Firm Overview Galliard Capital Management, LLC, (“Galliard”) is an institutional investment advisory firm that has specialized in customized fixed income active management against client-driven objectives and benchmarks as well as stable value management for qualified retirement plans, deferred compensation programs and 529 plans for more than 25 years. Galliard is a wholly-owned subsidiary of Allspring Global Investments Holdings, LLC (“Allspring Holdings”). Allspring Holdings is owned by two private equity firms, GTCR LLC (“GTCR”) and Reverence Capital Partners, L.P. (“Reverence Capital Partners”). Refer to Item 10 of this Brochure for information about Galliard’s Allspring Holdings affiliates. Certain employees of the Allspring Investments group of companies including Galliard, own non-voting, limited liability company interests in Allspring Group Holdings, LLC (“Allspring Group Holdings”), the indirect parent of Galliard and the Allspring Investments group of companies (“Allspring”). Such Allspring and Galliard employees collectively hold less than 25% of the fully diluted equity interests of Allspring Group Holdings. In addition, Wells Fargo owns a passive non-voting equity interest of less than 8.3% of the fully diluted equity interests of Allspring Group Holdings. Founded in 1980, GTCR is a leading private equity firm focused on investing in growth companies in the Healthcare, Financial Services & Technology, Technology, Media & Telecommunications, and Growth Business Services Industries. The Chicago-based firm pioneered The Leaders Strategy™ — finding and partnering with management leaders in core domains to identify, acquire, and build market-leading companies through transformational acquisitions and organic growth. Since its inception, GTCR has invested more than $20 billion in over 250 companies. Reverence Capital Partners is a private investment firm focused on thematic investing in leading global, middle-market financial services businesses through control and influence- oriented investments in five sectors: (1) Depositories and Finance Companies, (2) Asset and Wealth Management, (3) Insurance, (4) Capital Markets and (5) Financial Technology/Payments. The firm was founded in 2013 by Milton Berlinski, Peter Aberg, and Alex Chulack, who collectively bring over 90 years of advisory and investing experience across a wide range of financial services sectors. Galliard operates autonomously from its parent company in terms of investment management and client service. However, for certain functions, including but not limited to human resources, enterprise technology and vendor management, Galliard utilizes Allspring. Additionally, Galliard’s dedicated operational, legal and compliance resources are integrated with their Allspring counterparts. March 1, 2023 | 2 Prior to November 1, 2021, Galliard was owned by Wells Fargo & Company (“Wells Fargo”). Given the large scale and complexity of the divestiture to new ownership, some technology infrastructure, operational processes and certain Galliard employees temporarily remain at Wells Fargo to manage critical processes and systems that transition over time, under a Transition Services Agreement (“TSA”) between Allspring Holdings and Wells Fargo. Galliard has two Senior Managing Principals, Michael (Mike) Norman and Ajay Mirza who are responsible for the strategic management of the firm. Effective October 1, 2022, Mike Norman became President of Galliard. Mike Norman is also responsible for client service, sales and consultant relations. Ajay Mirza is responsible for Galliard’s investment process, strategy and oversight of client portfolios. Since its inception in 1995, Galliard has consistently managed its client accounts using a team approach, with responsibilities generally assigned by asset sector or strategy. The biographies of the individual professionals who have accountability for the management of client assets are included in Galliard’s Brochure Supplement, ADV Part 2B. As of 12/31/2022, Galliard managed $91,336,254,196 on a discretionary basis and $641,171,969 on a non-discretionary basis, which includes all assets in stable value investment options for which Galliard provides investment advisory services. Galliard Operating Structure Galliard maintains two primary oversight groups, the Operating Council and the Investment Council, each of which oversees specific sub-groups and/or working groups. Membership on the primary oversight councils includes Galliard executive management, senior management, and Galliard staff with relevant functional responsibilities. Galliard periodically reviews the structure and responsibilities of its groups and working groups reporting up through the two primary oversight councils and refines responsibilities or structure as necessary to facilitate strategy implementation and oversight. Galliard’s Operating Council: Galliard’s Operating Council is led by Galliard’s President and includes senior leadership representing all areas of the firm, including Galliard’s Chief Compliance Officer. The primary purpose of the Operating Council is to oversee Galliard’s financial and operational performance, including business development, technology, compliance and risk management. The Operating Council, has delegated responsibilities to certain working groups, which report to the Operating Council as follows:
• Compliance Working Group: Chaired by Galliard’s Chief Compliance Officer, Galliard’s Compliance provides oversight of Galliard’s compliance program, including policy development, compliance testing, issue remediation and regulatory inquiries and examinations. The Compliance Working Group also reports into the Allspring Compliance Committee to facilitate consistent governance and policies where appropriate.
