ARK Investment Management LLC

Description of the Advisory Firm ARK Investment Management LLC (“ARK”) is a Delaware limited liability company with headquarters located at 200 Central Avenue, Suite 220, St. Petersburg, FL 33701. ARK is an independent, womanowned and controlled firm that has been registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser since January 2014. ARK began managing assets in September 2014. ARK is principally owned by Catherine D. Wood. Ms. Wood is ARK’s founder, Chief Executive Officer (“CEO”), and Chief Investment Officer (“CIO”) and is the primary portfolio manager responsible for managing client assets. Ms. Wood has over 40 years of experience in theme-based investing (as defined below). Ms. Wood launched ARK after spending the previous 12 years at AllianceBernstein where she served as Chief Investment Officer for its global thematic portfolios, managing approximately $5-6 billion. Prior to AllianceBernstein, in 1997, Ms. Wood co-founded Tupelo Capital Management. Prior to Tupelo, Ms. Wood held numerous positions in her 18 years at Jennison Associates, including research analyst and portfolio manager. During her career, Ms. Wood has tracked technologies that enabled the development of new industries, such as cell phones and database publishing, from their nascent stage to their full realization for the benefit of her investors and clients. ARK (an acronym for “Active, Research and Knowledge”) specializes in thematic investing in disruptive innovation with a fresh take on fundamental analysis. Thematic investing is based on broader, macroeconomic topics (i.e., themes) rather than benchmarks, and seeks to capture long-term growth independent of sectors, geographic boundaries, and market-caps. Specifically, ARK invests in themes that participate in disruptive innovation across sectors. ARK defines “disruptive innovation” as the introduction of a technologically enabled new product or service that ARK expects to change an industry landscape. Typically, it involves declining cost structures and increased productivity and unit growth. Despite its potential, ARK believes the full magnitude of disruptive innovation and the investment opportunities it creates are often unrecognized or misunderstood by traditional investors. ARK’s goal is to invest at the pace of innovation based on the belief that technologically enabled change is occurring at an accelerated rate, challenging benchmarks and index-based products to adjust to this rapid pace of change. ARK’s differentiated investment strategy is to find and invest in the companies that are poised to transform the global economy. ARK’s Investment Process ARK recognizes that many traditional research analysts, by focusing narrowly on individual sectors, create inefficiencies in the financial markets both in understanding the market potential of disruptive innovations and in sizing investment opportunities appropriately. ARK’s cohesive team, specifically its Portfolio Managers, Associate Portfolio Manager(s), Traders (including the Director of Operations), Directors of Research and Research Analysts, including Research Associates and Analyst Interns, Chief Investment Strategist- Private Equity and Chief Futurist (“ARK Team”), seek to identify what they believe to be the best companies within their respective themes (and the elements within those themes) to power ARK’s investment decisions. ARK’s distinctive and dynamic investment process is rooted in fundamental

analysis and distinguished by ARK’s ability to access and harness the vast amount of information available through social media and traditional research sources to support ARK’s investment decisions. ARK has a rigorous investment process, which includes “top-down” and “bottom-up” investment analysis and a proprietary scoring system. ARK’s investment process initially examines from the top-down how the world is changing and where it is headed. By anticipating and quantifying multi-year value-chain transformations, typically caused by technologically enabled disruptive innovation, ARK believes it can identify and capitalize on these opportunities. To understand quickly changing innovation themes, ARK employs an open research ecosystem (“ARK’s Open Research Ecosystem”) to gather information and refine its internal research process. Inputs include ideas, thoughts and public information from theme developers who we believe are thought leaders in their fields, social media interactions, and crowdsourced insights as people respond to ARK’s public research. ARK’s Open Research Ecosystem powers the distinctive and dynamic investment process that enables ARK to understand and keep pace with the power of technologically enabled innovation. Using this information in an iterative fashion, ARK’s Team works to “size” and “re-size” the opportunities. As a result of extensive and iterative research steps, ARK anticipates and quantifies multi-year valuechain transformations and market opportunities. ARK models cost-curves and calculates elasticity of demand to identify entry points for technology-enabled disruption. Through this process, specific companies percolate to the top as those we believe are best positioned to benefit from the identified investment premise, at which point ARK begins its bottom-up process. ARK scores potential investments based on