Firm Description Although its roots go back to 1986, Mount Lucas Management, LP (“Mount Lucas”) was reorganized as a Delaware limited partnership in December of 2010. It’s predecessor, Mount Lucas Management Corporation (the “Corporation”) was formed in 1986 to act as an investment manager to institutional investors and high net worth individuals. Mount Lucas is registered as an investment adviser with the SEC under the Investment Advisers Act of 1940, as amended. It is also registered as a commodity trading advisor and a commodity pool operator under the U.S. Commodity Exchange Act, as amended; and a member of the U.S. National Futures Association, a self-regulatory organization authorized by the U.S. Commodity Futures Trading Commission. The principal address of Mount Lucas is 405 South State Street, Newtown, Pennsylvania; telephone (267) 759-3500. Principal Owners Mount Lucas is managed by its general partner, MLM LLC (the “General Partner”), a Delaware limited liability company. The members and managers of the General Partner are Roger E. Alcaly, Paul R. DeRosa, Raymond E. Ix, Jr., Timothy J. Rudderow Sr., and Gerald Prior III. In order to recognize the contribution and efforts and broaden equity ownership of Mount Lucas, the firm added several long-term employees as partners in 2022. At the same time, the Corporation, which had been a principal owner of Mount Lucas, was closed in order to simplify the ownership structure. Mount Lucas is over 90% employee owned, and no person owns more than 25%. Types of Advisory Services We offer clients a range of investment products that include actively managed strategies and proprietary passive indices. Our long-term tenure in the investment industry attests to our commitment to diversification, liquidity, risk management, and transparency. Mount Lucas offers several distinct investment strategies:  Our global macro strategy, MLM Macro-Peak™, combines quantitative and discretionary trading across the world’s major asset classes.  Our large cap equity strategy, MLM Focused Equity™,

uses value and momentum criteria to select S&P 500 stocks.  Our diversified futures index strategy, the MLM Index™, is both an investable index and a widely recognized benchmark for managed futures performance.  Our quantitative liquid alternative strategy, MLM Symmetry , seeks to capture the investment premiums generated by assuming economic risks in global markets. In implementing a particular strategy, Mount Lucas invests in listed or unlisted equity securities, such as common stock, preferred stock or some convertible securities, commodities, futures, options, bonds (including rated and unrated corporate bonds and bonds issued by sovereign governments and their agencies) and currencies, primarily through exchange-traded, liquid instruments. Our strategies differ in terms of their asset class participation, investment approach, return objective, and risk threshold. Within each strategy, we offer customized products and programs that directly target the needs and objectives of our clients. Terms in respect of specific asset classes, limitations of the types of securities, futures contracts or instruments are specified in the respective advisory agreement for a managed account client and/or in the Confidential Offering Memorandum for a particular product managed by Mount Lucas. Mount Lucas provides portfolio management services to wrap fee programs, and receives a portion of the wrap fee. Wrap fee accounts are not managed differently than other advisory accounts. As of February 28, 2024, Mount Lucas had approximately U.S. $1.43 billion of assets under discretionary management. Tailored Relationships Our strategies differ in terms of their asset class participation, investment approach, return objective, and risk threshold. Within each strategy, we offer customized products and programs that directly target the needs and objectives of our clients. Terms in respect of specific asset classes, limitations of the types of securities, futures contracts or instruments are specified in the respective advisory agreement for a managed account client and/or in Confidential Offering Memorandum for a particular product managed by Mount Lucas.