• New Business & Fee Working Group: Galliard’s New Business & Fee Working Group meets as needed to review and approve new business opportunities, March 1, 2023 | 3 approve investment management fee schedules for new or existing clients and provides oversight of agreements between Galliard and its clients or other third parties. Galliard’s Investment Council, described below provides reporting on Galliard’s management of client portfolios to Galliard’s Operating Council as needed for the Operating Council to oversee Galliard operations and structure. Galliard’s Investment Council: Ajay Mirza, Senior Managing Principal serves as Chair of Galliard’s Investment Council. The primary purpose of

the Investment Council is to evaluate and approve recommended changes to Galliard investment strategies and provide oversight of Galliard’s management of its clients’ stable value and fixed income accounts. The Investment Council’s oversight includes performance, trading, the use of external (unaffiliated) investment managers, valuation, including issues related to stable value investment contract compliance and remediation related to trade errors. The Investment Council and its two key strategy groups generally meet monthly. The working groups reporting to the two key strategy groups meet as needed, generally at least quarterly. The Strategy Groups and their working groups are:
• Stable Value Strategy Group: Responsible for establishing and overseeing the implementation of Galliard’s stable value strategies, compliance with stable value investment contract guidelines, including the work of the following working groups: o Investment Contract Review Working Group: Provides oversight and approval of stable value investment contract terms and standards as utilized by Galliard. o External Manager Oversight Working Group: Reviews investment performance, compliance and ongoing due diligence results related to external (unaffiliated) investment managers used by Galliard clients seeking diversification as part of a multimanager stable value strategy.
• Fixed Income Strategy Group: Responsible for establishing and overseeing the implementation of Galliard’s fixed income strategies, including the work of the following working groups: o Credit Working Group: Evaluates the results of credit analysis conducted on fixed income securities (and issuers) as well as the creditworthiness of investment contract issuers. o Fixed Income Valuation Working Group: Oversees execution of Galliard’s Valuation Procedures and determines and/or approves valuations that cannot be determined using third party valuation sources. The Fixed Income Valuation Working Group also reports into the Allspring Valuation Committee to facilitate consistency of valuation practices. o GIPS® Working Group: Reviews and recommends changes to Galliard composites, implementation of changes to GIPS requirements and the March 1, 2023 | 4 results of Galliard’s independent review of GIPS compliance. The GIPS® Working Group also coordinates with the Allspring GIPS Committee o Environmental, Social, and Governance (“ESG”) Working Group: Oversees adherence to, and implementation of, the Principles for Responsible Investment and monitoring developments with the ESG marketplace, accordingly. Galliard believes that our integrated team approach and operating oversight structure are key to supporting the fixed income and stable value strategies and products offered to our clients. Galliard’s operating structure facilitates consistency and integration in the implementation of Galliard’s management strategies and risk management processes, provides opportunities for cross-training and development and supports personnel across the firm in their Galliard roles. Galliard also believes that this operating and governance structure is an important component of succession planning. The following is a summary of Galliard’s investment management services: Stable Value Management. Galliard offers its stable value management services in either separate account or collective fund strategies to plans qualified under Sections 401(a), or 401(k) of the Internal Revenue Code, 457(b) plans for governmental entities, 529 plans for qualified tuition programs or collective investment trusts under the Internal Revenue Service Ruling 81-100. Galliard’s stable value management is designed to provide clients with vehicles for investment in a portfolio of securities and other financial instruments having fixed income characteristics, including, but not limited to, guaranteed investment contracts and security backed contracts, with the objectives of preserving capital and obtaining a moderate level of return. Galliard’s stable value strategy can be customized for separate account clients including those seeking manager diversification as part of a multimanager strategy as further described in Item 16. For qualified accounts and certain governmental plans seeking investment and reinvestment in a collective vehicle, Galliard serves as advisor to the Galliard Stable Return Fund (“SRF”) and the Galliard Managed Income Fund (“MIF”). The purpose of SRF and MIF is to provide qualified accounts with a vehicle for collective investment and reinvestment in a portfolio of securities and other financial instruments having fixed income characteristics, including, but not limited to, guaranteed investment contracts and security backed contracts, with the objectives of preserving capital and obtaining a moderate level of return. SRF and MIF are collective investment funds managed and trusteed by SEI Trust Company. In certain cases, Galliard also provides daily valuation services for defined contribution stable value portfolios. March 1, 2023 | 5 Fixed Income Management Galliard offers customized actively managed fixed income separate account management against client-driven objectives and benchmarks to institutional clients including corporations and U.S. and local government entities. Our fixed income philosophy and approach attempts to generate income and control risk. Additionally, Galliard offers a customized strategy utilizing securities rated below investment grade, unrated, or subject to a higher risk of default at the time of purchase (“High Yield”). These securities generally present a greater risk of loss and experience more price volatility than investment grade securities. Galliard serves as investment advisor to certain fixed income collective funds, which are managed and trusteed by SEI Trust Company. The purpose of these collective funds is to provide qualified accounts with a vehicle for collective investment and reinvestment in a portfolio of fixed income securities. Galliard also provides underlying fixed income management for insurance company separate accounts. Allspring Funds Management, LLC Mutual Funds - Fixed Income Funds Galliard provides fixed income sub-advisory services to its affiliate, Allspring Funds Management, LLC, in managing certain mutual fund assets in the Allspring Master Trust, which are distributed by Allspring Funds Distributor, LLC, member NYSE/SIPC. March 1, 2023 | 6