ALPS ADVISORS INC

Description of Advisory Firm ALPS Advisors, Inc. (“AAI”) was founded in 2006. AAI is a subsidiary of ALPS Holdings, Inc., (“AHI”) which is a subsidiary of SS&C GIDS, Inc. (“GIDS”), which in turn is a wholly owned subsidiary of SS&C Technologies, Inc. SS&C Technologies, Inc. is a wholly owned subsidiary of SS&C Technologies Holdings, Inc. (Nasdaq: SSNC)(“SS&C”). Description of Types of Advisory Services Registered Investment Companies AAI currently serves as an investment adviser to investment companies (each a “fund” and collectively, the “funds”) registered under the Investment Company Act of 1940 (“1940 Act”). AAI has the responsibility to appoint on behalf of the funds it advises, sub-advisers with full investment discretion, which may include the selection of brokers and other trading counterparties. AAI has the responsibility to oversee the activities of the sub-advisers and ensure that all transactions comply with applicable regulations and prospectus covenants. AAI also serves as investment sub-adviser to investment companies registered under the 1940 Act. In addition, where AAI is the adviser or sub-adviser, there are certain funds for which AAI will initiate placement, execution, and settlement of trades. In these instances, AAI will not actively make specific security investment decisions. Rather AAI’s trading desk will be responsible for initiating trades necessary to keep the funds in line with a model portfolio provided by the adviser, sub-adviser or, in the case of an exchange traded fund, the indexing agent or at the direction of the adviser or subadviser. Sub-Advisory Services AAI will enter into sub-advisory or model-provider agreements with other unaffiliated institutions, including other registered investment advisers, to provide portfolio management services. These third-party advisors and institutions outsource a portion of their portfolio management services which they offer to their clients through AAI. These relationships are memorialized in each contract between AAI and the third-party advisers and institutions (each a “Client”, collectively, “Clients”). Under AAI’s sub-advisory agreements, the Client agrees to deliver or make available AAI’s Brochure to its underlying clients, and underlying clients may request the Brochure directly from AAI at no cost. AAI makes the Brochure available to underlying clients so they can understand AAI’s role, fees, and conflicts of interest. Doing so does not create an advisory relationship between AAI and any underlying client.

Clients who enter into a sub-advisory agreement with AAI will delegate their discretionary authority to conduct trades on behalf of specified accounts held at a custodian. AAI will use this discretionary authority to implement model portfolio selections, strategies, or trade instructions provided by the primary investment adviser. When AAI acts as a sub-adviser, the primary adviser is responsible for ensuring that it complies with all applicable statutes, regulations, and rules. Furthermore, the primary adviser is responsible for assessing whether instructions, provided to AAI, regarding the selection of a model portfolio, the purchase of a security, or the sale of a security meet the applicable suitability/best interest standards. AAI makes available its proprietary model portfolios, certain thirdparty model portfolios, proprietary managed account strategies, and in some instances, Client-directed custom model portfolios to its Clients. Upon instruction from the Client, AAI may provide tax‑aware portfolio optimization support, such as tax‑sensitive rebalancing or loss‑harvesting parameters. AAI may also offer direct indexing services that seek to track an index while enabling tax management and/or Client screens. AAI will enter into agreements with third-party model providers to make their model portfolios available on the BDIM platform. Clients select the models, and AAI acts as the sub-adviser and exercises trading discretion to implement the selected models in client accounts, including placing, executing, and settling trades. AAI generally relies on trade or model update information received from each model provider and implements updates. However, AAI’s discretion is limited to implementing the investment strategy selected by the Client. When implementing a model, AAI may adjust, delay, or partially implement a model provider’s updates as needed to address operational constraints, account-level restrictions, cash flows, minimum trade sizes, ineligible securities limitations, or tax-management parameters the Client has elected. AAI does not substitute its own security selection or asset allocation views for those of the model provider or the Client. As a result, a Client’s portfolio may deviate from the model provider’s intended allocation. Timing differences, account-level restrictions, cash flows, or operational constraints may result in Client accounts deviating from the provider’s model and from one another. Certain third-party model providers deliver model portfolios through the Black Diamond Wealth Platform, which is operated by SS&C Advent, an affiliate of AAI. These model providers may participate in a platform program administered by SS&C Advent. AAI’s role with respect to these models varies: in some cases, Client Accounts are enrolled as Partner Managed Accounts in which AAI exercises discretionary trading authority to implement the selected model; in other cases, the Client retains responsibility for implementing the model. In all cases, the model provider has no advisory, fiduciary, or other relationship with AAI’s Clients or their underlying investors.

When AAI is engaged to provide discretionary services to its Clients, AAI creates the buy and sell orders and directs trading activity for the individual accounts, pursuant to a sub-advisory agreement. AAI’s services also include ongoing trading and rebalancing services, which generally accommodate cash management, periodic rebalancing and investment changes. AAI does not directly maintain a relationship with underlying investors of its Clients. As a result, AAI does not serve as an investment adviser to underlying investors of its Clients. Retirement Solutions Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. AAI may provide retirement plan services to plans and plan fiduciaries, as described below. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which plan fiduciaries may retain investment advisers for various types of services with respect to plan assets. For certain services, we will be considered a fiduciary under ERISA. For example, we will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the plan fiduciaries by recommending a suite of investments as choices among which plan participants may select. With respect to any account for which we meet the definition of a fiduciary under Department of Labor rules, we acknowledge that both the firm and its related persons are acting as fiduciaries. Services will be provided under the terms and conditions of a licensing agreement, whereby AAI provides investment analysis, investment performance data and mathematical modeling techniques for use in investment advice software made available to authorized plan participants. Through the software, AAI may provide investment recommendations, among a suite of investments, to authorized plan participants. These investment recommendations will constitute investment advice under ERISA § 3(21). Prior to accepting investment advice, authorized plan participants have the option of entering into an advisory agreement with AAI, which outlines the risks and limitations of accepting such advice. Additional disclosure is found elsewhere in this Brochure or in the written agreement between us and the client. Model Portfolio Solutions AAI constructs and provides model portfolios to other registered investment advisers through its SS&C Black Diamond Investment Management (“BDIM”) solutions. Among other things, SS&C BDIM provides investment advisers the ability to assess their client’s portfolios, implement model allocations, and monitor investments across their accounts. SS&C BDIM is solely available to investment advisers through SS&C Advent, an affiliate of AAI, and its Black Diamond Wealth Platform (the “Platform). Investment advisers have the ultimate decision

