Raymond James (USA) Ltd: investment adviser

As part of the Raymond James family of companies, the firm maintains access to some of the industry’s finest resources which include brokerage, in depth market research services, an experienced management team, and a broad scope of service offerings. Generally, there are several fundamental differences between brokerage services and advisory services, which may vary depending on the characteristics of a particular service. Brokerage services primarily involve assisting the client with the purchase and sale of securities, with the provision of investment advice being only incidental to those services. Investment advisory services, on the other hand, primarily involve separately agreeing with the client to provide investment advice to meet comprehensive long-term financial goals. While providing advisory services, RJLU and its investment adviser representatives have a fiduciary duty to its advisory clients, must put the client’s interests ahead of its own, and must treat all of its advisory clients fairly and equitably. Asset management services (Ambassador) The firm provides asset management services on a discretionary and non-discretionary basis. As discussed in Item 16 of this wrap fee brochure, discretionary asset management means that the firm may act in the client’s interest by placing trades in the client’s account without first obtaining client approval for each transaction. The firm may not exercise discretion over a client’s assets without written authorization from the client. The Ambassador Account utilizes a wrap fee advisory account, offered and administered by Raymond James, in which the client is provided with ongoing investment advice and monitoring of securities holdings by their financial advisor. Raymond James acts as a participant as a sponsor and portfolio manager to the wrap fee program. The client’s financial advisor will supervise their account on a non-discretionary basis (or manage on a discretionary basis, provided certain qualifications are met), according to the client’s objectives. Ambassador offers clients the ability to pay an asset-based advisory wrap fee in lieu of a commission for each investment transaction within the account. Ambassador-Directed The firm’s asset management services may include asset allocation recommendations to clients. The firm provides advice on asset allocation, diversification, and long-term investments as the primary strategies for pursuing investment objectives. Asset allocation entails the diversification of investments across various asset classes. The firm typically refrains from making any recommendations towards the short-term holding of

investments. However, asset allocation and investment recommendations may cause the firm to recommend the sale of investments which have been held for less than one year in certain cases. In providing asset management services, RJLU will assist the client in completing suitability forms, including a client questionnaire, in order to determine the client’s investment objectives, needs, and risk tolerance. Based on information provided by the client, the firm will tailor its services to the individual needs of the client, using investment strategies discussed in Item 8 of this wrap fee brochure. In the management of client assets, the firm may invest, or recommend investment in, a wealth of investment products including, but not limited to, mutual funds, stocks, bonds, options, interests in limited partnerships and other investments. Clients may impose restrictions on investing in certain securities or types of securities. Third Party Platform - Envestnet RJLU may, when in the client’s interest, recommend that the client participate in the Private Wealth Management Program offered by Envestnet Asset Management, Inc. (“Envestnet”), a third party platform manager and investment adviser. Envestnet operates a technology platform on which the Private Wealth Management Program functions and renders investment advice, including recommending an appropriate asset allocation for the client and specific investment managers or investment products. In recommending the services of Envestnet, RJLU remains an investment adviser to the client and assists the client with program implementation, model and/or asset allocation selections, and provides continuous monitoring of the client’s account. The client grants RJLU and Envestnet discretion in this program. As of November 14, 2025, RJLU has approximately $2,300,000,000 in assets under management, of which $500,000,000 is discretionary.

The client should understand that unless a lower rate has been negotiated, Raymond James will charge fees based upon the applicable standard fee schedule detailed below for each advisory account program. While the asset-based fees are negotiable, the standard fee schedule’s asset-level breakpoints and each applicable fee rate may not be modified in any way. An inherent conflict exists in how Raymond James handles billing variations from the applicable fee schedule as compensation adjustments can result in higher compensation to the financial advisor from one advisory program to another. Clients may pay us more or less than he/she might otherwise pay if the same services were purchased through another service provider. Clients may negotiate fees with different breakpoints and as a result, may pay a higher fee than as listed in the standard fee schedule detailed below (but not more than the program’s maximum fee) as a result of fluctuations

in the client assets under management and/or account performance. The client is generally assessed an allinclusive wrap fee, set forth as follows: STANDARD FEE SCHEDULE FOR AMBASSADOR PROGRAMS Asset Levels 0 - $500,000 $500,001 - $1,000,000 $1,000,001 - $3,000,000 $3,000,001 - $5,000,000 $5,000,001 +

