Privacy Policy

The relationship between Johnson Investment Counsel, Inc., our affiliates (Johnson Trust Company, Johnson Financial, Inc. and Johnson Mutual Funds) and our clients is the most important asset of our firm. We strive to maintain your trust and confidence, which is an essential aspect of our commitment to protect your personal information to the best of our ability. We believe that our clients value their privacy, and we do not disclose your nonpublic personal information to third parties unless it is permitted or required by law, at your direction, or is necessary to provide you with our services.

We have not and will not sell your personal information to anyone.

This Privacy Policy explains how we collect, use, share, and protect your personal information in accordance with federal and state privacy laws, including Regulation S-P under the Securities Exchange Act of 1934.

Johnson Investment Counsel and our affiliates collect and maintain your nonpublic personal information so that we can better provide investment management and trust services to you. The types and categories of information that we collect and maintain about you include:

• Information we receive from you to open an account or provide investment advice and trust services, such as your home address, telephone number, email address, date of birth, social security number, and financial information.
• Information about your transactions that we need to service your account, such as trade confirmations, account statements and other financial information.

In order for us to provide investment management and trust services to you, it is sometimes necessary for us to disclose your personal information to third parties (e.g., brokers, custodians, regulators, and tax return preparers). In addition we also outsource certain functions to various nonaffiliated third-party vendors. To allow these vendors to perform their contracted services, the firm may disclose certain nonpublic personal information about its clients to these vendors. While our contractual arrangements with third-party vendors prohibit third-party vendors from disclosing or using client information other than for the purposes of performing services for the firm, third-party vendors could experience information security breaches or other incidents that could expose client information. The occurrence of such an incident at a third-party vendor is outside of the firm's control.

We do not share your information with nonaffiliated third parties for their own marketing purposes, and therefore you are not required to opt out of any information sharing under Regulation S-P. We may share information among our affiliated companies to service your accounts and provide requested services.

To fulfill our privacy commitment at Johnson Investment Counsel, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:

• Adopting procedures that put in place physical, electronic, and other safeguards to keep your personal information safe, including encryption of sensitive data, multi-factor authentication, secure firewalls, and network monitoring.
• Limiting access to personal information to those employees and service providers who need to know that information to perform their job duties or to provide products or services to you.
• Requiring third parties that perform services for us to agree by contract to keep your information strictly confidential and maintain appropriate security standards.
• Conducting due diligence on service providers and ongoing monitoring of their compliance with our security requirements.
• Maintaining an incident response plan that includes procedures for investigating and responding to data security breaches and notifying affected clients as required by law.
• Providing regular training to employees on data security and privacy practices.
• Protecting the information of our former clients to the same extent as our current clients.

We retain your personal information for as long as necessary to provide services to you and to comply with legal and regulatory requirements (generally 6-7 years under SEC rules). When information is no longer needed, we securely destroy or delete it.

You have the right to request access to the personal information we maintain about you and to request corrections to inaccurate information. If you are a resident of certain states with comprehensive privacy laws (such as California, Virginia, Colorado, or Connecticut), you may have additional privacy rights under state law, including rights to know what information we collect, request deletion of information (subject to legal exceptions), and non-discrimination for exercising your rights. To exercise these rights or ask questions about our privacy practices, please contact us.

At Johnson Investment Counsel, we value your privacy.

If you have any questions, please feel free to contact us.

This Privacy Policy is provided in accordance with Regulation S-P under the Securities Exchange Act of 1934 and the Gramm-Leach-Bliley Act.

As of 2/2026