BAHL & GAYNOR INC

Part 2A of Form ADV: Firm Brochure 255 East Fifth Street Suite 2700 Cincinnati, OH 45202 Telephone: 513-287-6100 Email: info@bahl-gaynor.com Web Address: www.bahl-gaynor.com 4/17/2025 This brochure provides information about the qualifications and business practices of Bahl & Gaynor, Inc. If you have any questions about the contents of this brochure, please contact us at 513-287-6100 or info@bahl-gaynor.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Bahl & Gaynor, Inc is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with the information about which you determine to hire or retain an adviser. Additional information about Bahl & Gaynor, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 106139.  Item 2 Material Changes 6/2024 Throughout: Update the name change of AAM Bahl & Gaynor Small/Mid Cap Income Growth Fund (SMIG) to Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG) and AAM/Bahl & Gaynor Income Growth Fund mutual fund to Bahl & Gaynor Income Growth Fund mutual fund Throughout: Update Sub-Advisory language to Advisory language for Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG) and Bahl & Gaynor Income Growth Fund mutual fund: B&G is the Adviser to the Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG). As the Fund’s investment advisor, B&G arranges for transfer agency, custody, fund administration, distribution, and all other services necessary for the Fund to operate. For the services it provides to the Fund, the Fund pays Bahl & Gaynor a unified management fee, which is calculated daily and paid monthly, at an annual rate of 0.60% of the fund’s average daily net assets. You can obtain information regarding the Fund by contacting the Fund at c/o U.S. Bank Global Fund Services, P.O. Box 701, Milwaukee, Wisconsin 53201-0701 or by calling 1-800-617-0004. B&G is the Adviser to the Bahl & Gaynor Income Growth Fund mutual fund. As the Fund’s investment adviser, B&G provides investment advisory services to the Fund, including monitoring and measuring the Fund’s risk and return against appropriate benchmarks and peers. B&G is responsible for the day-to-day management of the Fund’s portfolio, selection of the Fund’s portfolio investments and supervision of its portfolio transactions subject to the general oversight of the Board and the adviser. For providing services to the Fund, B&G receives an annual advisory fee equal to 0.45% of the average daily net assets of the Fund. The Fund’s SAI provides additional information about fees paid to the Adviser. 6/2024 Item 5 Fees and Compensation in regards to the standard fee schedule for High Net Worth (HNW) clients and institutional client utilizing Bahl & Gaynor’s Separately Managed Accounts strategies. Update Fee Schedule to: Assets Under Management 1% on first $1 million .85% on next $2 million .65% on next $2 million .5% on amounts over $5 million 11/2024 Item 4. Advisory Business Add Eric M. Aber, Director of Software & Automation 11/2024 Item 4.a Management Services 2  Remove: Furthermore, B&G engages a wholesaler for the operations and servicing responsibilities of several SMA programs where B&G’s investment strategies are available. These wholesalers do not have any responsibility, discretion or authority for any investment decisions for these SMA accounts. In some cases, B&G will provide the model trade to the wholesaler. The wholesaler interacts with some of the SMA providers that are responsible for executing the recommended transactions. Update telephone numbers for the BGIG and SMIG ETF to 855-994-1711 11/2024 Item 5 Fees and Compensation Update fee language to: The majority of B&G fees are paid quarterly and in arrears. Clients may authorize B&G to deduct fees directly from their custodial accounts; otherwise, clients are responsible for paying fees to B&G directly. For relationships involving B&G and discretionary platform partners, fees are billed in advance. Billing in advance covers a full quarter, and fees are based on the anticipated advisory services for that period. Add: B&G will calculate fees for assets invested in Alternative Funds based on the most recent reported market value, which is typically subject to a delayed reporting period. Fees will be paid quarterly, in arrears, based on the reported market value as of the last day of the month prior to billing. In addition, to Alternative Funds, the client will incur charges imposed directly on the fund and series level (e.g. management fees and other fund expenses). 11/2024 Item 5.b General Information Update Termination of Advisory Relationship: B&G generally charges advisory fees either in arrears or in advance, depending on the client relationship. For certain accounts, fees are billed quarterly in advance based on the anticipated advisory services for the upcoming period. In the event of termination mid-period, clients are rebated any unearned portion of prepaid fees. B&G will calculate the earned portion of the fee up to the termination date. The remaining unearned fee will be refunded to the client, either directly or to the custodial account from which the fee was originally deducted. 11/2024 Item 8.a. Methods of Analysis and Investment Strategies Add: B&G from time to time may decide to invest in Alternative Funds when appropriate for B&G clients. Such investments are conditional on the client being an Accredited Investor, Qualified Purchaser, financially sophisticated and fully capable of assessing the merits and risk of the 3  investment, and financially able to bear the risk of the illiquidity of the interests and the risk of losing all or substantially all investment in the fund. The investment shall be conditioned on the client’s approval in writing. 11/2024 Item 11.b. Personal Trading Update Language: Employees of B&G are permitted to buy and sell securities for their personal accounts. To address potential conflicts of interest, our Code of Ethics mandates that employees: (1) pre- clear certain personal securities transactions, (2) report their personal securities transactions on at least a quarterly basis, and (3) provide B&G with a detailed summary of specific holdings at the start of employment and annually thereafter, including those over which they have a direct or indirect beneficial interest. Potential conflicts may arise when employees trade in the same securities that B&G is buying, selling, or holding on behalf of clients, as this could result in employees receiving a more favorable price than clients trading in the same security. To mitigate these conflicts, B&G has implemented a personal trading policy. A “restricted list” of securities is maintained to notify employees of securities they are prohibited from trading in their own accounts. Generally, employees must refrain from trading these securities for a specified period, typically one week after B&G has made a similar transaction for client accounts. internal standards, providing real-time data To further support our compliance oversight, B&G utilizes Compliance Alpha, a compliance technology platform that automates and enhances the efficiency of our compliance monitoring. Compliance Alpha assists our compliance team in tracking adherence to regulatory and insights, and supporting timely risk assessments. This technology is one of the tools we use within our comprehensive compliance framework. Our compliance staff monitors employee trading activity against the restricted list through quarterly transaction reports. Any policy violations are addressed by the Chief Compliance Officer in accordance with the Code of Ethics. 11/2024 Item 14 Client Referrals and Other Compensation Update Language: B&G does not receive any economic benefits, including sales awards, referral fees, or other compensation, from third parties in connection with providing advisory services to clients. Additionally, B&G does not compensate any third parties for client referrals. 12/2024 Throughout: Update ADV to incorporate two new Bahl & Gaynor advised ETFs, Bahl & Gaynor Dividend ETF (BGDV) and Bahl & Gaynor Small Cap Dividend ETF (SCDV). 4  12/2024 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Add 11.c.: Bahl & Gaynor’s firm accounts aim to invest in Bahl & Gaynor-advised ETFs over time, to build a long-term investment from the firm's balance sheet. We believe these investments intend to align the interests of the company, employees, and clients. Bahl & Gaynor may invest in its ETFs over time through trading activity in the market. Bahl & Gaynor will endeavor to make those trades in such a way that minimizes potential market impact. When transacting in the advised ETFs, Bahl & Gaynor may consider various factors including daily volume. We understand that the volume and timing of Bahl & Gaynor transactions does not reflect the liquidity of the advised ETFs, which is determined by the liquidity of their underlying holdings. 2/2025 Item 4 Advisory Business Update Vere W. Gaynor to Director Add Eric M. Aber, Chief Technology Officer Remove Glenn D. Warden, Chief Technology Officer Christopher J. Heekin, Wealth Management Managing Director 2/2025 Item 4.a. Management Services Strategic Name Updates & Definition Improvements Dividend Strategy: a large cap dividend growth strategy focused on delivering long-term growth of dividend income, downside protection, and total return. Small Cap Dividend Strategy: a small cap dividend growth strategy focused on delivering long-term growth of dividend income, downside protection, and total return. Income Growth Strategy: a large cap dividend growth strategy focused on delivering high current and consistently growing portfolio income, downside protection, and price appreciation. smig® Small/Mid Cap Income Growth Strategy: a small and mid cap dividend growth strategy focused on delivering high current and consistently growing portfolio income, downside protection, and price appreciation. 2/2025 Item 8.b. Risk of Loss Add ETF Risk 5  Mutual Fund Risk Alternative Investment Risk Artificial Intelligence (AI) Risk 2/2025 Item 13.a. Reviews Update Language The underlying securities used in accounts are continually monitored, and the compliance and portfolio management team conduct regular reviews. Each account is assessed in the context of the client’s stated investment objectives and guidelines. More frequent reviews are done by the portfolio manager based on the client circumstances. 4/2025 Item 5 Fees and Compensation in regards to the standard fee schedule for High Net Worth (HNW) clients and institutional client utilizing Bahl & Gaynor’s Separately Managed Accounts strategies. The fee schedule has been updated to reflect a new minimum fee of $10,000. 4/2025 Item 17 Voting Client Securities Disclosure has been added regarding Broadridge’s 12% fee for managing class action filings. This fee is deducted from any settlement proceeds recovered on behalf of clients. 6  Item 3 Table of Contents Item 2 Material Changes ............................................................................................................. 2 Item 3 Table of Contents ............................................................................................................ 7 Item 4 Advisory Business ........................................................................................................... 9 .............................................................................................. 