Meeder Investment Management, Inc. (“MIM”) offers a complete range of equity, fixed income and cash management investment solutions through its wholly owned SEC registered investment advisers: Meeder Advisory Services, Inc. (“MAS”), Meeder Asset Management, Inc. (“MAM”), and Meeder Public Funds, Inc. (“MPF”). MIM’s principal owners are Robert Meeder, Jr. and Robert Meeder, Sr. All affiliates of MIM are located at 6125 Memorial Drive, Dublin, Ohio 43017 and share employees. Meeder Advisory Services, Inc. offers separately managed account, strategist and portfolio management services to third-party financial institutions and their clients. MAS also provides retirement plan services to plan sponsors and participants, including plan fiduciary and participant account management services. As of December 31, 2023, MAS’s regulatory assets under management were $1,442,357,951, all of which were managed on a discretionary basis. Private Wealth Management Acting as a portfolio manager, MAS provides investment management services for separately managed account programs (“SMA programs”) sponsored by independent financial services firms, including banks, broker-dealers, asset management platforms, and other investment advisers (“Program Sponsors”). In all such programs, MAS is selected by the Program Sponsor to provide investment management services for some or all of a client’s invested assets. Program Sponsors help clients select a suitable investment strategy and provide MAS with written information regarding the client’s investment objectives, guidelines or applicable restrictions. SMA program clients typically have limited direct contact with MAS investment professionals and the Program Sponsor is responsible for periodically contacting the client to ascertain whether any changes have occurred in the client’s financial circumstances or investment objectives. The Program Sponsor provides clients with account monitoring, advice and account services regarding accounts enrolled in the Private Wealth Management program. AVAILABLE PROGRAMS MAS offers its Private Wealth Management SMA program in several different forms, each of which shares a common investment management strategy. Where MAS has been selected as an investment manager in a wrap fee program, clients do not pay a fee directly to MAS, which receives a portion of the wrap fee charged by the Program Sponsor for asset management, trade execution, custody and reporting functions. In these programs, MAS assumes investment discretion to buy or sell securities and investments for the account consistent with the strategy selected by the client and any applicable investment guidelines or restrictions. MAS also offers SMA program services through dual contract arrangements, in which clients execute agreements directly with MAS and pay a separate asset management fee for its investment management services. In these programs, clients enter into a separate agreement with a third-party investment adviser or program sponsor who is responsible for account monitoring, advice and account services. Fees paid to MAS in dual contract arrangements are in addition to those paid by clients to the third-party adviser. In these programs, MAS assumes investment discretion to buy or sell securities and investments for the account consistent with the strategy selected by the client and any applicable investment guidelines or restrictions. Finally, MAS offers SMA program services through model or strategist programs. In these programs, MAS is retained by the Program Sponsor to provide model portfolios for a given set of objectives. MAS does not exercise investment discretion or directly trade accounts for these programs. The Program Sponsor retains investment discretion and may or may not elect to execute any or all of the transactions recommended for the account. Any fee paid to MAS in a model or strategist program is paid by the Program Sponsor from the platform fees charged to the client. MEEDER ADVISORY SERVICES, INC. | MARCH 28, 2024 PAGE 5 INVESTMENT MANAGEMENT SERVICES Private Wealth Management accounts offer personalized investment management tailored to each client’s individual goals. All Private Wealth Management accounts are managed to a personalized benchmark selected by the client. Securities are selected for the account consistent with the selected benchmark and strategy. Portfolios are based on a strategy suitable for the client’s investment objectives and risk tolerances but are individually tailored to reflect each client’s investment objectives, risk tolerance, and time horizon. Meeder may deviate from the selected strategy to account for client directed mandates, including tax-management. Clients in the Private Wealth Management program may select from a series of available strategies and personalized performance benchmarks. Meeder utilizes proprietary quantitative methodologies to select individual equities and exchange traded or mutual funds that meet the client’s individualized risk and return objectives. Private Wealth Management accounts may utilize individual equity securities to maximize the deferral of capital gains and allow for tax loss harvesting where that is an account objective. Private Wealth Management accounts offer the option to further customize the account and deviate from available benchmarks and strategies. For clients with Private Wealth Management accounts, MAS may develop a custom strategy to guide the realization of gains or losses in existing positions. MAS also designs custom portfolios for Private Wealth Management accounts around existing large or concentrated positions. Private Wealth Management clients may take other steps to customize the realization of gains or losses in the account in order to meet individualized objectives. CLIENT INVESTMENT GUIDELINES AND RESTRICTIONS In all Private Wealth Management accounts, clients may impose reasonable restrictions on the management of their accounts, including restrictions on particular securities or types of investments. In Private Access accounts, clients may customize the investment strategy with individualized investment guidelines. All account guidelines and restrictions will be reflected in the account agreement, application or other documentation applicable to the account. MAS may decline to accept investment guidelines or restrictions that, in its judgment, would be unduly restrictive or impractical in light of the selected strategy. The imposition of client guidelines or restrictions on any investment strategy will cause the account to differ from other clients utilizing the same strategy. Strategist Services Acting as a strategist, MAS provides investment advisory and sub-advisory services to broker- dealers, platforms, and investment advisers (“Financial Intermediaries”). While each model portfolio is designed to achieve a certain investment objective, they are not tailored to meet the needs of any particular client. The Financial Intermediary is responsible for determining whether a particular model portfolio is suitable

