Tom Johnson Investment Management, LLC

Tom Johnson Investment Management, LLC Tom Johnson Investment Management, LLC 201 Robert S. Kerr Ave, Suite 510 Oklahoma City, OK 73102-4202 Telephone # (405) 236-2111 www.tjim.com April 2026 Welcome to TJIM. We thank you for considering our investment services. This brochure provides information about the qualifications and business practices of Tom Johnson Investment Management, LLC. If you have any questions about the contents of this brochure, please contact us at (405) 236-2111 or at www.tjim.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. Additional information about Tom Johnson Investment Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. We request that you avoid discussing account matters via text message due to industry regulations. Please reach out to us using the contact information above. Thank you again and we look forward to the opportunity to work with you in the near future. 1  Tom Johnson Investment Management, LLC Material Changes April 2026 Bimini Capital Management, Inc. (OTCQX:BMNM) on April 1, 2026 announced that its wholly owned subsidiary, Bimini Advisors Holdings, LLC, has completed the purchase of eighty percent (80%) of the fully diluted equity interests of Tom Johnson Investment Management, LLC (“TJIM”), a privately held registered investment adviser. Bimini Capital Management, Inc. and Tom Johnson Investment Management, LLC are affiliated through common ownership and control. Although the firms are under common ownership, they operate independently and do not share client fees, clients, or confidential client information. We will provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Our Brochure may be requested by contacting our office at (405) 236-2111 or by contacting Lori Calfy via email at lcalfy@tjim.com. This Brochure is also available free of charge on our web site www.tjim.com. Additional information about TJIM is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with TJIM who are required to be registered as investment adviser representatives of TJIM. 2  Tom Johnson Investment Management, LLC Table of Contents Item Page 1 2 3 4 7 8 8 8 14 14 1. Cover Page …………………………………………………………….………. 2. Material Changes ……………………………………………………………. 3. Table of Contents …………………………………………………………… 4. Advisory Business …………………………………………………………… 5. Fees and Compensation ………………………………………………….. 6. Performance-Based Fees and Side-By-Side Management ……. 7. Types of Clients ………………………………………………………………. 8. Methods of Analysis, Investment Strategies and Risk of Loss.. 9. Disciplinary Information …………………………………………………… 10. Other Financial Industry Activities and Affiliations ………………. 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ……………….………… 12. Brokerage Practices ………………………………………………………… 13. Review of Accounts …………………………………………………….…… 14. Client Referrals and Other Compensation ………………………….. 15. Custody …………………………………………………………………………. 16. Investment Discretion ……………………………………………………… 17. Voting Client Securities ……………………………………………………. 18. Financial Information …………………………….………………………… 15 15 17 18 18 18 19 19 Part 2 B – Investment Adviser Brochure Supplement ……………….. 20 TJIM’s Client Privacy Policy ……………………………………………………. 25 3  Item 4: Advisory Business Tom Johnson Investment Management, Inc., was founded in 1983 and is based in Oklahoma City, Oklahoma. Prior to the firm’s formation, several of the investment and administrative staff worked together at an Oklahoma bank’s Trust Department. In 1992 the firm's principals sold the company to United Asset Management (UAM). In 2000, UAM was acquired by Old Mutual, plc. In April of 2003, one of the principals, Richard H. Parry, bought back the company. In 2010, the firm was reorganized from a corporation to an LLC for tax purposes. Tom Johnson Investment Management, LLC (TJIM), is a registered Oklahoma Limited Liability Company. In April 2026, Bimini Advisors Holdings, LLC, a wholly owned subsidiary of Bimini Capital Management, Inc. (OTCQX: BMNM), purchased 80% of the fully diluted equity interests of Tom Johnson Investment Management, LLC (“TJIM”). Investment Services TJIM offers investment services to a broad range of clients, such as pension, profit sharing and 401(K) plans, individual taxable, individual retirement accounts (IRA), foundations, banks, insurance companies, public funds, corporations, and sovereign funds. TJIM is a fee-only advisor with a fiduciary duty to provide prudent investment advice to its clients. TJIM does not accept fees or compensation based on product sales. TJIM does not have custody or possession of securities or cash of any client. Clients use institutions such as banks and brokerage firms to perform the custodial duties. The client grants TJIM permission to trade in their custodial account. This provides control between the client, custodian, and investment manager to safeguard the client’s assets. Clients who are not associated with a broker/advisor may give TJIM authority regarding client directed withdrawal instructions to their custodian for a distribution to a third-party account. Such authority requires a documented standing letter of instruction signed by the client. This “transaction account” is subject to all the rules of SEC Regulation S-ID. TJIM is responsible for decisions and recommendations as to asset allocation and security selection. TJIM may also be responsible for executing transactions and reviewing the results with the custodian. In addition, TJIM may provide risk tolerance determination, diversification, asset allocation, and mutual fund selection services for a fee to clients. In such cases, separate account management may not be advisable for some of the client’s accounts given unique characteristics or issues such as asset size, or inherited low cost-basis assets that already exist in the portfolio. TJIM provides investment management services through 4 different channels. The chart below is a general summary of the differences and description of each channel. TJIM Investment Management Services to Client by Channel Investment Management in a Wrap-Fee Program Investment Management as a Sub Advisor to a Sponsor Program Investment Advisory and Management Investment Model Programs Services TJIM Contract Signed By Client Client Sponsor Program Sponsor Program TJIM TJIM TJIM TJIM Model Portfolio Management Responsibility Trade Execution Responsibility TJIM TJIM TJIM Sponsor Program TJIM TJIM Sponsor Program Sponsor Program Client Reporting & Performance Measurement TJIM Investment Fee Direct to Client Embedded in program fee Embedded in program fee Direct or may be embedded in program fee 4  TJIM Participation in “Wrap-Fee” Programs TJIM participates in wrap-fee programs on both an advisor and sub-advisor basis. TJIM’s management of accounts in these programs is the same as the management of an account not in a wrap- fee program. The wrap-fee charged by a program may include a portion that is paid to TJIM for our investment management services. Wrap-fee charges may include such other services as: investment management, consulting, trade execution, performance measurement, client reporting and custody. TJIM Participation in Model Portfolio Programs TJIM has contractual agreements to provide model portfolios for use in sponsors’ sub-advised programs. TJIM does not have individual account management responsibilities. These sponsors are responsible for determining account suitability, trade discretion and executions and for Form 13F filings. TJIM is compensated by the sponsors according to assets in the TJIM model portfolios. Investment Services to Meet the Needs of Clients Clients, with the assistance of TJIM or financial advisor, should determine their asset allocation