9 4.a. MANAGEMENT SERVICES ...................................................................................11 4. b. ASSETS UNDER MANAGEMENT Item 5 Fees and Compensation .................................................................................................11 ................................................................................13 Limited Negotiability of Advisory Fees ...............................................................................................13 5. a. PRICING OF SECURITIES ..............................................................................................13 5. b. GENERAL INFORMATION ............................................................................13 Termination of the Advisory Relationship ..................................................................................................................13 Mutual Fund Fees ............................................13 Wrap Fee Programs and Separately Managed Account Fees ..........................................................................................................14 Retirement Account(s) ..............................................................................................14 Additional Fees and Expenses ......................................................................................................14 Advisory Fees in General Item 6 Performance-Based Fees and Side-By-Side Management ...........................................14 Item 7 Types of Clients ..............................................................................................................14 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................15 ........................................15 8. a. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES ................................................................................................................16 8. b. RISK OF LOSS Item 9 Disciplinary Information .................................................................................................18 Item 10 Other Financial Industry Activities and Affiliations .......................................................18 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 18 ........................................................................................................18 11. a. CODE OF ETHICS ..................................................................................................19 11. b. PERSONAL TRADING .....................................19 11. c. TRADING OF BAHL & GAYNOR PROPRIETARY ACCOUNTS ..................................................................................................................20 11. d. SERVING AS OFFICER, TRUSTEE AND/OR DIRECTORS OF OUTSIDE ORGANIZATIONS ............................................20 11. e. RELATED PERSONS AT BROKERS AND CUSTODIANS ......................................................................................20 11. f. POLITICAL CONTRIBUTIONS Item 12 Brokerage Practices .......................................................................................................21 7  ........................................................................................................21 12. a. BEST EXECUTION ...........................................................................................................22 12. b. BLOCK TRADES ...........................................................................................................22 12. c. SOFT DOLLARS ...........................................................................................22 12.d. TRADE ORDER ROTATION ...........................................................................23 12. e. CROSS TRANSACTIONS (AGENCY) Item 13 Review of Accounts .......................................................................................................23 ......................................................................................................................23 13. a. REVIEWS .....................................................................................................................23 13. b. REPORTS Item 14 Client Referrals and Other Compensation .....................................................................24 Item 15 Custody ..........................................................................................................................24 Item 16 Investment Discretion ....................................................................................................24 Item 17 Voting Client Securities ..................................................................................................25 Item 18 Financial Information .....................................................................................................25 8  Item 4 Advisory Business Bahl & Gaynor, Inc. ("B&G") is a SEC-registered investment adviser with its principal place of business located in Ohio. B&G began conducting business in 1990. Bahl & Gaynor, Inc. is also conducting business using the name Bahl & Gaynor Investment Counsel. Listed below are the firm's board members and executive officers: Vere W. Gaynor, Director Charles A. Pettengill, Chairman of the Board Edward A. Woods, Director, Secretary John B. Schmitz, Director, Treasurer Ellis D. Hummel, Director W. Jeff Bahl, Director Robert S. Groenke, Chief Executive Officer & President Kevin T. Gade, Chief Operating Officer Peter M. Kwiatkowski. Chief Investment Officer Tita A. Rogers, Chief Compliance Officer Jenelle M. Armstrong, Chief Administrative Officer Eric M. Aber, Chief Technology Officer Stephanie S. Thomas, Institutional Client Managing Director Nicholas W. Puncer, Institutional Product Managing Director Peter G. Knipe, Managing Director John P. Galvin, Sr., Managing Director B&G offers the following advisory services to our clients: 4.a. MANAGEMENT SERVICES Bahl & Gaynor provides portfolio management investment advisory services for individual and institutional clients. Meetings and discussions with clients help determine an appropriate asset allocation and portfolio strategy. The portfolio may be managed uniquely for that client, or it may be determined that a model portfolio better suits the clients’ objectives. If an account is invested in a particular model the goals and objectives of the model are followed. The client still has the ability to place certain restrictions on the securities chosen. The client retains individual ownership of the securities. The following models are currently managed at B&G: Dividend Strategy: a large cap dividend growth strategy focused on delivering long-term growth of dividend income, downside protection, and total return. Small Cap Dividend Strategy: a small cap dividend growth strategy focused on delivering long-term growth of dividend income, downside protection, and total return. 9  Income Growth Strategy: a large cap dividend growth strategy focused on delivering high current and consistently growing portfolio income, downside protection, and price appreciation. smig® Small/Mid Cap Income Growth Strategy: a small and mid cap dividend growth strategy focused on delivering high current and consistently growing portfolio income, downside protection, and price appreciation. Some of these model strategies are also available to clients of some other investment advisory firms through Separately Managed Accounts (SMA) and Unified Managed Accounts (UMA) programs. In this instance B&G does not work directly with the individual client to determine if the model portfolio meets that client’s investment objectives or risks. As part of its portfolio management process, Bahl & Gaynor incorporates financial planning considerations to help clients align their investment strategy with their overall financial objectives. This includes analyzing a client’s current financial situation and assisting in identifying and implementing appropriate strategies to support their long-term goals. To facilitate this process, Bahl & Gaynor gathers client information through personal interviews and/or questionnaires, covering financial status, tax considerations, future goals, and return objectives. This information is reviewed and integrated into the portfolio management strategy, ensuring that investment recommendations are tailored to the client’s specific needs. Important Note: While financial planning is an integral part of the portfolio management process, Bahl & Gaynor does not provide tax, insurance, or legal advice. Clients are encouraged to consult with qualified professionals in these areas for specific guidance. B&G has also presented a Sub-Adviser to clients who it believes is a suitable candidate for the provision of investment advisory services to invest and reinvest the account, primarily in tax- exempt fixed income municipal securities. B&G would have discretionary authority to hire and fire the sub-adviser and re-allocate assets among them. B&G is the Adviser to the Bahl & Gaynor Income Growth ETF (BGIG), Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG), Bahl & Gaynor Dividend ETF (BGDV), and Bahl & Gaynor Small Cap Dividend ETF (SCDV). As the Fund’s investment advisor, B&G arranges for the transfer agency, custody, fund administration, distribution, and all other services necessary for the Fund to operate. For the services it provides to the Fund, the Fund pays Bahl & Gaynor a unified management fee, which is calculated daily and paid monthly. • • • Annual rate of 0.45% of the Bahl & Gaynor Income Growth ETF (BGIG), average daily net assets. Annual rate of 0.60% of the Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG), average daily net assets. Annual rate of 0.45% of the Bahl & Gaynor Dividend ETF (BGDV), average daily net assets. 10  • Annual rate of 0.70% of the Bahl & Gaynor Small Cap Dividend ETF (SCDV), average daily net assets. You can obtain information regarding the Fund by contacting the Fund at c/o U.S. Bank Global Fund Services, P.O. Box 701, Milwaukee, Wisconsin 53201-0701 or by calling 1-855-994-1711. B&G is the Adviser to the Bahl & Gaynor Income Growth Fund Mutual Fund. As the Fund’s investment adviser, B&G provides investment advisory services to the Fund, including monitoring and measuring the Fund’s risk and return against appropriate benchmarks and peers. B&G is responsible for the day-to-day management of the Fund’s portfolio, selection of the Fund’s portfolio investments and supervision of its portfolio transactions subject to the general oversight of the Board and the adviser. For providing services to the Fund, B&G receives an annual advisory fee equal to 0.45% of the average daily net assets of the Fund. The Fund’s SAI provides additional information about fees paid to the Adviser. B&G has a unique investment strategy, see Item 8, but individual client portfolios may be very different due to the unique circumstances of each client. All investments contain some level of risk. Upon client request and a further review of objectives and risk tolerances, we may also invest in other investment vehicles. These include option contracts, real estate, limited partnerships, exchange traded funds and private equity. 