six key metrics, inputting the values into a proprietary scoring system to quantify the companies in the context of the opportunity. ARK builds models that incorporate the company’s unit volume growth, cost declines, market adoption and penetration, share count growth, and future multiples. The CIO has final accountability for the selection of investments and approval for all investment decisions. Additionally, in ARK’s “top-down” and “bottom-up” approaches, ARK evaluates environmental, social, and governance (“ESG”) considerations. In its “top-down” approach, ARK uses the framework of the United Nations Sustainable Development Goals (“UN SDGs”) to integrate ESG considerations into its research and investment process. In its “bottom-up” approach, ARK makes its investment decisions primarily based on its analysis of the potential of individual companies, while integrating ESG considerations into that process. ARK’s highest-conviction investment ideas are those that it believes present the best risk-reward opportunities. ARK, however, does not use ESG considerations to limit, restrict or otherwise exclude companies or sectors from an investment universe. ARK’s Open Research Ecosystem ARK’s Open Research Ecosystem is the unique process through which the ARK Team evaluates, models and exchanges data and public information to fuel ongoing thematic research, start creative discussions around burgeoning research ideas, gather data and public information from multiple sources, and drive the conclusions leading to ARK’s theme-based research decisions in disruptive innovation. The ARK Team introduces an idea or concept that requires investment research and analysis, determines the overarching direction of the research and then pulls together and analyzes information, insights and data from numerous sources. ARK’s Open Research Ecosystem begins with internal

deliberations and iteration of disruptive innovation ideas generated from ARK’s discerning use of traditional and social media sources. Once the ARK Team believes an idea is ripe for deeper external analysis and comment, the appropriate ARK Team members may communicate and collaborate with relevant Theme Developers (as defined below) about the particular idea. This intense and deep exploration often results in “living research” articles that are prepared by the ARK Team members, which are published on our external website (www.ark-invest.com). This living research is available for open-source discussion and feedback and is subject to potential revisions, refinements and enhancements by the ARK Team and publication of further refined research. The knowledge and insights gained throughout ARK’s Open Research Ecosystem enables ARK to modify its portfolio positions accordingly, feeding the ARK investment process. ARK Theme Developers Theme Developers are those we deem to be thought leaders from a variety of fields who offer meaningful insights, experience, and knowledge about ARK’s research themes. The ARK Team actively engages with these Theme Developers in ARK’s Open Research Ecosystem. ARK’s Theme Developers do not receive any monetary compensation for participating in ARK’s Open Research Ecosystem and are only benefited through the exchange of ideas, knowledge and research. Also, ARK contractually obligates Theme Developers to, among other things: not exchange material non-public information; not share confidential information about ARK and/or its clients; and disclose all conflicts of interest to ARK’s Chief Compliance Officer (“CCO”) initially and on an ongoing basis with respect to serving as a Theme Developer for ARK. Types of Advisory Services Advisory and Supervisory Services to the ARK ETFs ARK provides investment advisory services to the ARK ETF Trust, a registered investment company. The ARK ETF Trust has thirteen separate series (each, an “ARK ETF”, and collectively, “ARK ETFs”), which are exchange-traded funds. ARK serves as the investment adviser to each ARK ETF, subject to the general supervision of the Board of Trustees (the “Board”) of the ARK ETF Trust. ARK’s duties as adviser to each ARK ETF include furnishing a continuous investment program for the ARK ETFs and determining what investments or securities will be purchased, held or sold. Certain ARK ETFs are subadvised by a third-party investment adviser. With respect to these ARK ETFs, ARK acts as “manager of managers” by providing oversight of the sub-adviser’s services. ARK performs due diligence on thirdparty investment advisers and selects candidates it believes are capable of successfully implementing an ARK ETF’s intended investment theme. After the initial two-year period following commencement of operations of the relevant ARK ETF, the Board annually reviews and evaluates the services provided by ARK under the investment advisory agreement (“Advisory Agreement”) and, where applicable, by a subadviser under an investment sub-advisory agreement (“Sub-advisory Agreement”), and is asked to approve the Advisory Agreement and Sub-advisory Agreement for an additional one-year period. When appropriate, ARK may recommend the appointment, retention or termination of a sub-adviser to the Board. Pursuant to a supervision agreement between ARK and the ARK ETF Trust, with respect to each ARK ETF (“Supervision Agreement”), and subject to the general supervision of the Board, ARK also provides

