We are O’Shaughnessy Asset Management, L.L.C. (OSAM), a Stamford, Connecticut-based quantitative money management firm. We deliver a broad range of equity portfolios to individual in- vestors, institutional investors and the high-net-worth clients of financial advisers. We also manage mutual funds in the United States as well as serving as a sub-adviser to a family of Canadian mutual funds through Royal Bank of Canada. OSAM is primarily an institutional discretionary investment manager, generally offering its in- vestment-management services in one of three ways: (1) to the public via various open-end mutual funds; (2) to individual investors in conjunction with the investor’s primary investment professional (usually an investment adviser unaffiliated with OSAM), whereby the investment professional maintains initial an ongoing responsibility for determination of the suitability of OSAM’s investment strategy(ies) and investor communication; the investment professional’s access to OSAM is usually obtained in con- junction with an unaffiliated investment custodian’s platform (OSAM is included among investment managers available to investment professionals on various custodian platforms); and (3) directly to in- stitutional investors, including serving as a sub-adviser to unaffiliated investment advisory firms, and engagements by foundations, endowments, and state and municipal retirement plans, among others. In September 2019, we launched an investment service called CANVAS®, which is powered by a proprietary research and investment management platform. The CANVAS system is an interactive, web- based customizable portfolio management platform developed by us that permits an investment pro- fessional (generally a registered investment adviser) to devise a desired investment strategy. At all times, the user, and not OSAM, is responsible for maintaining the initial and ongoing relationship with the underlying investor and rendering individualized investment advice to the investor. In addition, the user, and not OSAM, is responsible for (1) determining the initial and ongoing suitability of the strategy for the investor; (2) devising or determining the specific initial and ongoing desired strategy; (3) moni- toring performance of the strategy; and (4) modifying and/or terminating the management of the in- vestor’s account using the strategy. The user may not look to us for, and we do not have any responsibility for: (1) providing individualized investment advice or making any determination as to the initial or ongoing suitability of any strategy for any investor or user; (2) monitoring the strategy; or (3) the performance of the strategy. Additional information regarding our CANVAS system is directly acces- sible via link at canvas.osam.com. CANVAS is intended for use only by investment professionals with appropriate knowledge and experience who are able to bear the risks of loss associated with the use of the CANVAS platform. Our investment strategies are based on the research of our former Chairman/CIO and Founder James P. (Jim) O’Shaughnessy, who was widely regarded as a pioneer in quantitative equity analysis. The team have identified the characteristics that have led to successful investing over the last fifty years, and these characteristics form the foundation of our strategies. We strongly believe in the value of applying empirical, fundamental research to uncover the best quantitative stock selection strategies. We have done an exhaustive study of the historical charac- teristics that the best value and growth stocks possess, and this research forms the basis of every port- folio we offer. Our strategies select stocks in a logical, unemotional way; and we believe appeal to common sense: we look for stocks selling at a discount but showing good potential for growth. We seek not to deviate from our strategies, and we adhere to a disciplined, systematic process. We believe that many money managers underperform their benchmarks because of their inherent ina- bility to divorce themselves from the emotions that often cloud good decision-making. Our process is consistent and rational; we do not let short-term market fluctuations distract us from our longer-term goals. We allow our stock selection screens to seek to add value over full market cycles, and we gener- ally stay fully invested in the market. And, unlike most other quantitative managers, our process is transparent. We show how and why we choose the stocks that we do, helping our clients fully under- stand our models and how they are designed to work. We offer a broad range of equity and exchange traded product strategies, from small capitali- zation to large capitalization, growth to value, fixed income exchange traded funds (ETFs), and includ- ing multi-capitalization and international strategies (i.e., non-U.S., Canadian, Global, International, etc.). For institutional and other direct client relationships, we provide ongoing portfolio manage- ment services based on the individual objectives, time horizon and risk tolerance of each client. Our investment supervisory services include investment strategy, asset selection and portfolio monitoring. We participate in some brokers’ so-called “wrap–fee” programs; we receive a portion of the wrap fee for our services. See page 8 for more information about these programs. Sometimes we receive information about a client’s finances from the client or from the client’s

