Atom Investors LP (“Atom,” the “Investment Manager,” or the “Firm”), a Delaware limited partnership, was founded in February 2018 and commenced operations in June 2018. The principal owners of Atom are (i) Fusion Investors LLC (“Fusion”), a Delaware limited liability company, and (iii) Atom Strategies LLC (“Strategies”), a Delaware limited liability company. Basil Qunibi, the Chief Executive Officer and Chief Investment Officer of Atom (the “Principal”), and his related parties are the controlling members of Fusion. The Principal is also the controlling member of Strategies. No other member or partner owns, directly or indirectly, over 25% of Fusion, Strategies or Atom, respectively. As of the close of business on December 31, 2022, Atom advised approximately $1.2 billion in regulatory assets under management on a discretionary basis. Atom is an investment management company that provides discretionary investment advice to private investment funds, and discretionary and non-discretionary advice to individuals and institutions either directly or through financial intermediaries, including investment advisers, consultants, and wealth managers (“Intermediaries,” and individually, an “Intermediary”). These private investment funds, individuals, and institutions advised by Atom, including Index Pro Clients and Advisory Clients (as defined below) are collectively referred to as “Clients” throughout this brochure. Private Investment Funds The private investment funds Atom advises on a discretionary basis include (a) Atom Overseas Ltd. (the “Offshore Feeder Fund”), (b) Atom Partners LP (the “Domestic Feeder Fund”) and (c) Atom Master Fund L.P. (the “Master Fund” and, collectively with the Offshore Feeder Fund and the Domestic Feeder Fund, the “Funds”). The Offshore Feeder Fund is an exempted company incorporated under the laws of the Cayman Islands to facilitate investment by U.S. tax-exempt investors and non-U.S. investors. The Domestic Feeder Fund is a limited partnership formed primarily for investment by U.S. investors. The Master Fund is a Cayman Islands exempted limited partnership. The Offshore Feeder Fund and the Domestic Feeder Fund invest substantially all of their investable assets through the Master Fund in a “master-feeder” arrangement. Atom Associates LLC, a Delaware limited liability company and an affiliate of the Investment Manager (the “General Partner”), serves as the general partner of the Domestic Feeder Fund and the Master Fund, and is expected to serve as the general partner to any other feeder funds that may be formed to invest in the Master Fund. The General Partner has ultimate responsibility for the management, operations and the investment decisions made on behalf of the Master Fund. The principal owners of the General Partner are (i) Fusion and (ii) Strategies. The investment objective of the Funds is to provide attractive risk-adjusted returns over full market cycles with less volatility than the broad equity markets. The Investment Manager, on behalf of the Funds, seeks to achieve this investment objective using a proprietary equity market neutral investment strategy based upon fundamental research, quantitative analysis, the application of a systematic risk management program and systematic trading executions. The Investment Manager allocates a portion of the Funds’ assets to accounts managed by investment managers (each, a “Sub-Adviser”) that are not affiliates of the Firm. The Firm has discretion with respect to investment decisions it makes for the Funds and also with respect to the selection of brokers, dealers and other counterparties for such transactions, and the amount of commissions or other compensation to be paid by the Funds. The Firm provides investment advisory services to the Funds based on the particular investment objectives and strategies described in the offering documents for the Offshore Feeder Fund and the Domestic Feeder Fund, and investors in the Funds cannot obtain services tailored to their individual specific needs. Index Pro Atom offers customized discretionary advisory and sub-advisory services, as well as non- discretionary model delivery services, for separately managed accounts for individuals and institutions through its Index Pro platform (each generated portfolio, an “Index Pro Portfolio”). Index Pro is a digital platform that enables Clients, through separate accounts, to create customized equity portfolios tailored to their specific goals. Index Pro provides Clients and their financial intermediaries with a scalable platform to build and manage custom equity portfolios on any benchmark that seek to reflect personalized values, performance, risk and tax-efficiency goals. Through Index Pro, Atom uses quantitative models and tools to incorporate Client specifications for benchmark tracking, factor or sector exposures, socially responsible investing (“SRI”) and environmental, social, and governance (“ESG”) values, other investment themes (e.g., artificial