A. Description of the Advisory Firm Vanguard Personalized Indexing Management, LLC (“VPIM”), formerly JustInvest, LLC is a Delaware limited liability company and an investment adviser registered with and regulated by the SEC under the Investment Advisers Act of 1940 (the “Advisers Act”). VPIM is an indirect wholly-owned subsidiary of The Vanguard Group, Inc (“Vanguard”), the sponsor and manager of the family of mutual funds and ETFs (exchange-traded funds) comprising The Vanguard Group of Investment Companies (“Vanguard® Funds”). As used in this Brochure, the term “Adviser” refers to VPIM, except where the context otherwise requires. References to “Vanguard” in this Brochure include The Vanguard Group, Inc., together with its subsidiaries, including investment advisory subsidiaries which includes VPIM. B. Types of Advisory Services VPIM provides professional portfolio management services to Registered Investment Adviser (“RIA”) firms, wealth managers (including banks and broker-dealers) their Clients and a limited number of Clients who contract with us directly (collectively “Clients”). The RIA firms and wealth managers VPIM works with service individuals, families, family offices, and small endowments and foundations. The Firm specializes in delivering investment processes and expertise in tailoring custom portfolios that are unique to, and reflective of, each investor. Our core offering is delivered as a Separately Managed Account (“SMA”) for each end investor. We deliver SMAs primarily as a sub-adviser to a primary RIA. Portfolio Management Services Central to our advisory services, VPIM offers ongoing portfolio management tailored to the individual needs, goals, values, time horizon, and risk tolerance of each investor. In sub-advisory arrangements, VPIM works with the primary RIA to understand the investor’s Investment Policy Statement (IPS), and to integrate our portfolio management services in-line with the IPS. For direct Clients, VPIM creates an Investment Policy Statement, which outlines the Client’s current situation (including risk tolerance level and cash flow needs) and constructs an asset allocation and portfolio that matches each Client's specific situation. Portfolio management services include, but are not limited to, the following:
• Personal investment policy • Investment strategy
• Asset allocation • Asset selection
• Risk management • Transition management
• Ongoing portfolio management • Regular rebalancing In carrying out these services, VPIM evaluates the suitability of current investments, considering the Client’s risk tolerance, objectives, and values as documented in the Investment Policy Statement which is given to each Client. VPIM provides our portfolio management services on either a discretionary or non- discretionary basis. In a discretionary arrangement, VPIM receives authority from Clients to effect securities selection and trading directly on their behalf. Algorithms To perform its portfolio management services, VPIM uses certain algorithms, which are sets of rules embedded in a computer program, to manage Client portfolios. Currently, the algorithms VPIM leverages (1) identifies portfolio rebalancing opportunities and initiates buy/sell orders for such rebalances to maintain applicable portfolio requirements/index tracking (the "Rebalancing Algorithm"); (2) identify tax- loss harvesting opportunities and initiate buy/sell orders to harvest such tax-losses (the "TLH Algorithm") in taxable accounts and (3) locate certain assets and asset classes in a tax efficient manner based on income and tax treatment (the “Location Algorithm”) are together referred to as the "Algorithms"). To manage a given portfolio VPIM may utilize one or multiple of these algorithms, depending on the services selected by a Client. SRI/ESG Choices Consistent with VPIM’s personalized portfolio management services, we offer Clients the option to integrate Socially Responsible Investing (SRI) and Environmental, Social and Governance (ESG) considerations into their portfolios. VPIM utilizes SRI/ESG ratings provided by

our vendors in conjunction with Client-selected preferences to tailor equity and fixed income investment portfolios to the specific restrictions or goals of the Client. In doing so, we employ asset selection procedures and portfolio risk management techniques to maintain broad diversification and prudent risk profiles of each portfolio. Finally, VPIM carries out investment decisions in accordance with the fiduciary duties owed to its accounts and without consideration of VPIM’s economic, investment or other financial interests. To meet its fiduciary obligations, VPIM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain Client portfolios. Accordingly, VPIM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its Clients, and to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its Clients on a fair and equitable basis over time. Sub-Advisory Services VPIM delivers portfolio management services on behalf of other Registered Investment Advisers (RIAs) and wealth managers on a sub-advisory basis. Sub-advisory arrangements may be provided on a discretionary or non-discretionary basis. In either arrangement, VPIM will work with the primary RIA to deliver portfolio management services in-line with the investor’s Investment Policy Statement and the specific mandate assigned to VPIM. Financial Planning VPIM works with a limited set of Clients to craft holistic financial plans. Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the Client. The Client is under no obligation to act upon the investment adviser's recommendation, and, if the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through the investment adviser. This statement is required by the California Code of Regulations, 10 CCR Section 260.235.2. VPIM is not currently taking on new Clients for financial planning services. Services Limited to Specific Types of Investments VPIM generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs, treasury inflation protected/inflation linked bonds, American Depository Receipts (ADRs), and non-U.S. equity securities. VPIM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions For sub-advised Clients, VPIM will tailor an investment program for each individual Client based on the instructions received from the Client’s adviser. For direct Clients, VPIM will work with Clients to define the investment program. In both cases, VPIM follows a multi-stage investment program grounded in three core steps: investor profiling, asset allocation, and individual asset selection. This will include a Client or advisor interview, typically captured digitally through our policy setting portal, to identify the Client’s specific needs and requirements resulting in an investment policy that will be executed by VPIM on behalf of the Client. VPIM may use model allocations together with a specific set of recommendations for each Client based on their personal restrictions, needs, and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent VPIM from properly servicing the Client account, or if the restrictions would require VPIM to deviate from its standard suite of services, VPIM reserves the right to end the relationship. E. Assets Under Management VPIM has the following assets under management as of December 31, 2023: Discretionary Amounts: Non-discretionary Amounts: Total Assets: $4.3465 Billion $0 Million $4.3465 Billion