This Brochure describes the investment advisory services offered by Rockefeller Asset Management (“RAM”), a division of Rockefeller & Co. LLC (“Rockefeller & Co.”). RAM provides a broad range of investment strategies in varying investment vehicles to institutional clients, intermediaries, high net-worth individuals and family offices, and other types of investors. Rockefeller & Co. and its affiliates offer additional investment advisory services which are not described in this Brochure. Specifically, Rockefeller & Co. offers investment advisory and family office services through a separate division, the Rockefeller Global Family Office (the “Global Family Office”). Additionally, Rockefeller & Co.’s affiliate, Rockefeller Financial LLC (“Rockefeller Financial”), offers investment advisory and wrap programs to its clients in its capacity as a dually registered investment adviser and broker-dealer. Separate brochures describing the advisory services offered by the Global Family Office and the advisory and wrap fee programs offered by Rockefeller Financial are available on the SEC’s website at www.adviserinfo.sec.gov and may also be obtained by contacting us by email at [email protected]. Rockefeller Financial also offers brokerage and other services to its clients. Firm Overview RAM is a division of Rockefeller & Co., which is a Delaware limited liability company that is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Rockefeller & Co. also conducts business under the trade name Rockefeller Capital Management. RAM and a vast majority of its investment personnel are based in the firm’s principal place of business operations at 510 Madison Avenue, 21st Floor, New York, New York 10022. Certain RAM professionals work from different locations, including but not limited to Rockefeller Capital Management’s headquarters at 45 Rockefeller Plaza, 5th Floor, New York, New York 10111. Rockefeller & Co.’s history, through its predecessors, dates to 1882 when John D. Rockefeller established a New York office to manage the Rockefeller family’s investment, personal, and philanthropic interests. Rockefeller & Co.’s immediate predecessor, Rockefeller & Co., Inc. was incorporated in 1979 and in 1980 registered with the SEC as an investment adviser under the Advisers Act. Rockefeller & Co. is now an indirect, wholly-owned subsidiary of Rockefeller Capital Management L.P. Rockefeller Capital Management L.P. was established on March 1, 2018, when Gregory J. Fleming, together with investment funds affiliated with Viking Global Investors, L.P. (“Viking”), acquired the investment advisory and trust company businesses established by the Rockefeller Family. Today, RCM is majority owned by the Viking funds, with minority stakes held by a U.S. affiliate of IGM Financial Inc. (“IGM”), a trust representing the Rockefeller family, and current and former members of RCM’s management and individual members of the Rockefeller family. Viking and IGM are not involved in the day-to-day management of RCM or the Firm. No employee, officer, director, or other representative of Viking or IGM, or any of their respective controlled affiliates, is a member of any committee of RCM or the Firm that determines which products or services are offered or sold to Firm clients. Please refer to Schedule A of Rockefeller & Co.’s Form ADV Part 1A for additional information about the ownership of the firm. Rockefeller Capital Management L.P.’s operating subsidiaries include: Rockefeller & Co., an investment adviser registered with the SEC providing investment advisory and family office services through its Global Family Office division and investment management services through its RAM division; Rockefeller Asset Management International Ltd. (“RAM International”), a UK limited company performing non-US distribution and investor servicing activities for RAM; Rockefeller Financial, a broker-dealer and investment adviser registered with the SEC providing private wealth management services, securities services and strategic advice; Rockefeller Trust Company, N.A., a national trust bank regulated by the Office of the Comptroller of the Currency (“RTC NA”) and The Rockefeller Trust Company (Delaware), a limited purpose trust company regulated by the State Bank Commissioner of the State of Delaware (“RTC Delaware”), both of which provide fiduciary services acting either as a trustee, co-trustee, executor, co-executor, or as a fiduciary or agent for other fiduciary relationships; Rockefeller Strategic Services LLC (“Rockefeller Strategic Services”), which provides strategic advisory services with respect to certain types of business transactions not requiring registration in the U.S. as a broker dealer; and Rockefeller Capital Management Insurance Services, LLC (“RCM Insurance Services”), an insurance company licensed in all 50 states that provides access to a broad range of personal insurance expertise and services through multiple national providers to enable effective estate planning, asset protection or other key wealth management planning strategies and priorities. Unless otherwise specified, references herein to “clients” or “you” refer to advisory clients of RAM and the descriptions of investment advisory services refer to those of RAM and not