy statement. All portfolios are managed on a segregated basis, meaning they are managed in the clients’ name and securities are held in the clients’ accounts. This allows us to respect your wishes Page 4 of 28

and exclude any securities you may not wish to hold such as securities issued by alcohol or tobacco companies for example. We tailor your portfolio to your wishes using our research methodology. Portfolio management software and accounting software allow us to create a tailored portfolio. D. WRAP FEE PROGRAMS

Claret does not engage in wrap fee programs. Therefore, this part is not applicable. E. CLIENT ASSETS MANAGED ON A DISCRETIONARY BASIS

Claret manages portfolios on a discretionary basis which means that you sign a contract which gives us the authority to buy and sell securities within your account(s) without having to first ask your permission to do so. Claret had approximately $2.2 billion U.S. dollars under management as of December 31, 2025.

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Claret does not provide custodial services, so you will have to choose a qualified custodian to hold your assets. Several options are available. Traditional custodians or trust companies usually charge a fee based on the value of your portfolio. They may also charge fees for each transaction within the portfolio. The fees are set out in your contract with the custodian you have selected. Brokerage firms can also provide custody services. They do not generally, charge a fee on the value of your portfolio; instead they make their money from commissions charged on transactions. You will pay brokerage commission fees whenever we trade in your portfolio. Claret is able to select any broker to use for trading in your account. We are not limited to trading only with your broker. However, if a client selects a brokerage firm that Claret does not have a relationship with, the brokerage firm will charge you fees for transactions regarding custody of your security. These fees are charged on transactions commonly called DAP or RAP (delivery against payment or receipt against payment). If Claret has a relationship with the broker you choose as custodian, we generally negotiate more favorable commission rates due to our volume of business. Brokerage firms allow Claret to use outside brokers, either to get access to a particular investment or to obtain a better price for you. In these cases, if your broker also acts as your custodian, you will not be charged a DAP or RAP (delivery against payment or receipt against payment) fee to settle the trade within your account. Custodians and brokers may also charge a fee to wire payments to you Page 6 of 28

or to research information for you (such as printing duplicate tax slips or verifying tax costs). When you hold non-North American securities, the brokerage commission you pay for each transaction will generally be higher. Other expenses you may pay would include government withholding taxes on income such as dividends. Additional governmental charges, taxes and duties may apply. D. PAYMENT

The investment management fees on Claret’s separately managed client accounts are payable in arrears, using the quarter end market value of the previous quarter. If you terminate the advisory contract with us before the end of the billing period, we will send your custodian an invoice for the portion of the fees payable from your account from the agreed upon date of termination. You are required to inform us of termination. We do not force clients to prepay our fees or pay fees in advance of services. E. COMPENSATION TO SUPERVISED PERSONS

We do not have compensation arrangements to disclose with respect to supervised persons, i.e. we do not pay commissions or sales charges to any Claret employees.

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Performance based arrangements may also create an incentive for Claret to recommend investments that are more risky or speculative than those that would be recommended under a different fee arrangement. To mitigate these conflicts, Claret’s policies and procedures seek to provide that investment decisions are made in accordance with the fiduciary duties owed to clients and without consideration of Claret pecuniary, investment or other financial interests. All client accounts are monitored on a regular basis to ensure compliance with Claret’s policies and procedures. One of the investment funds managed by Claret is subject to a performance fee of 25% of the amount that the aggregate of the NAV and all distributions made to the partners exceeds an internal rate of return of 6% per annum on capital contribution. However, this fund is not available to U.S. residents.

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In general, we look for companies that can provide strong cash flow growth per share over the long term and have a strong balance sheet. We favor companies and industries with consistent above average cash flow generation. Stocks and corporate bonds which we identify as a prospect or which we own are reviewed based on a combination of fundamental qualitative and quantitative analysis. The firm relies primarily on internal resources to develop strategy and generate investment ideas. Our research concentrates on identifying companies possessing three main characteristics. 1. Strong engaged management 2. Sound balance sheets 3. Sustainable cash flows Once these companies are identified they are purchased at historically lower valuations to improve the potential for future returns. We believe that buying companies at lower historical valuations with strong balance sheets provides for a margin of safety on the downside. We do buy structured products or asset backed securities for our client’s portfolios or funds. In the case of structured products, we are faced with a “made or buy” decision. If it is more beneficial for the client, we will purchase a structured product otherwise we would make it in house. As with any investment, there is the potential for a loss of capital.