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Fees and Compensation The following information describes ARK’s compensation for the advisory services it provides to each type of client account, including management fees (“Management Fees”) and other fees and expenses. ARK ETFs In accordance with the Supervision Agreement, each ARK ETF pays an annual Management Fee in return for providing investment management and supervisory services (including the provision of all services typically needed for the operation of the ARK ETF) under a comprehensive unitary fee structure. The unitary fee structure allows each ARK ETF to pay for the advisory, supervisory, administrative, custody and other services they require under what is essentially an all-in fee structure. However, each ARK ETF bears other expenses that are not covered under the Supervision Agreement (i.e., that are not included in the Management Fee) that can vary and will affect the total level of expenses paid by each ARK ETF. Those expenses include taxes and governmental fees, certain transaction expenses, certain custodial fees and expenses, costs of borrowing money (including interest expenses), and extraordinary expenses (such as litigation and indemnification expenses), as well as various fees and expenses relating to regulatory reporting and filings, and preparing and sending reports to shareholders. Actively Managed ETFs. The annual Management Fee of 0.75% for each of the six actively managed ETFs is paid to ARK monthly in arrears based on the average daily net assets of each ARK ETF. Pursuant to the Advisory Agreement, the annual investment advisory fee payable to ARK by each ARK ETF, which fee is included within the Management Fee, is 0.55% of average daily net assets of each ARK ETF. Index ETFs. The annual Management Fee for the two current index ARK ETFs are 0.48% for the ARK Israel Innovative Technology ETF and 0.65% for The 3D Printing ETF, and each Management Fee is paid to ARK monthly in arrears based on the average daily net assets of each ARK ETF. Pursuant to the Advisory Agreement, the annual investment advisory fee payable to ARK by each of these index ARK ETFs, which fee is included within the Management Fee, is

0.30% of average daily net assets of each ARK ETF. The ARK Israel Innovative Technology ETF and The 3D Printing ETF are also charged an additional 0.01% to cover foreign custodial fees and expenses. DIET Buffer ETFs. The annual Management Fee of 0.69% for each of the four actively managed ETFs is paid to ARK monthly in arrears based on the average daily net assets of each DIET Buffer ETF subject to certain waivers of its management fee payable by each fund in an account equal to the investment advisory fee portion of the management fee it earns as an investment advisor to the affiliated fund(s) in which the fund invests. Active Autocallable Income ETF. The annual Management Fee of 0.85% for this actively managed ETF is paid to ARK monthly in arrears based on the ETF’s average daily net assets. Pursuant to the Advisory Agreement, the annual investment advisory fee payable to ARK by the ETF, which fee is included within the Management Fee, is 0.65% of average daily net assets of the ETF. Additional information about the fees charged to the ARK ETFs is available in the ARK ETFs’ prospectuses and statement of additional information, which are publicly available at www.arkfunds.com, on the EDGAR Database on the SEC’s website (www.sec.gov), or by contacting the ARK ETFs’ principal underwriter, Foreside Fund Services, LLC at Three Canal Plaza, Suite 100, Portland, ME 04101 or calling 855-406- 1506. Interval Fund: Venture Fund Pursuant to the Advisory Agreement, and in consideration of the advisory services provided by ARK to the Venture Fund, ARK is entitled to a Management Fee, which is calculated and payable monthly in arrears at the annual rate of 2.75% of the average daily value of the Venture Fund’s Net Assets. “Net Assets” means the total assets of the Venture Fund minus the fund’s liabilities. In addition to the Management Fee, the Venture Fund bears other fees and expenses, which may vary and will affect the total expense ratio of the Venture Fund, such as taxes and governmental fees, brokerage fees, commissions and other transaction expenses, certain foreign custodial fees and expenses, costs of borrowing money, including interest expenses, and extraordinary expenses (such as litigation and indemnification expenses). Additional information regarding the Venture Fund expenses can be found in the Venture Fund prospectus in the “Fund Expenses” section, which is publicly available at www.ark-funds.com, on the EDGAR Database on the SEC’s website (www.sec.gov) or writing to the Venture Fund at ARK Investment Management, LLC, 200 Central Ave., Suite 220, St. Petersburg, Florida 33701, or by calling toll-free 888-511-2347. Separately Managed Accounts, Other Pooled Investment Vehicles and Clients When ARK enters into an investment advisory agreement or other agreements to provide investment management or advisory services to clients, ARK will charge each such client a fee at a specified annual percentage rate of the client’s assets under management. Fees also can include a performance component for certain clients and Private Funds, as discussed in Item 6.