making and discretionary responsibility for the determination of which securities are to be purchased and sold for their account and effect all security transactions in connection with such determinations. In addition, AAI has no specific knowledge of the investment adviser’s clients or their circumstances. Model portfolios will include third-party ETFs and ETFs that are advised by AAI (“Affiliated ETFs”). As a result, AAI’s conflict in selecting Affiliated ETFs within a particular model is heightened because it has an additional incentive to decrease the model portfolio’s allocation to third-party ETFs in order to increase the investment advisory fees it receives. Refer to Item 5 “Fees and Compensation” below for additional conflicts of interest disclosures. AAI also licenses certain model portfolios directly to other registered investment advisers and platforms for use in managing their clients' accounts. The licensee retains full discretion over whether and how to implement AAI's models, including trade timing, and AAI does not provide advice to the licensee's clients. Investment adviser representatives of AAI may provide consultative support and investment advice to investment advisers regarding model implementation and selection. Third-Party Model Marketplace AAI enters into agreements with unaffiliated investment advisers (“Model Providers”) that furnish non-discretionary model portfolios to AAI. AAI hosts these models through its web portals and makes them available only to Clients that have signed a sub-advisory agreement with AAI. AAI decides in its sole discretion whether to host a model and may interrupt or discontinue a model with or without notice. The Model Provider has no advisory, fiduciary, or contractual relationship with the Client or its underlying clients. Custom Indexing Solutions AAI offers custom indexing services through its sub-advisory relationships and managed account platforms. Custom indexing is an investment strategy in which a portfolio of individual securities is constructed and managed to approximate the risk and return characteristics of a target index, model portfolio, or other reference portfolio, while incorporating Client-specific preferences such as tax management, security-level screens or exclusions, and factor tilts. Portfolios are typically constructed using individual equity securities and may also include ETFs (including Affiliated ETFs) and other instruments, depending on the specific mandate, available investment universe, and any legacy assets incorporated into the portfolio. AAI utilizes optimization technology and systematic rebalancing processes to manage custom index accounts.

AAI offers the following categories of custom indexing services: • DirectIndex: Standardized direct indexing strategies that seek to approximate a target equity index. • Custom DirectIndex: Bespoke custom indexing strategies constructed based on Client-specific parameters communicated by the Client, including investment restrictions, factor tilts, ESG/SRI screens, concentrated position management, and tax management preferences. AAI’s custom indexing services may include, but are not limited to: tax-loss harvesting; tax-sensitive transitions of legacy or concentrated holdings; capital gains budgeting within Clientspecified thresholds; security-level screens and exclusions; and factor tilts or overlays relative to a reference index or model. When providing custom indexing services in a sub-advisory capacity, AAI’s advisory relationship is with the Client, not with the underlying investor. The investment adviser, and not AAI, exercises the ultimate advisory, fiduciary, and discretionary responsibility over their client’s assets, including the selection of the investment strategy and the determination that it is in their client’s best interest. AAI implements the selected investment strategy within the parameters communicated by the Client. AAI does not provide tax, legal, or accounting advice in connection with custom indexing services. While AAI employs tax-aware portfolio management techniques, Clients should consult their own tax professionals regarding the tax implications of custom indexing strategies. Custom indexing services are available to Clients with a minimum account size of $100,000, although AAI may waive this minimum at its discretion. Certain restrictions apply to Client accounts below $50,000. Certain categories of securities are not eligible for inclusion in sub-advisory and custom indexing accounts (“Ineligible Securities”). The specific categories of Ineligible Securities may vary depending on the applicable agreement, platform, or strategy type, but generally include: foreign ordinary local shares; digital assets (except U.S. SEC-regulated exchangetraded products providing exposure to digital assets and CFTCregulated exchange-traded futures and options on digital assets); cannabis-related securities; futures contracts; limited partnerships (unless electronically traded); and direct real estate. For certain strategies accessed through the Platform, fixed income securities may also be classified as Ineligible Securities. Donor Advised Fund Solutions AAI provides white-label Donor Advised Fund (“DAF”) services in partnership with GiveClear Foundation (“GiveClear”), a 501(c)(3), and TIFIN Give, Inc. (“TIFIN”), a SEC-registered

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Registered Investment Companies AAI is an adviser or sub-adviser to registered funds and receives advisory and other compensation for the investment management services provided to such clients. There is no standard fee schedule for services provided to investment

companies. The services and fees with respect to such clients are negotiated on an individual basis. Generally, fees are calculated as a percentage of the fund’s net assets, accrued daily at the rate of 1/365th of the applicable advisory fee rate and are payable monthly in arrears. In some situations, AAI may collect the greater amount of either an agreed upon minimum fee, as contemplated in the contract, or a percentage of the fund’s daily net assets. Each AAI advisory agreement will describe how AAI calculates advisory fees, other expenses that the client agrees to pay, and the method and timing for making advisory fee payments to the firm. AAI will charge a fee that is reasonable in relation to the advisory services it provides. In determining the reasonableness of the fee, AAI will examine the facts and circumstances of the particular relationship. Advisory fees will be negotiated between AAI and the Independent Directors/Trustees of the applicable fund, in accordance with Section 15(c) of the 1940 Act. AAI does not charge a contingency fee. A fee is contingent if AAI will receive the fee only upon the occurrence of certain events (e.g., client only pays if the value of the client’s account increases by 15%). Fees that are a percentage of total value of an account averaged over a definite period, or as of definite dates, or taken as of a definite time are permissible. Performance fees meeting the requirements of the Advisers Act are not contingent fees. To the extent that we may place client assets into funds we advise, we generally will not receive fees on such assets other than indirectly from the funds. A complete explanation of fees and expenses charged by the funds is contained in each fund’s prospectus. Sub-Advisory Services In return for providing sub-advisory services, AAI receives subadvisory fees from Clients. The fees paid to AAI vary widely depending on the complexity and features of the specific investment strategy selected by the Client and are typically between 3 and 50 basis points per year. Services related to taxaware portfolio optimization overlays are typically between 5 and 20 basis points per year. All fees are negotiated in advance and are not based on performance. Platform rebates may be made to Clients and are calculated based on assets under management allocated. When a Client selects a third-party model, AAI charges a separate overlay/sub-advisory fee for implementing the model in the Client’s account, typically 3 to 5 basis points per year. In certain arrangements, the third-party model provider or strategist compensates AAI for implementation and platform services rather than the Client paying a separate sub-advisory fee. In addition, for certain third-party strategist and SMA