income and growth requirements risk tolerance based on: • • • unique circumstances  time horizon  tax implications • liquidity needs Based on the above considerations, clients give TJIM asset allocation parameters to manage portfolios. Additional client requested guidelines may also be required in the management of a specific portfolio. Examples of these are coordination with other assets, quality ratings, issuer size, issue size, yield, exclusion of certain types of business or products. Portfolios under TJIM care, whether they are equity, balanced or fixed, are managed by a team. The accompanying chart illustrates this investment process. Four Step Process 1. Identify Objectives 4. Review Process 3. Investment Evaluation & Selection 2. Strategy/Asset Allocation 5  For control purposes, our investment compliance committee reviews with frequency investment performance, asset allocation, trades to implement model changes, quality ratings, security level deviation from model holdings and account restrictions to ensure compliance with client and TJIM guidelines. Portfolio managers, when reviewing client accounts under their care, consider such matters as: • Is the portfolio structured to meet the investment objective? • Is the investment objective still suitable for the client? • Are the policies and procedures of the client being followed? While accounts adhering to a specific style or model are managed to be homogenous, they may vary in individual holdings and weights due to deposit or withdrawal timing, tax implications, individual account restrictions, inherited positions, account size or rounding. TJIM Additional Services Financial Planning TJIM assists some clients with financial planning services, which can include the following: • Department of Labor (DoL) Fiduciary acknowledgement when providing investment advice to retirement investors with a SWOT analysis of potential IRA rollovers Income planning and budgeting • Asset allocation planning • Tax planning • Efficient gifting • Social Security planning • Efficient retirement distribution strategies • • Analysis using financial planning software Reporting Services TJIM offers reporting services for those clients who want to supervise and direct their own portfolios but do not have the resources to maintain the data. Our reporting capability provides information: • For tax reporting • To assess investment characteristics • To address documentation and control Portfolio Reporting Portfolio reporting provides annual, quarterly and/or monthly information. Reports include: • Realized gain/loss • Tax lots • Transaction history • Investment performance Portfolio composition capable of being sorted alphabetically, by industry, market value, unrealized appreciation and/or yield Fixed Income Portfolio Analysis For fixed income investors, a unique analysis for examining the investor’s holdings and risk level is provided. This may be particularly useful for those who maintain custody accounts with a variety of institutions. Reports contain individual securities and aggregate portfolio statistics as well as the range and structure of such key fixed income variables as: • Duration • Quality • Cash flow • Callability • Maturity • Yield • Taxability • Diversification Such a report enables an investor to assess risk and return on a security level and on an aggregate basis. TJIM Portfolio Managers are available to meet with clients to explain the reports, make portfolio suggestions, and to address questions. 6  TJIM Assets Under Management As of 12/31/2025, TJIM’s Regulatory Assets under Management: $1,632,586,982 The TJIM Regulatory Assets Under Management (AUM) amount identified above is calculated according to SEC Form ADV instructions for Item 5.F: “Calculating Your Regulatory Assets Under Management”. Item 5.F. defines Regulatory Assets Under Management to include “securities portfolios for which you provide continuous and regular supervisory or management services”, therefore we include all accounts for which we have access to the underlying portfolio of securities, and we build the trades for the specific account. We do not include accounts for which we do not build the trades for the account but rather set a “model” target percentage position and the underlying account is not monitored by TJIM. This creates a distinction where some Unified Managed Accounts (UMA) are included in AUM and others are excluded. We exclude UMA portfolios where we do not monitor the underlying portfolio, and we include UMA portfolios where we monitor and trade the underlying portfolios. Assets Under Supervision (UMA equity model) $17,102,986 Item 5: Fees and Compensation Explanation of Services and Fees TJIM Standard Fee Schedule: Fees are charged at calendar quarter intervals in arrears based upon the following fee schedule: 1.00% annually of the first $1,000,000 market value .75% of the next $4,000,000 market value .60% of the next $5,000,000 market value .50% of the next $15,000,000 market value .45% of the next $25,000,000 market value .40% of the next $50,000,000 market value Over $100,000,000 is quoted upon request. Fees may be further negotiated, depending upon a variety of variables. Investment fees are calculated on a calendar quarter based upon the market value of the assets, including cash, and excluding accrued income, at the close of the quarter. TJIM fees are charged in arrears. Clients may utilize additional services which could result in a negotiated fee. There are circumstances where a percentage of assets charge does not make economic sense due to the request by a client for advice on securities, asset allocation and portfolios not included in assets under management at TJIM. In such circumstances, TJIM and the client will determine in writing an hourly or fixed charge for such research and recommendation. Clients in model and wrap programs should be aware of the fees charged which are disclosed in the program client agreement(s). Billing Procedures A client not in a wrap-fee program may be billed directly for TJIM’s fee or may have the fee debited from their custodial account. If the client elects to have the fee debited, they must give their authorization to the custodian. TJIM will send to the client a copy of the fee calculation and the amount to be debited. Other Types of Fees Mutual Funds, Exchange Traded Funds, Cash Sweep Vehicles The client will select a brokerage firm or bank as the custodian. The custodian is responsible for investing cash reserves that are not invested by TJIM and may provide short-term cash vehicles and sweep options from which clientele can choose. The custodian may charge a fee that is embedded in the cash vehicle’s interest rate and might not be disclosed on custodial statements. Any such charges by the custodian are separate from TJIM's fees. Depending on the custodian there may be a periodic account 7  fee charged by the custodian. Custodian fees may also be charged to the client for transaction costs, account maintenance and cash/security requests. Clients who have directed TJIM to hold mutual funds will incur expenses associated with the fund. While TJIM primarily invests in individual equity securities with no additional fees, at times we may determine that it is in the client's best interest to purchase Exchange Traded Funds (ETFs) that have an additional fee. If TJIM decides to add additional asset class exposure through purchase of an investment fund, we will focus on finding a low effective cost fund, factoring in expense ratio, discount to NAV, and uniqueness of exposure. Investment Fees May Be Paid in Advance At the request of the client or wrap program, we may receive quarterly fees in advance. When an account's inception