Separately Managed Accounts ARK’s standard fee rates for management of separately managed accounts are normally between 0.45% and 0.60% of assets under management. The fees charged to separately managed accounts are negotiable and typically will vary and can be reduced or can include breakpoints at ARK’s sole discretion depending on a number of factors including, but not limited to: the type of client, the strategy, the size of the account, the total amount of client assets managed or advised by ARK, whether the client wishes to impose particular limitations or restrictions on ARK’s discretionary investment authority (e.g., restrictions on the types of securities that ARK acquires for the account), and other business considerations. ARK generally imposes investment minimums on separately managed accounts. ARK’s fee rates do not include fees that separately managed account clients normally pay to other thirdparty service providers, including custodial, administrative, securities lending agent, consultant, brokerage, and exchange fees. Additional information on brokerage fees are detailed in Item 12 Brokerage Practices. Generally, ARK will not enter into contracts with “most favored nation” clauses. However, certain institutional separately managed account clients could seek to include such clauses in their investment advisory agreements. These clauses generally would require ARK to decrease the fees charged to the “most favored nation” client if ARK entered into an advisory agreement at a lower fee rate with another similarly situated institutional client. The applicability of a “most favored nation” clause depends on factors including the degree of similarity between institutional clients, including the assets under management and the particular investment objective, strategy, guidelines, limitations, restrictions, reporting requirements, policies, and practices applicable to each client. ARK will not agree to “most favored nation” clauses in all circumstances where institutional clients are similarly situated. ARK does not consider the fee structure charged to a seeding client for a new strategy to be applicable to most favored nation clauses, calculations or considerations. Sub-Advised Funds The fees charged to any Sub-Advised Funds are negotiable and in some cases, ARK receives fees from Sub-Advised Funds that are different from those it receives for managing separately managed accounts or directly advised pooled investment vehicles. For funds that ARK sub-advises, the respective fund’s adviser (not ARK) typically provides administrative, regulatory compliance, distribution, marketing and shareholder services, including any necessary disclosures to and communications with shareholders. ARK’s fee will be a component of the total investment advisory fee paid by an investor in the specific sub-advised fund. Additional detail about the fees charged to an investor in any such Sub-Advised Fund will be available in (i) the sub-advised fund’s prospectus and statement of additional information (if the fund is a U.S. registered investment company), (ii) in the offering document for an unregistered fund or (iii) similar disclosure documents for a non-U.S. sub-advised fund. Pooled Investment Vehicles ARK’s fees for providing management and advisory services to pooled investment vehicles, which can include performance-based fees, are described in the offering documents for such vehicles. Further information about ARK’s ability to receive performance-based fees is described below in response to Item 6.

Wrap and UMA Programs and Model Portfolios Wrap Fee and UMA Program Fees Typically, a managed account sponsor client pays the sponsor a single asset-based fee for brokerage, custody and advisory services and ARK is paid by the sponsor for ARK’s services. For additional information about the fees that a wrap account client could incur, please review the sponsor’s brochure for the wrap program. We negotiate the fee for ARK’s services to wrap and UMA programs with the sponsor of the programs. The fees negotiated with the sponsor for ARK’s advisory service to such programs vary and depend on such factors as the asset class, market capitalization of the strategy, and discretionary versus nondiscretionary services. ARK can individually negotiate its fees for dual contract managed accounts dependent on the sponsor program and does not have a standard fee schedule. Model Portfolios ARK enters into agreements with certain institutional clients to provide them with periodic investment instructions or model portfolios based on the assets of the portfolio in question. ARK’s standard fee rates for such services normally are between 0.25% and 0.50% of assets under