Management Fee 2.25% 1.75% 1.50% 1.25% 1.00%

Fees are prorated for such accounts beginning on any date other than a quarterly start date. All fees remain negotiable, but at the sole discretion of the firm. Per written agreement/authorization, management fees will be deducted by the firm from client accounts. Clients may incur additional fees or expenses in addition to the management fees charged by RJLU. Accounts with assets invested in mutual funds may incur expenses related to these investments, which may include marketing and distribution charges. Further, fees may be charged by the brokerage firm and/or custodian associated with the account for services provided to the account. Additional information about the brokerage and custodial services recommended by RJLU may be found under Item 12 of this wrap fee brochure. The firm’s investment adviser representatives may also be registered representatives of RJLU in its capacity as a FINRA member broker-dealer. As such, these individuals are entitled to receive compensation, generally in the form of commissions, for the sale of securities-related products, including mutual funds. Where one of the firm’s investment adviser representatives makes a recommendation to a client, or transacts for a client on a discretionary basis, that may result in receipt of commissions or other sales-related compensation. This practice could potentially present a conflict of interest and gives the representative an incentive to recommend investment products based on the compensation received, rather than on the client’s needs. Where available and appropriate, RJLU’s investment adviser representatives will transact in, or recommend investment in, loadwaived or no-load mutual funds to avoid this conflict of interest.

In certain cases, the firm may reduce the amount of advisory fees charged where the receipt of commissionbased compensation presents fair and equal payment for services rendered. This determination remains the sole decision of RJLU. In cases where portfolio assets pay a 12b-1 fee, the firm will have those fees credited to the client account in essences reducing net advisory fees charged. Where the receipt of this additional nonadvisory-related compensation presents a conflict of interest, RJLU monitors the business activities of its associated personnel to ensure that such persons refrain from favoring such incentive-based arrangements. RJLU maintains its fiduciary obligation to clients by conducting regular oversight of such activities and maintaining a policy of serving the clients best interests first. Clients are advised that the services provided by RJLU and its affiliates may be found elsewhere at a reduced rate, but at the exception of the professional services provided by the firm. A client agreement may be canceled at any time, by either party, for any reason upon receipt of written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. The client has the right to terminate an agreement without penalty within five business days after engagement. All agreements remain non-transferable unless otherwise consented-to in writing by the client.

Cyclical: Cyclical analysis is a time based assessment which incorporates past and present performance to determine future value. The primary risk of using cyclical analysis is that past performance cannot guarantee to future results.

Charting and Technical: Charting consists of preparing a technical analysis using diagrams to illustrate various patterns or progressions in market or account movement. Similar to charting, technical analysis employs the use of statistical models and quantitative methodologies to evaluate performance and value over a specified period of time. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients, and may involve the use of charts to identify market patterns and trends which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that CFA will be able to accurately predict such a reoccurrence.

The firm’s evaluation of mutual funds includes an analysis of portfolio holdings, investment policies, management philosophy, historical performance, and the qualifications of advisers, sponsors and distributors. Historical performance of investments is analyzed over periods that include several market cycles to identify investments which have demonstrated consistent long-term performance. Clients must note that past performance is not a guarantee of future results. Affiliates of RJLU may utilize other methods of analysis in formulating recommendations and making investment decisions. As RJLU maintains an affiliate relationship with a variety of investment related entities, the firm makes use of information provided by such affiliates to better formulate its investment management strategies. Where value and growth remains a mainstay of the firm’s overall investment management strategy, investing in securities involves a certain amount of risk of loss that clients should be prepared to bear. Where short term trading methods are employed, the cost of more frequent trades can often incur more expense than that of a more conservative or long term purchase approach. Questions regarding these risks and/or increased costs should be directed to the firm and its representatives.

