(a) General Description of Advisory Firm The Adviser is a Delaware limited liability company that began offering investment management and advisory services in January 2014. It currently serves as the manager/member to the general partner of two collective investment funds, interests in which are offered to investors on a private placement basis. The Adviser also offers separately managed accounts to institutional investors and high net worth individuals, and serves as a sub-adviser to various funds as described herein. In addition, the Adviser offers investment strategy models to certain platforms that allow their clients to invest their assets according to the Adviser’s models. Dr. Sanjeev Bhojraj and Mr. Matthew Malgari are the principal owners of the Adviser and Portfolio Managers.. Mr. Nathan Przybylo is a minority owner of the Adviser and a Portfolio Manager (together with Dr. Bhojraj and Mr. Malgari “the Portfolio Managers”) Mr. Malgari also is the Adviser’s Managing Member. (b) Description of Advisory Services The Adviser offers investment advisory services on a discretionary and nondiscretionary basis to its clients, which include individuals and institutions with separately managed accounts, registered investment companies, and pooled investment vehicles intended for sophisticated investors. The Adviser invests client assets in large-cap equity securities (i.e., securities issued by companies, each with a market capitalization that is greater than approximately the 70th percentile of market capitalization in the Adviser-defined universe) that are publicly traded primarily, if not exclusively, on U.S. securities exchanges. The Adviser also invests in mid-cap equity securities (i.e., securities issued by companies, each with a market capitalization of between $1 billion and $20 billion) of companies that are primarily listed on the S&P 400 Midcap Index. In managing the client assets, the Adviser takes long positions, short positions, or leveraged long and short positions using its hybrid quantitative and fundamental investment process. That process is generally

stock-specific and sector-agnostic, which may, at times, cause certain client portfolios to have significant exposure to a specific sector. The Adviser also manages a client account that seeks to replicate performance of a specific index. The Adviser’s advisory services are subject to any investment management agreement or other agreement that sets forth the scope of the Adviser’s discretion. The Adviser also participates in certain platforms, that use the Adviser’s investment strategy models to manage their client accounts. These platforms have developed an investment management program whereby their clients will allow them to trade their assets pursuant to the Adviser’s investment strategy models. The Adviser grants these platforms a non-exclusive license to use the Adviser’s investment strategy models for these purposes. For more information on the Adviser’s investment advisory services, see “Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss,” below. All investment strategies are available to those types of investors described in “Item 7 - Types of Clients,” below, through separately managed accounts held by banks, broker-dealers, and other types of financial institutions. (c) Availability of Tailored Services for Individual Clients Client accounts generally are managed in accordance with each such client’s investment advisory agreement with the Adviser, or in the case of a client that is a collective investment fund, the collective investment fund’s offering materials and other constituent documents. Investors in a collective investment fund have no opportunity to select or evaluate any fund investment or strategy. (d) Wrap Fee Programs The Adviser currently does not participate in any wrap fee program. (e) Client Assets under Management As of December 31, 2023, the Adviser managed total regulatory assets under management of approximately $473,255,122on a discretionary basis. As of December 31, 2023, The Adviser did not manage any assets on a nondiscretionary basis, but may do so in the future.