management. These fees are negotiable and will depend on a variety of factors, including customary rates of other similar advisers and advisory structures for providing substantially the same advisory services in the jurisdiction in question. Non-Discretionary Sub-advisory and Sub-Sub advisory Services The fees charged for non-discretionary sub-advisory and sub-sub advisory services are negotiable and in some cases, ARK receives fees from sub-advised and sub-sub advised funds that are different from those it receives for providing discretionary advice to separately managed accounts or directly advised pooled investment vehicles. Fees are not negotiable for individual investors and have been subject to a waiver. Bitcoin ETF For the Bitcoin ETF that ARK provides non-discretionary sub-advisory services, the respective fund’s sponsor (not ARK) typically provides administrative, custody, and other services, including any necessary disclosures to and communications with shareholders. Additionally, ARK provides marketing support services. ARK’s fee will be a component of the total unitary sponsor fee paid by an investor in the specific sub-advised fund. In the sponsor’s sole discretion, all or any portion of these operating expenses can be re-designated and would become payable by the fund. The Bitcoin ETF bears other expenses that are not included in the unitary sponsor fee that can vary and will affect the total level of expenses, including certain extraordinary, non-recurring expenses, including, but not limited to, taxes and governmental charges, expenses and costs of any extraordinary services performed by the sponsor (or any other service provider) on behalf of the trust to protect the trust or the interests of shareholders, any indemnification of the bitcoin custodian, administrator or other agents, service providers or counterparties of the trust, the fees and expenses related to the listing, and extraordinary legal fees and expenses, including any legal fees and expenses incurred in connection with litigation, regulatory enforcement or investigation matters. There are other fees that you could pay to third-parties as well, including the brokerage commissions on the purchase and sale of shares. Additional information

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Descriptions of Investment Themes ‘ARK 10’ Theme Investment Objective: Long-term growth of capital. Principal Investment Strategies: The ‘ARK 10’ theme-based investment strategy is a selection of ten (10) equity securities that ARK believes presents the best risk-reward profile from the Disruptive Innovation theme-based investment strategy. The ten equity securities are domestic and foreign equity securities of companies that are relevant to the investment theme of disruptive innovation. ARK believes companies relevant to this theme are Genomic Revolution Companies (as defined below), Automation Transformation Companies, Energy Transformation Companies, Artificial Intelligence Companies, Next Generation Internet Companies (as defined below) and FinTech Innovation Companies (as defined below). For accounts using this strategy, ARK will select investments that represent its highest-conviction investment ideas within the theme of disruptive innovation. Material Risks: Communications Sector Risk; Consumer Discretionary Risk; Cryptocurrency Risk; Cryptocurrency Tax Risk; Emerging Markets Securities Risk; Equity Securities Risk; FinTech Risk; Foreign Securities Risk (including Depositary Receipts Risk); Future Expected Genomic Business Risk; Health Care Sector Risk; Industrials Sector Risk; Information Technology Sector Risk; Issuer Risk; Innovative Technology Risk; Large-Capitalization Companies Risk; Management Risk; Market Risk; Market Trading Risk; Micro- Capitalization Companies Risk; Small- and Medium-Capitalization Companies Risk; Next Generation Internet Companies Risk; Technology and Cyber Security Risks; Currency Risk; Disruptive Innovation Risk; and International Closed-Market Trading Risk. Bitcoin Theme Investment Objective: Growth by seeking to track the performance of bitcoin. Principal Investment Strategies: The Bitcoin theme-based investment strategy seeks to track the performance of bitcoin, as measured by the performance of the CME CF Bitcoin Reference Rate - New York Variant (the “Index”), through investment in bitcoin. This theme-based investment strategy is valued daily based on the bitcoin price reported by the Index. Material Risks: Risks Associated with Bitcoin and the Bitcoin Network; Risks Associated with Investing in the Trust; Risks Associated with the Regulatory Environment of Bitcoin; Risks Associated with the Tax Treatment of Bitcoin; Other Risks.