or termination occurs during a calendar quarter, fees are prorated according to the number of days for which we provided our management service. For terminating accounts which have prepaid fees, fees are refunded on a prorated basis. Compensation for Sale or Purchase of Securities Neither TJIM nor any of its supervised persons receive compensation for the sale or purchase of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. TJIM is not affiliated with any brokerage firm. Item 6: Performance-Based Fees and Side-By-Side Management TJIM does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7: Types of Clients TJIM has and can provide investment services to a broad range of clients, such as Individuals Foundations Bank Trust Dept (Common Funds) Corporations Individual Retirement Accounts (IRA) Pensions Profit Sharing Plans Insurance Companies Public Funds Sovereign Funds 401(K) Plans Item 8: Methods of Analysis, Investment Strategies and Risk of Loss TJIM has a conservative philosophy for the investing of client assets. TJIM believes that attractive risk-adjusted performance is best achieved by building a prudent, well-diversified, high-quality portfolio that addresses capital preservation and risk. TJIM’s over-riding goal is to provide good returns in up markets while protecting wealth when down markets inevitably occur, which should lead to outperformance over a full market cycle. Clients should be aware of the following risk factors: equity risk, market risk, manager risk, liquidity risk, interest rate risk, purchasing power risk, credit risk, asset allocation risk. There will also be secondary risk exposure to non-US investment risk, call risk, and investment grade downgrade risk. Diversification does not protect against losses. There is a risk of loss inherent in any investment. Past performance does not guarantee future results. TJIM Investment Process Our team builds fixed income, equity, balanced and asset allocation portfolios. Our research is a blend of economic, earnings, and credit analysis which uncovers interesting opportunities. For example, fixed income price improvement specific to one security has in some circumstances been an early 8  indicator of a credit problem resolution with eventual earnings and stock price improvement. Likewise, fixed income price deterioration can be an early indicator of an eventual equity decline. Our process is disciplined. When constructing our equity portfolios, we have always maintained a respect for diversification and valuation standards. Our focus is to provide attractive returns with less risk over a market cycle. Regarding fixed income portfolio construction, we strive to optimally balance risk, return, yield, and liquidity by managing duration, quality, structure, and sector selection. In our fixed income and equity portfolios, we only buy high-quality individual securities. Our asset allocation portfolios may utilize ETFs, open-ended or closed end funds to gain exposure to broadly diversified asset classes at low costs. This process is illustrated by the following charts. Equity Analysis Fixed Analysis 9  TJIM's stature as a boutique investment management firm along with our team-oriented approach provides clients with enhanced accessibility to the investment decision makers. This allows our investment process to be nimbler and more opportunistic than larger alternative business models. Investing in securities involves risk of loss that clients should be prepared to bear. EQUITY (STOCKS) The accompanying charts illustrate TJIM’s potential equity investment universe and examples of selected investment criteria. TJIM Core/Relative Value Stock Portfolio TJIM’s Core Equity approach adheres to the time-tested and market-weathered principles of diversification and valuation standards with a goal of providing favorable risk-adjusted returns over a market cycle. TJIM’s focus is on purchasing equity securities that have valuations lower than their peer group in industries that provide the best opportunity in the foreseeable future. Under normal circumstances, portfolios are managed with the following guidelines: Diversification • 5% max position size • Own at least 8 of 11 sectors • Max sector allocation of 2x the S&P Or 10%, whichever is larger Valuation • Aggregate Price/Earnings less than the market • Low price-to-cash flow • Low price-to-book • Sum-of-parts analysis Security Selection • Primarily large/mid cap companies • Rigorous fundamental analysis • Tactical macro-economic opportunities Risk Management • Favorable up/down capture • Unsystematic risk review • Historically lower standard deviation than the S&P 500 10  TJIM Diversified Stock Income Portfolio The primary goal of TJIM’s Diversified Stock Income (DSI) portfolio is to generate a stable and growing income stream by buying and managing a diversified portfolio of common stocks that pay or are expected to pay attractive dividends while factoring in future dividend growth. The portfolio has a secondary goal of appreciation. Under normal circumstances, portfolios are managed with the following guidelines: Diversification Valuation • Aggregate Price/Earnings less than the • 5% max position size • Own at least 8 of 11 sectors • Max sector allocation of 2x the S&P or market Low price-to-cash flow 10%, whichever is larger • • Sustainable and growing dividend • Sum-of-parts analysis Security Selection Risk Management • Favorable up/down capture • Unsystematic risk review • Historically lower standard deviation • Focus on dividend payers & growers • Rigorous fundamental analysis • Primarily large/mid companies • Tactical macro-economic opportunities than the S&P 500 11  Why Diversified Stock Income? There are multiple benefits to dividend focused investing-– increased income, reduced volatility, an income stream that grows over time, and better downside protection. While the portfolio was developed to generate a growing income stream and not necessarily to exploit any specific market inefficiency, by its nature it exploits the intersection of several related market inefficiencies--value anomaly, low volatility, dividends and dividend growth. FIXED INCOME (BONDS) The chart below is an example of the factors TJIM uses in building fixed income portfolios: Fixed Income Management TJIM’s fixed income strategies tactically balance total return, income generation, and capital preservation. Our firm’s conservative investment approach and a focus on maintaining liquidity at the individual account level establishes minimum quality parameters. Based on our best efforts at purchase, portfolio issues must have a category A (A3,A-,A-) or better rating by one of the major ratings agencies (Moody’s, S&P or Fitch). Of Note: We use our best efforts to identify an issue’s rating at time of purchase for our clients. Our best efforts include using an issue’s rating provided by Bloomberg or an equivalent information source available to us at the start of our business day. An issue rating can change at any time during the day. Our procedures are designed to alert us to a change, but we cannot guarantee we will be alerted to a change prior to purchase of an issue for a client’s account. TJIM’s investment team conducts quantitative and qualitative analysis of yield, quality, duration, and yield curve positioning to identify the most attractive sector(s) within our fixed income universe and the most attractive securities within each sector. Prior to any purchase, a review is done of the fundamentals of credit issuers that pass TJIM’s initial universe screening criteria to ensure adequate cash flow for bond repayment and to identify unsystematic risks that could signal a material risk to an issuer’s business. Bond issues that pass our rigorous initial analysis are recommended for portfolio models and subject to TJIM’s ongoing review process. At the portfolio level, TJIM’s investment team employs proprietary forecasting tools and scenario analysis models. This analysis identifies optimal portfolio structure and duration positioning relative to the underlying benchmark and provides a distribution of probable performance outcomes under different interest rate and economic environments. TJIM’s investment team combines the individual security analysis, portfolio structure modeling, and disciplined duration management to build a liquid, diversified portfolio of individual bonds that we believe is well positioned to outperform, and equally important, is designed to address client cash flow objectives. 