Nationwide Fund Advisors (“NFA”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (“Advisers Act”). NFA was organized in 1999 as an investment adviser and is a wholly-owned subsidiary of Nationwide Financial Services, Inc. (“Nationwide Financial”). Nationwide Financial, a holding company, is a direct wholly- owned subsidiary of Nationwide Corporation. All of the common stock of Nationwide Corporation is held by Nationwide Mutual Insurance Company, which is a mutual insurance company owned by its policyholders. NFA may do business, either individually or together with its affiliates Nationwide Fund Management LLC (“NFM”) and Nationwide Fund Distributors LLC (“NFD”), as “Nationwide Funds Group” or “Nationwide Investment Management Group.” NFA is an investment adviser to open-end management investment companies that are registered as such under the Investment Company Act of 1940, as amended (“1940 Act”), including those that operate as exchange-traded funds, and to an unregistered managed separate account that is sponsored by Nationwide Life Insurance Company (“Nationwide Life”), an affiliate of NFA. NFA also is an investment adviser to one or more collective investment trusts the units of which are offered to certain qualified retirement plans. During the course 2024, NFA plans to cease managing exchange-traded funds. Nationwide Large Cap Growth Portfolio NFA is the investment adviser to the Nationwide Large Cap Growth Portfolio (the “LCG Portfolio”), an unregistered managed separate account designed to provide investors with access to a specialized investment strategy through investment in a single portfolio. The LCG Portfolio is sponsored by Nationwide Life, which is affiliated with NFA, and is exempt from registration under the federal securities laws pursuant to an exemption available in Section 3(c)(11) of the 1940 Act and an exemption available in Section 3(a)(2) of the Securities Act of 1933, as amended (“1933 Act”). Interests in the LCG Portfolio are available as investment options only through participation in retirement plans described in Section 401(a) of the Internal Revenue Code of 1986, as amended (the “IRC”) and deferred compensation plans described in Section 457(b) of the IRC that are exempt from the provisions of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), whether directly or through participation in a group annuity contract that invests in the LCG Portfolio. The LCG Portfolio is governed by a Board of Managers consisting of employees of Nationwide Financial. Nationwide Collective Investment Trust NFA is the investment adviser to Nationwide Collective Investment Trust (“NCIT”), which consists of multiple series, or portfolios, that provide for the collective investment and reinvestment of assets of certain tax-exempt employee benefit plans. NCIT is exempt from registration under the federal securities laws pursuant to an exemption available in Section 3(c)(11) of the 1940 Act and an exemption available in Section 3(a)(2) of the 1933 Act. Interests in the various series of NCIT are available as investment options only through participation in retirement plans described in Section 401(a) of the IRC and deferred compensation plans described in Section 457(b) of the IRC that are exempt from the provisions of ERISA, whether directly or through participation in a group annuity contract that invests in NCIT. Global Trust Company (“GTC”) is the trustee of NCIT. Nationwide Funds NFA currently provides investment advisory services for Nationwide Mutual Funds, Nationwide Variable Insurance Trust, and certain series of ETF Series Solutions (collectively, the "Nationwide Funds"), each of which consists of multiple series, or portfolios (“Funds”). The Nationwide Funds are registered as open- end investment companies under the 1940 Act. The series of ETF Series Solutions for which NFA serves as investment adviser operate as exchange-traded funds (“ETFs”). The Nationwide Funds are governed by their respective Boards of Trustees, the majority of which are independent of Nationwide Mutual, Nationwide Financial, Nationwide Life and NFA. Investment Advisory Services NFA provides its investment management services through Nationwide Life products, on behalf of the

LCG Portfolio, NCITs, and to each of the Nationwide Funds (collectively, “Client Accounts”). In fulfilling this role, NFA provides, or arranges for the provision of, a continuous investment program and overall investment strategies for each Client Account. Investment advice to the Client Accounts is provided in accordance with the terms and conditions of investment advisory agreements between NFA and the Client Accounts, and is based on the investment objectives, policies and restrictions as set forth in each Client Account’s investment advisory agreement, prospectus or offering memorandum, as applicable. NFA determines, or arranges for others to determine, what securities and other investments will be purchased, retained, or sold by each Client Account, and executes, or arranges for others to execute, portfolio transactions with such broker-dealers as may be so selected. For Client Accounts that meet their objectives by investing primarily in other investment companies or collective investment trusts (“Funds-of-Funds”), NFA usually provides all such services directly. For all other Client Accounts (including certain Funds-of-Funds for which NFA does not provide such services directly), NFA delegates certain investment discretion, trading, and other functions to one or more subadvisers (“Subadvised Accounts”). For the Subadvised Accounts, NFA delegates direct portfolio management functions to one or more other registered investment advisers that serve as subadvisers. Any such delegation of functions to a subadviser for the LCG Portfolio is subject to the approval of the LCG Portfolio’s Board of Managers in accordance with the investment advisory agreement between NFA and Nationwide Life. Any such delegation of functions to a subadviser for NCIT is subject to the approval of GTC as the trustee. For any Fund that is a Subadvised Account (a “Subadvised Fund”), any such delegation of functions to a subadviser is subject to the approval of the applicable Fund's Board of Trustees and, if required by applicable law, the Fund's shareholders, consistent with the requirements of exemptive relief that NFA and the Nationwide Funds have obtained from the Securities and Exchange Commission (“SEC”) in respect to the selection of subadvisers (“Manager-of-Managers Order”). Where NFA delegates functions to a subadviser, it researches and recommends the selection of the subadviser, negotiates a contract with the subadviser, determines the allocation of Subadvised Account assets among that and possible other subadvisers, and supervises the subadviser's activities, investment performance, adherence to the Subadvised Account’s investment objective, style mandate and policies, and compliance with such policies and all applicable regulatory requirements. The activities performed by NFA in this regard, include, but are not limited to:  Performing initial due diligence on prospective Subadvisers;  Monitoring subadviser performance, including conducting on-going analysis and periodic consultations;  Communicating performance expectations and evaluations to subadvisers;  Making recommendations to the applicable Fund's Board of Trustees, LCG Portfolio’s Board of Managers, the ESS Trust or GTC regarding renewal, modification, or termination of a subadviser’s contract; and  Selecting and monitoring approved subadvisers. Please see Item 8 below for additional information on the subadviser selection process. While NFA normally does not provide direct discretionary advisory services with respect to the assets of a Subadvised Account, NFA retains the right to do so and maintains full discretionary investment authority pursuant to its advisory agreements with each Subadvised Account. In addition, as described further in Item 8 below, NFA may direct the investment of cash balances that remain uninvested by approved subadvisers. As of December 31, 2023, NFA had $76 billion of assets under discretionary management. Of this amount, $52.3 billion represented assets held by Subadvised Funds, $21 billion represented assets held by registered Funds-of-Funds, $434.5 million represented asset held by the LCG Portfolio, $1.6 billion represented assets held by subadvised CITs and $876 million represented assets held by Fund-of-Funds CITs. Most Funds-of-Funds invest the majority of their respective assets in shares of certain Subadvised Funds.