relationships, AAI charges a platform fee and collects a maintenance fee from the asset manager. The model provider or strategist may also charge a separate fee for model management, typically 10 to 200 basis points per year, which is paid by the Client or by the model provider depending on the specific arrangement. These fees are in addition to any platform/program fees charged by the BDIM platform or the Client’s custodian, as well as any transaction costs, and the internal expenses of any underlying funds held in the account. Fees may be negotiable based on account size or other factors. AAI has entered into arrangements under which AAI shares a portion of its fees with certain Clients. For example, AAI may pay a portion of the fees it receives back to a Client pursuant to a revenue sharing arrangement, as described further under "Revenue Sharing" below. Because AAI’s net compensation varies across arrangement types and strategies, including as a result of revenue sharing obligations and differences in platform and maintenance fees, AAI has a financial incentive to recommend or prioritize strategies on which it retains higher net compensation. This conflict is mitigated by the fact that the Client, and not AAI, is responsible for selecting the investment strategy for each of their underlying clients. Each sub-advisory agreement in place between AAI and the Client specifies how sub-advisory fees will be charged. Generally, fees are calculated as a percentage of the assets of invested capital, accrued daily are payable monthly in arrears. AAI, with the assistance of its parent company, SS&C, will provide the investment adviser with an invoice detailing the breakdown of the fees associated with the services provided. Sub-Advisory Services - Conflicts of Interest Certain third-party model providers that make model portfolios available through the Black Diamond Wealth Platform (an affiliate product operated by SS&C Advent, an affiliate of AAI) participate in a platform program under which the model provider pays an asset-based participation fee to SS&C Advent. Under this program, the model provider’s participation fee is reduced when the model provider includes AAI Affiliated ETFs in its model portfolios. Specifically, the model provider receives an offset of up to 5 basis points on assets allocated to Affiliated ETFs within the model. This offset creates a financial incentive for the model provider to include Affiliated ETFs in its models, which in turn generates advisory fee revenue for AAI and its affiliates when Client assets are invested in those models. Because AAI and its affiliates benefit economically when Affiliated ETFs are included in third-party models, and because the offset structure is established by AAI’s affiliate, a conflict of interest exists. AAI addresses this conflict by: (1) disclosing the existence and nature of the offset arrangement in this Brochure; (2) conducting independent due diligence on third-party model providers and their models without regard to whether the model

includes Affiliated ETFs; and (3) requiring independent evaluation of whether each model is appropriate for the account’s investment objectives and risk tolerance. Sub-Advisory Services – Revenue Sharing & Platform Rebates Revenue Sharing AAI has entered into revenue sharing arrangements with certain Investment Advisers that maintain sub-advisory relationships with AAI. Under these arrangements, AAI shares a portion of the fees it earns on Client’s accounts. The revenue share is calculated monthly on the average daily balance of Client accounts and is paid quarterly in arrears. The revenue share rate varies depending on the type of investment strategy selected by the Client for each of their accounts, as follows: Investment Strategy Category

Revenue Share Rate

Proprietary Models, ALPS DirectIndex and Custom DirectIndex; Third-Party Subsidized Models, and Tax Optimized Trading Program

Up to 10 basis points per year

Third-Party Created Models, ClientDirected Strategies

Up to 5 basis points per year

Revenue sharing is generally available to Clients that maintain a minimum of $250 million in aggregated assets under management receiving sub-advisory services from AAI. Revenue share rates are subject to change with the Client’s prior written approval. If AAI proposes a change to revenue share rates and the Client does not agree within 15 days, AAI may terminate the sub-advisory agreement on 90 days’ notice. Revenue Sharing – Conflicts of Interest The revenue sharing arrangements described above create conflicts of interest. Because AAI shares a portion of its revenue with the Client, the Client has a financial incentive to allocate account assets to strategies and products available through AAI’s platform rather than to comparable alternatives available outside of AAI’s platform. Additionally, because the revenue share rate differs by strategy type, the Client has a financial incentive to select strategies that generate higher revenue share payments. AAI also has a conflict of interest in that it has a financial incentive to onboard and retain Clients that maintain higher asset levels on the platform, as revenue share payments increase with the volume of assets allocated to AAI’s subadvisory services. This incentive could influence the level of service, support, and resources that AAI provides to Clients of different sizes. AAI addresses these conflicts by: (1) disclosing the existence, structure, and rates of its revenue sharing arrangements in this

Brochure; (2) requiring that the Client, and not AAI, is responsible for determining that the selected investment strategy is in the best interest of their underlying clients; (3) requiring that revenue sharing arrangements are memorialized in written agreements; and (4) implementing supervisory controls to monitor the recommendation and allocation process for potential conflicts. The Client is independently obligated under the Advisers Act to disclose revenue sharing and other compensation it receives to its underlying clients and to manage any resulting conflicts consistent with its fiduciary duties. Platform Rebates AAI, together with its affiliate SS&C Advent, may offer certain Clients a fee rebate (the “Platform Fee Rebate”) against the Client’s monthly technology platform invoice for use of the Black Diamond Wealth Platform (“Black Diamond”), an affiliate product of AAI. The Platform Fee Rebate is available to Clients that satisfy both of the following conditions: (1) the applicable account incurs both a management fee for sub-advisory services from AAI and a monthly technology fee for the use of Black Diamond; and (2) the Client maintains in excess of $100 million in aggregated average daily balance of eligible accounts. The amount of the rebate for each eligible account is the lesser of (a) the monthly Black Diamond technology fee for that account or (b) 1 basis point of the monthly average daily balance of that account. The Platform Fee Rebate may be revoked by AAI after one year from the effective date of the applicable sub-advisory agreement. Investment Advisers should not rely on the continuation of the Platform Fee Rebate beyond the initial period when evaluating the total cost of AAI’s services. Platform Rebates – Conflicts of Interest The Platform Fee Rebate creates a conflict of interest because it provides a financial incentive for the Clients to use both AAI’s sub-advisory services and the Black Diamond platform (an affiliate product) rather than evaluating each service independently on its merits. The rebate effectively reduces the Client’s technology costs when the Client concentrates assets in AAI’s managed account services, which may discourage the Client from considering competing sub-advisory or technology platforms. The asset-level threshold further incentivizes the Client to consolidate assets on AAI’s platform rather than diversifying across multiple sub-advisers or technology providers. AAI addresses this conflict by: (1) disclosing the existence, conditions, and amount of the Platform Fee Rebate in this Brochure; (2) requiring that the Client independently evaluate and disclose to its clients any economic benefits it receives from the rebate arrangement; and (3) providing that the Platform Fee Rebate may be revoked, so that Client and their underlying clients are not led to rely on the continuation of the rebate as a permanent feature of the relationship.