12  TJIM Fixed Income Portfolio While we do not explicitly forecast interest rates, disciplined duration management is an important tool in our strategic risk-management process. TJIM typically maintains the TJIM Fixed Income Portfolio duration within 75% to 125% of the Bloomberg Government/Credit Index, which would imply a duration range of roughly 5.5 years to 9.5 years. TJIM will generally have a higher duration than the index when we anticipate lower interest rates and a lower duration when we anticipate higher rates. The objective of this strategy is to outperform the Bloomberg Government/Credit Index over a business cycle while providing disciplined risk management. TJIM Intermediate Fixed Income Portfolio While we do not explicitly forecast interest rates, disciplined duration management is an important tool in our strategic risk management process. TJIM typically maintains the TJIM Intermediate Fixed Income Portfolio duration within 75% to 125% of the Bloomberg Intermediate Government/Credit Index, which would imply a duration range of roughly 3 years to 5.25 years. TJIM will generally have a higher duration than the index when we anticipate lower interest rates and a lower duration when we anticipate higher rates. TJIM limits maturities in this portfolio to a maximum of 10 years, which is consistent with the underlying benchmark. The objective of this strategy is to outperform the Bloomberg Intermediate Government/Credit Index over a business cycle while providing disciplined risk management. The above two portfolios participate in the universe shaded below. TJIM Tax Exempt Fixed Income Portfolio TJIM’s goal is to maximize tax-free income while conserving capital, with a secondary objective of obtaining satisfactory total return. Given our conservative philosophy, issues must have a category A or better rating by one of the rating agencies at purchase date. The average maturity of the portfolio will not exceed 15 years. These portfolios are very client specific in respect to state, tax status, and monthly income needs. Thus, the dispersion of holdings and returns across portfolios is likely to be greater than the dispersion of our other fixed income portfolios. The accompanying charts illustrate TJIM’s tax-exempt investment universe and our preferred investment criteria. The above portfolio participates in the universe shaded below. 13  BLOOMBERG MUNICIPAL INDEX COMPONENTS TJIM MUNICIPAL UNIVERSE General Obligations Revenue Bonds AAA - Insured Pre-Refunded AAA – A- AAA – A- Underlying AAA – A- AAA – A- BBB +/- BBB /- BBB +/- Underlying BBB +/- TJIM Short Term Income Portfolio TJIM’s goal for this strategy is to maximize income within capital preservation and high liquidity parameters. The portfolio will consist of a portfolio of high-quality liquid securities with limits to maturities of 3 years. The objective of this strategy is to maximize income within risk/return parameters that will minimize price volatility and result in minimal risk of realized losses. The portfolio will generally be invested in a mix of US Treasury securities, US agency securities, and corporate bonds with an A or better rating. TJIM Balanced Portfolio All of TJIM’s investment expertise comes together in our balanced strategy. A blend of equities and fixed income in the same portfolio provides significant diversification benefits while easily allowing rebalancing between stocks and bonds over time. The objective of TJIM’s balanced strategy is to provide attractive returns while reducing the risk of a pure equity portfolio and generating a stable and growing income stream. TJIM’s default portfolio is 60% Core Equity and 40% Fixed Income. However, the portfolio can be tailored to meet individual needs by adjusting the asset allocation or using the more income-oriented Diversified Stock Income (DSI) and a fixed income portfolio. TJIM Asset Allocation Portfolios In certain instances where individual securities don’t make economic sense due to size, trading costs, frequent cash flows, or diversification needs TJIM has developed multiple models of varying risk tolerance that utilize ETFs across differing asset classes. Item 9: Disciplinary Information As a registered investment advisor, TJIM is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of TJIM or the integrity of TJIM’s investment management. Since the inception of the firm in 1983, neither TJIM nor any of its investment advisory personnel have ever been the subject of disciplinary or legal action. Item 10: Other Financial Industry Activities and Affiliations We are affiliated with Bimini Advisors, LLC through common ownership and control. Although these firms are under common ownership, they operate independently and do not share client fees, clients, or confidential client information. Clients are under no obligation to use the services of Bimini Advisors, LLC. 14  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading TJIM Code of Ethics TJIM has a fiduciary duty to its investment clients to act solely for their benefit. Therefore, it has adopted a Code of Ethics (“Code”) designed to avoid potential conflicts of interest and to prevent any conduct in breach of this duty. Accordingly, TJIM will distribute a copy of the Code to each person who is or becomes an employee of the firm. TJIM employees are required to review and acknowledge receipt of the Code. Clients or prospective clients may request a copy of TJIM’s Code of Ethics by contacting the firm at www.tjim.com. It is the policy of TJIM to establish such rules and guidelines of conduct to prevent actual or potential conflicts, and to prevent any violations of legal or other duties to clients. TJIM’s Code of Ethics covers the following: • Restrictions on securities transactions by employee • Pre-clearance of personal securities transactions • Reporting requirements • Other conflicts of interest: use of inside information, use of gifts and sensitive payments • Other prohibited transactions • Background information of “advisory affiliates” • Review of reports and oversight of the Code of Ethics Participation or Interest in Client Transactions TJIM and employees of TJIM may be active in securities owned in client accounts. However, in doing so they must observe the guidelines stated in the Code of Ethics adopted by TJIM and acknowledged by the employee. TJIM maintains a Code of Ethics and a restricted securities list to comply with our responsibility to give the interest of client priority over personal transactions. TJIM’s Code of Ethics does not allow employees of the firm to engage in principal or agency trading. Compliance is monitored by reviewing employee custodial statements. Item 12: Brokerage Practices Recommending Broker/Dealers for Client Transactions For accounts in which TJIM is given full discretion over the broker to be used, brokers are evaluated on such criteria as: • Execution quality • Commission costs • Contact and service • Trade Away Capability Research and Other Soft Dollar Benefits Currently TJIM has no formal or informal arrangements in place with brokerage firms with regards to the amount of commission business TJIM should direct to them for research or other benefits. Brokerage for Client Referrals From time to time, registered representatives of brokerage firms may refer one or more of their established clients to TJIM and the account may direct TJIM to use the referring brokerage firm in connection with the execution of the client's trades. Directed Relationships Expense rates (commissions, wrap fee, and money market sweep vehicle expenses) for many of our clients are determined by the client's existing association with an adviser, consultant, or brokerage 15  platform and/or their particular representative (i.e., broker, investment consultant, financial planner). In most cases, these institutions perform a variety of services such as custody, manager search and selection, performance monitoring and appraisal, evaluation of conformity with investment policies and financial planning exercises. The client and the representative negotiate a fee based upon the services rendered. When a client selects TJIM and desires to also be on such consultant or brokerage platforms, TJIM may be unable to further negotiate trading expenses, obtain volume discounts or achieve best execution. Under these circumstances, a disparity in net trading outcomes may exist between what is achieved for clients who direct TJIM to use a particular platform and those who do not. Trading and Allocation The goal of TJIM's trading department is to minimize the trading price differential between accounts in order to minimize performance dispersion, thus minimizing market impact and obtaining the best price available given the specific trade circumstances. As a fiduciary to each client, TJIM owes each client the same duty of loyalty. Consistent with this duty, TJIM does not give one client or a group of clients’ preference over others. This is particularly true when we trade the same security for several client accounts. However, it is generally not possible to execute all trades in the same security for all client accounts simultaneously. TJIM has developed appropriate, predetermined allocation procedures to minimize the risk that any particular client would be systematically advantaged or disadvantaged by the aggregation or allocation of orders and to promote fairness and equity for all clients. TJIM utilizes a random selection process for determining trade order. In addition to this process, TJIM also takes into consideration best execution factors including execution capability of brokers, market efficiency, and issue liquidity. The TJIM’s trading desk initiates trades in random order based on a random selection process for discretionary clients and notifies “model portfolio” platforms that execute their own trades at their appropriate “turn” based on the outcome of random order selection. This process provides clients equitable treatment while also working to achieve the best execution on actual trades. The TJIM Compliance Committee reviews the results of this process to ensure equitable treatment. Once TJIM's Investment Committee makes a portfolio decision, the trading department is responsible for generating the orders across all accounts, printing tickets, randomizing trades, and executing trades. With the exception of partial fills, all TJIM's allocations are done prior to the actual trade taking place. This process alleviates the issue of trades being allocated to client accounts after a gain/loss is known. Partial fills, though very rare, may occur. In this instance TJIM will allocate trades on a pro-rata basis for wrap accounts but may not allocate pro-rata to commission accounts to avoid paying an extra commission. For partial fills with commission accounts, TJIM will typically allocate the trade to spread the fill across as many accounts as possible. Partial fills for bond trades may not be feasibly allocated pro-rata due to minimum piece/minimum increment trading restrictions on certain bonds (e.g., many corporate bonds have a 2,000 minimum piece/1,000 minimum increment). In these instances, TJIM may use random allocation if it is deemed the fairest method to allocate a partial fill across accounts. TJIM will typically aggregate trade orders for a client with those of one or more other clients if it is deemed appropriate to do so and if such aggregation is consistent with both TJIM’s duty to seek best execution for its clients, as well as the terms of the firm’s investment advisory agreement with its clients. It should be noted however, that TJIM’s decision not to or failure to aggregate orders does not violate its duty of best execution or its duty to allocate trade opportunities fairly and equitably. When trade orders of clients are aggregated, the actual prices applicable to the aggregated orders are generally averaged, and all participating accounts are deemed to have purchased or sold their respective shares of the security involved at such average price. TJIM's trading department has the responsibility of implementing all investment committee decisions in a manner most advantageous to our clients. Technological and operational improvements have made the execution process more efficient. However, it is still our opinion that each investment decision and the resulting securities transactions must be treated as a dynamic and unique occurrence. Although the automation and real time data provides improved measurement and response capabilities, it 16  is the overall experience and competence of our trading department that ensures TJIM clients receive optimal trade execution. Where TJIM has full discretion, fixed income trades are executed on a net basis. Bids and offers are gathered from competing firms and are executed when the levels offered are in-line with TJIM’s trading department’s expectations. With respect to the execution of over-the-counter equity trades, it is generally the policy of TJIM to execute those trades at best all-in-cost to the client for the securities involved. Additionally, as part of TJIM’s effort to seek best execution for our clients, we may aggregate orders to facilitate trades. Principal or Agency Cross Securities Transactions TJIM will never act as principal in client trades, meaning we will never buy or sell securities directly to or from client accounts. TJIM does not initiate cross trading of securities between client accounts. Trade-Aways for Wrap Sponsor Fixed Income Accounts TJIM may trade-away fixed income from a wrap sponsor when we believe we can receive better executions. TJIM has two types of trades: (1) “Across the Board” trades, which are trades that are executed for essentially every account within that style due to a team decision to buy or sell a certain security, and (2) individual trades that happen for individual accounts due to opening, closing, withdrawals, deposits, taxes, or other account specific issues. Individual trades are typically traded with the sponsor trading desk under the wrap arrangement. “Across the Board” trades are sometimes traded away from the sponsor desk in an effort to achieve better execution. Trade aways or “step-out” trades will likely entail an undisclosed mark-up or mark-down not covered by the wrap agreement, however it is TJIM’s intent to only trade away when the all-in execution quality (considering both speed and price) is better to that provided by the sponsor desk. TJIM generally will only trade away when there isn’t an explicit cost charged by the custodian or sponsor, except in the case of municipal securities, where bonds are often only available with