Russell Investments Implementation Services, LLC (“RIIS”) is part of Russell Investments (defined below), a global investments solutions company. Headquartered in Seattle, Washington, Russell Investments operates globally with other offices in various financial centers around the globe. RIIS and its affiliates are indirect wholly-owned subsidiaries of Russell Investments Group, Ltd., a Cayman-domiciled company (“Russell Investments” or “RI”). The limited partners of certain private equity funds affiliated with TA Associates Management, L.P. indirectly hold a majority ownership interest, and the limited partners of certain private equity funds affiliated with Reverence Capital Partners, L.P. indirectly hold a minority ownership interest in Russell Investments. Hamilton Lane Advisors LLC, a private markets firm, along with current and former management of Russell Investments also hold minority positions in Russell Investments. References to “we”, “us”, and “our” refer to RIIS unless the context otherwise requires. We provide investment advisory services to institutional clients including other financial services companies, corporations, employee benefit plans and not-for-profit organizations. We also provide services to series portfolios (each a “Fund”) of open-ended investment companies (“mutual funds”) registered under the Investment Company Act of 1940, as amended (“Investment Company Act”) and to pooled investment vehicles not required to be registered under the Investment Company Act (“Private Funds”). Our investment advisory services include advisory implementation, transition management, and investment management services. The section below provides a summary of each of these services. Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, for more information regarding our investment strategies. Our investment advisory services are based on investment guidelines and restrictions that are developed in consultation with the client, or in accordance with the mandate selected by the client. Each portfolio managed or otherwise advised by us is managed in accordance with investment guidelines and restrictions of the portfolio. Depending on the investment strategy or strategies a client wishes to pursue, a client’s contractual relationship may be with RIIS and one or more of its affiliates. RIIS has been a registered investment adviser since June 13, 2001. RIIS is also registered as a broker-dealer with the SEC under the Securities Exchange Act of 1934, as amended (the “Exchange Act”); is a member of the Financial Industry Regulatory Authority (“FINRA”); and a member of the Municipal Securities Rulemaking Board (“MSRB”). As of December 31, 2023, RIIS had $80,625,546,336 in discretionary and $2,031,604,321 in non-discretionary regulatory assets under management. ADVISORY IMPLEMENTATION SERVICES The implementation services we provide clients generally involve a combination of advisory, brokerage and other activities, and may be provided as part of a manager change, portfolio rebalancing, policy implementation, or other investment management services designed to complete the client’s desired investment program structure. We provide the following advisory implementation services to clients: Russell Investments Implementation Services, LLC / Form ADV Part 2A / 6 Overlay Services Institutional investment portfolios are often overseen by several money managers, which can create challenges in keeping investment exposures within desired ranges. We provide overlay investment advisory services using securities, derivatives, and other instruments, designed to keep a client’s overall assets aligned with its investment policy. We create an investment framework for improved visibility into investment exposures and the ability to control those exposures using our overlay services. Our overlay services include a combination of administrative coordination, cash, and exposure management. The overlay services seek to reduce performance tracking error, inefficient cash flow management, asset allocation mismatch, unintended structural biases, and implementation delay. The objective is to reduce risk (defined as tracking error relative to the policy portfolio or target), improve portfolio returns, and reduce the administrative burden associated with frequent cash flows. Specific overlay services include: Policy Implementation Many institutional portfolios are managed to a Strategic Asset Allocation (“SAA”), but as time passes, these exposures drift in relation to one another. A disciplined rebalancing plan helps to keep such risk under control. With daily oversight of portfolio positioning, we manage exposures to asset classes in the SAA via overlay exposures that address cash and rebalancing policy issues. Cash Equitization Cash is necessary for liquidity purposes. Our solutions convert cash exposures to equity and/or bond exposures using derivatives, adjusting for total cash holdings on a daily basis. Our turnkey management service adjusts exposures and handles the downstream aspects of managing those positions. Beta Transformation The mix of asset classes (or “betas”) in the SAA do not always coincide with the best excess return (or “alpha”) opportunities. Our beta transformation strategies reduce undesired asset classes and add desired asset classes using an overlay program. Downside Protection Institutional clients generally need to maintain exposure to risk assets over the long term in order to meet expected return targets. We offer risk management tools designed to reduce the frequency and/or magnitude of drawdowns in portfolio value resulting from significant market declines. Liability Based Solutions Our liability-based solutions clients are defined benefit pension plans, whose current and former employees are depending on future payouts of their pensions to fund their retirement. We have developed a holistic approach to help pension plans achieve and maintain funded status and take into account unexpected contributions, balance sheet volatility and increasing expenses through Russell Investments Implementation Services, LLC / Form ADV Part 2A / 7 the use of liability-driven investing (“LDI”). LDI is refocusing management of a pension plan’s assets away from