4. b. ASSETS UNDER MANAGEMENT As of 12/31/2024, we were actively managing $19,742,039,261 of clients' assets on a discretionary basis plus $353,041,016 of clients' assets on a non-discretionary basis and oversee $31,777,878,220 (12/31/2024) of clients' assets through Separately Managed Accounts (SMA) programs. Item 5 Fees and Compensation The annualized fee for Portfolio Management Services is charged as a percentage of assets under management and varies according to the selected investment strategy. The following schedule represents the standard fee schedule for High Net Worth (HNW) clients and institutional client utilizing Bahl & Gaynor’s Separately Managed Accounts strategies: Assets Under Management 1% on first $1 million .85% on next $2 million .65% on next $2 million .5% on amounts over $5 million B&G's minimum account fee is $10,000.00 which on occasion may be waived or discounted. A minimum of $1,000,000.00 of assets under management is required for all service. This minimum may be negotiable under certain circumstances. B&G groups certain related client 11  accounts for the purposes of meeting the minimum account size and determining the applicable annualized fee. Fee calculations include cash held in the account and margin balances, unless explicitly excluded in the Investment Advisory Agreement. The majority of B&G’s advisory fees are billed on a rolling quarterly basis, in arrears. Fees are calculated based on the market value as of the last day of the billing period, using trade date accounting and including accruals, as reported by Bahl & Gaynor’s independent pricing service, ICE. Clients may authorize B&G to deduct fees directly from their custodial accounts; otherwise, clients are responsible for paying fees to B&G directly. For relationships involving B&G discretionary platform partners, fees are billed in advance. These fees are based on the anticipated advisory services for the upcoming quarter. Clients who have agreed to the terms to engage Sub-Advisers for their fixed income assets agree that B&G will pay the sub-adviser for its services on a quarterly basis, an amount equal to a percentage of the fair market value of the assets in the accounts. The value of the accounts shall include accrued interest income. The fee shall be charged to each account on a prorated basis upon inception of the account and at the beginning of each calendar quarter, thereafter, based on the portfolio value as determined by the custodian for the client accounts as of the last business day of the previous calendar quarter. The sub-adviser will receive an annual rate of 0.30% of an aggregate accounts size of under $200 million, and 0.25% of an aggregate accounts size of greater than $200 million. Clients who invest in the Bahl & Gaynor Income Growth Fund Mutual Fund will have that asset excluded from management fees of their account. B&G may, from time to time, recommend that a client invest in the Bahl & Gaynor Income Growth ETF (BGIG), Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG), Bahl & Gaynor Dividend ETF (BGDV), and/or Bahl & Gaynor Small Cap Dividend ETF (SCDV) for which B&G provides investment management services. In that event, a conflict of interest arises as a result of B&G receiving a fee at the ETF level in addition to the fee it receives from the client at the account level. In that event, B&G will resolve the conflict by crediting against the account level fee an estimate of the investment management fees it receives from the fund or ETF (but not exceeding the full account level fee) for the period per the client’s stated fee schedule above. This reduction is not applied at the combined and pro-rated relationship level. B&G will collect the stated full SMIG ETF management fee from the Adviser of the Fund, net of certain expenses. B&G will calculate fees for assets invested in Alternative Funds based on the most recent reported market value, which is typically subject to a delayed reporting period. Fees will be paid quarterly, in arrears, based on the reported market value as of the last day of the month prior to billing. In addition, to Alternative Funds, the client will incur charges imposed directly on the fund and series level (e.g. management fees and other fund expenses). 12  In the event the client account managed by B&G holds ERISA plan assets or assets of an IRA or other account subject to Section 4975 of the Internal Revenue Code, B&G will also comply with all other requirements of Prohibited Transaction Exemption 77-4. Limited Negotiability of Advisory Fees: Although B&G has established the standard fee schedules, we retain, at our sole discretion, the right to negotiate fees on a client-by-client basis for all investment strategies. The specific annual fee schedule will be identified in the contract between the adviser and each client. 5. a. PRICING OF SECURITIES Securities owned by B&G's clients are priced at least monthly by an independent pricing service. From time to time some securities do not receive a price from the pricing service. It is B&G's policy to obtain the most accurate price for these excepted securities. It is possible that the value of these securities may be overstated or understated at the month end valuation. B&G takes considerable care to provide as accurate a price as possible. This process presents a possible conflict of interest in that a higher valuation for a security would result in a higher fee. 5. b. GENERAL INFORMATION Termination of the Advisory Relationship: B&G generally charges advisory fees either in arrears or in advance, depending on the client relationship. For certain accounts, fees are billed quarterly in advance based on the anticipated advisory services for the upcoming period. In the event of termination mid-period, clients are rebated any unearned portion of prepaid fees. B&G will calculate the earned portion of the fee up to the termination date. The remaining unearned fee will be refunded to the client, either directly or to the custodial account from which the fee was originally deducted. Mutual Fund Fees: Client portfolios may, from time to time, be invested, in part, in mutual funds/index funds/exchange traded funds. Mutual funds/index funds/exchanged traded funds pay advisory fees to their investment advisers, which reduces the assets of the fund accordingly. B&G's clients are billed an advisory fee set forth in the advisory agreement and clients investing in mutual funds/index funds/exchanged traded funds may therefore pay two levels of advisory fees with respect to the portion of their portfolio invested in mutual funds/index funds/exchange traded funds. Wrap Fee Programs and Separately Managed Account Fees: B&G is not a sponsor of a wrap fee program. Some clients of B&G may participate in a wrap fee program sponsored by the custodian. Clients participating in separately managed account programs may be charged various program fees in addition to the advisory fee charged by B&G. Such fees may include the investment advisory fees of the independent advisers, which may be charged as part of a wrap fee arrangement. In a wrap fee arrangement, clients pay a single fee for advisory, brokerage and custodial services. Clients’ portfolio transactions may be executed without a 13  commission charge in a wrap fee arrangement. In evaluating such an arrangement, the client should also consider that, depending upon the level of the wrap fee charged by the broker- dealer, the amount of portfolio activity in the client’s account, and other factors, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately. Retirement Account(s): 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. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and broker dealers, including, commissions and any other trade related fees. Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Advisory Fees in General: Clients should note that similar advisory services may be available from other registered investment advisers for similar or lower fees. Item 6 Performance-Based Fees and Side-By-Side Management B&G does not charge performance-based fees. Item 7 Types of Clients B&G provides advisory services for the following types of clients: Individuals (other than high net worth individuals) High net worth individuals Pension and profitsharing plans (other than plan participants) 14  Charitable organizations Corporations or other businesses not listed above State or municipal government entities Investment Companies Insurance Companies Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 8. a. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES The B&G equity investment strategies are focused on high quality, dividend growth companies. We are long-term investors (which we define as 2-5 years) and therefore do not generally have high turnover of the investments in our portfolios. B&G believes high quality companies generate consistent earnings growth, have very manageable debt levels, pay and grow dividends, and are leaders in their respective markets. B&G portfolio managers/analysts (our Investment Committee) screen equities based on these high quality, fundamental characteristics. We use thorough fundamental analysis and a variety of qualitative and quantitative data points to determine which companies best fit our investment philosophy. The Investment Committee decides which stocks to include in the Model Portfolios. Individual accounts are invested by the assigned portfolio manager using individual client goals and objectives. B&G fixed income strategy is based on the same high-quality investment philosophy of our equity investment strategy. We allocate capital in a fashion that maximizes total return relative to the client’s objectives. We recognize every client’s needs are different and individually tailor portfolios from both a bottom-up and top-down perspective to achieve our return objectives. We do not limit ourselves to specific ratings or maturity criteria as that may not suit our client’s best interests. However, we do stress that all fixed income sectors and potential possess a “margin of safety”. Additionally, we stress secondary liquidity and tax efficiency for our clients. For a portion of our municipal holdings, B&G has engaged in a relationship with a sub-adviser that specializes in tailored municipal portfolios. Such sub-advisory relationships are an exception and employed on a very limited basis. The Bahl & Gaynor Income Growth ETF (BGIG), Bahl & Gaynor Small/Mid Cap Income Growth ETF (SMIG), Bahl & Gaynor Dividend ETF (BGDV), and Bahl & Gaynor Small Cap Dividend ETF (SCDV) offer certain potential benefits to Bahl & Gaynor clients. These benefits may include increased tax efficiency and the ability to gain diversified exposure to large-cap (BGIG & BGDV) and small/mid-cap (SMIG & SCDV) companies with a relatively small investment. In certain circumstances, the potential benefits may outweigh the added costs for clients, given that Bahl & Gaynor’s investment management fees are lower than the ETF management fees. Clients should carefully consider the potential costs and benefits of investing in the ETFs compared to all other options before making an investment decision. If an asset allocation 15  decision is made to include the ETFs in a portfolio, Bahl & Gaynor will take steps to avoid duplicate charges on those assets. Additionally, small account sizes that do not meet the SMA account size minimums can still benefit from the ETFs. In cases where a client account managed by Bahl & Gaynor holds ERISA plan assets or assets of an IRA or other account subject to Section 4975 of the Internal Revenue Code, Bahl & Gaynor will comply with all applicable requirements of Prohibited Transaction Exemption 77-4. B&G from time to time may decide to invest in Alternative Funds when appropriate for B&G clients. Such investments are conditional on the client being an Accredited Investor, Qualified Purchaser, financially sophisticated and fully capable of assessing the merits and risk of the investment, and financially able to bear the risk of the illiquidity of the interests and the risk of losing all or substantially all investment in the fund. The investment shall be conditioned on the client’s approval in writing. 