Overview Wilmington Trust Investment Management, LLC (“WTIM,” “our,” “we” or the “Firm”), organized in 2001, is a wholly-owned subsidiary of M&T Bank Corporation, a publicly traded bank holding company (NYSE: MTB). WTIM offers investment advisory services to Clients in WTIM’s Separately Managed Account Program, whereby WTIM offers discretionary investment services. This WTIM Form ADV Part 2A Brochure (the “Brochure”) is intended to provide information regarding our firm and its Separately Managed Accounts (“SMA”) Program. This Brochure describes WTIM’s role in connection with services it provides to its SMA clients ( “client”, “you” and “your”), including the scope of advisory services provided and the fees associated with an SMA Account, as well as investment risks clients should be aware of in connection with the Firm’s SMA services. This Brochure also describes WTIM’s other business activities, financial industry affiliations, and the related economic and other benefits creating conflicts of interest in certain situations. As of the date of this brochure, WTIM had estimated discretionary assets under management of approximately $188,937,6511. WTIM leases designated personnel from one or more of the following affiliates: Wilmington Trust Investment Advisors, Inc. (“WTIA”), Wilmington Trust Company (“WTC”), Wilmington Trust, N.A. (“WTNA”), and/or Manufacturers and Traders Trust Company (“M&T Bank”). Such personnel, as employees of WTIM, provide WTIM investment management related services. Account Establishment In order to participate in the WTIM SMA Program you will enter into a written agreement directly with WTIM (“Agreement”). Clients entering into an Agreement with WTIM to establish an investment management account are appointing WTIM as their agent to invest, reinvest and manage the assets and investments in such account on a discretionary basis. Your decision to engage WTIM as your investment manager is subject to WTIM’s acceptance. Once accepted by WTIM, the Agreement will establish WTIM’s investment advisory relationship with you as a client and describe the scope of WTIM’s services and obligations to you. Your account assets are invested in various exchange-traded products,

mutual funds, individual securities, closed-end funds, and/or model portfolios (collectively, “Investment Vehicles”) pursuant to the investment policy statement established for your account. WTIM may use other types of Investment Vehicles in the future as it deems appropriate to pursue the investment objectives for each account. WTIM maintains full and complete discretion over the selection of the Investment Vehicles included in each account. On an ongoing basis, your investment advisor representative (“IA”) will be responsible for responding to your questions and discussing whether the management of your account continues to reflect your investment objectives. You should promptly notify your IA if material changes occur in your financial circumstances, your investment objectives change or if you wish to impose or modify restrictions pertaining to the management of your account. 1 Total assets under management are estimated based upon data as of December 31, 2023 with respect to current accounts. It is important that you read and review all communications, including any performance reports, trade confirmations and monthly account statements that we send to you. These materials could provide you notification of important changes, and/or contain important information, related to your account. You should promptly notify your IA if you have questions about any communications or believe the information provided is inaccurate. Investment Restrictions You will have the opportunity to impose reasonable restrictions on the management of your account. You may request that specified securities or, in some cases, categories of securities not be purchased for your account. However, WTIM reserves the ability to decline restrictions it deems unreasonable. You will not be able to impose restrictions on individual holdings in a mutual fund or exchange-traded fund. Please be aware that accounts with investment restrictions may perform differently than accounts without restrictions; performance may be lower or higher for accounts with restrictions than those without restrictions. Restrictions may also cause your account performance to vary from other accounts invested pursuant to a similar investment strategy.