Newday Funds, Inc., d/b/a Newday Impact, is a privately held corporation formed in 2015 for the purposes of providing advisory services, research, and investment management to individuals, registered investment advisors and institutional investors as defined under Rule 501 of the Securities Act of 1933, as amended. Newday Impact’s ownership is set forth below. Newday Impact provides authentic strategies for responsibility-minded investors. Backed by insightful research and recognized community leaders, Newday Impact offers strategies aligned with the major ESG issues in the world, including climate action, fresh water, human rights, gender equality, animal welfare, and quality of governance. Newday Impact provides solutions for institutional investors, high-net- worth individuals and novice investors who want their investments to generate competitive returns as well as make an impact in the world. The Newday Impact had $113,130,619 of assets under management as of December 31, 2022, which are managed on a discretionary basis. In addition, we had $1,201,982 of assets under advisement. This Disclosure Brochure describes the investment advisory business of Newday Impact. As used in this Disclosure Brochure, the words “we”, “our” and “us” refer to Newday Impact and the words “you” and “client” refer to you as either a client or prospective client of Newday Impact. Ownership Newday Impact is owned by Newday Financial Technologies, Inc. which is in turn owned by its employees, private individuals and certain investment and venture capital investors. Research and Capabilities Newday Impact is an institutional asset management company offering investment solutions focused exclusively on environmentally sustainable, socially responsible companies and countries with good governance practices. Newday Impact Thematic portfolio strategies use proprietary ESG and fundamental investment research to identify companies that align with specific areas of social, economic or governance impact selected by the client. These are applied to create portfolios that seek to maximize return subject to alignment with the area of desired impact chosen by the client. Newday Impact portfolios address major ethical issues and are designed and constructed around a combination of UN Sustainable Development Goals and ESG principles using a rigorous, repeatable process. We believe that enhanced investment returns are attainable on a consistent basis by applying a disciplined investment approach that capitalized on a combination of ESG, governance and fundamental factors to create a portfolio. Newday exclusionary ESG screens include fossil fuels, armaments, gambling, tobacco, alcohol, and child labor. We believe that consistent alpha can be generated by combining our highest rated ESG companies with an emphasis on governance and fundamental factors to create a portfolio of our highest conviction companies. We identify which companies will perform or underperform in any given stage of the prevailing economic/business cycle. We believe Newday Impact is a leader in country-level research on good governance. Newday Impact developed the Sustainable Wealth Creation Principles by researching the accounting, legal, regulatory, adjudicative, and economic structures of countries around the world. Its extensive research database contains data from a range of factors collected over 19 years. Newday Impact then uses this information to construct investible portfolios. Newday Impact has taken the research methodology used for our country-level governance research and applied it to individual company research in the US through its Sustainable Value Creation principles. Newday Impact’s Corporate Governance Assessment is used to evaluate a range of qualitative factors for all the stocks in the S&P 500 Index. This assessment analyzes each company’s relationship not only with its shareholders and its employees, but also with its customers, suppliers, competitors, and communities in which a company operates. This approach provides a holistic analysis of governance as well as social aspects of ESG investing. Investment Management Services Newday Impact constructs and manages equity strategies for private and institutional investors on a fully discretionary basis in the form of separately managed portfolios. Each client’s assets are managed through a separately managed account (SMA). SMA portfolios consist of US equity securities and foreign exposure through American Depository Receipts (“ADRs”), based on the portfolio strategy selected by the client. Newday Impact serves as the investment advisor and manager

to each client’s SMA pursuant to an Investment Management Agreement between the client and Newday Impact. Client assets are held at the client’s custodian of choice for institutional clients and at the custodian affiliate of the designated back-office service provider, currently Charles Schwab & Co., Inc., for private clients. Clients are advised to notify Newday Impact promptly if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions or mandates on the management of their SMA. Clients may impose reasonable restrictions or mandates on the management of the SMA if, in Newday Impact’s sole discretion, the conditions do not appear likely to have a material impact on the performance of a portfolio strategy or prove overly burdensome to its management efforts. Such restrictions must be fully documented in each client’s Investment Management Agreement, or in any subsequent written instructions sent to and accepted by Newday Impact. Senior Investment & Financial Management Team Shireen Eddleblute, Director of ESG Research, Co-Portfolio Manager and Chief Diversity Officer Ms. Eddleblute has over 20 years of investment management experience and a decade- long involvement in philanthropy and nonprofit volunteerism. She has been the Director of ESG Research, Portfolio Manager, and Chief Diversity Officer at Newday since September 2021. She was previously a Senior Equity Analyst and Portfolio Manager at RBC Global Asset Management since September 1999. Ms. Eddleblute also served as an Equity Research Analyst at US Bancorp Asset Management, Inc. and an Institutional Analyst at Wellington Management. Prior to that, she was a Registered Sales Associate and Assistant Syndicate Coordinate at Prudential Securities. Ms. Eddleblute is a graduate of the Fisher School of Business at The Ohio State University and holds an MBA with honors from the Sawyer School of Business at Suffolk University. She is DEI certified from Stanford University’s Graduate School of Business and holds a certificate in ESG Investing from the Columbia Business School. Douglas Heske, President & Chief Executive Officer Doug brings more than 30 years’ experience in the investment industry. Prior to joining Newday Impact, Douglas served as the head of Private Client Services for Stifel Nicolaus in San Francisco (2011 - 2016) as well as the COO and Head of Wealth Management for Nollenberger Capital Partners and subsequently Sterne Agee (2004 - 2011). Prior to his role at Nollenberger, he was the Regional Managing Director of Wealth Management with Piper Jaffray & Co. (1993 - 2004). He is a graduate of Rhode Island University with a Bachelor of Science in Finance. Matt Zimmer, Director of Governance Research and Co-Portfolio Manager Mr. Zimmer joined Newday Impact as part of its acquisition of Magni Global Asset Management in January 2021. As Director of Governance Research and Co-Portfolio Manager, Mr. Zimmer has responsibility for the Newday governance research process and helps oversee Newday’s equity portfolios. He has more than 20 years of research and investment experience with expertise evaluating macro-level economic and political developments to inform investment decisions. Mr. Zimmer served in a similar capacity as Director of Research at Magni where he developed their proprietary methodology for governance research at both the company and country level. Prior to joining Magni, he was a Principal at eStandardsForum, a data service provider that monitored the country compliance with international financial standards, as well as a Program Officer for the Reinventing Bretton Woods Committee, a consultancy and advisory firm focused on issues related to financial reform. A long-time advocate for environmental and social causes, Mr. Zimmer served as a Business Development volunteer with the United States Peace Corps in Ukraine (1995-1997). Mr. Zimmer received an MBA in International Economics from Pace University, a Masters of International Affairs in International Economic Policy from Columbia University, and a B.S. in Business Administration and Economics from the University of Florida. David Hsu, Chief Compliance Officer Mr. Hsu brings more than 20 years of regulatory compliance experience in the financial services industry . Prior to Newday, he was the Chief Compliance Officer of 280 CapMarkets, Liberty Group and Stone & Youngberg as well as a regulator with the Financial Industry Regulatory Authority (FINRA). He has degrees in Economics and Psychology from the University of North Carolina.