an “asset only” approach to an approach that considers both the assets and specific liabilities of the pension plan, as well as the financial situation of the plan’s sponsor. Success of the plan’s investment strategy is then measured relative to the behavior of the plan’s liabilities, how funded status improved during the period, and the decreasing volatility of the funded status. Our LDI team includes a team of credentialed actuaries with knowledge of pension regulations and the pension environment, as well as knowledge of plan design and the impact of different management strategies, including open pension plans versus closed or frozen plans, and cash balance plans. Currency Services Agency Foreign Exchange Service (Currency Trading) We provide discretionary and non-discretionary currency trading and implementation services pursuant to our registration as an investment adviser. Through this service, clients outsource their foreign exchange (“FX”) trading to us. The service involves various combinations of trading and settlement services designed to help clients improve the implementation of their currency investment strategies. Currency Management We offer passive, dynamic, and absolute currency overlay services to help clients manage the risk that results from currency exposure within their portfolios. We work with each client to implement a suitable custom hedging program including unique currency exposures, performance benchmarks (custom or public), tracking error tolerance and preferred strategic hedge ratio (fixed or variable). This service seeks to effectively reduce portfolio volatility. TRANSITION MANAGEMENT SERVICES We generally provide the following transition management related services under our registration as an investment adviser; however, we may perform transition services in our capacity as an agency-only broker-dealer for certain assignments. Transition Management Services Transition management is the process of converting a portfolio from one manager to another. We provide a combination of analysis, strategy development, implementation, trading and brokerage services designed to reduce the total cost and risk associated with a reallocation of assets from an existing portfolio of securities, cash and/or other assets to a portfolio of securities, cash and/or other assets identified by the client and/or the money manager who will receive the assets. Transition services are generally provided as an investment adviser; however, we may perform transition services in our capacity as an agency-only broker-dealer for certain assignments. In configuring the portfolio to be received by the new money manager, we generally do not review or assess the investment decisions made by the client and/or the money manager who will receive that portfolio. We do not select securities or other instruments for investment of transition assets, except to the extent that we have been authorized to invest in financial futures, securities, or other Russell Investments Implementation Services, LLC / Form ADV Part 2A / 8 instruments to achieve desired

exposures during the course of a transition or until a final target portfolio can be identified. Interim Management Services Interim investment services provide temporary management of assets to gain exposure to, or hedge against, a particular class of investments or benchmark. Interim investment management is most often used when:  There are changes in outlook or market fundamentals and a client, for example, decides to implement a new asset allocation policy, reduce exposure to the equity market, or rebalance policy target allocations;  A large cash inflow needs to be invested, for example, from an investment, or as part of a spin-off or acquisition; or  There are unexpected changes to the current investment manager, including the departure of key personnel, changes in investment management style, or performance. We provide interim management services using financial futures, securities, or other instruments to obtain desired exposures for specified periods according to client instructions while the client’s final target portfolio and money manager structure is being determined. INVESTMENT MANAGEMENT SERVICES We offer a range of investment management services focused on identifying and solving clients’ needs with risk adjusted solutions. We blend our core capabilities including capital markets insights, asset allocation, manager research, portfolio implementation and factor exposures to design, construct and manage portfolio. Portfolios are often invested using a “multi-style multi- manager” open-architecture approach, which may include assets managed by us, our affiliates and third-party investment managers (“money managers”). Asset Allocation Our asset allocation process incorporates information about the potential implications of changes in capital markets with client specific information that includes a client’s goals, return objectives, spending policy, ability to tolerate risk and liquidity needs. We help clients to, among other things:  Develop investment objectives;  Define and control risk for their specific requirements;  Diversify their investment portfolio;  Meet cash flow needs; and  Conduct scenario analysis on asset allocations of portfolios as well as evaluate alternative portfolios. Once a strategic asset allocation is determined, an investable portfolio is constructed by identifying the specific investment strategies and money managers that will be used in the portfolio. Russell Investments Implementation Services, LLC / Form ADV Part 2A / 9 Portfolio Management and Construction In moving from a strategic asset allocation to an implementable portfolio, the portfolio is developed using our proprietary strategies (discussed below) and active strategies from selected third-party money managers. In addition to utilizing discretionary third-party money managers to manage client portfolios, we construct certain portfolios by combining non-discretionary money manager models in a centralized portfolio (“Enhanced Portfolio Implementation” or “EPI”). Under EPI, we hire money managers to provide lists of recommended investments and the weightings of such investments. For example, a portfolio may