Strategic Capital Advisers, Inc.

Strategic Capital Advisers, Inc. is an independent investment management firm based in Denver, Colorado, established in 1994 and owned by its principals, John Hancock and Jonathan Ahalt. The firm offers discretionary investment advisory services to various clients, including individuals, trusts, tax-exempt funds, charitable organizations, government entities, and corporations. Clients work with the firm to determine asset allocation policies based on factors such as risk tolerance and long-term goals. SCA manages client investments on a fully discretionary basis and provides detailed quarterly reports on portfolio holdings and activity. The firm charges annual fees ranging from 1.30% to 0.05% based on assets under management, billed quarterly. Clients can pay fees by check or have them deducted from their accounts. SCA does not offer or sponsor a wrap fee program. As of December 31, 2021, the firm had $719,836,686 in discretionary assets under management. SCA does not use performance-based fees and works with various types of clients, including Defined Benefit and Defined Contribution Plans. The firm utilizes Fundamental, Technical, and Cyclical Analysis in its investment strategies, investing in various securities and vehicles. SCA has not been involved in any legal or disciplinary events in the past 10 years and does not compensate or receive compensation for client referrals. Clients receive statements from their custodian monthly and reports from SCA monthly or quarterly. SCA has established proxy voting guidelines to serve clients' best interests and maximize shareholder value. The firm exercises investment discretion approved by clients and provides detailed information on its voting practices and financial safeguards.