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Registered Investment Companies AAI does not research or actively recommend portfolio securities for certain registered investment companies it advises. Rather, it collects, validates and utilizes quantitative data and information from various sources with the goal of identifying one or more sub-advisers that are appropriate to their respective investment objectives and that provide an appropriate mix of diversified investment styles or alternatively through products that are passively managed, and track a designated index. AAI’s principal sources of information for evaluating, selecting and monitoring the performance of sub-advisers or a passive product’s correlation to its index are the qualitative and quantitative information developed by its personnel and quantitative data furnished by various unaffiliated database providers. On the qualitative side, AAI’s personnel conduct in-person meetings with investment management firms that are potential candidates for selection as sub-advisers. Moreover, the qualitative information is further supplemented by telephonic, or in person, discussions with these investment management firms when circumstances suggest further inquiries are in order. AAI periodically conducts performance reviews with each subadviser. AAI also reviews and evaluates publicly available information concerning investment management firms contained in financial newspapers, magazines, and other thirdparty sources. On the quantitative side, AAI analyses information on the investment results and portfolios of the investment management firms. In addition to investment results that are reported publicly, AAI utilizes databases that includes the results of portfolios managed by investment management firms where information is not generally reported publicly. For those products that are passively managed, and track an index, AAI utilizes various databases and portfolio analytic tools in evaluating the performance and risk levels of the portfolio manager(s). Equity Opportunity Strategy AAI has developed and refined a disciplined investment process that is founded in the fundamental analysis of a company’s Return on Invested Capital (“ROIC”), identifying companies with either accelerating or high and sustainable ROIC.

This approach utilizes a longer-term investment horizon and is not restricted to any particular industry, geography, or business function. The building blocks of ROIC – revenue growth, margins, and capital utilization – are each analyzed to assemble a complete picture of the return prospects for potential investments. The process begins with a business model analysis, including but not limited to volume, pricing, competitive positioning, industry analysis, capital allocation and corporate lifecycle. AAI will use dividend policy as a window into management’s views on current and potential cash flow generation. This fundamental business model analysis informs AAI’s opinion on the level, direction and sustainability of ROIC as the individual components are reassembled in AAI’s internal ROIC calculation. AAI has coined the term “Contextual Concentration” to improve upon traditional industry or sector classifications. By combining industries with factors and themes, Contextual Concentrations assists AAI in understanding common fundamental and statistical drivers inherent across traditional sector classifications. Through the lens of Contextual Concentrations, AAI is able to assemble portfolios that maximize the stockspecific return potential, while minimizing unintentional risk exposures. After AAI has identified companies through the business model analysis showing potential for either accelerating or high and sustainable ROIC, those companies are identified using Contextual Concentrations to create a risk and return focused portfolio comprising 50 and to 80 equity positions. Global Opportunity Strategy AAI has developed a proprietary database that identifies companies that pursue a highly disciplined and flexible capital allocation process, choosing investment projects that provide a high ROIC. This approach utilizes a longer term investment horizon and capital return assumptions that is not restricted to any particular industry, geography, or business function. In addition, companies in the portfolio have often used M&A to enhance the competitive position of their businesses. AAI has coined the term “unconstrained capital allocation” to describe these companies and believe that it is this capital allocation process which can provide attractive risk-adjusted returns for investors. In creating the extensive and proprietary database of companies with an unconstrained capital allocation process, AAI looks for companies with the following characteristics:

Business model with centralized capital allocation and decentralized operations

Flexibility to allocate capital across a broad opportunity set Track record of evolving portfolio through M&A Unconstrained by legacy businesses and product cycles

From this list of approximately 500 companies, AAI develops a focus list of 75-100 companies using the following quantitative and qualitative characteristics:

Track record of high ROIC over longer investment cycles Track record of consistently growing book value Alignment of interests between management and shareholders High-quality management teams Valuations

In constructing the portfolio, AAI analyzes companies on the focus list for possible inclusion in the portfolio. This analysis includes:

Valuations and growth potential Outlook and alignment with our portfolio strategy Investment horizon and holding period Potential diversification benefits for portfolio Other considerations such as: geography, industry, size, currency exposure

The result of the research is a diversified portfolio of 40 to 60 securities. AAI has a minimum position of 0.3% and a maximum position of 10% in any given security at the time of purchase. Emerging market exposure is limited to less than 10% of the portfolio. For purposes of determining emerging markets exposure, AAI does not include China, India, Brazil, and South Africa.

There are no intra-quarter additions. Intra-quarter deletions occur only following de-listings from major stock exchanges. The re-balancing of an Index within AAI is performed by index personnel (known as “Index Personnel”). Composing and calculating the Index requires that a rigorous methodology is implemented to ensure consistency and to eliminate any potential conflicts of interest between AAI personnel. The portfolio managers of an actively managed registered investment company, commingled funds, or a collective investment trust (each a “Fund”) for which AAI is an adviser or sub-adviser (the personnel charged with making purchase/sales decisions of individual securities within the Fund(s), known as “Actively Managed Fund Personnel”) will not have access to, or provide any input regarding, any changes to an Index (additions, subtractions and re-weightings) in advance of public dissemination. Only Index Personnel, the AAI Chief Compliance Officer, including his compliance personnel, and operations personnel (need-to-know personnel) may have access to index constituent changes in advance of the general public. Compliance and operations personnel will only provide cursory reviews of the proposed Index changes prior to being disseminated to the Index licensor/licensees, to ensure accuracy and completeness. At no point will compliance or operational personnel provide input as to the Index constituents. To ensure that communications and information regarding nonpublic index information does not occur between the Index Personnel and the Actively Managed Fund Personnel, several controls have been put into place including, but not limited to:

We consider the following areas of diversification while constructing the portfolio:

Stage of investment: All stages of investment with an emphasis on mid-stage to late-stage investments Geography: Global coverage of private equity investments Industry: Investments in a broad range of industries Vintage year: Diversification as to when the actual private investments were made, helping to minimize specific time period risk Capital structure: An emphasis on firms that make equity investments in private businesses, with some exposure to debt investments

Red Rocks Global Listed Private Equity Index Construction AAI maintains the Red Rocks Global Listed Private Equity Index. The Index is rebalanced at the end of each calendar quarter.

Electronic Controls – Separate systems and file spaces used by the Index Personnel that only need-toknow personnel may access; Email reviews of Index Personnel and Actively Managed Fund Personnel to ensure material nonpublic information is not distributed; and Compliance monitoring after rebalance to ensure that any material changes in the Index constituent vis-à-vis the Fund holdings do not create a conflict.

