Frontier manages equity portfolios generally on a discretionary basis. The Firm has been in business since 1980. Frontier currently has 41 employees working in the Firm’s sole office in Boston. As of December 31, 2023, Frontier had approximately $10.1 billion in assets under management. Frontier principally serves as an investment adviser or sub-adviser to various institutional investors, including, but not limited to, corporate and public pension and profit- sharing plans, charitable institutions, foundations, endowments, municipalities, other public and private institutions, mutual funds, collective investment trusts and private investment funds sponsored and managed by Frontier (referred to collectively as “clients” in this Brochure). Please see Item 7 of this Brochure for more information with respect to Frontier’s clients. Principal Ownership Frontier’s institutional partner, Affiliated Managers Group, Inc. (“AMG”), holds a majority equity interest in Frontier, with Frontier employees holding the remaining ownership interests. AMG’s equity interest in Frontier is structured so that Frontier maintains operational autonomy in managing its business. AMG, a publicly-traded asset management company (NYSE: AMG), also holds equity interests in other investment management firms (“AMG Affiliates”). Further information on both AMG and AMG Affiliates is provided in “Item 10 – Other Financial Industry Activities and Affiliations.” Advisory Services Frontier is an investment manager specializing in growth and value equity portfolios for institutions. Our primary focus is our internally generated fundamental research. Through in- depth “bottom up” analysis, we identify companies that we believe have the potential to show above average returns for our clients' portfolios. Our team of investment professionals provides a wide range of industry coverage and individual company analysis. As an asset manager for our clients, Frontier recognizes that all of our clients are unique and that, therefore, their investment needs may be different. As such, we may modify our primary investment strategies, as necessary, to meet the goals that our clients specify, in an effort to accommodate the particular investment objectives and accompanying restrictions requested by our clients. At the commencement of the client relationship, each of our clients executes an investment management agreement, which sets forth their

investment objectives, investment strategy and any investment restrictions that will be applicable to our management of the assets in the client’s account. Prior to the execution of the agreement, we review requested objectives and restrictions and work with the client as needed to refine these objectives and restrictions to both meet the client’s needs and provide us with sufficient discretion to properly invest the client’s assets. In some instances, certain investment restrictions imposed by a client may increase the client account’s concentration in certain sectors, securities, or cash instruments, for periods of time, especially in comparison to other client accounts following a similar investment strategy with limited or no investment restrictions. A small number of clients are privately offered investment funds sponsored and managed by Frontier (“Private Funds”) that are available only to qualified institutional and individual investors (“Private Fund Investors”). With respect to each Private Fund, which commingles the contributions of all investors in a single portfolio managed on their behalf, the investment objectives and guidelines are described in the Private Fund’s offering documents. Frontier also provides investment advice not involving discretionary management services, such as diversified manager allocation products, which include the provision of a model portfolio. In these instances, another manager is the discretionary investment manager, has investment discretion over the accounts, and is responsible for monitoring the individual needs of the client. Frontier amends and updates the model portfolios from time to time and provides updated information to the sponsor. These updates are typically communicated after Frontier has completed trading activity in that security on behalf of clients for whom Frontier has trading discretion. Therefore, discretionary managers of these model portfolios will typically not obtain the same level of or as timely an execution as if Frontier had investment discretion over these client accounts. Accordingly, the discretionary manager may experience performance and other differences from similarly managed accounts advised by Frontier. Assets Under Management As noted above, as of December 31, 2023, Frontier’s client assets under management total (“AUM”) was approximately $10.1 billion. Please see Frontier’s Form ADV Part 1A – Item 5.F for more information.