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B. DESCRIPTION OF THE RISK INVOLVED IN INVESTING FOR EACH OF OUR STRATEGIES

Investing your money in stocks and bonds involves a risk of loss and potentially a permanent loss of capital. Your account could suffer a loss. Bonds are generally purchased for income and safety but they can also lose value – in the extreme case the companies or the governments which issue bonds may go bankrupt or default on their obligations. It is important that you understand these risks associated with investing in these markets. Our goal is to reduce the volatility or risk within your portfolio, through prudent diversification. If you would like Claret to manage only a specific portion of your portfolio (example, Canadian or International equities) then our diversification will be limited to these markets. C. WERE WE TO RECOMMEND A PARTICULAR TYPE OF SECURITY, WE WOULD EXPLAIN THE MATERIAL RISKS INVOLVED

Investment Risks Investing entails an element of risk.

⁺ Credit risk: Securities issued by entities with a low credit rating are considered to have a

higher credit risk. Interest rate risk: Changes in interest rates may also affect the value of fixed income and equity securities. Currency risk: The value of securities denominated in a currency other than client’s currency will be affected by changes in the value of the client’s currency in relation to the value of the currency in which the security is denominated. Equity risk: Equity securities tend to be more affected by economic and market conditions, interest rates and trends in corporate earnings, and are, consequently, more volatile. Foreign security risk: They may be affected by factors such as the absence of timely information, less stringent regulatory or auditing standards and less liquid markets. Liquidity risk: Liquidity risk deals with the possibility that the portfolio manager will not be able to convert their client’s investments to cash when required. Specific issuer risk: Individual securities will vary positively or negatively based on developments related to the company. Stock market risk: Market value of many securities tend to move with the overall stock market conditions which, in turn, are directly affected by general economic and market conditions. There is always a risk of loss to the investments of a client.

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Option writing:

⁺ From time to time, as we deem appropriate, and in accordance with the investment

mandate for the client, we may also use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligations, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. The two types of options are calls and puts: A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we have determined that the stock will increase substantially before the option expires. We may use ‘’covered calls’’, in which we sell an option on security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. We may use ‘’selling naked puts’’ meaning we sell put options on stocks we do not own but would like to purchase at a specific price and have the appropriate amount of cash available to buy the stock if required. We may use ‘’stock replacement strategy’’ for tax purposes. If we need to realize a capital loss, that means selling a share to have a capital loss to reduce the taxes you owe, we may wish to maintain a similar holding until we can buy back the actual stock. We use this to manage your tax bill. We may use a ‘’currency collars” to protect your buying power also called your purchasing power in your currency. The idea came from the Province of Quebec and their sovereignty referendums. The idea is tomorrow you do not want your currency to drop by 25% after a vote to exit from a federation. In no case do we use options as a way of leveraging the portfolio of a separately managed account. Leverage means investing more money than you deposited in the account. This would magnify the gain or loss.

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1. Broker-dealer, municipal securities dealer, or government securities dealer or broker. 2. Investment company or other pooled investment vehicle (including mutual fund, closedend investment company, unit investment trust, private investment company or ‘’hedge fund,’’ and offshore fund) 3. Other investment adviser or financial planner 4. Futures commission merchant, commodity pool operator, or commodity trading advisor 5. Banking or thrift institution 6. Accountant or accounting firm 7. Lawyer or law firm 8. Insurance company or agency 9. Pension consultant 10. Real estate broker or dealer 11. Sponsor or syndicator of limited partnerships. In regard to Item C (2): We have discretionary authority to purchase or sell units issued by the investment funds we manage (see above) in our Canadian clients’ separately managed accounts. The units of these funds are offered to investors in reliance on exemptions from registration and prospectus requirements of applicable securities legislation. These funds are related to us

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because we act as the manager of the portfolios and distribute units of these funds to our Canadian clients. D. IF WE RECOMMEND OR SELECT OTHER INVESTMENT ADVISERS FOR OUR CLIENTS AND WE RECEIVE COMPENSATION DIRECTLY OR INDIRECTLY FROM THOSE ADVISERS, OR WE HAVE OTHER BUSINESS RELATIONSHIPS WITH THOSE ADVISERS, WE ARE REQUIRED TO DESCRIBE IF THESE PRACTICES CREATE CONFLICT OF INTEREST AND HOW WE ADDRESS THEM

We have nothing to disclose in this regard, as Claret does not recommend other investment advisers.

