DESCRIPTION OF FIRM Syntax Advisors, LLC (“Syntax Advisors,” “us” or “we”) is a SEC-registered investment adviser with its principal place of business in New York, New York. In 2009, predecessors of Syntax Advisors began conducting the business currently conducted by us. Rory B. Riggs serves as the firm’s CEO. Rory B. Riggs is the sole owner member of Syntax Advisors. Syntax Advisors provides advisory services to Exchange Traded Funds (“ETFs”) registered under the Investment Company Act of 1940, subject to the supervision of the Board of the Syntax ETF Trust, (the “Trust”), and a limited number of Separately Managed Accounts (“SMAs”). Collectively, the ETFs, and SMAs are Syntax Advisors’ clients (our “clients”). Syntax Advisors provides investors with rules-based, diversified exposure to business risks via products that track Syntax Stratified Weight Indices. Syntax Indices are a new class of indices that reweight the most widely-used benchmarks, including but not limited to the S&P 500® Index, S&P MidCap 400® Index, S&P SmallCap 600® Index, Russell 1000 Index and MSCI EAFE Index using the Stratified Weight methodology. Syntax’s Stratified-Weight™ is the weighting method by which Syntax diversifies its indices by hierarchically grouping and distributing the weight of an index’s constituent companies that share “Related Business Risks.” Related Business Risk occurs when two or more companies provide similar products and/or services or share economic relationships such as having common suppliers, customers or competitors. The process of identifying, grouping, and diversifying holdings across Related Business Risk groups within an index is called “stratification.” Stratified Weight seeks to provide investors with more balanced exposure than other weighting methodologies, which can concentrate in particular sectors and industries, such as those that have seen high recent momentum or those that have many constituents. Syntax products were developed in conjunction with Functional Information System (FIS), a patented business classification system that provides the technology used to identify business risks in a portfolio. FIS makes it possible to control for risks shared by groups of related companies by: 1) organizing companies that share related business risks into well-defined functional groups; and 2) weighting these groups to spread exposure across these underlying risks. Other commonly used industry and sector classifications lack codified definitions and instead simply group together companies that seem similar. FIS-based industries are engineered to reduce performance distortions caused by the uncontrolled risk exposures that are present

in cap-weighted and equal- weighted indices. Stratified Weight uses FIS-based sectors to group and limit weighting in companies that have shared business functions that can make them perform similarly when events happen to change expectations in a given part of the economy. As of December 31, 2022, Syntax Advisors had $130,264,303 of collective assets under management. Syntax Advisors does not participate in wrap fee programs. THE TRUST Syntax Advisors serves as the investment adviser to exchange-traded funds (“ETFs”), subject to the supervision of the Board of the Trust and is responsible for the investment management of the ETFs, executed through the selection of the Sub-Adviser for portfolio management and other agreed upon activities. As the ETFs’ investment adviser, Syntax provides an investment management program for the ETFs and manages the investment of the ETF assets through sub- advisory relationships. Pursuant to an investment sub-advisory agreement with Syntax, Vantage Consulting Group (“Vantage” or the “Sub-Adviser”) serves as the sub-adviser to the ETFs and performs the day to day management of the ETFs and places orders for the purchase and sale of securities for the ETFs (equity portfolio only for SHUS). For its services to the ETFs, the Sub-Adviser is compensated by Syntax. Pursuant to an investment sub-advisory agreement with Syntax, Swan Global Investments, LLC (“Swan”) serves as the options sub-adviser for Syntax Stratified U.S. Total Market Hedged ETF(“SHUS”). It performs the day to day management of the options strategy for SHUS and places orders for the purchase and sale of options for SHUS. Swan is compensated by Syntax. Additional information regarding the services provided by Syntax Advisors to the Trust can be found in the ETFs’ prospectuses and Statement of Additional Information, which are publicly available at www.syntaxadvisors.com, on the EDGAR Database on the SEC’s website (www.sec.gov) or by contacting Foreside Fund Services, LLC at Three Canal Plaza, Suite 100, Portland, ME 04101 or by calling (866) 972-4492. Foreside Fund Services, LLC is the distributor of the Syntax ETF Trust, and not affiliated with Syntax Advisors, LLC. SEPARATELY MANAGED ACCOUNTS The Syntax Separately Managed Accounts (“SMAs”) provides investment services include, but are not limited to, interpreting investment objectives and risk tolerance, asset selection and allocation, organizing, administering to and regular monitoring of portfolio assets, developing and documenting an individualized investment policy and investment strategy; and managing the investment process.