intelligence, robotics, and clean energy), and tax management. A Client receiving services through the Index Pro platform (an “Index Pro Client”) is also able to customize an investment portfolio to meet specific requirements, such as holding restrictions, industry/country limitations, rebalancing frequency, position size, and situation-appropriate tax needs. Benchmarks tracked include broad market equity indices representing domestic and/or foreign companies (e.g., S&P, Russell, and MSCI indices). Once an Index Pro Client has selected an investment strategy and benchmark for its account, Atom provides continuous supervision and management of the assets in the account. Each Index Pro Client, directly or through its relevant Intermediary is responsible for informing Atom of any changes to the Index Pro Client’s investment objectives, individual needs, and/or restrictions. To the extent an Index Pro Client includes any special instructions or limitations on the management of its account, Atom reserves the right to reject such restriction if Atom determines that the request is not reasonable in its sole discretion. Please refer to Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss for detailed information regarding the Index Pro strategy. Index Pro is currently available to clients of Intermediaries through either sub-advisory or model delivery arrangements. It is also available on a discretionary basis to advisory services clients (“Advisory Clients”) as well as institutional Clients interested in investing in long-only strategies. In a sub-advisory arrangement, an Intermediary acts as the primary fiduciary to its clients, and the Intermediary is responsible for selecting Atom as a sub-adviser to certain of the Intermediary’s clients’ investment portfolios. This selection is based on the Intermediary’s assessment about whether Atom’s advisory services provided through Index Pro are appropriate for the Intermediary client’s investment objectives and financial situation. Each Index Pro sub-advisory arrangement is governed by a Sub-Advisory Agreement between Atom and the relevant Intermediary, as well as the Intermediary’s own agreement with the applicable Index Pro Client. Pursuant to each Sub- Advisory Agreement, the relevant Intermediary grants Atom full authority to buy, sell, or otherwise effect investment transactions for an Index Pro Client’s account, in accordance with the Index Pro Client’s stated investment objectives, strategies, and restrictions. If there is

a change to an Index Pro Client’s investment guidelines, the Index Pro Client is responsible for informing Atom of such change by notifying its applicable Intermediary. In an Index Pro model delivery arrangement, Atom provides an Intermediary with one or more model investment portfolios through Index Pro (“Model Portfolio”), which the Intermediary may implement when managing one or more of its clients’ investment portfolios. Model Portfolios are tailored to the investment objectives and portfolio restrictions of each Index Pro Client account managed by an Intermediary based on information provided by the Intermediary. Each model delivery arrangement is governed by a Model Delivery Agreement between Atom and an Intermediary. Under such arrangement, Atom, as model manager, is responsible for designing a Model Portfolio for an Index Pro Client based on information provided by the Intermediary, monitoring the Model Portfolio on a continuous basis to review the investment guidelines applicable to such Model Portfolio, and updating the Model Portfolio, as necessary. The relevant Intermediary is responsible for interposing its own investment judgement in exercising its investment discretion when implementing a Model Portfolio and placing orders for the execution of investment transactions for its Index Pro Client. Accordingly, the Intermediary can deviate from a Model Portfolio or any of Atom’s non-discretionary advice when managing an Index Pro Client’s portfolio. As primary fiduciary to the Index Pro Client, the relevant Intermediary retains initial and ongoing responsibility for determining whether Index Pro and each applicable Model Portfolio is suitable and appropriate for the relevant Index Pro Client. In addition, with regard to each Index Pro Client’s portfolio, the Intermediary is responsible for selecting the custodian, the quality of trade execution, trade reporting, trade settlement, daily position cash reconciliation, regulatory reporting, investor reporting, and the voting of proxies and monitoring of corporate events. Index Pro relies on quantitative models, information and data supplied by third parties (“Models and Data”) to inform its investment decisions with respect to the Index Pro Portfolios. Models and Data are used to construct sets of transactions and investments, to value investments or potential investments (whether for trading purposes, or for the purpose of determining the net asset value of the assets), to provide risk