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Cross Trades Claret will perform a cross trade only when it complies with its cross trade policies and procedures, when it is not prohibited under the applicable client’s investment restrictions or applicable law, and when it believes that it is in the best interests of both the selling account and the buying account. Claret acknowledges its duty to seek best execution for its clients and that the use of cross trades raises potential conflict of interest. To address these and other concerns, Claret’s policies require that cross trades be effected at the independent “current market price” of the security, as determined by the applicable custodian and that Claret will execute cross trades only in the best interests of both the selling account and the buying account. Claret will not act as principal or agent or otherwise receive commission or any type of compensation for effecting cross trades. Trade Error If Claret is responsible for trading errors in client accounts and the error results in losses, Claret’s policy is to reimburse the clients or funds to bring them to the position they would have been in had the error not occurred. Where the errors result in gains, such gains are to be retained by the clients or funds.

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B. IF OUR FIRM OR A RELATED PERSON RECOMMENDS TO CLIENTS, OR BUYS OR SELLS FOR CLIENT ACCOUNTS, SECURITIES IN WHICH OUR FIRM OR A RELATED PERSON HAS A MATERIAL FINANCIAL INTEREST (EXCLUDING AN INTEREST AS A SHAREHOLDER OF AN SECREGISTERED, OPEN-END INVESTMENT COMPANY), WE MUST DESCRIBE OUR PRACTICE AND DISCUSS THE CONFLICTS OF INTEREST IT PRESENTS

Claret and Claret employees are not permitted to purchase or sell securities between their personal account and the client’s account. Should Claret or its employees have a direct material financial interest in a security or a company, such security and company will be put on a restricted list. Claret does act as manager and general partner of seven pooled funds. We only purchase these funds for Canadian clients and rely on an exemption to do so and where suitable. We receive no benefit from these funds other than management fees we invoice directly to our clients in their separately managed accounts and a performance fee in 3700666 Canada Investments Limited Partnership. We have no conflicts of interest to disclose in this regard. C. IF OUR FIRM OR A RELATED PERSON INVESTS IN THE SAME SECURITIES (OR RELATED SECURITIES, E.G., WARRANTS, OPTIONS OR FUTURES) THAT OUR FIRM OR A RELATED PERSON RECOMMENDS TO CLIENTS, WE ARE REQUIRED TO DESCRIBE OUR PRACTICE AND DISCUSS THE CONFLICTS OF INTEREST THIS PRESENTS AND GENERALLY HOW WE ADDRESS THE CONFLICTS THAT ARISE IN CONNECTION WITH PERSONAL TRADING

Please see Item 11A above; we put our clients first and the policies we have in place set forth standards of conduct expected of advisory personnel and address conflicts that could arise in personal trading by advisory personnel. Employees may invest in the same securities we recommend to clients, in fact we encourage this practice, however we do require each such investment to be approved by the compliance team in order to ensure that no conflict exists. We follow the CFA Institute Code of Ethics and Standard of Conduct. D. IF OUR FIRM OR A RELATED PERSON RECOMMENDS SECURITIES TO CLIENTS, OR BUYS OR SELLS SECURITIES FOR CLIENT ACCOUNTS, AT OR ABOUT THE SAME TIME THAT WE OR A RELATED PERSON BUYS OR SELLS THE SAME SECURITIES FOR OUR FIRM’S (OR THE RELATED PERSON’S OWN) ACCOUNT, WE ARE REQUIRED TO DESCRIBE OUR PRACTICE AND DISCUSS THE CONFLICTS OF INTEREST. WE ARE ALSO REQUIRED TO DESCRIBE GENERALLY HOW WE ADDRESS CONFLICTS THAT ARISE.

Claret may purchase securities for the funds it manages and directly for clients. We do not believe that any conflict of interest would arise from this practice. Employees are required to receive approval for transactions in certain types of securities. Our clients always receive the priority of transactions. Clients come first.