Also in 2006, Raymond James Ltd., RJLU’s parent company, settled with Market Regulation Services, Inc. (“RS”), its Canadian regulator, and agreed to pay a total monetary fine of $525,000 for contravention of RS’ universal market integrity rules relating to client priority, failure to record client consent order making, and audit trail on numerous occasions from February 2003 to February 2005 and for failing to comply with the firm’s trading supervision obligations from July 2003 to February 2005. Further information regarding these events may be found by visiting http://brokercheck.finra.org

Some of these investments may be placed at, or about the same time as, the placement of client securities transactions. This presents a conflict of interest, as the firm and its related persons may be incented to benefit from client transactions by placing their own interests ahead of those of the firm’s clients. RJLU requires that client transactions in Reportable Securities (as this term is defined in the Code of Ethics) be placed ahead of those of the firm or its related persons. Such transactions remain under strict supervision and subject to regular review by the firm’s compliance staff. The firm’s investment adviser representatives are also registered representatives of RJLU in its capacity as a broker-dealer. In their capacity as registered representatives, these personnel may sell securities and receive commissions for the sale of such securities. This creates an incentive for the representative, in his or her capacity as an investment adviser representative, to recommend securities products based on the compensation received rather than on the client’s needs. The representative may also be incented to trade heavily in client accounts. However, all trading is supervised to ensure that each client’s investment objectives and goals are being adhered to. Further, as stated in Item 5 above, in certain cases and at the discretion of the firm, RJLU may reduce the amount of advisory fees charged where the receipt of commission-based compensation presents fair and equal payment for services rendered. The firm conducts a regular review of all firm-client

communications and performs routine surveillance of its trading practices to ensure that clients receive the best possible service overall. The Code of Ethics is reviewed by the firm no less than annually for modifications and updates in keeping with the latest securities regulations. A copy of the Code remains available for review upon request.

As further discussed below, RJLU periodically evaluates the execution received from the brokerdealer to ensure clients receive best execution. Best Execution The firm also maintains a fiduciary duty to seek the best execution pricing available for client transactions. While best execution is difficult to define and challenging to measure, there is some consensus that it does not solely mean the achievement of the best price on a given transaction. Rather, it appears to be a collective consideration of factors concerning the trade in question. Such factors include the security being traded, the price of the trade, the speed of the execution, apparent conditions in the market, and the specific needs of the client. RJLU’s primary objective when placing orders for the purchase and sale of securities for client accounts is to obtain the most favorable net results taking into account such factors as price, size of order, difficulty of execution, and broker skill. Based on these criteria, the firm may not necessarily pay the lowest commission or commission equivalent, as specific transactions can involve specialized services on the part of the broker. RJLU evaluates daily whether clients are receiving best execution to ensure the services provided by RJLU as broker-dealer remain competitive and are in the best interest of the firm’s clients. While RJLU’s services are priced at the most competitive rates available, clients are encouraged to weigh their options and review this and all other disclosure materials carefully.

The custodian sends clients written statements on a monthly or quarterly basis depending on the level of activity within the account. Such statements reflect the account value, the holdings within, and the activity conducted over the previous period. Clients are encouraged to review their statements carefully and to contact the firm with any questions or concerns regarding same. Clients must also contact the firm immediately with any changes to their financial situation as such changes may impact the status of their investment account(s).

Clients participating in the services of Envestnet or other third-party platform should be aware that the separate account managers providing services to the client under such platform may have the authority to vote proxies on the client’s behalf. Clients are encouraged to carefully review the disclosure brochures and written agreements of third party providers and contact with RJLU with any questions regarding a third party’s authority to vote proxies on the client’s behalf.