to the advisory services and business practices of the Global Family Office or of other affiliates, including Rockefeller Financial, RTC NA, RTC Delaware, Rockefeller Strategic Services and RCM Insurance Services. RAM Investment Advisory Services RAM provides a broad range of investment strategies on a discretionary, non-discretionary and model delivery basis for institutional clients, intermediaries, high net-worth individuals and family offices, and other types of investors. Clients may access RAM’s investment strategies through a variety of investment vehicles and arrangements, such as separately managed accounts, registered investment companies, exchange traded funds, privately offered investment funds, and non-U.S. investment vehicles. In certain cases, RAM offers these services on a sub-advisory capacity and through separately managed account programs, including wrap fee, dual contract and model delivery programs (“SMA Programs”). RAM’s primary investment strategies are set forth below. Long-Only Equity Strategies
• Climate Solutions Equity Strategy
• Emerging Markets Equity Strategy
• Global Equity Strategy
• Global Environmental, Social and Governance (“ESG”) Equity Strategy
• Global Fossil Fuel Free ESG Equity Strategy
• Global Dividend Growth Equity Strategy
• Global ESG Improvers Strategy
• Global Innovation Strategy
• Non-U.S. Equity Strategy
• Non-U.S. ESG Equity Strategy
• Ocean Engagement Equity Strategy
• Thematic Equity Strategies
• U.S. Large Cap Equity Strategy
• U.S. ESG All Cap Equity Strategy
• U.S. ESG Improvers Strategy
• U.S. Concentrated Strategy
• U.S. Small Cap Equity Strategy
• U.S. Small Cap ESG Equity Strategy
• U.S. SMID Cap Equity Strategy Hedge Fund Strategy
• Long/Short Equity Strategy Taxable Fixed Income Strategies
• Short-Term Taxable Strategy
• Short-Term Taxable ESG Strategy
• Intermediate Taxable Strategy
• Core Taxable Strategy
• Taxable Laddered Strategy
• Treasury Laddered Strategy
• Core Taxable ESG Strategy
• Preferred Securities Strategy
• Cash Management Strategy Tax Exempt Fixed Income Strategies
• Short-Term Tax Exempt Strategy
• Intermediate Tax Exempt Strategy
• Intermediate Tax Exempt ESG Strategy
• Long-Term Tax Exempt Strategy
• Municipal Laddered Portfolio Private Equity
• FinTech Venture Capital
• Growth Equity Other Investment Strategies RAM offers additional investment strategies which are not listed above. These strategies include, but are not limited to:
• Multi-asset class

strategies, including some with allocations to third party managers and funds and alternative asset classes
• Quantitative strategies
• Customized investment strategies tailored to a client’s particular requirements. SMA Programs As mentioned above, RAM serves as portfolio manager to certain sponsors of SMA Programs, including its affiliate Rockefeller Financial. Under these arrangements, the program sponsor typically engages RAM to provide investment management services to the program sponsor. The program sponsor then makes these investment strategies available to its program participants. The program sponsor is responsible for the design of their SMA Program, and for determining suitability of the SMA Program for each of its program participants. Program participants are permitted to establish reasonable investment restrictions on the management of their program accounts. For equity strategies made available on SMA Programs, we typically provide portfolio recommendations (i.e., the model portfolio) to a program sponsor who is responsible for implementing the portfolio on behalf of its program participants. For example, the model program sponsor is responsible for, among other things, executing portfolio transactions for program participants and ensuring compliance with investment restrictions established by program participants. For fixed income strategies, RAM is generally responsible for executing transactions for these accounts. Fixed income trading is typically done away from the program sponsor. Please refer to Item 12 for information about RAM’s brokerage practices for additional information. In providing a model, RAM generally uses the same sources of information and investment/research personnel as it uses to manage its other client accounts that have similar investment objectives. Models provided to SMA Program sponsors often may differ from portfolios that RAM manages directly for other clients that have similar investment objectives. For example, SMA Program sponsors may place restrictions and limitations on securities that can be held in a model. In addition, as compared to RAM’s directly managed strategies, SMA Program strategies may, for example and without limitation. invest only in US listed securities, trade at different times and rebalance positions at different frequencies or dispersion tolerances, Accounts within the same model, or a similar model, can hold different securities and/or trade at different times. Program account performance may be adversely affected depending on when the specific model account was funded, or the implementation and portfolio trading taken by the program sponsor on its program accounts. In general, material portfolio changes will not be communicated to model program sponsors until completion of aggregated trading