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Code of Business Conduct: Claret will not condone any violation of the law or any unethical business dealing by any employee. Employees must not use their positions, or knowledge gained through their employment with Claret, for private or personal advantage or in such a manner that a conflict or an appearance of conflict arises between Claret’s clients’ interests and their personal interests.

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The frequency of analyst visits by a broker. Portfolio managers and the trading team monitor commissions and the competitiveness of trading costs. While not usual practice, Claret may from time to time pay higher commissions than those obtainable from other brokers. We often use electronic trading platforms to sell a basket of securities for a client’s account to cover overdrafts in client accounts as this is often the least expensive way for us to trade a group of shares. 1. RESEARCH AND OTHER SOFT DOLLAR BENEFITS. IF WE RECEIVE RESEARCH OR OTHER PRODUCTS OR SERVICES OTHER THAN EXECUTION FROM A BROKER-DEALER OR A THIRD PARTY IN CONNECTION WITH CLIENT SECURITIES TRANSACTIONS (‘’SOFT DOLLAR BENEFITS’’), WE ARE REQUIRED TO DISCLOSE OUR PRACTICES AND DISCUSS THE CONFLICTS OF INTERESTS THEY CREATE. PLEASE NOTE THAT WE MUST DISCLOSE ALL SOFT DOLLAR BENEFITS WE RECEIVE, INCLUDING, IN THE CASE OF RESEARCH, BOTH PROPRIETARY RESEARCH (*CREATED OR DEVELOPED BY THE BROKER-DEALER) AND RESEARCH CREATED OR DEVELOPED BY A THIRD PARTY.

Claret does not engage in soft dollaring. Page 19 of 28

a. EXPLANATION OF WHEN WE USE CLIENT BROKERAGE COMMISSIONS (OR MARKUPS OR MARKDOWNS) TO OBTAIN RESEARCH OR OTHER PRODUCTS OR SERVICES, AND HOW WE RECEIVE A BENEFIT BECAUSE OUR FIRM DOES NOT HAVE TO PRODUCE OR PAY FOR THE RESEARCH, PRODUCTS OR SERVICES

Claret does not engage in this practice. b. INCENTIVE TO SELECT OR RECOMMEND A BROKER-DEALER BASED ON OUR INTEREST IN RECEIVING THE RESEARCH OR OTHER PRODUCTS OR SERVICES, RATHER THAN ON OUR CLIENT’S INTEREST IN RECEIVING BEST EXECUTION

We have examined the potential conflict of interest and believe that our commission expenses are used in the best interest of our clients. c. CAUSING CLIENTS TO PAY COMMISSIONS (OR MARKUPS OR MARKDOWNS) HIGHER THAN THOSE CHARGED BY OTHER BROKER-DEALERS IN RETURN FOR SOFT DOLLAR BENEFITS (KNOWN AS PAYING-UP)

We do not engage in soft dollaring. d. DISCLOSING WHETHER WE USE SOFT DOLLAR BENEFITS TO SERVICE ALL OF OUR CLIENTS’ ACCOUNTS OR ONLY THOSE THAT PAID FOR THE BENEFITS. DISCLOSING WHETHER WE SEEK TO ALLOCATE SOFT DOLLAR BENEFITS TO CLIENT ACCOUNTS PROPORTIONATELY TO THE SOFT DOLLAR CREDITS THE ACCOUNTS GENERATE.

Not applicable. e. DESCRIPTION OF THE TYPES OF PRODUCTS AND SERVICES THAT WE AND ANY OF OUR RELATED PERSONS ACQUIRED WITH CLIENT BROKERAGE COMMISSIONS (OR MARKUPS OR MARKDOWNS) WITHIN OUR LAST FISCAL YEAR.

Not applicable. f.

EXPLAINING THE PROCEDURES WE USED DURING OUR LAST FISCAL YEAR TO DIRECT CLIENT TRANSACTIONS TO A PARTICULAR BROKER-DEALER IN RETURN FOR SOFT DOLLAR BENEFITS WE RECEIVED.

Not applicable.

