2 Retirement Income Security Act (“ERISA”). Altair has adopted the following practices and controls in recommending each Fund to its clients subject to ERISA:
• As more fully described in Item 5 below, Altair does not charge a separate fee for managing the Funds;
• The ERISA plan will not pay any sales commission or redemption fee related to investments in the Funds; and
• Altair will obtain approval to invest the client’s assets in each Fund from an independent fiduciary of the ERISA plan after providing information about each Fund to the independent fiduciary, including a description of: a) fees paid; b) Altair’s rationale for recommending each Fund as a suitable investment; and c) any limitations related to the timing of purchases and withdrawals. As described more fully within the prospectus, the Funds utilize a “multi-manager” approach whereby the Funds’ assets are allocated to one or more third-party advisers (“Sub-Advisers”) in percentages determined by Altair. Each Sub-Adviser acts independently from other Sub- Advisers and utilizes its own distinct investment style in selecting securities. However, each Sub-Adviser, under the oversight of Altair, must operate within the constraints of each Fund’s investment objective and strategies and the particular investment restrictions applicable to that Sub-Adviser. Altair does not provide investment services related to specific securities or sectors other than: (a) to recommend various third-party investment managers, mutual funds, ETFs, private investments and derivatives; and (b) in connection with its role as adviser to the Funds. Altair will be responsible for arranging the execution of the investment decisions for its discretionary clients. For its non-discretionary clients, Altair will arrange the execution of the investment decision only after it receives authorization to do so from the client. Clients can impose restrictions with respect to specific securities or types of securities in the accounts managed by third-party investment managers. In addition, Altair typically provides administrative services to both its discretionary and non- discretionary clients, including transferring assets between a client's accounts. For clients who have invested their assets in private investment vehicles that make additional capital calls, Altair generally has limited discretion to respond directly to such capital calls without the need to first seek client authorization. Specifically, Altair will process the capital call by transferring assets to the investment vehicle directly from the client's account. Further, should a client's account not have sufficient cash to fund the capital call, Altair's limited discretion would give it the ability to dispose of holdings/investments in the client's account sufficient to meet the capital call. Altair also provides consulting and investment advisory services to retirement plans, trusts, estates, charitable organizations, corporations or other business entities. Typical services provided to these clients are consistent with the process described above. Altair works with a third-party vendor which provides class action litigation monitoring and securities claim filing services. This vendor will complete claims for all of our clients who do not opt out of such a service. In return for

this service, the vendor receives a percentage of any settlement collected. Altair does not receive a payment for services provided by the third-party vendor, aside from its negotiated investment management fees for managing Altair assets as described within Item 5 below. Altair is not responsible for class action or similar legal litigation matters related to the Funds. SERVICES FOR LIMITED FINANCIAL PLANNING CLIENTS Altair provides financial planning services in addition to investment advisory services. Financial planning services include an analysis of financial goals, which generally considers advice regarding capital sufficiency and cash flow, retirement planning, income tax planning, education funding, corporate benefit decisions and estate planning matters. Altair is at times retained by a corporation to provide these financial counseling services to key officers and executives of the corporation and to provide financial planning seminars and other educational services to groups of employees. PROJECTS Altair will provide other limited, negotiated services as an accommodation to clients, as agreed to by Altair. ASSETS UNDER ADVISEMENT As of December 31, 2023, Altair had total assets under advisement of $7,386,489,664. Of this total, $3,162,885,118 were managed on a discretionary basis and $4,223,604,546 were managed on a non-discretionary basis. Fees for Altair’s services are documented in a written engagement contract at the inception of each engagement. While we generally do not negotiate fees, we will negotiate fees in certain circumstances based primarily on the size of the account and relationship with Altair. Fees for Investment Advisory Clients In the case of investment advisory services clients (i.e., for both Altair assets and outside assets), Altair will at times charge fees for the first phase of services, which includes developing a strategic investment plan. These fees are determined based on the complexity of the client's situation and the scope of the work involved. If there is a fee for this phase it is generally billed as a one-time project fee. Fees for the second phase of services, including implementation and ongoing portfolio review, are generally calculated based on a percentage of client assets under advisement and are payable quarterly in advance. Assets under advisement include those mutually determined and agreed upon with the client and Altair. Our current standard fee schedule is: Fees as a Percentage of Assets Assets Subject to Fee 0.80% on the first $5 million plus 0.50% on the next $15 million up to assets of $20 million plus 0.35% on the next $30 milion up to assets of $50 million plus 0.25% on the next $50 million up to assets of $100 million plus 0.10% on the assets above $100 million Altair has had other fee schedules in effect during the time it has been in business that could be lower or higher than those outlined above. Based on the fee schedule in effect at the time of engagement and the size of a particular account, Altair clients will probably pay different fees. Altair follows policies to manage client accounts based on their investment goals, regardless of their fees. While Altair’s fee schedule creates an incentive to encourage clients to remain