Choate Investment Advisors LLC (“ChoateIA” or “we”) is an SEC registered investment advisor and subsidiary of Choate, Hall & Stewart LLP (“CHS”), a Boston, Massachusetts law firm. Originally established in 1996 primarily to provide investment advisory services to CHS attorneys who serve as trustees, ChoateIA now provides investment advisory services, financial planning, and wealth management services to a variety of clients, including high net worth individuals, trusts, charitable foundations, donor advised funds, and endowments. We believe that asset allocation is the primary determinant of long-term investment performance. The proper combination of asset classes can improve the overall return of a client’s portfolio and help to mitigate risk. Our process seeks to deliver strong results consistent with the client’s objectives and a defined level of risk. We believe that an investment strategy should be founded upon two core principles: long-term discipline (the fundamental reason to have a strategy is to provide a meaningful framework for discipline) and diversification (the strategy should specify how risks will be managed to meet a specified risk tolerance). We believe that a proper asset allocation strategy must be founded upon a clear understanding of appropriate risk. We begin our relationship with clients with a discussion about the client’s willingness and ability to take risk, and the risk level of various potential strategies. Together with the client, we identify an appropriate risk level based upon assumptions regarding future market volatility. Our role is to manage to that risk level as responsibly and productively as possible via a diversified asset allocation strategy. ChoateIA typically manages money for clients on a “discretionary” basis, though certain accounts are non-discretionary. In any event, we strive to ensure that clients are positioned in a portfolio strategy that corresponds to their needs at a risk level which is appropriate for them. The execution of the investment strategy is tailored to each client’s needs. For example, we will often work with taxable clients to establish a capital gains “budget” and aim

to limit capital gains realized in client portfolios over a specific period. We also will discuss client preferences for restricting investments in certain securities or types of securities, for example, socially responsible investing. Additionally, ChoateIA may appoint subadvisors to manage all, or a portion, of certain client accounts, to the extent permitted under the investment management agreement between ChoateIA and the client. In selecting subadvisors, ChoateIA considers the following quantitative and qualitative factors:
• screening prospective advisors based on risk-adjusted returns and consistency;
• holdings and returns-based stylistic analysis;
• fees and expenses; and
• personal interviews with the firm. From time to time, ChoateIA also offers advisory services on assets and portfolios managed outside of ChoateIA to offer the client guidance on items that would otherwise not be included in the scope of the relationship. These advisory services are billed at an hourly rate discussed below in Item 5. ChoateIA also advises two private investment funds established by ChoateIA in 2018 and 2021, which invest in a diversified portfolio of other private funds managed by unaffiliated third parties, as more fully described below (the “Funds”). ChoateIA established the Funds as vehicles in which its clients and employees may invest to gain exposure to private investments, and will invest primarily in private equity, but could also opportunistically invest in select diversified private investment opportunities (e.g., real assets, real estate, and private credit) if a situation which the Manager believes is attractive arises. As of December 31, 2023, ChoateIA managed accounts, including accounts of high net worth individuals, trusts, charitable foundations, donor advised funds, and endowments, on a discretionary basis with assets of approximately $6,720,519,964. In addition, as of that date, ChoateIA advised accounts with assets of approximately $776,419,404on a non-discretionary basis. The majority of the assets managed by ChoateIA are held in trusts with respect to which CHS attorneys serve as fiduciaries.