8. b. RISK OF LOSS Investing in stocks or bonds has risk – markets can experience significant decline and specific stocks can decline due to the company’s failure to meet investors’ expectations. Bond investing has risks based on interest rate fluctuation and specific credit deterioration or default. Any of the above factors can lead to a loss of value. ETF Risks - The risk of owning an ETF generally reflects the risks of owning the underlying securities of the ETF. The Client will bear additional expenses based on your pro rata share of the ETF’s operating expenses. The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks - The risk of owning a mutual fund generally reflects the risks of owning the underlying securities the mutual fund holds. The Client will bear additional expenses based on your pro rata share of the mutual fund’s operating expenses. The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Certain Mutual Funds also invest in the equity securities of private operating or growth companies or real estate and are structured as a closed-end interval fund. Similar to a private fund, these mutual funds can also bear a high degree of risk, be leveraged, speculative and volatile, and an investor could lose all or a substantial amount of their investment. Interval funds 16  are less liquid than a standard mutual fund, as they usually limit shareholders to quarterly or other specific repurchase window and may also be limited as to the dollar amount that can be liquidated in each window. Alternative Investments - The performance of alternative investments can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. B&G believes Clients should only have a portion of their assets in these investments. Cybersecurity and Business Continuity risk – B&G has a policy in place to respond to a Significant Business Disruption (SBD). In the event of an SBD, our policy is to safeguard our employees’ lives and B&G prosperity, to conduct a rapid financial and operational assessment, to recover quickly and resume operations swiftly, to protect B&G’s books and records, and to allow B&G clients to transact business seamlessly. If it is determined B&G is unable to continue its business, B&G will assure clients prompt access to their funds and securities. B&G has taken significant steps to reduce the impact of business interruptions resulting from a wide variety of potential events. This Disaster Recovery Plan (DRP) in conjunction with the Business Continuity Plan (BCP) and other related policies and procedures are meant to reduce any business downtime. These plans put in place the resources, personnel, equipment, and procedures designed to minimize operational downtime. The DRP and BCP involve defining the mission critical systems and is designed to document the information and procedures needed to safeguard business operations and restore the necessary operations after any natural or man-made disaster event. - Artificial Intelligence (AI) Risk Recent technological advances in generative AI and machine learning technology (collectively, “Artificial Intelligence (AI)”) pose risks to B&G and its clients. AI is a branch of computer science focused on creating systems capable of performing tasks that typically require human intelligence; this includes, among other things, methods for analyzing, modeling, and understanding language, as well as developing algorithms that can learn to perform various tasks. B&G and the companies in which clients invest could be further exposed to the risks of AI if third-party service providers or any counterparties, whether or not known to B&G, also use AI in their business activities. B&G cannot control third-party operations, product development, or service provision. AI is generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that AI utilizes to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error — potentially materially so — and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of AI. To the extent that B&G or the companies in which clients invest are exposed to the risks of AI, any such inaccuracies or errors could have adverse impacts on a client’s performance. Natural & Unavoidable Events risk - Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war, terrorism or 17  threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term and wide-spread effects on the world economies and markets generally. Clients may have exposure to countries and markets impacted by such events, which could result in material losses. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. B&G and our management personnel have no reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations B&G and any related persons are not engaged in other financial industry activities and have no other industry affiliations. From time to time a broker, dealer or custodian may pay in full or in part, for educational conferences and events; consulting on technology, compliance, legal and business needs; publications and conferences on practice management and business succession; access to employee benefits providers, human capital consultants, and insurance providers; or marketing consulting and support. These benefits do not obligate Bahl & Gaynor in any way to recommend, request, or require the use of that broker, dealer, or custodian. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11. a. CODE OF ETHICS The Code of Ethics is predicated on the principle that B&G owes a fiduciary duty to its clients. Accordingly, B&G’s employees must avoid activities, interests and relationships that run contrary (or appear to run contrary) to the best interests of clients. At all times, B&G must: • • Place client interests ahead of B&G’s – As a fiduciary, B&G must serve in its clients’ best interests. In other words, B&G employees may not benefit at the expense of advisory clients. This concept is particularly relevant when employees are making personal investments in securities traded by advisory clients. Engage in personal investing that is in full compliance with B&G’s Code of Ethics – Employees must review and abide by B&G’s Personal Securities Transaction and Insider Trading Policies. 18  • • • Avoid taking advantage of your position – Employees must not accept investment opportunities, gifts or other gratuities from individuals seeking to conduct business with B&G, or on behalf of an advisory client. Accept no more than reasonable compensation - B&G believes that fees for its services should be reasonable and appropriate for the level of service provided. Fee structures are available for reference in the B&G ADV 2A. Maintain full compliance with the Federal Securities Laws – Employees must abide by the standards set forth in Rule 204A-1 under the Advisers Act. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to info@bahl-gaynor.com, or by calling us at 513-287-6100. 11. b. PERSONAL TRADING Employees of B&G are permitted to buy and sell securities for their personal accounts. To address potential conflicts of interest, our Code of Ethics mandates that employees: (1) pre- clear certain personal securities transactions, (2) report their personal securities transactions on at least a quarterly basis, and (3) provide B&G with a detailed summary of specific holdings at the start of employment and annually thereafter, including those over which they have a direct or indirect beneficial interest. Potential conflicts may arise when employees trade in the same securities that B&G is buying, selling, or holding on behalf of clients, as this could result in employees receiving a more favorable price than clients trading in the same security. To mitigate these conflicts, B&G has implemented a personal trading policy. A “restricted list” of securities is maintained to notify employees of securities they are prohibited from trading in their own accounts. Generally, employees must refrain from trading these securities for a specified period, typically one week after B&G has made a similar transaction for client accounts. internal standards, providing real-time data To further support our compliance oversight, B&G utilizes Compliance Alpha, a compliance technology platform that automates and enhances the efficiency of our compliance monitoring. Compliance Alpha assists our compliance team in tracking adherence to regulatory insights, and supporting timely risk and assessments. This technology is one of the tools we use within our comprehensive compliance framework. Our compliance staff monitors employee trading activity against the restricted list through quarterly transaction reports. Any policy violations are addressed by the Chief Compliance Officer in accordance with the Code of Ethics. 11. c. TRADING OF BAHL & GAYNOR PROPRIETARY ACCOUNTS 19  Bahl & Gaynor’s firm accounts aim to invest in Bahl & Gaynor-advised ETFs over time, to build a long-term investment from the firm's balance sheet. We believe these investments intend to align the interests of the company, employees, and clients. Bahl & Gaynor may invest in its ETFs over time through trading activity in the market. Bahl & Gaynor will endeavor to make those trades in such a way that minimizes potential market impact. When transacting in the advised ETFs, Bahl & Gaynor may consider various factors including daily volume. We understand that the volume and timing of Bahl & Gaynor transactions does not reflect the liquidity of the advised ETFs, which is determined by the liquidity of their underlying holdings. 11. d. SERVING AS OFFICER, TRUSTEE AND/OR DIRECTORS OF OUTSIDE ORGANIZATIONS Employees may, under certain circumstances, be granted permission to serve as directors, trustees or officers of outside organizations. These organizations can include public or private corporations, partnerships, charitable foundations and other not-for-profit institutions. Employees may also receive compensation for such activities. Service with organizations outside of B&G can, however, raise serious regulatory issues and concerns, including conflicts of interests and access to material non-public information. As an outside board member or officer, an employee may come into possession of material non-public information about the outside company, or other public companies. It is critical that a proper information barrier be in place between B&G and the outside organization, and that the employee does not communicate such information to other B&G employees in violation of the information barrier. Similarly, B&G may have a business relationship with the outside organization or may seek a relationship in the future. In those circumstances, the employee must not be involved in the decision to retain or hire B&G. 11. e. RELATED PERSONS AT BROKERS AND CUSTODIANS Relatives of employees may work for financial entities that B&G does business with. A review of the relationship between the employee and related party and the financial entity that B&G does business with is performed and evaluated for any conflict of interest. 11. f. POLITICAL CONTRIBUTIONS Rule 203(4)-5 requires any covered associate that makes political contributions to an “official” of a state or local “government entity” client to: 20  1) impose a two-year ban on the adviser receiving compensation for advisory services, 2) prohibit an adviser and its covered associates from coordinating or soliciting any person or political actions committee (“PAC”) to make contributions to officials or payments to certain state or local political parties, 3) prohibit an adviser from paying a third-party solicitor to solicit a government client for the adviser’s advisory services unless the third party is a “regulated person,” currently defined as a SEC-registered broker-dealer or SEC-registered investment adviser subject to pay to play restrictions, and 4) the rule also applies to an investment adviser that manages assets of a government entity indirectly through a covered investment pool in which a government entity invests or is solicited to invest; such as hedge funds, private equity funds, venture capital funds, and collective trust funds, as well as registered investment companies that are investment options of participant-directed plans or programs of a government entity; such as 529 plans, 403(b) plans and 457 plans. The portfolio management team of B&G are permitted to make political contributions up to the de minimis of, $350.00 in contributions per election to a candidate for whom he or she is entitled to vote, and up to $150.00 per election to a candidate for whom he or she is not entitled to vote. Quarterly B&G officers must report any political contributions using the B&G Quarterly Political Contribution form, showing date of contribution, who the contribution was made to, if the contributor is entitled to vote for the candidate and the amount of the contribution. Any contribution over the de minims amount must be pre-cleared. B&G will perform two year look back for new officers. Item 12 Brokerage Practices 12. a. BEST EXECUTION B&G’s principal objective in selecting brokers and placing client trades is to receive the best execution for those client trades. Best execution involves a number of factors, including: 1) 2) 3) 4) 5) 6) Price received/paid for the security Brokerage cost Timeliness of the transaction Ability to transact smoothly from order placement to settlement Record keeping Custody services provided B&G has a Best Execution Committee that meets semi-annually to review brokers. We also engage with an outside provider for quantitative best execution analysis. Clients that direct brokerage reduce our ability to seek best execution and negotiate commissions. For clients in custody with a broker we have limited ability to negotiate commissions and monitor for best execution. Trading away from a custodian broker will usually result in additional charges to the client. 