Cryptoasset Theme Investment Objective: Diversified growth and capital preservation by providing exposure to cryptoasset strategies. Principal Investment Strategies: The Cryptoasset theme-based investment strategy invests in (a) Cryptoassets that ARK considers, in its sole and absolute discretion, to be relevant to public blockchain innovation, (b) decentralized finance and similar activities operating through the use of technologies, protocols, networks, or platforms involving Cryptoassets or other blockchain technologies, and (c) equity and equity-like investments in public and private companies operating in the blockchain and Cryptoasset industries. ARK defines “Cryptoassets” generally to include digital “native” assets issued on a decentralized, open-source peer-to-peer protocol and all other digital assets related to public blockchain technology, including, without limitation, cryptocurrencies, digital currencies, virtual currencies, tokens, blockchain-based assets, decentralized application tokens, protocol tokens, securities tokens, nonsecurities tokens, non-fungible tokens, smart contracts, digital currency networks, stablecoins, digital coins, altcoins, network participants, token warrants, decentralized autonomous organizations and their underlying protocol tokens, synthetic digital assets, other similar digital and cryptofinance assets that currently exist or may exist in the future, the ownership or transmission of which is recorded or verified by a distributed ledger or other similar technology, including, without limitation, a blockchain or directed acyclic graph. Material Risks: Market Risk; Forward Trading Risk; Concentration Risk; Hedging Transactions Risk; Counterparty Risk; Bitcoin and Bitcoin Network Risks; Ether and the Ethereum Network Risks; Regulatory Environment of Bitcoin under “Bitcoin ETF”; Equity Securities Risk; “Follow-on” Investment Risk; Portfolio Company Selection; Portfolio Company Deal Flow; Lack of Operating History of Portfolio Companies; Intellectual Property Risk; Portfolio Company Financing Risk; Liquidity Risk; Blockchain Investment Risk; Valuation Risk; Audit Risks; Cryptoasset Risk; Cryptoasset Regulation Risk; Volatility Risk for Cryptoassets; Investment Capacity Risk; Decentralized Exchanges and Investing in DeFi and Decentralized Lending and Borrowing Risk; Staking Risks; and Cryptoasset Derivative Regulatory Risk. Cryptocurrency Theme Investment Objective: Diversified growth by providing exposure to cryptocurrency. Principal Investment Strategies: The Cryptocurrency theme-based investment strategy seeks to provide exposure to a high-conviction portfolio of cryptocurrencies measured against a Bitcoin benchmark. Under normal conditions, the strategy will be invested primarily in bitcoin and ether, the largest cryptocurrencies by network value. In selecting cryptocurrencies, ARK uses its internal research and analysis to identify assets that provide strong money assurances including but not limited to, censorshipresistance, inflation-resistance, seizure-resistance and open validation & transparency. ARK applies both a top-down and bottom-up approach to analyzing potential investments. The top-down analysis includes macro indicators and sentiment, global adoption, infrastructure development, and regulations. The bottom-up analysis includes fundamental and quantitative metrics for individual cryptocurrencies. Material Risks: Cryptocurrency Risk; Cryptocurrency Tax Risk; Valuation Risk; Counterparty Risk; Liquidity Risk; Leverage Risk; Market Risk; Concentration Risk; Futures, Options, Swaps, and Commodities Risk; Forward Trading Risk; Short Sales Risk; Hedging Transactions Risk; Foreign Securities Risk; Valuation Risk; Audit Risks; and Technology and Cyber Security Risks. Early Stage Disruptors Theme Investment Objective: Long-term growth of capital. Principal Investment Strategies: The Early Stage Disruptors theme-based investment strategy invests under normal circumstances, in companies that ARK believes are early stage disruptors. “Disruptors”

are leading innovative companies that stimulate substantial growth or create new markets while also disrupting existing sectors. An innovative company is one that introduces a technologically enabled new product or service that ARK believes might change an industry by creating simplicity and accessibility, while possibly driving down costs. An early stage disruptor is either: 1) a newer public company that the sponsor believes is a disruptor company and has the potential for future long-term growth, or 2) a company that has introduced a technologically enabled product or service that is in the early stages of development and has the potential for future long-term growth. ARK invests in securities that it believes are early stage disruptors that are involved in at least one of the following five innovation platforms: DNA sequencing, robotics, energy storage, artificial intelligence, and blockchain technology. Each innovation platform has associated transformative technologies and while the client could be exposed to some of the associated transformative technologies, the client might not have exposure to all of them. The associated transformative technologies for the innovation platforms are: • DNA sequencing – immunotherapy, gene editing and sequencing technology • Robotics – adaptive robotics, 3D printing and reusable rockets • Energy