one source, and a trade away is necessary to obtain those bonds. Trade Error & Corrections TJIM has established error correction procedures which provide that the resolution of all errors be made consistent with TJIM’s fiduciary duties. TJIM’s general policy is to resolve all errors impacting client accounts so that, to the extent possible, affected accounts are restored to the condition they would have been in had the error not occurred. Item 13: Review of Accounts See TJIM’s client account review under Item 4. Advisory Business, Investment Services to Meet the Needs of Clients. Portfolio Reporting to Investment Advisory & Management Clients: Clients are furnished the following quarterly (or monthly upon request) reports detailing their specific account: • Security holdings arranged by asset category and industry classification, including cost and market value, percentage breakdown, and yield. • A chronological transaction history detailing purchases and sales, income received and cash flow • A year-to-date realized capital gain/loss schedule • A summary of performance including total and sector returns compared to the applicable benchmark of the performance style. (Equity and fixed income sector performance will reflect only the equity or fixed securities’ performance, it will not include any cash allocation. TJIM’s discretionary cash decisions are reflected only in the total portfolio return. A blended equity and fixed income index may not necessarily be reflective of an accounts’ asset allocation history.) • Quarterly an investment commentary reviewing the last quarter and discussing the current economic and investment environment. This commentary is also available to clients on the TJIM website (www.tjim.com). 17  Item 14: Client Referrals and Other Compensation Referral Arrangement TJIM does not have any agreements for client referrals or compensation. Other Compensation As a fiduciary, TJIM must act in each client’s best interest. TJIM may recommend and/or clients/advisors may direct that a client custody their assets with a particular custodian. TJIM may have access to additional products and services. Such products and services may include economies of scale, software and other technology that provide access to client account data (such as trade confirmations and account statements), and/or facilitate trade execution such as allocation of aggregated trade orders for multiple client accounts, research, pricing information and other market data, payment facilitation of TJIM’s fees from its clients’ accounts, and assistance with back-office functions, recordkeeping and client reporting. Other services may be made available to TJIM to assist in managing and further developing its business enterprise. These services may include consulting, publications, and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. Custodian institutions may make available, arrange and /or pay for these types of services rendered to TJIM by independent third parties. They may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to TJIM. TJIM acknowledges that this arrangement may create a potential conflict of interest. Item 15: Custody TJIM does not have custody of client cash or securities. Selection of a custodian, either a bank or brokerage firm, to secure cash and securities is at the discretion of the client. This provides good control between the client, custodian and investment manager to safeguard the client’s assets. In some cases, TJIM may be given the authority to pass on client directed withdrawal instructions to a custodian for a distribution to a third-party account. Such authority requires a documented standing letter of instruction signed by the client. This “transaction account” is subject to all the rules of SEC Regulation S-ID. The client should receive at least quarterly statements from the custodian who holds and maintains the client’s investment assets. TJIM urges each client to carefully review and compare this official custodial record to the account statement that we may provide to you. Our statement may vary from the custodial statement based on accounting procedures, reporting dates or valuation methodologies of certain securities. TJIM’s internal procedures include reconciling custodian statements to our internal account data monthly. Item 16: Investment Discretion TJIM accepts discretionary authority to manage securities accounts on behalf of clients. This authority is granted to TJIM by the client through an executed limited power of attorney with the client’s selected custodian. When selecting securities and determining amounts, TJIM observes the investment policies, limitations, and restrictions of the clients for which it advises. Investment guidelines and restrictions are provided to TJIM through client meetings and/or written communications. Limitations on Investment Discretion Limitations on the authority of TJIM to determine without specific client consent the securities and amounts of securities to be bought and sold are imposed only by the established investment objectives, parameters, and restrictions of each individual client or by the state and local laws governing certain accounts. Each account is managed individually in accordance with its limitations. While most accounts have no limitations, some impose such limits as no foreign investments, dividend requirements, or percentage limitation on individual and industry holdings. Some accounts also set equity, fixed income, and cash equivalent parameters. 18  Other limitations are self-imposed by TJIM in the equity and fixed income portfolio model guidelines available for client selection, see Item 8. Methods of Analysis, Investment Strategies and Risk of Loss. Item17: Voting Client Securities – Proxy Voting Policy Proxies have economic value and must be voted in accord with the best investment interest, stated objective, and preferences if stated or known, of the investor, participant(s), or beneficiary(ies) of an account. As an investment advisor, we have the responsibility with respect to voting proxies unless such responsibilities are specifically and properly reserved to others (i.e., clients, custodians, trustees). To vote such proxies requires adequate examination of the underlying issues. Guidelines for major proxy-related issues have been adopted from Institutional Shareholder Services Inc. (ISS). Periodically, revisions will be made by select individuals on our investment staff dependent upon the unique circumstances at hand. Procedures 1. At which time new clients are accepted, it will be determined in the investment advisory agreement who has the voting proxy authority. This will be documented and properly coded in our new business organization form. Preferences stated by the investor, participant(s) or beneficiary(ies) are to be documented and easily referenced. 2. Maintain a record of stock held. 3. Correspond periodically and when appropriate with custodians to receive timely receipt of proxies. 4. Reconcile proxies received with the stock held on record date. 5. Maintain records of how proxies are voted and why. 6. Vote proxies in a timely manner and be reviewed by the investment compliance committee. Analysis of Proxies 1. Review of proxies is to be done normally by appropriate sector analyst. Proxy research is provided by Institutional Shareholder Services Inc. (ISS). 2. Specific proposals are evaluated against the history and productivity of current management as well as the conceptual reasons for or against the proposal. 