or appropriate to meet the investment needs of the client. MAS does not enter into investment management agreements with clients who select model portfolios or assume continuous supervision of the accounts. Financial Intermediaries who elect to offer model portfolios are typically responsible for trade execution, reporting, monitoring and client service tasks. MEEDER INVESTMENT PORTFOLIOS Meeder Investment Portfolios offer clients the opportunity to purchase a managed portfolio of Meeder Funds designed to meet a variety of investment objectives. MAS offers risk-based models designed to achieve objectives that balance growth and income with portfolio risk, age-based models designed to match specific investment objectives and risk tolerances with the investor’s current age and target withdrawal portfolios designed to achieve returns commensurate with an expected withdrawal rate throughout retirement. The portfolios consist principally or exclusively of Meeder Funds selected by the portfolio manager to meet specific investment objectives and risk tolerance levels. Meeder Funds are often the only investment options utilized for a Meeder Investment Portfolio. In other cases, MAS exercises a preference for its affiliated MEEDER ADVISORY SERVICES, INC. | MARCH 28, 2024 PAGE 6 proprietary mutual funds but may supplement the portfolio with limited third-party mutual funds to meet specific objectives. Clients select a portfolio that meets their needs. MULTI-MANAGER PORTFOLIOS Multi-Manager Portfolios are offered under different platforms and under several different names. Multi-Manager Portfolios consist of a combination of Meeder Funds and non-affiliated mutual or exchange-traded funds selected by MAS from those made available by the Financial Intermediary to meet specific investment objectives and risk tolerance levels. These portfolios are generally designed to diversify assets across a series of different investment management styles and asset classes. In some cases, MAS charges a management overlay fee for its portfolio management services. In addition, MAM, an affiliated investment adviser, receives investment management fees from the Meeder Funds for fund assets included in the portfolios. MEEDER EDGE Meeder Edge advisory consulting services are offered to investment advisers on a non- discretionary basis. Services include a comprehensive analysis of existing investment models, analytics and model portfolio recommendations. MAS will assist Meeder Edge clients with development of suitable investment policy statements and implementation of an investment committee and portfolio review process. Meeder Edge clients receive periodic reports tracking performance of the model to suitable benchmarks with recommendations for changes or further review. Meeder Edge services are offered on a model portfolio basis. Clients retain investment discretion and may or may not elect to execute any or all of the transactions recommended for the model portfolios. Most Meeder Edge portfolios include a tactical allocation to Meeder Funds as well as various other asset managers representing other asset classes or strategies. MAS selects managers based upon their particular expertise, product line, and how well they fit into the overall objectives of the portfolio; however, MAS will exercise a preference for its own Funds when selecting for tactical management objectives. Investment Consulting Services MAS offers professional investment consulting and management services for institutional clients. In this program, institutional clients engage MAS to provide advice on governance, investment objectives, asset allocation, portfolio strategy, manager selection and performance monitoring. Each Investment Consulting engagement is uniquely tailored to the needs of the institutional client and may include discretionary or non-discretionary management of an investment portfolio. Retirement Plan Services MAS also provides investment management services to retirement plan sponsors and their participants, including plan level investment management services, managed portfolio solutions, and participant level investment management services. PLAN LEVEL SERVICES MAS provides retirement plan sponsors with fiduciary investment management services. Acting as an ERISA Section 3(38) investment manager, MAS works with the plan sponsor to develop an investment policy statement detailing the methodology used to select, monitor and replace retirement plan investment options. In accordance with the terms of the retirement plan agreement and investment policy statement, MAS provides plan fiduciary services and exercises discretion to select, review and replace investment alternatives made available to participants in the plan. MAS representatives periodically report to plan sponsors and review the plan’s investment options and their suitability under the terms of the investment policy statement and retirement plan agreement. MEEDER RETIREMENT PORTFOLIOS Retirement plan sponsors also engage MAS to offer managed portfolio solutions to their participants. In this program, MAS enters into an agreement with the plan to offer managed portfolios to plan participants as a designated investment option under the plan. Pursuant to the agreement and investment policy statement, MAS exercises discretion in creating and maintaining the portfolios and directs the plan’s MEEDER ADVISORY SERVICES, INC. | MARCH 28, 2024 PAGE 7 recordkeeper to implement any changes to the portfolios. Participants select a portfolio that meets their needs from those made available by the plan. Available portfolios include risk-based portfolios designed to achieve a certain investment objective and risk tolerance, age-based portfolios that match an investment objective and risk tolerance with the participant’s current age, and target date portfolios that follow an incremental glidepath in which the asset allocation becomes more conservative over time. Meeder Retirement Portfolios may be constructed from proprietary Meeder Funds, non-affiliated mutual or exchange-traded funds. For portfolios constructed from Meeder Funds, the portfolio manager exercises a strong preference for Meeder Funds, but on some platforms may supplement the portfolio with limited third-party mutual funds to meet specific objectives. Participant Level Services Retirement plan sponsors may also designate MAS as a discretionary investment manager for participant accounts. Under this program, plan participants execute an investment advisory agreement with MAS and select from a series of portfolios, which may include Meeder Investment Portfolios containing Meeder Funds or portfolios built from non-affiliated mutual and exchange- traded funds. Plans may offer both risk-based portfolios designed to achieve a certain investment objective and risk tolerance and age- based portfolios that match an investment objective and risk tolerance with the participant’s current age. Participants select a portfolio that meets their needs from those made available by the plan.