by RAM for its managed account clients, which could result in model portfolio clients receiving executions which are less or more favorable than the executions received by RAM managed account clients. Clients of model delivery programs benefit from research acquired through soft dollars but do not contribute to the cost of acquiring such research because brokerage transactions for model delivery programs are typically executed by the plan sponsor and not by RAM. Clients accessing a RAM investment strategy through a SMA Program should consult the Form ADV Part 2A and/or wrap fee brochure, if applicable, of the program sponsor for additional information. Qualified Custodians Clients select their own bank or broker-dealer as their qualified custodian to hold the funds and securities for which RAM will provide investment advisory services. RAM has certain business arrangements in place with unaffiliated third party banks and broker-dealers who can serve as the qualified custodian for client accounts, including FNZ Trust Company LLC (“FNZ”) and JP Morgan Private Bank (“JP Morgan”). RAM may suggest that clients consider utilizing one of these firms for custody services. RAM may also recommend that clients access its investment strategies through SMA Programs, including the wrap fee program sponsored by its affiliate Rockefeller Financial. Additional information about RAM’s business arrangements with these qualified custodians and with Rockefeller Financial is provided below in Items 11, 12, 14 and 17. Rockefeller & Co. does not custody client funds and/or securities on behalf of RAM clients. Please refer to Item 15 – Custody for additional information. Other Services Available to Accounts Customized Advisory Services and Client Restrictions As discussed above, RAM makes available to clients customized investment strategies. Any such arrangements must be agreed upon in advance and typically will be documented through written investment guidelines or in an investment policy statement. Clients may impose reasonable investment restrictions on the management of their accounts which, if accepted by RAM in writing, will apply until changed or withdrawn by the client. If RAM determines that a client imposed restriction prevents the efficient management of the account, it will seek to have it modified or removed by the client. Client imposed investment restrictions will not apply to investment strategies accessed through investments in mutual funds, exchange traded funds and other comingled investment vehicles, which have their own stated investment objectives and policies. We reserve the right to deem any proposed investment restriction as unreasonable and to not accept the proposed investment restriction. If one or more investment restrictions is determined to be unreasonable, we may not be able to accept management of the account or may elect to terminate the account. If you elect to restrict investments, you accept any effect such restrictions may have on the investment performance and diversification of your portfolio. The performance of accounts with client imposed investment restrictions will differ from, and may be lower than, the performance of accounts without such restrictions. Affiliated Investment Products and Affiliated Services Providers Use of investment strategies, investment funds and other investment products managed by the Global Family Office division of Rockefeller & Co. (“Affiliated Investment Products”) and services offered by affiliates of RAM, including but not limited to the Global Family Office and Rockefeller Financial (collectively, “Affiliated Service Providers”) raises conflicts of interest between RAM and its clients. Please see Item 11 – Conflicts of Interest below for a more comprehensive discussion of the conflicts associated with Affiliated Investment Products and Affiliated Service Providers. Bloomberg Rockefeller ESG Improvers Index Bloomberg and RAM have jointly established the Bloomberg Rockefeller U.S. All Cap Multi-Factor ESG Improvers Index (the “ESG Improvers Index”). The ESG Improvers Index is a multi- factor index which combines the Rockefeller ESG Improvers Score™, an uncorrelated and proprietary ESG factor supplied by RAM, with quality and low volatility factors from Bloomberg. Unlike other ESG indices that emphasize screening around ESG leaders or laggards, this index ranks a company’s improvement in performance on material ESG issues relative to industry peers because of the potential that companies exhibiting positive ESG momentum will become more highly valued in the marketplace. The ESG Improvers Index seeks exposure to ESG Improvers, Quality, and Low Volatility attributes with minimal tracking error and sector deviations relative to the Bloomberg US 3000 Index. Bloomberg is responsible for calculation, governance, and provision of the ESG Improvers Index. Regulatory Assets Under Management As of December 31, 2023, Rockefeller & Co.’s regulatory assets under management were:
• Regulatory Assets under Management: $27,371,518,357 o Discretionary Assets: $25,159,860,967 o Non-Discretionary Assets: $2,211,657,390 The firm’s Regulatory Assets Under Management comprise assets managed by both the RAM and Global Family Office divisions of Rockefeller & Co.