Managed Account Services Tax-Aware Portfolio Optimization When requested by the Client, AAI may utilize tax-aware techniques, such as tax-loss harvesting, gain deferral, lot selection, and tax-smart transitions or withdrawals, to improve after-tax results. These techniques can raise turnover and transaction costs and increase tracking error versus a benchmark or model. Opportunities to harvest losses depend on market conditions and may be limited in rising markets. U.S. wash-sale rules and activity in a client’s other accounts can limit

or negate losses, so actual tax outcomes may differ from expectations. Custom Indexing Services AAI’s custom indexing services use portfolio optimization technology to construct and maintain portfolios of individual securities (and, where appropriate, ETFs) that seek to approximate the risk and return characteristics of a target index or reference portfolio while incorporating Client-specific tax management, screening, and customization preferences. The optimization process considers factors including tracking error budgets, tax lot characteristics, wash sale constraints, transaction costs, and Client-directed restrictions when determining the composition and weighting of portfolio holdings. Because custom index portfolios typically hold a representative subset of the securities in the target index rather than the full index, and because individual accounts are managed for Clientspecific tax and customization parameters, the performance of each custom index account will differ from the target index and from other accounts managed using the same reference portfolio. This performance dispersion is an inherent feature of the strategy. AAI’s custom indexing team periodically reviews and rebalances accounts in accordance with the parameters established for each account. Rebalancing activity may be triggered by market movements, cash flows, tax-loss harvesting opportunities, index reconstitutions, or changes to Client-directed restrictions. Model Portfolio Solutions AAI model portfolios use quantitative methods, in conjunction with qualitative due diligence, for selecting ETFs from the universe of available funds. The universe consists solely of active and passive ETFs, which include unaffiliated, third-party ETFs and Affiliated ETFs. The portfolio construction process applies quantitative and qualitative methodologies to apply weights on selected ETFs based on a combination of the capital markets assumptions formulated by AAI’s research team and the objective of each model portfolio. An important objective of this process is to enhance expected risk-adjusted returns while adhering to the relevant set of risk constraints. Performance information for third-party model portfolios displayed on AAI’s platform or in AAI’s materials represents the performance of the model as maintained by the third-party model provider for its own clients or as a composite, and does not represent the actual performance achieved by AAI in implementing the model in Client accounts. Actual account performance will differ from model-provider composite performance due to, among other factors, the timing of trades, cash flows, account-level restrictions, AAI’s exercise of discretion in implementing the model, fees, and transaction costs.

Retirement Services Services will be provided under the terms and conditions of a licensing agreement, whereby AAI provides investment analysis of mutual funds and ETFs, capital market assumptions, investment performance data and portfolio optimization techniques for use in investment advice software made available to authorized plan participants.

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AAI provides discretionary investment management services primarily to: investment companies registered under the 1940 Act; unaffiliated registered investment advisers; charitable organizations and sponsors; and other institutions. Accounts receiving AAI’s sub-advisory services are subject to a minimum of $5,000 per account. Custom indexing accounts are subject to a $100,000 minimum, which AAI may waive. Model portfolios licensed directly to other advisers may carry their own minimums, currently $50,000 for the models described in Item 4. AAI also provides non-discretionary investment advice to intermediaries and registered investment advisers in the form of the model portfolio solutions directly or through the Platform, Retirement Services, and its Trade List Delivery services. AAI does not provide such non-discretionary investment advice directly to any underlying clients of the intermediaries or investment advisers. If this Form ADV Part 2A brochure is provided to an intermediary or underlying client with whom AAI does not have an advisory relationship, or where it is not legally

required to be delivered, it is provided to the intermediary solely for informational purposes and does not imply that AAI has an advisory, fiduciary or any relationship at all with such underlying clients.

AAI does not charge advisory fees on a share of the capital appreciation of the funds or securities in a client account (socalled performance-based fees). Fees that are a percentage of total value of an account averaged over a definite period, or as of definite dates, or taken as of a definite time are permissible. Our advisory fee compensation is charged only as disclosed above in Item 5 “Fees and Compensation.” AAI may manage investments for a variety of clients including mutual funds, exchange-traded funds, SMA/UMA program accounts, private funds, plan sponsors and retirement plan accounts. The potential conflicts of interest can arise from the side-by-side management of these clients based on fee structures. AAI has policies and procedures designed and implemented to ensure that all clients are treated fairly and to prevent this conflict from influencing the allocation of investment opportunities among clients.

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AAI is also registered with the Commodities Futures Trading Commission and is a member of the National Futures Association as a Commodity Pool Operator under the Commodity Exchange Act. Affiliated Technology Platform AAI’s affiliate, SS&C Advent (a subsidiary of SS&C Technologies, Inc.), operates the Black Diamond Wealth Platform ("Black Diamond"), a portfolio accounting and reporting platform used by investment advisers. AAI utilizes Black Diamond as the technology infrastructure for its BDIM subadvisory and model portfolio services. Certain third-party model providers that deliver model portfolios through Black Diamond participate in a platform program administered by SS&C Advent, under which the model provider pays an asset-based participation fee to SS&C Advent. The conflicts of interest arising from this affiliate relationship, including incentives related to the inclusion of Affiliated ETFs in third-party models, are described in Item 5 of this Brochure. Affiliated Broker-Dealers AAI is affiliated with ALPS Distributors, Inc. (“ADI”) and ALPS Portfolio Solutions Distributor, Inc., (“APSD”) both registered broker-dealers under the Securities Exchange Act of 1934 as each of AAI, ADI and APSD are wholly owned subsidiaries of AHI. AAI’s clients may employ the services of ADI or APSD in connection with the promotion and distribution of their fund’s shares. A complete explanation of services rendered is contained in each fund’s prospectus. AAI does not trade through either APSD or ADI as both broker–dealers do not trade National Market Securities. AAI is also affiliated with SS&C Market Services, LLC (“SS&C Market Services”), Second Street Securities, Inc. (“Second Street”), EZE Castle Transaction Services, LLC (“EZE Castle”), and EZE Software Group PTY Limited (“EZE Software”), each affiliated with a registered broker-dealer under the Securities Exchange Act of 1934 as they are under common control with SS&C. AAI does not trade through SS&C Market Services, Second Street, EZE Castle, nor EZE Software. Investment Advisory Agreements AAI has Investment Advisory agreements with the following registered investment companies: • ALPS ETF Trust; • ALPS Variable Investment Trust; • Liberty All-Star Growth Fund, Inc.; • Liberty All-Star Equity Fund; • Principal Real Estate Income Fund; and • Financial Investors Trust for the following funds:

ALPS/CoreCommodity Management CompleteCommodities Strategy Fund; ALPS/CoreCommodity Natural Resources ETF; ALPS/Smith Credit Opportunities Fund; ALPS/Smith Short Duration Bond Fund; ALPS/Smith Total Return Bond Fund; ALPS Asset Allocation Growth & Income; ALPS Balanced Opportunity Fund; ALPS Global Opportunity Fund; and Kotak India Equity Fund.