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2. BROKERAGE FOR CLIENT REFERRALS. a. DISCLOSING THAT WE MAY HAVE INCENTIVE TO SELECT OR RECOMMEND A BROKER-DEALER BASED ON OUR INTEREST IN RECEIVING CLIENT REFERRALS, RATHER THAN ON OUR CLIENTS’ INTEREST IN RECEIVING MOST FAVORABLE EXECUTION

Claret does not engage in this practice. b. EXPLAINING THE PROCEDURES WE USED DURING OUR LAST FISCAL YEAR TO DIRECT CLIENT TRANSACTIONS TO A PARTICULAR BROKER-DEALER IN RETURN FOR CLIENT REFERRALS

Claret does not engage in this practice.

3. DIRECTED BROKERAGE. a. DESCRIPTION OF OUR PRACTICE OR POLICY FOR ROUTINELY RECOMMENDING,

REQUESTING OR REQUIRING A CLIENT TO DIRECT US TO EXECUTE TRANSACTIONS THROUGH A SPECIFIC BROKER-DEALER. EXPLAINING THAT NOT ALL ADVISERS REQUIRE CLIENTS TO DIRECT BROKERAGE. DESCRIPTION OF THE RELATIONSHIP WITH THE BROKER-DEALER. EXPLAINING THAT BY DIRECTING BROKERAGE WE MAY BE UNABLE TO ACHIEVE MOST FAVORABLE EXECUTION OF CLIENT TRANSACTIONS, AND THAT THIS PRACTICE MAY COST THE CLIENT MORE MONEY.

Claret does not engage in this practice. b. DESCRIPTION OF OUR PRACTICE FOR PERMITTING A CLIENT TO DIRECT US TO

EXECUTE TRANSACTIONS THROUGH A SPECIFIC BROKER-DEALER. EXPLAINING THAT BY DIRECTING BROKERAGE WE MAY BE UNABLE TO ACHIEVE MOST FAVORABLE EXECUTION OF CLIENT TRANSACTIONS, AND THAT THIS PRACTICE MAY COST CLIENT MORE MONEY .

Claret does not engage in this practice. B. DISCUSSING WHETHER AND UNDER WHAT CONDITIONS WE AGGREGATE THE PURCHASE OR SALE OF SECURITIES FOR VARIOUS CLIENT ACCOUNTS.

We do purchase securities as bulk trades. This means every client purchases the same security at the same cost base. Page 21 of 28

Each quarter Claret prepares a written report which addresses the following: Portfolio valuation, distribution of assets, transactions during the quarter and portfolio performance. Claret encourages clients to schedule regular investment meetings so that all parties maintain a full understanding of changing requirements. Communication is vital to the effective management of assets. Communications are usually held semi-annually after the first year.

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Claret has very few referral arrangements. When a client is referred to Claret the terms of the referral arrangement are set out in a written agreement between Claret and the referring party. Written disclosure of the referral arrangement is then provided to the client. This disclosure includes the names of the parties involved, the terms of the agreement, whether any conflicts of interest result from the relationship between the parties to the agreement, details of the referral fee etc. The client signs the written disclosure as acknowledgement of the arrangement, including the amount of the fee.

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Additional information is always welcome. Your asset allocation guidelines, risk tolerance and income requirements may be developed in concert with your financial consultant, tax advisor, lawyer or accountant. It is important to read and understand these account opening documents as they serve as the basis for managing your portfolio. They will also describe any limitations you make wish to impose on your portfolio.

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It is the responsibility of the custodian of each client’s assets to forward all proxy material to Claret. Claret assesses each proxy resolution and management’s recommendations. In practice, proxy forms for clients are sent directly by their custodians. Claret follows the principle that the vote must be in the best long-term economic interest of clients. While Claret makes all proxy voting decisions internally, Claret uses Broadridge to provide administrative proxy related services. Clients can choose to directly vote their shares. They must inform us of this request in writing and specify the company shares that they wish to vote. Clients may obtain a copy of how we voted their securities. Clients may obtain a copy of our voting policy. B. DISCLOSE THE FACT THAT WE DO NOT HAVE AUTHORITY TO VOTE. EXPLAIN WHETHER CLIENTS WILL RECEIVE THEIR PROXIES OR OTHER SOLICITATIONS DIRECTLY FROM THEIR CUSTODIAN OR A TRANSFER AGENT OR FROM US, AND DISCUSS WHETHER (AND, IF SO, HOW) CLIENTS CAN CONTACT YOU WITH QUESTIONS ABOUT A PARTICULAR SOLICITATION.

Not applicable. Claret has the authority to vote their securities and exercises this authority.

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