Introduction Zebra Capital Management, LLC (hereafter “Zebra Capital,” “Firm” or “we”) is a Connecticut limited liability company and investment management firm with its principal place of business in Stamford, Connecticut. The Firm has been in business since 2001 and is a registered adviser with the U.S. Securities and Exchange Commission (the “SEC”). Registration with the SEC does not imply any level of skill or training. Zebra Capital is owned and managed by Professor Roger Ibbotson, Managing Member and Chairman, and Mr. John J. Holmgren Jr., Managing Member, President and Chief Investment Officer. Zebra Capital provides Investment Supervisory Services, defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client. Zebra Capital provides these services primarily to pooled investment vehicles and separate accounts. Zebra Capital manages each client portfolio on either a discretionary or a non-discretionary basis in accordance with the terms and conditions of each client's organizational and/or offering documents, if any, client agreements and objectives. Zebra Capital also licenses its intellectual property to third parties on a case-by-case basis. Zebra Capital’s mission and objective is to apply the substantial investment experience and expertise of Professor Ibbotson and Mr. Holmgren. Zebra Capital is affiliated through common ownership and control with Zebra Advisors, LLC (“Zebra Advisors”), a Delaware limited liability company and registered investment adviser with the SEC. Zebra Advisors provided Investment Supervisory Services primarily to pooled investment vehicles. Zebra Advisors managed the client portfolios on a discretionary basis in accordance with the terms and conditions of each client's organizational and/or offering

documents, if any, client agreements and objectives. As of December 31, 2023, Zebra Capital managed approximately $3,152,000 in regulatory assets under management on a discretionary basis and its affiliate, Zebra Advisors, did not have any regulatory assets under management. Investment Management Services POOLED INVESTMENT VEHICLES (INVESTMENT COMPANIES) Zebra Capital provides advisory services to GVC Gaesco Gestión, SGIIC, S.A., a company incorporated under the laws of Spain, in relation to the GVC Gaesco Zebra US Small Caps Low Popularity, FI (the “Fund”), which is considered a “mutual fund” under Spanish Law. The investment objective of the Fund is primarily long-term capital appreciation through investing primarily in equity securities, including small capitalization securities. Investors should be aware of the risks associated with investing in pooled investment vehicles, many of which are described in the offering documents of the respective pooled investment vehicles. MANAGED ACCOUNTS Zebra Capital offers professional advisory services for managed accounts, in each case offering long only and long-short strategies or other strategies based on a client's particular circumstances. A client investment policy is developed, and Zebra Capital creates and manages each client's portfolio consistent with the client's individual investment policy. Zebra Capital provides such advisory services on a discretionary basis. The Pooled Investment Vehicles and Managed Accounts are collectively referred to in this Firm Brochure as the "Zebra Clients." LICENSING Zebra Capital licenses its intellectual property to third parties pursuant to third-party licensing arrangements. The terms, fees and services provided under such arrangements are negotiated on a case-by-case basis.