AAI has Investment Sub-Advisory agreements with the following registered investment companies: • ALPS Series Trust o Fundsmith Equity ETF • Sprott Funds Trust for the following funds: o Sprott Active Gold & Silver Miners ETF; o Sprott Active Metals & Miners ETF o Sprott Copper Miners ETF; o Sprott Critical Materials ETF; o Sprott Gold Miners ETF; o Sprott Junior Copper Miners ETF; o Sprott Junior Gold Miners ETF; o Sprott Junior Uranium Miners ETF; o Sprott Lithium Miners ETF; o Sprott Nickel Miners ETF; o Sprott Rare Earths Ex-China ETF; o Sprott Silver Miners & Physical Silver ETF; and o Sprott Uranium Miners ETF. • Wasatch Funds Trust o Wasatch Small/Mid Cap ETF

AAI has adopted a Code of Ethics (“Code”) for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code requires that our employees act with honesty and integrity, adhere to the highest standards and comply with applicable federal securities laws. All employees must acknowledge the terms of the Code initially upon hire and thereafter annually. Employees with access to certain information (as determined by their job position or as so designated by the Chief Compliance Officer) may also be deemed to be “Access Persons” or “Investment Persons.” Each such distinction has specific restrictions, limitations, reporting requirements and other policies and procedures that apply to persons defined as such. Our Code includes the following:

Requirements related to confidentiality of client information;

Prohibitions on: o Insider trading and tipping (if we are in possession of material, non-public information); o The acceptance of gifts and entertainment that exceed our policy standards; Requirements and reporting related to gifts and/or business entertainment; Pre-clearance of applicable personal securities transactions by “Access and Investment Persons”; Reporting of personal securities transactions by employees deemed to be “Access Persons” or “Investment Persons”; and On an annual basis, “Access and Investment Persons” must disclose any account in which they have beneficial ownership (they “own” the account or have “authority” over the account) and disclose all covered securities they own at that time.

AAI employees may trade for their own accounts in securities which are purchased or sold for AAI’s clients. Because AAI permits such personal trading, this creates the conflict that employees could use their knowledge of pending client transactions in an attempt to benefit their own personal transactions. For example, if an employee owns a security the employee knows AAI will be selling out of a client’s account, the employee could sell the personal holding ahead of time in an effort to obtain a higher price than might exist when the client account holdings are sold. To address conflicts related to personal trading, the Code requires any person deemed to be an “Investment Person” to pre-approve many types of securities transactions and imposes holding period requirements. The Code also requires reporting of personal securities transactions by any person deemed to be an “Access Person” or “Investment Person” and AAI reviews such reports. AAI’s clients or prospective clients may request a copy of AAI’s Code of Ethics policy by contacting us at 303-623-2577.

Best Execution and Trade Management Pursuant to an agreement with specific funds it advises, AAI may have authority to determine the securities and the amount of securities to be bought or sold, the broker or dealer to be used, and the commission rates to be paid on behalf of the fund. Funds may specifically direct AAI to limit the forgoing authority. AAI has the responsibility to appoint on behalf of the funds it advises, sub-advisers with full investment discretion, which may include the selection of brokers and other trading counterparties. AAI has the responsibility to oversee the

activities of the sub-advisers and ensure that all transactions comply with applicable regulations and prospectus covenants. In addition, where AAI is the adviser or sub-adviser, there are certain funds in which AAI will initiate placement, execution, and settlement of trades. In these instances, AAI will not actively make any specific security investment decisions. Rather AAI’s trading desk will be responsible for initiating trades necessary to keep the funds in line with a model portfolio provided by the adviser, sub-adviser or, in the case of an exchange-traded fund, the indexing agent or at the direction of the adviser or subadviser. Fund specific trading procedures are maintained for each relationship where AAI performs this function. AAI seeks to execute all trades at the best net price considering all relevant circumstances including any direction AAI may request in using a particular broker or dealer for the execution of transactions in exchange for research services provided to AAI, while complying with applicable law, including the Securities Exchange Act of 1934. Use of Client Commissions In accordance with a fund’s statement of additional information and/or investment advisory agreements, AAI may request its sub-advisers to direct commissions to certain brokers who, in turn, pay for third-party research products/services - provided such products/services fall within the safe harbor provisions of Section 28(e) of the Securities Exchange Act of 1934, as amended. Subject to the criteria of Section 28(e) of the Securities Exchange Act of 1934, as amended, and regulatory guidance from the SEC, a sub-adviser may pay a broker a brokerage commission higher than that which another broker might have charged for effecting the same transaction in recognition of the value of the brokerage and research services provided by the broker. In other words, the sub-adviser may “pay up” using client brokerage commissions or “soft dollars” to obtain research or brokerage services for the benefit of the funds who’s trading activity generated the commissions. When AAI uses client brokerage commissions to obtain research or other products or services, AAI receives a benefit because it does not have to produce or pay for research, products or services. AAI currently does not utilize soft dollars, however may choose to do so in the future. AAI allows the use by sub-advisers of soft dollars to purchase research data and analytical software in support of AAI advised funds. To ensure the funds receive maximum benefit in return for commissions, AAI’s Trade Order Management Committee (“TOMC”) will maintain oversight of soft dollar arrangements. The TOMC will also monitor soft dollar and brokerage activity throughout the year utilized by sub-advisers.

