Windham Capital Management, LLC (“Windham Capital,” “Windham,” or “Advisor”) is a Massachusetts limited liability company organized in 1988. The principal owner of Windham is Mark P. Kritzman. Investment Management and Advisory Services Windham offers a variety of investment products based on its proprietary research, and its investment solutions are used by privately offered investment funds, institutional investors, and individuals. Most of our discretionary solutions are multi-asset class and, with the exception of the private fund strategies , are primarily implemented using efficient, low-cost, fully transparent exchange-traded funds. Depending on client need, we offer both tactical and dynamic solutions that are designed to serve an array of investment objectives within a client portfolio including downside protection, volatility stabilization, income generation, and overall diversification of a client portfolio. Diversification neither assures a profit nor eliminates the risk of experiencing investment losses. For more information on Windham’s portfolio strategies, see “Item 8 ‐ Methods of Analysis, Investment Strategies and Risk of Loss,” below. Portfolio strategies implemented through the use of exchange-traded funds are available to the types of investors described in Item 7 – Types of Clients through separately managed accounts held by unrelated financial institutions and model delivery relationships. Windham Capital’s private fund strategies, which include Risk Premia and Commodity strategies are available primarily through interests in privately offered investment funds for high net worth and institutional investors that meet “accredited investor,” “qualified eligible purchaser,” and “qualified purchaser” standards. Windham offers Risk Premia and Commodity strategies to U.S. investors primarily through multiple Delaware limited partnerships (collectively, the “Private Funds”). Risk Premia and Commodity strategies may also be available to clients as a separately managed account. Typically, clients grant Windham discretionary investment management authority over the client’s assets or, alternatively, Windham provides only portfolio recommendations and other advisory services, in which

case the client retains the discretion to select the actual portfolio investments. In either case, Windham may allow a client may impose restrictions on investments made by Windham. Investors in the Private Funds do not have the right to participate in the management of such funds or impose restrictions on the types of investments the funds make. When we provide investment advice to clients regarding a retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with such client’s interests, so we operate under a special rule that requires us to act in the client’s best interest and not put our interests ahead of the client. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of a client when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in the client’s best interest;
• Charge no more than is reasonable for our services; and
• Give the client basic information about conflicts of interest. Investment Consulting Services Through its Windham Labs division, Windham provides investment services to institutional investors that wish to retain investment discretion. Windham also licenses proprietary software products for portfolio development to institutional investors (primarily broker-dealers, other investment advisers, asset managers, and trading customers of banks). Windham tailors investment consulting services to the individual needs of clients. Windham Capital does not accept trading authority with respect to the securities for which it provides only investment consulting services. * * * As of December 31, 2023, Windham Capital managed on a discretionary basis assets valued in the aggregate at approximately $611,852,065.