21  12. b. BLOCK TRADES Whenever possible we will block clients’ trades together to achieve a better transaction price. Directed broker accounts are not available for blocking and may lose this price and execution advantage. All accounts in the blocks receive the same price for the trade. Partial fills of the block are allocated pro-rata among the accounts. 12. c. SOFT DOLLARS B&G may use non-directed client commission dollars to receive investment related research and services. This practice is referred to as “Soft Dollars” This research includes, but may not be limited to, written company and industry reports, economic data, historical charts and graphs, visits from company managements and access to industry conferences hosted by brokerage firms. Investment services include security information such as price quotes, dividend information, stock split information, news updates, access to the exchanges, daily, monthly pricing of securities, price charts and graphs and other technical analysis of stocks and bonds. The use of soft dollars does create a conflict of interest. Only certain trades are used for soft dollars, but all clients may benefit. Though we have negotiated competitive commission rates with all these brokers, it may result in clients paying a higher commission than they may receive for trade execution only. It may also result in brokers being favored because they provide the soft dollar benefits. Some of these trades are placed directly with the broker providing the research and some are made through third party brokers that then make the payment to the service provider. 12.d. TRADE ORDER ROTATION B&G’s fully discretionary non-directed brokerage accounts and B&G directed accounts in a randomized rotation program are within a single trade rotation with all Separately Managed Accounts (SMA) and Unified Managed Accounts (UMA) programs, traded in a snake-like order. Model strategies are also available to clients in some other investment advisory firms through SMA and UMA programs. In this instance B&G does not work directly with the individual client or execute trades. B&G communicates model trades the SMA/UMA platform partners. The Trade Order Rotation is as follows: • • When a model trade is scheduled, trades are entered using a single trade rotation that includes B&G fully discretionary accounts and all SMA/UMA platform relationships. Within the rotation, all groups are traded in snake order (i.e. trade first today, trade last on the next trade). 22  • All allocations are made by close of business on trade date. In the event an order is “partially filled” the allocation is made on a pro-rata basis. Each account in the order will receive the same percentage of the trade. Bahl & Gaynor advised ETFs trades through an independent trade process determined at the discretion of the Bahl & Gaynor ETF Basket Committee based on various factors including, but not limited to, ETF capital market factors, ETF market liquidity, and other general investment considerations. 12. e. CROSS TRANSACTIONS (AGENCY) An agency cross trade is a transaction between two clients’ accounts managed by the same investment adviser. `It is B&G’s policy to engage in cross transactions only when necessary. Agency cross transactions will only occur when it is in both client’s best interest. All agency cross trades must be reported to the firms CCO. B&G does not receive any additional compensation other than the normal advisory fee for these trades. B&G does not participate in Principle cross trades. Item 13 Review of Accounts 13. a. REVIEWS The underlying securities used in accounts are continually monitored, and the compliance and portfolio management team conduct regular reviews. Each account is assessed in the context of the client’s stated investment objectives and guidelines. More frequent reviews are done by the portfolio manager based on the client circumstances. Clients should always compare their custodian reports to the B&G reports to make sure they are consistent. 13. b. REPORTS In addition to the monthly or quarterly statements and confirmations of transactions that clients receive from their custodian, B&G will provide monthly, quarterly or annual reports at the client’s request. These reports summarize the value of the account, securities held with the market value of each, the estimated annual income, and the cost basis of each holding, if available. This report is available by mail or online based on the client’s preference. Individual securities have the following information: number of shares, price, total market value, dividend, estimated annual income and cost basis if available. B&G is not responsible for the accuracy of cost information provided by the client. 23  Item 14 Client Referrals and Other Compensation B&G does not receive any economic benefits, including sales awards, referral fees, or other compensation, from third parties in connection with providing advisory services to clients. Additionally, B&G does not compensate any third parties for client referrals. Item 15 Custody B&G has custody of assets in that we debit our management fee directly from your account. This type of custody falls under Fee Deduction Exemption and is not required by the SEC to undergo an annual custody examination. We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that B&G can directly debit advisory fees from client custodial accounts if authorized. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the qualified custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians, we also send account statements directly to our clients monthly, quarterly or annually at a client’s request by mail or electronically. We urge our clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current. Item 16 Investment Discretion Some clients engage B&G to provide discretionary asset management services, which allows us to place trades in the client’s account without obtaining their prior approval for each transaction. Clients grant us discretionary authority by signing a discretionary management agreement with B&G. This authority may be limited if clients provide us with specific written instructions. For clients with non-discretionary agreements, B&G will obtain the client’s approval, either orally or in writing, before executing any recommended investment transactions in their accounts. 24  Item 17 Voting Client Securities Proxy voting is an important right of clients, and reasonable care is taken to exercise these rights properly and in a timely manner. When B&G has discretionary authority to vote client proxies, it votes in the best interests of its clients, following its proxy policies and procedures. B&G does not vote proxies in-house. Instead, we have engaged Broadridge’s ProxyEdge platform to facilitate proxy voting and maintain records of all proxy activities. This open- architecture platform allows B&G to select from multiple proxy advisory firms to provide recommendations for proxy voting. B&G has chosen Glass Lewis as our advisory firm, which evaluates issuers based on factors such as the reputation, experience, and competence of the company’s management and board of directors. B&G’s complete proxy voting policy and procedures, as well as those of its proxy voting service providers, are maintained in writing and available for client review upon request. Additionally, B&G’s proxy voting records are available exclusively to our clients. Clients may contact B&G at the phone number provided in this document if they have questions or wish to review these documents. In addition to proxy voting, B&G has engaged Broadridge to manage class action claim filings. Occasionally, securities held in client accounts may be the subject of class action lawsuits. B&G has contracted with Broadridge to identify eligible class action cases, file Proof of Claim forms, monitor the status of claims, and facilitate the distribution of settlement proceeds in accordance with SEC guidelines. For these service, Broadridge collects a fee equal to 12% of any settlement account received. This fee is deducted from the proceeds prior to distribution to the client. Item 18 Financial Information B&G has no additional financial circumstances to report. Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. B&G has not been the subject of a bankruptcy petition at any time during the past ten years. 25 

Part 2B of Form ADV: Brochure Supplement 255 East Fifth Street Suite 2700 Cincinnati, OH 45202 Telephone: 513-287-6100 Email: info@bahl-gaynor.com Web Address: www.bahl-gaynor.com 4/17/2025 This brochure supplement provides information about investment management personnel of Bahl & Gaynor, Inc. that supplements the Bahl & Gaynor Investment Counsel brochure. You should have received a copy of that brochure. Please contact Bahl & Gaynor if you have not received the Bahl & Gaynor brochure or if you have any questions about the contents of the supplement. Bahl & Gaynor, Inc is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with the information about which you determine to hire or retain an Adviser. Additional information about Bahl & Gaynor, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 106139.  Full Legal Name VERE W. GAYNOR Born 1947 Education Columbia University; BS, Political Science; 1970 Columbia University; MBA, Finance; 1971 Business Experience Bahl & Gaynor, Inc.; Director Emeritus; from 4/2022 to current Bahl & Gaynor, Inc.; Chairman of the Board/President; from 7/2/1990 to 4/2022 Disciplinary Information Vere W. Gaynor has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Vere W. Gaynor is not engaged in any other investment related activities. 2. Vere W. Gaynor does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Vere W. Gaynor is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Vere W. Gaynor does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 2  Full Legal Name CHARLES A. PETTENGILL Born 1961 Education Colgate University; BA, Economics; 1984 University of Chicago; MBA; Finance; 1986 Business Experience Bahl & Gaynor, Inc.; Chairman of the Board; from 4/2022 to current Bahl & Gaynor, Inc.; Vice President, Senior Wealth Advisor; from 5/1/1997 to 4/2022 Designation Charles A. Pettengill has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/1996 * Please see Minimum Qualifications Required below Disciplinary Information Charles A. Pettengill has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Charles A. Pettengill is not engaged in any other investment related activities. 