Aggregation of Client Orders Where AAI has appointed a sub-adviser with full investment discretion, the sub-adviser will follow its own policies and procedures as it relates to aggregation of client orders. In addition, where AAI is the adviser or sub-adviser, there are certain funds for which AAI will initiate placement, execution, and settlement of trades. AAI may aggregate the placement of trades if two or more trades are of the same stock and same side. AAI will look to aggregate those trades into a larger trade block to gain more favorable and exact execution for those affected accounts. Internal Cross Transactions An internal cross trade occurs when a security is moved from one account to another account. A registered investment company is subject to additional restrictions pursuant to Rule 17a-7 under the 1940 Act. The rule provides an exemption for certain securities transactions between registered investment companies that are affiliated solely by reason of having common or affiliated investment advisers, directors or officers. “If an advisory account and an investment company or two investment companies that are affiliated solely by reason of having a common investment adviser comply with each provision of Rule 17a-7, then they are permitted to purchase securities from and sell securities to one another.” It is recognized that cross trades can be beneficial to both the purchaser and seller because no brokerage commission is paid. Cross transactions shall be permitted, to the extent permitted by Rule 17a-7, if such transactions comply with procedures adopted by a fund’s Board of Directors/Trustees, including a majority of its Independent Directors/Trustees pursuant to Rule 17a-7. AAI and applicable sub-advisers will adhere to the 17a7 procedures of each Fund for which it provides services. Sub-Advisory Services AAI supports and works with multiple custodians at the direction of the Client. AAI will generally execute brokerage transactions on behalf of a Client with the supported custodian selected by the Client. Clients are not permitted to direct brokerage to a specified broker-dealer other than selecting a supported custodian. As a policy, AAI will generally execute securities transactions for a specified account directly with the custodian holding the account. As such, the account may not receive the benefit of the lowest trade price then available for any particular transaction. AAI may aggregate trades across eligible accounts where operationally feasible to seek fair and equitable execution. Although AAI’s sub-advisory agreements permit AAI, where the Client directs or authorizes it, to use broker-dealers other than the custodian and to pay commissions higher than another

broker would charge in reliance on Section 28(e) of the Securities Exchange Act of 1934, AAI currently executes subadvisory transactions through the Client’s selected custodian and does not receive soft dollar benefits from these transactions. AAI will update this Brochure before changing this practice. AAI will not direct brokerage in exchange for client referrals from a broker-dealer or other third-party. Underlying clients should consult the disclosure brochure of their advisor for more information on their advisor’s brokerage practices. Trade Errors AAI requires prompt resolution of trade errors upon detection with the intent to return the impacted client account to its original status had the error not occurred and the intended transaction had occurred without error (if applicable). Trade errors may include, but are not limited to, transactions in an incorrect security or an incorrect quantity of securities, an over/under allocation of a security to a client, transactions inconsistent or in violation of client investment guidelines or other failure to follow specific client directives, and transactions not legally authorized for the client’s account. If AAI executed the trade and a trade error has occurred where AAI is responsible, AAI will compensate the client for any resulting losses and compensate the client for any lost income that otherwise would have been earned had the error not occurred. Errors resulting in a gain should be awarded to the client unless the client is otherwise prohibited from receiving such gain. To the extent that a sub-adviser executed a trade that resulted in a trade error, the sub-adviser will follow its own policies and procedures for rectifying any trading error as long as the sub-adviser’s policies and procedures are deemed to be adequate by AAI. Oversight of Trading Practices AAI’s TOMC is responsible for the overall supervision of its trading practices. The Committee meets on a regular basis.

AAI does not currently have any active solicitation or referral arrangements in place. Other Compensation Arrangements As described in Item 5 of this Brochure, AAI has entered into revenue sharing arrangements with certain Clients under which AAI shares a portion of its sub-advisory fee revenue with the Investment Adviser. Revenue sharing is calculated based on the average daily balance of accounts managed by AAI at rates that vary by strategy type (up to 10 basis points per year for most strategies). Revenue sharing is generally available to Clients maintaining a minimum aggregate AUM threshold on AAI’s platform. Certain third-party model providers pay some or all of AAI’s trading and rebalancing fee for Client accounts that use their models ("Third-Party Subsidized Models"). This gives AAI an incentive to make these models available and to support their use, and the Client, which pays lower fees and receives a higher revenue share rate on these models, an incentive to select them.

Model Providers whose models are hosted on AAI's platform pay AAI a maintenance fee of 5 basis points per year on Client assets allocated to their models. This gives AAI an incentive to host, retain, and support models that attract more Client assets. AAI's proprietary models and SMAs are offered alongside thirdparty models on AAI's platform. Because AAI generally earns more when Clients use its proprietary strategies or Affiliated ETFs, AAI has a conflict of interest when deciding whether to host, discontinue, or modify its implementation of third-party models. To address this conflict, AAI implements third-party models using the same trading, rebalancing, aggregation, and trade rotation procedures it applies to its own strategies. Lastly, the Client, not AAI, selects the strategy for each account and is responsible for determining that it is in its client’s best interests. In addition, AAI and its affiliate SS&C Advent may offer certain qualifying Clients a Platform Fee Rebate that reduces the Client’s technology platform costs when the Client utilizes both AAI’s sub-advisory services and the Black Diamond Wealth Platform. The amount, conditions, and limitations of the Platform Fee Rebate are described in Item 5 of this Brochure. These arrangements create economic incentives for Clients to allocate assets to AAI’s platform and to maintain or increase assets under management with AAI. The conflicts of interest associated with these arrangements are described in further detail in Item 5 of this Brochure.

Registered investment advisers are obligated to disclose any disciplinary event that would be material to a client’s evaluation of AAI or the integrity of AAI’s management. AAI does not have any legal, financial or other “disciplinary” items to report to you.

Registered Investment Companies The Product Oversight Committee (“POC”) at AAI, which consists of senior and executive members of AAI’s management, reviews each fund’s portfolio and these reviews are based upon stated investment objectives as outlined in each fund’s prospectus. Where there is a sub-adviser appointed, such reviews will be made with the respective sub-adviser. AAI regularly provides to each fund’s Board of Directors/Trustees, reports on the portfolios of each fund along with information on market and economic conditions. Each fund is also monitored for compliance and investment limitations outlined in the prospectus and statement of additional information.

Model Portfolios AAI reviews the composition of its strategies and model portfolios periodically, and updates made in accordance with their mandates, or more often if appropriate. AAI may make adjustments as necessary in times of market disruption or distress within the parameters of the model portfolios. In addition, AAI will conduct periodic reviews of third-party ETF providers utilized in its model portfolios. AAI will apply a similar methodology as it uses to evaluate its sub-advisers to providers of model portfolios and the underlying funds. The POC will also review the models and strategies utilized by AAI to ensure the allocations are consistent with the stated objectives. Sub-Advisory Services & Donor Advised Fund Solutions AAI periodically reviews accounts to ensure consistency with the Client’s instructions, account restrictions, and the parameters of the applicable strategy. Reviews may be triggered by material market movements, significant cash flows, index reconstitutions, changes in Client-directed restrictions, or tax-management events. AAI monitors accounts on an ongoing basis for adherence to tracking error budgets, wash sale compliance within accounts under AAI’s management, and proper implementation of Client-directed screens and exclusions. The information in this Brochure does not include all the specific review features associated with each investment strategy or applicable to a particular client account. Clients are urged to ask questions regarding AAI’s review process applicable to a particular account.