3. Make written note of any deviation from any stated policy relating to specific issues. • TJIM security analysts may vote with the policies as noted below however they also have the choice to decline further incentives to directors, officers, and or employees based on their combined attitude about dilution impact, performance, and management of a particular company. Maintaining status quo and not diluting further the profitability or ownership structure does not require further notation by the analyst. • TJIM security analyst may vote with the ISS policies, however they also have the choice to consider if management’s efforts are sufficient (particularly in the areas of social responsibilities). Identifying efforts as sufficient does not require further notation by the analyst. 4. Make note of any contacts from plan sponsors or issuers with staff related to proxy voting functions and the actions taken. 5. Note any specific conflicts of interest and how handled. Clients may obtain a copy of TJIM’s complete proxy voting policies and procedures upon request. Clients may also obtain information from TJIM about how TJIM voted any proxies on behalf of their account(s). Item 18: Financial Information TJIM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Tom Johnson Investment Management, LLC 19  Part 2B – Item 1: Cover Page Investment Adviser Brochure Supplement April 2026 Supervised Persons: Richard H. Parry Douglas A. Haws Nicholas J. Pointer Cory J. Robinson Jeremy H. Wilcox Virginia (Jenny) A. Davis This Brochure Supplement provides information about the Firm’s Supervised Persons that supplements the Tom Johnson Investment Management, LLC (TJIM) Brochure. You should have received a copy of that Brochure. Please contact us via our web site www.tjim.com or contract Lori Calfy if you did not receive TJIM’s Brochure or if you have any questions about the contents of this supplement. Additional information about the Firm’s Supervised Persons is available on the SEC’s website at www.adviserinfo.sec.gov. 20  Item 2: Education Background and Business Experience Tom Johnson Investment Management LLC (TJIM) requires its portfolio managers to have a college degree and at least two (2) years of experience before they will be able to perform portfolio management duties. Portfolio Managers seeking to become full voting members of the investment committee will be encouraged to continue their education and to become Chartered Financial Analyst (CFA) charterholders. Portfolio managers are required to be registered Investment Advisor Representatives (IAR) of TJIM and to complete IAR Continuing Education requirements as directed by the Oklahoma Department of Securities. Please see below for the biographies of TJIM’s Investment Team professionals. Richard H. Parry, CFA – Mr. Parry has been the President and Chief Investment Officer of TJIM since 2003. He began his investment career in 1981, working with other TJIM principals in the Trust Investments department of First National Bank and Trust Company which later became First Investment Management Corporation (FIMCO), a subsidiary of First Interstate Bank of Oklahoma City. Other work experience includes being a member of the Executive Committee Planning and Advisory Staff in 1981 and Staff Auditor in 1980 for First National Bank and Trust Company of Oklahoma City. He received his Bachelor of Science Degree in Business from the University of Colorado with an emphasis in international business and his MBA from Oklahoma City University. He is a CFA® charterholder, past adjunct Professor for Oklahoma City University and past President of the Oklahoma Society of Financial Analysts. Currently, he serves on the Board of Directors for the Oklahoma Medical Research Foundation and has been a past board member for Oklahoma City University, Dean McGee Eye Institute Foundation, Economic Club of Oklahoma, and Rotary Club 29 Foundation. He is also a member of Rotary Club 29 of Oklahoma City, Economic Club of Oklahoma, The Fortune Club, Oklahoma City Estate Planning Council, and an alumnus of Leadership Oklahoma City. Douglas A. Haws, CFA – Vice President and Portfolio Manager. Mr. Haws joined Tom Johnson Investment Management, LLC in October 1994 as Trader and Investment Officer and became Vice President and Portfolio Manager in 1997. Prior to TJIM, Mr. Haws worked as an Internal Auditor for Union Pacific Corporation in Omaha, Nebraska. As staff auditor, his responsibilities included comprehensive audits of both the financial and operational aspects of all corporate subsidiaries. Mr. Haws received his BBA in Finance from the University of Oklahoma and his MBA in Finance from The Wharton School, University of Pennsylvania. He is a CFA® charterholder, past adjunct Professor at the University of Oklahoma and past President of the Oklahoma Society of Financial Analysts. Mr. Haws serves on the Board of Directors for Bridges, a non-profit organization dedicated to empowering homeless students to succeed, is a Deacon at Christ Church Norman and is a member of the Oklahoma Christian Student Investment Fund Advisory Board. Nicholas J. Pointer, CFA – Vice President, Portfolio Manager and Trader. Prior to joining Tom Johnson Investment Management, LLC in September 2011, Mr. Pointer worked as an Investment Analyst for Oklahoma Teachers Retirement System in Oklahoma City, OK. His responsibilities included portfolio allocation, and performance analysis and reporting. From 2008 to 2009, Mr. Pointer was a Financial Analyst for American Airlines in Dallas, TX. Mr. Pointer received his BA in Political Science from the University of Oklahoma and his MBA in Corporate Finance/Investment Management from the University of Oklahoma. He is a CFA® charterholder, has served as the Industry Mentor to students at the University of Oklahoma in the CFA Research Challenge, serves as the Red River Kidney Care Entity Independent Consumer Advocate and is a past adjunct Professor at Oklahoma City University. Cory J. Robinson, CFA, FRM - Vice President and Portfolio Manager. Prior to joining Tom Johnson Investment Management, LLC in June 2000, Mr. Robinson graduated from Oklahoma State University with a Bachelor of Science in Business Administration with a major in Finance and minors in Accounting and Management Information Systems. He is a CFA® charterholder and has received the FRM (Financial Risk Manager) designation from the Global Association of Risk Professionals. He is an officer of the CFA 21  Society of Oklahoma and has served as an industry mentor for the CFA Institute Research Challenge for both the University of Central Oklahoma and the University of Oklahoma. Jeremy H. Wilcox, CFA, CFP® – Vice President, Portfolio Manager and Trader. Prior to joining Tom Johnson Investment Management, LLC in September 2015, Mr. Wilcox graduated from Oklahoma State University with a Bachelor of Science in Business Administration with a major in Business Economics and Quantitative Studies and a minor in Finance. He is a CFA® charterholder and a CERTIFIED FINANCIAL PLANNER™ professional. He serves as a Trustee at Mayflower Congregational United Church of Christ. Virginia (Jenny) A. Davis – Trader and Portfolio Manager. Ms. Davis joined Tom Johnson Investment Management, LLC (TJIM) in April of 2019, having also worked for TJIM in the capacity of Trader and Compliance Administrator from 1999 to 2004. Between these TJIM employment time frames, Ms. Davis worked at her family-owned firm in an internal accounting capacity (Tripp Davis and Associates, a golf architectural firm). From 1996 to 1999, Ms. Davis was an Internal Wholesaler for Mid-America Partners, a third-party annuity marketing company. From 1992 to 1995, she worked in the Trust Department of Bank of Oklahoma. Ms. Davis earned her Bachelor of Science degree in Finance from Oklahoma State University. Ms. Davis is a non-voting member of the TJIM Investment Committee. Employee