2. Charles A. Pettengill does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Charles A. Pettengill is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Charles A. Pettengill does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 3  Full Legal Name ELEANOR K. MOFFAT Born 1956 Education Princeton University; AB, History; 1978 John Hopkins University; MAS; Administrative Science; 1983 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 1/1/1999 to current Designation Eleanor K. Moffat has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/1988 * Please see Minimum Qualifications Required below Disciplinary Information Eleanor K. Moffat has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Eleanor K. Moffat is not engaged in any other investment related activities. 2. Eleanor K. Moffat does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Eleanor K. Moffat is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Eleanor K. Moffat does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 4  Full Legal Name SCOTT D. RODES Born 1962 Education Vanderbilt University; BE, Mechanical Engineering; 1985 Xavier University; MBA; Business; 1987 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 6/1/2001 to current Designation Scott D. Rodes has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/1993 * Please see Minimum Qualifications Required below Disciplinary Information Scott D. Rodes has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Scott D. Rodes is not engaged in any other investment related activities. 2. Scott D. Rodes does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Scott D. Rodes is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Scott D. Rodes does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 5  Full Legal Name EDWARD A. WOODS Born 1966 Education Wittenberg University; BA, Business Administration; 1989 University of Cincinnati, MBA, Finance; 1996 Business Experience Bahl & Gaynor, Inc.; Director, Senior Wealth Advisor; from 9/1/2004 to current Designation Edward A. Woods has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/1996 * Please see Minimum Qualifications Required below Disciplinary Information Edward A. Woods has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Edward A. Woods is not engaged in any other investment related activities. 2. Edward A. Woods does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Edward A. Woods is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Edward A. Woods does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 6  Full Legal Name JOHN B. SCHMITZ Born 1960 Education University of Cincinnati, BA, Finance and Real Estate; 1982 Business Experience Bahl & Gaynor, Inc.; Director, Portfolio Manager; from 12/1/2005 to current Designation John B. Schmitz has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/1992 * Please see Minimum Qualifications Required below Disciplinary Information John B. Schmitz has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. John B. Schmitz is not engaged in any other investment related activities. 2. John B. Schmitz does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. John B. Schmitz is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation John B. Schmitz does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 7  Full Legal Name ELLIS D. HUMMEL Born 1968 Education Skidmore College, BA, Government; 1990 Business Experience Bahl & Gaynor, Inc.; Director, Senior Wealth Advisor; from 2/1/2008 to current Designation Ellis D. Hummel has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 6/2002 **Please see Minimum Qualifications Required below Disciplinary Information Ellis D. Hummel has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Ellis D. Hummel is not engaged in any other investment related activities. 2. Ellis D. Hummel does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Ellis D. Hummel is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Ellis D. Hummel does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 8  Full Legal Name STEPHANIE S. THOMAS Born 1967 Education Wittenberg University, BA, Economics; 1989 University of Notre Dame, MBA 1996 Business Experience Bahl & Gaynor, Inc.; Institutional Client Managing Director, Portfolio Manager; from 7/2/2012 to current Designation Stephanie S. Thomas has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/2001 * Please see Minimum Qualifications Required below Disciplinary Information Stephane S. Thomas has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Stephane S. Thomas is not engaged in any other investment related activities. 2. Stephane S. Thomas does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Stephane S. Thomas is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Stephane S. Thomas does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 9  Full Legal Name W. JEFF BAHL Born 1979 Education Washington & Lee University, BSBA, Commerce; 2002 Business Experience Bahl & Gaynor, Inc.; Director, Senior Wealth Advisor; from 5/1/2014 to current Disciplinary Information W. Jeff Bahl has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. W. Jeff Bahl is not engaged in any other investment related activities. 2. W. Jeff Bahl does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. W. Jeff Bahl is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation W. Jeff Bahl does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 10  Full Legal Name CHRISTOPHER M. ROWANE Born 1960 Education Gannon University, BSBA, Finance; 1983 Gannon University, MBA, Finance; 1988 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 5/1/2014 to current Designation Christopher M. Rowane has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/1998 * Please see Minimum Qualifications Required below Disciplinary Information Christopher M. Rowane has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Christopher M. Rowane is not engaged in any other investment related activities. 2. Christopher M. Rowane does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Christopher M. Rowane is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Christopher M. Rowane does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 11  Full Legal Name NICHOLAS W. PUNCER Born 1987 Education University of Cincinnati; BBA, Finance and Business Economics; 2010 Business Experience Bahl & Gaynor, Inc.; Institutional Product Managing Director, Portfolio Manager, from 5/1/2014 to current; Analyst, from 2010 to April 2014 Designation Nicholas W. Puncer has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/2014 * Please see Minimum Qualifications Required below CFP®; College of Financial Planning™; 6/2014 ** Please see Minimum Qualifications Required below Disciplinary Information Nicholas W. Puncer has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Nicholas W. Puncer is not engaged in any other investment related activities. 2. Nicholas W. Puncer does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Nicholas W. Puncer is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Nicholas W. Puncer does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 12  Full Legal Name JAMES E. RUSSELL Born 1961 Education Centre College of Kentucky, BS, Chemistry; 1983 Emory University, MBA, Finance; 1986 Business Experience Bahl & Gaynor, Inc.; Portfolio Manager; from 10/27/2014 to current Designation James E. Russell has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/1992 * Please see Minimum Qualifications Required below Disciplinary Information James E. Russell has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. James E. Russell is not engaged in any other investment related activities. 2. James E. Russell does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. James E. Russell is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation James E. Russell does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 13  Full Legal Name CHRISTOPHER J. HEEKIN Born 1970 Education Duke University, BA, Economics; 1992 Darden School at University of Virginia, MBA, 1999 Business Experience Bahl & Gaynor, Inc.; Wealth Management Managing Director, Senior Wealth Advisor; from 10/17/2016 to current Designation Christopher J. Heekin has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 7/2017 ** Please see Minimum Qualifications Required below Disciplinary Information Christopher J. Heekin has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Christopher J. Heekin is not engaged in any other investment related activities. 2. Christopher J. Heekin does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Christopher J. Heekin is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Christopher J. Heekin does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 14  Full Legal Name STEVEN N. BROWN Born 1981 Education University of Cincinnati; BA, Finance; 2004 Business Experience Bahl & Gaynor, Inc.; Financial Planning Specialist; from 1/8/2018 to current Huntington National Bank; Vice President and Wealth Advisor; from August 2011 to January 2018 Designation Steven N. Brown has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 3/2008 ** Please see Minimum Qualifications Required below Disciplinary Information Steven N. Brown has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Steven N. Brown is not engaged in any other investment related activities. 2. Steven N. Brown does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Steven N. Brown is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Steven N. Brown does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 15  Full Legal Name SAMUEL L. KOOPMAN Born 1988 Education Xavier University, BSBA, Finance; 2010 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 7/1/2018 to current; Wealth Advisor Analyst; from 6/15/2015 to 6/30/2018 United States Army, Company Executive Officer; from 1/1/2014 to 6/1/2015; Brigade Medical Operations Officer; from 1/1/2013 – 12/31/2014 Designation Samuel L. Koopman has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 5/2017 ** Please see Minimum Qualifications Required below Disciplinary Information Samuel L. Koopman has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Samuel L. Koopman is not engaged in any other investment related activities. 2. Samuel L. Koopman does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Samuel L. Koopman is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Samuel L. Koopman does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 16  Full Legal Name KEVIN T. GADE Born 1991 Education University of Cincinnati; BBA, Finance & Business Economics; 2014 Business Experience Bahl & Gaynor, Inc.; Chief Operating Officer & Portfolio Manager, from 4/2022 to current; Portfolio Manager, from 7/17/2018 to 4/2022; Portfolio Analyst, from 9/1/2016 to 7/11/2018 Designation Kevin T. Gade has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 8/2017 * Please see Minimum Qualifications Required below CFP®; College of Financial Planning™; 3/2018 ** Please see Minimum Qualifications Required below Disciplinary Information Kevin T. Gade has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Kevin T. Gade is not engaged in any other investment related activities. 2. Kevin T. Gade does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Kevin T. Gade is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Kevin T. Gade does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 17  Full Legal Name KEITH HERBERT RENNEKAMP Born 1980 Education The Ohio State University Fisher College of Business BSBA, Finance, 2002 Xavier University Williams College of Business MBA, Finance, 2007 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 5/29/2018 to current Huntington National Bank; Vice President, Senior Portfolio Manager; from September 2013 to May 2018 Designation Keith Herbert Rennekamp has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/2009 * Please see Minimum Qualifications Required below CFP®; College of Financial Planning™; 4/2012 ** Please see Minimum Qualifications Required below Disciplinary Information Keith Herbert Rennekamp has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Keith Herbert Rennekamp is not engaged in any other investment related activities. 