To the extent AAI serves as investment adviser to certain private funds, AAI may be deemed to have “custody” of client funds and securities within the meaning of Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). AAI will seek to comply with all applicable provisions of the Custody Rule. With respect to the sub-advisory services AAI may provide to other registered investment advisers, AAI will not have custody of any securities, cash or other assets of the underlying account, as understood under the Custody Rule and applicable SEC guidance.

Registered Investment Companies Pursuant to an agreement with specific funds it advises, AAI may have authority to determine the securities and the amount of securities to be bought or sold, the broker or dealer to be used, and the commission rates to be paid on behalf of the fund. Funds may specifically direct AAI to limit the forgoing authority. AAI has the responsibility to appoint on behalf of certain funds it advises, sub-advisers with full investment discretion, which may include the selection of brokers and other trading

counterparties. AAI has the responsibility to oversee the activities of the sub-advisers and ensure that all transactions comply with applicable regulations and prospectus covenants. Sub-Advisory Services Each Client’s sub-advisory agreement, as well as agreements under which AAI has been delegated comparable services, generally grants AAI discretionary authority to execute trades and invest its Clients’ assets in accordance with the model portfolio selected by the Client, subject to any specific limitations as to type, amount, concentration, or leverage, as determined by each Client and set forth in the applicable agreement. Any limitations on this authority shall be included in the applicable agreement and/or written authority statement. Clients may amend these limitations as permitted pursuant to the applicable agreement, and any such amendment requests shall be in writing. Retirement Solutions While AAI may provide investment recommendations to authorized plan participants, AAI does not exercise investment discretion or control over investments or plan assets. Donor Advised Fund Solutions Where authorized under the OCIO or sub-advisory agreement, AAI has discretion to purchase/sell securities and rebalance within the applicable DAF investment options or account(s), subject to the sponsor’s IPS, liquidity for grantmaking, and platform constraints. AAI does not have discretion to select brokers or custodians in DAF programs. Model Portfolio Solutions AAI constructs and provides model portfolios to other registered investment advisers through SS&C BDIM. AAI does not have investment discretion as investment advisers have the ultimate decision making and discretionary responsibility for the determination of which securities are to be purchased and sold for their account and effect all security transactions in connection with such determinations. Trade List Delivery Pursuant to a Trade List Delivery Services Agreement, AAI will provide buy and sell recommendations to its Clients on a nondiscretionary basis. AAI does not exercise investment discretion over accounts on which it provides recommendations.

Registered Investment Companies AAI has adopted and implemented proxy voting policies and procedures, which it believes are reasonably designed to: (1) ensure that proxies are voted in the best economic interest of

clients; and (2) address material conflicts of interest that may arise. With respect to certain funds advised by AAI, day-to-day investment decisions are performed by the fund’s investment sub-adviser(s). The funds’ Board of Trustees/Directors may elect to delegate the responsibility of voting proxies to such subadviser to be voted in accordance to the sub-adviser’s proxy voting policies and procedures in conformance with Rule 206(4)6 under the Investment Advisers Act of 1940, as amended. All proxies regarding client securities for which AAI has authority to vote will, unless AAI determines in accordance its policies to refrain from voting, be voted in a manner considered by AAI to be in the best interest of AAI’s clients. The best interest of clients is defined for this purpose as the interest of enhancing or protecting the economic value of client accounts, considered as a group rather than individually, as AAI determines in its sole and absolute discretion. AAI may refrain from voting if doing so would be in the client’s best interest. These circumstances may arise, for example, when the expected cost of voting exceeds the expected benefits of voting, (e.g., when exercising the vote results in the imposition of trading or other restrictions). There may also be instances where a fund relies upon Section 12(d)(1)(F), and by law, the fund may be required to vote proxies in the same proportion as the vote of all other shareholders of the acquired fund (i.e., “echo vote”). In the event a client believes that its other interests require a different vote, AAI will vote as the client clearly instructs, provided AAI receives such instructions in time to act accordingly. As it pertains to proxy voting, a material conflict of interest is a relationship or activity engaged in by AAI, an AAI affiliate, or an AAI associate that creates an incentive (or appearance thereof) to favor the interests of AAI, the affiliate, or associate, rather than the clients’ interests. For example, AAI may have a conflict of interest if either AAI has a significant business relationship with a company that is soliciting a proxy, or if an AAI associate involved in the proxy voting decision-making process has a significant personal or family relationship with the particular company. A conflict of interest is considered to be “material” to the extent that a reasonable person could expect the conflict to influence AAI’s decision on the particular vote at issue. In all cases where there is deemed to be a material conflict of interest, AAI will seek to resolve it in the clients’ best interests. AAI seeks to avoid the occurrence of actual or apparent material conflicts of interest in the proxy voting process by voting in accordance with predetermined voting guidelines and observing other procedures that are intended to guard against and manage conflicts of interest. AAI follows the proxy guidelines and uses other research services provided by Institutional Shareholder Services, Inc. (“ISS”) or another independent third party. In providing proxy voting services to AAI, ISS provides vote recommendations on a pre-determined policy. Generally, AAI will vote proxies based on ISS’ pre-determined voting policy. In

doing so, AAI demonstrates that its vote would not be a product of a conflict of interest as AAI would have little or no discretion on how the proxy was voted. AAI will provide clients with a copy of its policies and procedures, as they may be updated from time to time, upon request. AAI will not selectively disclose its investment company clients’ proxy voting records to third parties; the investment company clients’ proxy records will be disclosed to shareholders by publicly-available annual filings for each investment company’s proxy voting record for 12-month periods ending June 30th. AAI’s clients or prospective clients may request a copy of AAI’s Proxy Voting policy by contacting us at 303-623-2577. Sub-Advisory Services & Donor Advised Fund Solutions With respect to sub-advisory accounts, AAI does not accept authority to vote proxies for securities held in Client accounts. The Client retains the right to vote all proxies held in subadvisory accounts, and AAI is expressly precluded from voting proxies or taking any action or rendering any advice with respect to the voting of proxies for securities held in sub-advisory accounts. AAI will not monitor or respond to proxy solicitations unless AAI has accepted that authority in writing. Model Portfolio Solutions Unless expressly authorized in the applicable OCIO or subadvisory agreement, AAI does not accept authority to vote proxies for securities held in DAF program accounts. Proxy voting responsibility is determined by the DAF sponsor agreement.

Audited Balance Sheet The requirement to provide an audited balance sheet is not applicable to AAI as it does not require clients to prepay fees six months or more in advance. Financial Condition Disclosures Registered investment advisers are required to provide certain financial information or disclosures about its financial condition. AAI has no financial condition that impairs its ability to meet contractual commitments to clients and has not been the subject of a bankruptcy proceeding.