utilize strategies from multiple non-discretionary money managers. We implement the portfolio by aggregating the model portfolios of each manager and may adjust the combined aggregated model in order to vary certain exposures, to adhere to any portfolio level guidelines and other restrictions, and for transaction cost management. We also offer our EPI services to third parties as an implementation service. We generally allocate portfolio assets to two or more money manager strategies, however, RIIS or its affiliates also may directly manage all or some portion of a portfolio’s assets (“direct investment”) for a variety of purposes. In such a scenario, Russell Investments may retain more of its advisory fee as it pays less in fees to money managers. Our direct investment of portfolios can include the implementation of certain quantitative analysis and/or rules-based processes to assess a portfolio’s characteristics or fundamental strategies; investing in securities and instruments which provide desired exposures (such as volatility, momentum, value, growth, quality, capitalization size, industry, sector, region, currency, commodity, credit or mortgage exposure, country risk, yield curve positioning or interest rates); modifying the portfolio’s overall investment strategy or risk/return characteristics relative to investments made by one or more money managers; and enhanced funding, cash management, currency overlay or other direct investment management techniques (collectively, “Proprietary Strategies”). We may also use strategies based on indexes. We, or our affiliates, may also directly manage portions of a portfolio during transitions between money managers. Third-Party EPI EPI is a strategy designed to improve investment outcomes by reducing the costs of operating a multi-manager structure by capturing investment insights of multiple managers in a centralized portfolio. Third-party portfolios can potentially benefit from EPI through improved incremental returns over time due to lower aggregate transaction costs (resulting from lower trading volumes and efficiencies gained through aggregation of orders). Most third-party EPI trades are executed through RIIS. Additionally, portfolios benefit from improved portfolio efficiency and control by enabling more options for controlling investment exposures, including any ESG factors; managing cash flows and rebalances between manager strategies; managing manager transitions; and further reducing risk and cost where appropriate. EPI also provides for enhanced tax management by providing a more flexible structure to manage optimal tax lot selection, minimize wash sales, manage holding period, defer realized gains and harvest losses. TYPES OF INVESTMENTS Our advisory services encompass all types of investments and asset classes, including equity, fixed income, multi-asset, alternatives, and derivatives. Types of investments in which we offer investment advice include, but are not limited to: exchange listed securities, privately placed Russell Investments Implementation Services, LLC / Form ADV Part 2A / 10 securities, Private Funds, Funds, Fund of Funds, Real Estate Investment Trusts (“REITS”), exchange traded funds (“ETFs”), exchange traded notes (“ETNs”), master limited partnerships (“MLPs”), securities traded over-the-counter, foreign issues, depository receipts, warrants; corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual fund shares, U.S. and non-U.S. sovereign government securities, commodities, listed futures and options contracts. Other types of investments may include FX instruments, including forwards, spots and swaps, centrally cleared swaps and other bilateral OTC instruments. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, for more detail on the types of instruments used in implementing our strategies. SERVICES OF AFFILIATES Russell Investments utilizes its affiliates to offer certain services to clients, some of these affiliates also are investment advisers or broker-dealers registered with the SEC, FINRA, and some are registered or are exempt from registration with other federal, state or non-U.S. regulatory authorities. We may use the services of personnel of one or more of our affiliates for investment advice and client servicing in their local or regional markets or their areas of special expertise, except to the extent restricted by the client pursuant to its investment management agreement or other type of advisory agreement (“IMA”), or inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including dual employee, delegation, participating affiliate, sub-advisory, sub-agency or other formal or informal servicing arrangements. Certain of those affiliates’ employees are deemed “associated persons” within the meaning of Section 202(a)(17) of the Advisers Act, as Russell Investments’ affiliates may, through such employees, contribute to our investment advisory and investment research process. These arrangements comply with applicable law and regulation including, but not limited to, Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and its prohibited transaction exemptions, U.S. federal securities laws and regulations, and the regulations of applicable self- regulatory organizations such as FINRA, the National Futures Association (“NFA”) and the MSRB. This practice of utilizing affiliates is designed to make Russell Investment’s global capabilities available to our clients in as seamless a manner as practical within a varying global regulatory framework. In these circumstances, we remain fully responsible for the portfolio from a legal and contractual perspective. If provided in a client’s IMA, a fund’s governing documents and/or private placement memorandum or offering memorandum (both and similar documents referred to as the “OM”), we will charge additional fees for such services and as allowed by applicable law and regulation. RIIS provides trade execution services to other affiliates as an adviser and under our broker- dealer registration, for which we earn additional compensation in the form of commissions. For additional information, please refer to Item 10 – Other Financial Industry Activities and Affiliations and Item 12 – Brokerage Practices of this Brochure.