2. Keith Herbert Rennekamp does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities Keith Herbert Rennekamp consults with the CFA Institute that results in approximately 120 hours of his time in a one-year cycle. The majority of that time is outside of normal business hours, and Mr. Rennekamp is paid a stipend for his consultation. Additional Compensation Keith Herbert Rennekamp does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 18  Full Legal Name PETER MICHAEL KWIATKOWSKI Born 1969 Education California State University at Long Beach BS, Finance, Real Estate, & Law 1999 Business Experience Bahl & Gaynor, Inc.; Chief Investment Officer, Portfolio Manager; from 4/2022 to current; Portfolio Manager; from 1/14/2019 to 4/2022 ClearArc Capital; in multiple positions most recently as Director, Growth & Income Strategies from 11/2002 to 12/2018 Designation Peter Michael Kwiatkowski has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/2002 * Please see Minimum Qualifications Required below Disciplinary Information Peter Michael Kwiatkowski has no reportable disciplinary history. Other Business Activities A. Investment Related Activities Peter Michael Kwiatkowski is not engaged in any other investment related activities. 2. Peter Michael Kwiatkowski does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities Peter Michael Kwiatkowski is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Peter Michael Kwiatkowski does not receive any economic benefit from a non- advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 19  Full Legal Name JOHN ERIC STRANGE Born 1973 Education Georgetown College, BS, Accounting, 1996 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 4/15/2019 to current Fifth Third Private Bank; Vice President, Senior Portfolio Manager; from July 2016 to February 2019 Designation John Eric Strange has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/2002 * Please see Minimum Qualifications Required below Disciplinary Information John Eric Strange has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. John Eric Strange is not engaged in any other investment related activities. 2. John Eric Strange does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. John Eric Strange is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation John Eric Strange does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 20  Full Legal Name ROBERT SCOTT GROENKE Born 1983 Education University of Michigan, BA, Economics, 2005 University of Chicago, MBA, 2012 Business Experience Bahl & Gaynor, Inc.; Chief Executive Officer & President, Portfolio Manager, from 4/2022 to current; Portfolio Manager, from 12/16/2019 to 4/2022 Franklin Templeton; Vice President & Research Analyst, from 2018 to December 2019; Research Analyst; from August 2012 to 2018 Disciplinary Information Robert Scott Groenke has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Robert Scott Groenke is not engaged in any other investment related activities. 2. Robert Scott Groenke does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Robert Scott Groenke is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Robert Scott Groenke does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 21  Full Legal Name MAURA ANNE KELLY Born 1980 Education University of Dayton, BSBA, Finance (major) & Accounting (minor), 2002 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 3/30/2020 to current US Bank; Senior Vice President, Senior Portfolio Manager; from May 2017 to March 2020 Fifth Third Bank; Vice President, Senior Portfolio Manager; from December 2012 to May 2017 Designation Maura Anne Kelly has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; Xavier University, 2/2008 ** Please see Minimum Qualifications Required below Disciplinary Information Maura Anne Kelly has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Maura Anne Kelly is not engaged in any other investment related activities. 2. Maura Anne Kelly does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Maura Anne Kelly is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Maura Anne Kelly does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 22  Full Legal Name ANDREW HAGEDORN Born 1976 Education University of Kentucky BSBA, Management and Economics, 1998 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 10/4/2021 to current Huntington National Bank; Senior Vice President & National Portfolio Manager Executive; from 12/2001 to 9/2021 Disciplinary Information Andrew Hagedorn has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Andrew Hagedorn is not engaged in any other investment related activities. 2. Andrew Hagedorn does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Andrew Hagedorn is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Andrew Hagedorn does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 23  Full Legal Name IAN THOMAS OWENS Born 1993 Education University of Cincinnati, BBA, Finance; 2017 Business Experience Bahl & Gaynor, Inc.; Associate Portfolio Manager, from 5/2023 to current; Portfolio Analyst, from 8/14/2017 to 5/2023 Designation Ian Thomas Owens has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 11/2021 * Please see Minimum Qualifications Required below Disciplinary Information Ian Thomas Owens has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Ian Thomas Owens is not engaged in any other investment related activities. 2. Ian Thomas Owens does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Ian Thomas Owens is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Ian Thomas Owens does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 24  Full Legal Name ERIC JAMES ZINS Born 1995 Education University of Cincinnati College of Business BBA, Finance; 2018 Business Experience Bahl & Gaynor, Inc.; Associate Portfolio Manager, from 5/2023 to current; Portfolio Analyst; from 8/20/2018 to 5/2023 Designation Eric James Zins has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 2/2021 * Please see Minimum Qualifications Required below Disciplinary Information Eric James Zins has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Eric James Zins is not engaged in any other investment related activities. 2. Eric James Zins does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Eric James Zins is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Eric James Zins does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 25  Full Legal Name MATTHEW JOHN CARROLL Born 1997 Education Xavier University Williams College of Business BSBA, Finance, 2020 Business Experience Bahl & Gaynor, Inc.; Wealth Management Analyst; from 8/17/2020 to current Prior to 8/2022 Matthew John Carroll was a student at Xavier University Designation Matthew John Carrol has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 3/2022 ** Please see Minimum Qualifications Required below Disciplinary Information Matthew John Carroll has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Matthew John Carroll is not engaged in any other investment related activities. 2. Matthew John Carroll does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Matthew John Carroll is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Matthew John Carroll does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 26  Full Legal Name KELSEY MARIE FLANNERY Born 1995 Education University of Kentucky Gatton College of Business BBA, Finance 2016 Business Experience Bahl & Gaynor, Inc.; Wealth Management Analyst; from 8/26/2021 to current Huntington National Bank; Portfolio Manager; from 9/2017 to 8/2021 Designation Kelsey Marie Flannery has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 8/2022 ** Please see Minimum Qualifications Required below Disciplinary Information Kelsey Marie Flannery has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Kelsey Marie Flannery is not engaged in any other investment related activities. 2. Kelsey Marie Flannery does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Kelsey Marie Flannery is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Kelsey Marie Flannery does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 27  Full Legal Name MICHAEL MURRAY DELPRINCE Born 1990 Education Centre College, BA, Economics, 2013 University of Cincinnati, MS, Taxation, 2022 Business Experience Bahl & Gaynor, Inc.; Wealth Advisor; from 2/2023 to present; Senior Wealth Management Analyst; from 2/14/2022 to 2/2023 Nationwide Financial; Territory Manager; from January 2017 to February 2022 Designation Michael Murray Del Prince has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 12/2016 ** Please see Minimum Qualifications Required below CLU®; Charter Life Underwriter ®; 8/2018 *** Please see Minimum Qualifications Required below Disciplinary Information Michael Murray DelPrince has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Michael Murray DelPrince is not engaged in any other investment related activities. 2. Michael Murray DelPrince does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Michael Murray DelPrince is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Michael Murray DelPrince does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 28  Full Legal Name CHRISTIAN ROBERS WING Born 1974 Education University of Cincinnati BA, Communications 1997 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 2/03/2023 to current Huntington National Bank; from June 2010 to January 2023 Disciplinary Information Christian Roberts Wing has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Christian Roberts Wing is not engaged in any other investment related activities. 2. Christian Roberts Wing does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Christian Roberts Wing is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Christian Roberts Wing does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 29  Full Legal Name GRANT EMERSON COOPER Born 1987 Education Miami University, BS, Finance, 2009 University of Cincinnati, MS, Finance, 2015 Business Experience Bahl & Gaynor, Inc.; Wealth Advisor; from 10/31/2022 to current US Bank Private Wealth Management; Portfolio Manager and Vice President; from May 2018 to October 2023 Johnson Investment Counsel; Portfolio Manager Assistant, from May 2015 to May 2018 Designation Grant Emerson Cooper has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 9/2019 * Please see Minimum Qualifications Required below CFP®; College of Financial Planning™; 3/2020 ** Please see Minimum Qualifications Required below Disciplinary Information Grant Emerson Cooper has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Grant Emerson Cooper is not engaged in any other investment related activities. 2. Grant Emerson Cooper does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Grant Emerson Cooper is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Grant Emerson Cooper does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 30  Full Legal Name MARCIE LIN WRIGHT Born 1974 Education Loyola University Chicago, Quinlan School of Business, M.B.A., Business Administration, 2014 Columbia College of Missouri, B.S., Business Administration, 2000 Highland Community College, A.S., Business Administration, 1995 Business Experience Bahl & Gaynor, Inc.; Senior Wealth Advisor; from 5/1/24 to current Fifth Third Bank; Senior Vice President, Managing Director, Private Bank Portfolio Management, Regional Director of Portfolio Management, Team Lead and Senior Portfolio Manager; from April 2005 – April 2024 Designation Marcie Lin Wright has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 7/2008 ** Please see Minimum Qualifications Required below Disciplinary Information Marcie Lin Wright has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Marcie Lin Wright is not engaged in any other investment related activities. 