management insights, and to assist in hedging the account’s investments. When Models and Data prove to be incorrect, misleading or incomplete, any decisions made in reliance thereon expose Clients to potential risks. As part of Atom’s advisory services (“Advisory Services”), the Investment Manager may determine that it is suitable for an Advisory Client to invest in an Index Pro Portfolio. In an Advisory Services relationship, which includes an Index Pro strategy as part of the Client’s overall investment portfolio, the Advisory Client will enter into a master service agreement (“Master Services Agreement”) with a specific Index Pro annex. Advisory Services Atom provides investment management and financial advice to Advisory Clients. Each Advisory Client will enter into a Master Services Agreement on a non-discretionary and/or discretionary basis. Atom manages and oversees Client’s assets (“Managed Assets”) primarily on a discretionary basis, though certain accounts may be non-discretionary. As part of the advisory relationship, Atom works with each Advisory Client to assess its unique financial situation to develop and maintain a customized investment policy statement (“IPS”) that reflects the Advisory Client’s overall investment objectives and constraints. Atom strives to ensure that Advisory Clients are invested in a portfolio strategy that corresponds to their needs at an appropriate risk level which is tailored in accordance with the IPS. Together with the Advisory Client, Atom’s Chief of Investment Strategy, along with its investment professionals, identify an appropriate risk level based upon assumptions regarding future market volatility utilizing a diversified investment strategy. The Advisory Client’s IPS facilitates Atom’s development of an overall investment strategy to invest Managed Assets across a spectrum of investment strategies in one or more of the following ways: (i) directly in exchange-traded funds (“ETFs”), mutual funds, individual stocks and other investments (collectively “Direct Investments”), (ii) directly in pooled investment funds managed by Atom (“Atom Funds”), (iii) through a customized Index Pro Portfolio, and/or (iv) through a portfolio of separately managed accounts on a sub-advisory basis. Using these investment strategies Atom can customize each portfolio to meet an Advisory Client’s particular needs. Depending on the Advisory Client’s investment goals and risk tolerance, the Investment Manager may determine to buy or sell various types of financial products, including but not limited to equity securities (such as exchange-listed securities, securities traded over-the-counter, securities of U.S. or foreign issuers, whether publicly or privately traded, and distressed securities), options on equity securities, debt securities (such as municipal securities and U.S. government securities, and which also could include other fixed income securities such as high yield bonds), warrants, commercial paper, exchange-traded funds, mutual funds, including but not limited to money market funds, exchange-traded products, such as exchange-traded notes, and complex financial products, such as structured notes. Our trading strategies, depending on the applicable Advisory Client’s investment goals and risk tolerance, may include both short-term trading and long-term purchases. Trading strategies may also include buying on margin, short-selling and options trading if approved by the Advisory Client. Certain Index Pro Portfolios may include investments in ESG focused strategies informed by data provided by third party providers. Strategies involving direct equity investments of Managed Assets will be managed using Index Pro. Index Pro enables Atom to provide Advisory Clients with and Index Pro Portfolio which includes individual equities that meet each Advisory Client’s specific risk, tax, values and other objectives. Each Advisory Client acknowledges and understands that Atom engaging Index Pro is a conflict of interest because Index Pro, a subsidiary of the Investment Manager, will receive compensation from this arrangement. As such, the Investment Manager has an incentive to recommend and Index Pro Portfolio instead of recommending non-affiliated investment portfolio providers which may provide superior and/or less expensive investment portfolios. Atom’s investment professionals do not receive commissions from Index Pro and are not otherwise incentivized to use Index Pro on behalf of an Advisory Client. For the avoidance of doubt, the Advisory Client understands and agrees they do not maintain an account with, nor has it entered into a contractual relationship with Index Pro. Index Pro is a service provider to, and provides recommendations of non-personalized investment advice to the Investment Manager. The management of trading Managed Assets will be conducted by the Investment Manager not by Index Pro or any other investment portfolio provider. The Firm does not participate in wrap fee programs.