other advisers; we assume this kind of information is correct. Sometimes we recommend the services of other professionals to our clients; it is up to the client to decide whether or not to use anyone whom we recommend. Clients must advise us promptly if there is ever any change in their financial situation or investment objectives. We provide an updated copy of this brochure to each client prior to signing an investment management agreement. Any client may end our services without owing us anything for five business days after signing an investment management agreement. We have been in business since 2007, although the team have been working together at other firms for much longer. On December 31, 2021, OSAM became a wholly owned subsidiary of Franklin Resources Inc. / (Franklin Templeton). As of September 30, 2023, we managed $7,983,580,249 of assets across 4,197 accounts, all of which was on a discretionary basis. We also have approximately $523,070,477 of assets we advise upon in multiple unaffiliated unified managed accounts (UMA) platforms which would NOT be considered as- sets under management. Miscellaneous: No Financial Planning/Consulting Services. We do not hold ourselves out as providing, nor do we provide, any financial planning or related consulting services. Neither our firm, nor any of our rep- resentatives, serves as an attorney, accountant or insurance agent, and no portion of our services should be construed as legal, accounting, tax, or insurance advice. Client Obligations. In performing our services, we are not required to verify any information received from the client or from the client’s other professionals and are expressly authorized to rely on the information we receive. Moreover, each client is advised that it remains the client’s responsibility promptly to notify us if there is ever any change in the client’s financial situation or investment objec- tives; we rely on the client to make sure we have this information so that we can review, evaluate and, if necessary, revise our previous recommendations or services. Wrap-Fee/Managed-Account Program Limitations: In the event that we are engaged to provide investment advisory services as part of an unaffiliated “wrap-fee” program or managed-account pro- gram, we will be unable to negotiate commissions or transaction costs. Under a wrap-fee program, the sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, and custody and reporting services for a single specified fee. Partici- pation in a wrap-fee program may cost the participant more or less than purchasing such services sepa- rately. If the program is offered on a non-wrap basis, the program sponsor will generally determine the broker-dealer though which transactions must be effected and the amount of transaction fees and/or commissions to be charged to the participant investor accounts. As noted above, in a wrap-fee or managed-account program, the custodian/broker-dealer is determined by the unaffiliated program sponsor; accordingly, we will be unable to negotiate commis- sions or transaction costs, or seek better execution, for such accounts. As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative clearing ar- rangements. Higher transaction costs adversely impact account performance. When we are engaged as a participating manager in a wrap-fee program or managed-account program, our exclusive responsibility is to manage the account assets consistently with the primary ad- viser’s instructions. At all times, such an adviser, and not we, will remain exclusively responsible for initial and ongoing suitability determination for our investment strategy(ies) and client communica- tions. Accordingly, unless we fail to manage the account consistently with our received instructions, we will not have any responsibility for account losses, absent OSAM’s gross negligence or willful miscon- duct. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by us) will be profitable or equal any specific performance level(s). Tradeaway Fees. When we provide discretionary investment management services, when bene- ficial to the client, individual equity and/or fixed income transactions may be effected through broker- dealers other than the account custodian. In any such event, the client generally will incur both the transaction fee charged by the executing broker-dealer and a “tradeaway” fee charged by the account custodian. ERISA Plan-Trustee Directed Plans. We may be engaged to provide discretionary investment ad- visory services to ERISA retirement plans, whereby we manage plan assets consistently with the in- vestment objective designated by the plan’s trustees. In such engagements, we will serve as an investment fiduciary, as that term is defined under the Employee Retirement Income Security Act of 1974. We will generally provide services on an assets-under-management fee basis per the terms and conditions of an investment management agreement between the plan and us.