Transition Planning TJIM recognizes that our primary added value to our clients comes from the experience and efforts of our staff. Incentive packages are in place to address the needs of the employee and reward successful individual and team effort and results. Additionally, our team is very cognizant of the importance of laying a foundation for employee transition. We want to ensure that the workflow is motivating and that experience is passed on to new employees. We also have proactive plans in place to address approaching retirements as they arise. Wherever possible our approach involves a multi-year transition to address client service and retention sufficiently and successfully, and investment performance, which are the critical key result areas for our organization. This multi-year process may result in slowly increasing flexible office hours and a reduction in other responsibilities. An important part of our planning for investment personnel retirement is also identifying and hiring new members for our team. TJIM is aware of a broad talent pool of potential employees through industry contacts and through our internship program with local business schools. A new hire has either extensive investment analysis and portfolio management experience or has the educational credentials and work background which we believe indicate the potential to become a successful portfolio manager, trader, and investment analyst. The latter type of person typically starts with our firm as a trainee trader. Portfolio Managers seeking to become full voting members of the investment committee will be encouraged to continue their education and to become a Chartered Financial Analyst (CFA) charterholders. TJIM Commitment to Employees At TJIM, our commitment is to create a workplace that is both positive and productive for all our employees, regardless of their backgrounds or identities. We place a high value on treating everyone with dignity and respect, ensuring that all our employees have access to favorable benefit packages, and enabling them to participate in our profit-sharing arrangements. Our record of very low personnel turnover is a testament to the success of our corporate effort in this regard. In addition to our focus on creating an excellent work environment, we are also committed to making a positive impact on our local community. Our staff and company make both monetary and volunteer contributions, and we have an internship program that allows us to support the next generation of professionals. 22  Description of CFA Charter - Chartered Financial Analyst To become a charterholder, you have to: • Agree to follow the CFA Institute Code of Ethics and Standards of Professional Conduct. • Pass the CFA Program exams for Levels I, II, and III. • Have four years of qualified investment work experience. • Become a regular member of CFA Institute and apply for membership in a local CFA member society. How Long Does it Take? • Each of the three exams requires approximately six months of preparation. • You have to successfully complete the three exams in order (Level I, II, and III). • There is no limit to the number of times you can take each exam. • You need to have 48 months of approved work experience (before, at the same time as, or after you prepare for the exams). Successful candidates take an average of four years to earn the CFA charter. Description of Financial Risk Manager - Certification Requirements In order to be certified as a Financial Risk Manager (FRM®) from the Global Association of Risk Professionals and be able to use the FRM acronym after your name, the following is required: • A passing score on both Part I and Part II of the FRM Examination • A minimum of two years professional full-time work experience in the area of financial risk management or another related field including, but not limited to, trading, portfolio management, faculty academic, industry research, economics, auditing, risk consulting, and/or risk technology. Earning the right to use the FRM designation after your name demonstrates professionalism and dedication to the profession. Thus having experience is important to assure the FRM designation maintains its status as the benchmark certification for financial risk professionals worldwide. Description of CERTIFIED FINANCIAL PLANNER™ professional CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. 23  • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Item 3: Disciplinary Information TJIM’s employees do not have any disciplinary events and there have never been, nor are there any current investigations against any members of the firm. Item 4: Other Business Activities TJIM’s investment professionals are not involved in any other investment-related business or occupation. Item 5: Additional Compensation TJIM’s investment professionals only receive compensation from TJIM. Staff is motivated toward providing investment performance and customer service through a combination of base salary, profit sharing/bonus incentives and a competitive benefits package. Item 6: Supervision Richard H. Parry, President, and Chief Investment Officer, 405-236-2111, is responsible for the supervision of all advisory activities performed by supervised persons. Item 7: Requirements for State-Registered Advisers Not Applicable 24  TJIM Client Privacy Policy Revised Date: July 2007 We consider our relationship with our clients our most important asset. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all our clients value their privacy, so we will not disclose your personal information to anyone unless: TJIM’s COMMITMENT TO YOUR PRIVACY • • • it is required by law at your direction is necessary to provide you with our services. We have not and will not sell your personal information to anyone. YOUR PRIVACY IS NOT FOR SALE TJIM collects and maintains your personal information so we can provide investment management services to you. The types and categories of information we collect and maintain about you include: • investment objectives, tolerance, • • WHAT INFORMATION DO WE COLLECT, MAINTAIN, AND COMMUNICATE? Information we receive from you to open an account (social security number, home and/or work address, cell phone number, and email), to establish that our services are suitable given your situation, requirements, and expectations (income, assets, investment risk preferences), or to provide investment advice to you information that we generate to service your account such as account statements and other reports information that we may receive from third parties with respect to your account (such as trade confirmations from brokerage firms, account statements from custodians, and suitability documentation). TJIM will not disclose any personal information about you or your account(s) unless one of the following conditions is met: • We receive your prior written consent • we believe the recipient is your authorized representative • we are permitted by law to disclose information to the recipient. To fulfill our privacy commitment at TJIM, we have instituted firm-wide practices to safeguard the information that we maintain about you. These practices include: • Adopting policies and procedures addressing physical, electronic and other • • safeguards to keep your personal information safe limiting access to personal information to those employees who need it to perform their job duties requiring third parties that perform services for us to agree by contract to keep your personal information strictly confidential. HOW WE PROTECT YOUR PERSONAL INFORMATION Even if you decide to close your account(s) or become an inactive client, we will adhere to the privacy policies and practices described above. 25