2. Marcie Lin Wright does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Marcie Lin Wright is a member of Haul Four Fast, LLC. The LLC; does not provide direct compensation or involve a substantial amount of time. Additional Compensation Marcie Lin Wright does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 31  Full Legal Name CHRISTOPHER ANTHONY GUY Born 1999 Education University of Cincinnati College of Business BBA, Finance, 2022 Business Experience Bahl & Gaynor, Inc.; Wealth Management Analyst; from 08/15/2022 to current Prior to 8/2022 Chris Anthony Guy was a student at University of Cincinnati Designation Christopher Anthony Guy has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 8/2024 ** Please see Minimum Qualifications Required below Disciplinary Information Christopher Anthony Guy has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Christopher Anthony Guy is not engaged in any other investment related activities. 2. Christopher Anthony Guy does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Christopher Anthony Guy is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Christopher Anthony Guy does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 32  Full Legal Name DERRICK KIHEMBO Born 1994 Education The Johns Hopkins University B.S., Economics 2016 Business Experience Bahl & Gaynor, Inc.; Associate Portfolio Manager & Senior Trader; from 6/01/2018 to current Designation Derrick Kihembo has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 2/2022 * Please see Minimum Qualifications Required below Disciplinary Information Derrick Kihembo has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Derrick Kihembo is not engaged in any other investment related activities. 2. Derrick Kihembo does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Derrick Kihembo is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Derrick Kihembo does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 33  Full Legal Name SHANE RISHAUN FARMER Born 1997 Education University of Cincinnati College of Business BBA, Finance, 2022 Business Experience Bahl & Gaynor, Inc.; Wealth Management Analyst; from 02/17/2023 to current Apple Inc.; from 5/2017 to 2/2023 Prior to 2017 Shane Rishaun Farmer was a student at University of Cincinnati Disciplinary Information Shane Rishaun Farmer has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Shane Rishaun Farmer is not engaged in any other investment related activities. 2. Shane Rishaun Farmer does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Shane Rishaun Farmer is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Shane Rishaun Farmer does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 34  Full Legal Name MARY KATHERINE WALSH Born 1999 Education University of Cincinnati, BBA, Finance, 2022 University of Cincinnati, MS, Marketing, 2023 Business Experience Bahl & Gaynor, Inc.; Wealth Management Analyst; from 08/14/2023 to current Prior to 8/2023 Mary Katherine Walsh was a student at University of Cincinnati Disciplinary Information Mary Katherine Walsh has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Mary Katherine Walsh is not engaged in any other investment related activities. 2. Mary Katherine Walsh does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Mary Katherine Walsh is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Mary Katherine Walsh does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 35  Full Legal Name JOHN WILLIAM LANGENDERFER Born 1999 Education The Ohio State University, Max M. Fisher College of Business, BBA, Finance, 2023 Business Experience Bahl & Gaynor, Inc.; Wealth Management Analyst; from 08/14/2023 to current Prior to 8/2023 John William Langenderfer was a student at The Ohio State University Disciplinary Information John William Langenderfer has no reportable disciplinary history. Other Business Activities A. Investment Related Activities John William Langenderfer is not engaged in any other investment related activities. 2. John William Langenderfer does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. John William Langenderfer is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation John William Langenderfer does not receive any economic benefit from a non- advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 36  Full Legal Name WESLEY ANN ALSPAUGH Born 2001 Education University of Cincinnati, BBA, Accounting, 2023 University of Cincinnati, Certificate, Business Analytics, 2023 University of Cincinnati, MS, Finance, 2024 Business Experience Bahl & Gaynor, Inc.; Wealth Management Analyst; from 01/22/2024 to current Prior to 01/2024 Wesley Ann Alspaugh was a student at University of Cincinnati Disciplinary Information Wesley Ann Alspaugh has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Wesley Ann Alspaugh is not engaged in any other investment related activities. 2. Wesley Ann Alspaugh does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Wesley Ann Alspaugh is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Wesley Ann Alspaugh does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 37  Full Legal Name KATHERINE HELEN KOBER Born 1995 Education Georgetown University BSBA, Finance & Accounting, 2017 Business Experience Bahl & Gaynor, Inc.; Portfolio Analyst from 12/2021 to current Blue Owl Capital (formerly known as Dyal Capital): Associate from 2/2020 to 9/2021 J.P. Morgan Chase: Analyst from 6/2017-2/2020 Designation Katherine Helen Kober has earned the following designation and is in good standing with the granting authority. CFA®; Institute of Chartered Financial Analyst; 7/2022 * Please see Minimum Qualifications Required below Disciplinary Information Katherine Helen Kober has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Katherine Helen Kober is not engaged in any other investment related activities. 2. Katherine Helen Kober does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Katherine Helen Kober is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Katherine Helen Kober does not receive any economic benefit from a non-advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 38  Full Legal Name KRISTEN ELIZABETH ANKENBAUER Born 1983 Education Bowling Green State University, B.A., Economics, Political Science, 2005 Business Experience Bahl & Gaynor, Inc.; Senior Portfolio Manager; 1/2025 to current U.S. Bank Private Wealth Management: Senior VP, Private Wealth Advisor & Consultant from 5/2017 to 12/2024 Designation Kristen Elizabeth Ankenbauer has earned the following designation and is in good standing with the granting authority. CFP®; College of Financial Planning™; 7/2019 ** Please see Minimum Qualifications Required below Disciplinary Information Kristen Elizabeth Ankenbauer has no reportable disciplinary history. Other Business Activities A. Investment Related Activities 1. Kristen Elizabeth Ankenbauer is not engaged in any other investment related activities. 2. Kristen Elizabeth Ankenbauer does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non-Investment Related Activities 1. Kristen Elizabeth Ankenbauer is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Additional Compensation Kristen Elizabeth Ankenbauer does not receive any economic benefit from a non- advisory client for the provision of advisory services. All Bahl & Gaynor financial professionals who meet their goals are eligible to participate in an equity program. 39  Supervision of Firm Supervisor & Title: Robert S. Groenke, Chief Executive Officer& President Phone Number: 513-287-6100 Bahl & Gaynor provides supervisory services in accordance with its Compliance Policies and Procedures Manual. These policies and procedures are designed to comply with the supervision requirements under Section 203(e)(6) of the Advisers Act. The Chief Compliance Officer oversees their implementation and can be reached at 513-287-6118. Robert S. Groenke is responsible for overseeing the company’s and business practices. Jenelle M. Armstrong, Chief Administrative Officer, manages staff-related matters, while Tita A. Rogers, IACCP®, Chief Compliance Officer, oversees the Code of Ethics, Investment Policies, Review Processes, Conflicts, and Risk Assessments. Mrs. Armstrong and Mrs. Rogers report any concerns or risks to Mr. Groenke, who has supervisory responsibility for all investment and executive employees. Above Business Experience is for the most recent 5 years. * CFA - Minimum Qualifications Required The CHARTERED FINANCIAL ANALYST, CFA® charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. ** CFP - Minimum Qualifications Required The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have obtained CFP® certification in the United States. • • To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; 40  • • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. *** CLU - Minimum Qualifications Required The CHARTER LIFE UNDERWRITER®, CLU® is a financial professional with extensive knowledge of life insurance. The American College of Financial Services is an accredited non-profit educational institution founded in 1927. It has the highest level of educational accreditation —regional accreditation—through the Middle States Commission on Higher Education. The college has a full-time faculty of industry experts and is one of the leading educators of financial professionals in the United States. To earn the CLU, individuals must complete five core courses plus three elective courses and pass eight 100- question, two-hour examinations. Required course titles include Fundamentals of Insurance Planning, Individual Life Insurance, Life Insurance Law, Fundamentals of Estate Planning and Planning for Business Owners and Professionals.1 Other course topics include financial planning, health insurance, income taxation, group benefits, investments, and retirement planning. A Chartered Life Underwriter must adhere to The American College of Financial Services’ Code of Ethics, which includes the following professional pledge: “I shall, in light of all conditions surrounding those I serve, which I shall make every conscientious effort to ascertain and understand, render that service which, in the same circumstances, I would apply to myself.” Furthermore, maintaining the designation requires 30 hours of continuing education every two years, and the designation may be removed for unethical conduct through the certification committee of The American College’s Board of Trustees. ****IACCP – Minimum Qualifications Required INVESTMENT ADVISOR CERTIFIED COMPLIANCE PROFESSIONAL, IACCP® The first industry designation of its kind, the Investment Adviser Certified Compliance Professional (IACCP®), was developed by the Center for Compliance Professionals, the education and professional development division of National Regulatory Services (NRS), a resource closely in tune with the changing complexity of the financial securities compliance profession and provider of compliance education for over 20 years. The IACCP® is awarded to knowledgeable, experienced individuals who complete an instructor-led program of face-to-face and online study, pass a certifying examination, and meet work experience, ethics and continuing education requirements. The designation signifies knowledge of investment adviser regulation and compliance best practice, and adherence to national recognized professional standards and ethical leadership. Exhaustive certification and course development, together with expert instructors and facilitators from the compliance, legal, regulatory, industry, and academic sectors, help ensure that individuals earning the IACCP® designation have been trained, tested and certified to meet high industry professional standards. IACCP® is a certification owned by the Investment Adviser Compliance Certificate Program®. This certification is awarded to individuals who successfully complete the program's initial and ongoing certification requirements. 41