storage – autonomous mobility and battery systems • Artificial intelligence – neural networks, mobile connected devices, cloud computing and internet of things • Blockchain technology – blockchain and frictionless value transfer Material Risks: Market Risk; Early Stage Disruptors Risk; Health Care Sector Risk; Financial Sector Risk; DNA Sequencing Companies Risk; Artificial Sequencing Companies Risk; Foreign Securities Risk; Emerging Markets Securities Risk; Small- and Medium-Capitalization Companies Risk; Technology and Cyber Security Risk; Operational and Service Provider Risk; Litigation and Legislation Risk; and Inflation Risk. Global Digital Theme Investment Objective: Mid and long-term growth of capital. Principal Investment Strategies: The Global Digital theme-based investment strategy invests primarily in domestic and foreign equity securities of companies that are relevant to the investment theme of Global Digital. ARK believes companies relevant to this theme are focused on and expected to benefit from using digital technology to offer zero-contact, interactive services and/or products related to interactive services. These companies can include mail order houses which generate the entirety of their business through websites and which offer internet-based products and services, such as streaming media or cloud storage in addition to traditional physical goods. These companies can also include ones that develop, use or rely on innovative payment methodologies, big data, the internet of things, and social distribution, cybersecurity, cryptocurrencies, media and technologies that make financial services more efficient. Material Risks: Communications Sector Risk; Cryptocurrency Risk; Cryptocurrency Tax Risk; Emerging Markets Securities Risk; Equity Securities Risk; FinTech Risk; Foreign Securities Risk (including Depositary Receipts Risk); Information Technology Sector Risk; Issuer Risk; Large-Capitalization Companies Risk; Management Risk; Innovative Technology Risk; Market Risk; Market Trading Risk; Micro-Capitalization Companies Risk; Small- and Medium-Capitalization Companies Risk; Next Generation Internet Companies Risk; Technology and Cyber Security Risks; Blockchain Investment Risk; Concentration Risk; Consumer Discretionary Risk; Currency Risk; Disruptive Innovation Risk; and International Closed-Market Trading Risk.

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ARK ETFs ARK acts as investment manager and provides management and supervisory services to the ARK ETFs. The ARK ETFs are exchange-traded funds. Each ARK ETF is an open-end management investment company registered under the 1940 Act, whose shares are registered for sale under the 1933 Act. ARK’s services to each ARK ETF are supervised by the Board, currently composed of four Trustees. For independence purposes, three of the four Trustees are not “interested persons” of the ARK ETF Trust or ARK. Additional information about each ARK ETF, including the services that ARK provides and the ARK ETFs’ investment objectives, strategies and risks, can be found in the ARK ETFs’ prospectuses and statement of additional information, which are publicly available at www.ark-funds.com, on the EDGAR Database on the SEC’s website (www.sec.gov) or by contacting the ARK ETFs’ principal underwriter, Foreside Fund Services, LLC at Three Canal Plaza, Suite 100, Portland, ME 04101 or by calling 855406-1506. ARK Monthly Webinars. ARK publishes a Monthly webinar to provide ongoing education around the ARK ETFs, including discussions of performance, composition, outlook, and commentary and providing answers to investor questions. This information is not investment advice and will only discuss public information. The on-demand webinars and materials will be posted to the ARK website and can be found at www.ark-funds.com. All interested parties can obtain more information at www.ark-funds.com. Such webinars are published on the third Thursday following a month end at 4:30PM EST unless otherwise announced. Advisory Services to the Venture Fund ARK provides investment advisory services to the Venture Fund, a Delaware statutory trust that is registered under the 1940 Act as a non-diversified, closed-end management investment company. ARK serves as the investment adviser to the Venture Fund, subject to the general oversight of the Venture Fund’s Board of Trustees, and is responsible for the day-to-day investment management of the fund. The Venture Fund is designed primarily for long-term investors and not as a trading vehicle. The Venture Fund is an “interval fund” pursuant to which it, subject to applicable law, will conduct quarterly repurchase offers for between 5% and 25% of the fund’s outstanding shares of beneficial interest at NAV generally. Generally, the stated minimum initial investment by an investor in the Fund for Shares is $500, which stated minimum may be reduced for certain investors pursuant to the purchase terms in the Fund’s plan of distribution. The ARK Monthly Webinars, detailed above, also include the Venture Fund and provide ongoing education around the Venture Fund, answer investor questions, and discuss performance, composition, outlook, and commentary for the Venture Fund. As noted above, this information is not investment advice and will only discuss public information. The on-demand webinars and materials will be posted to the ARK website and can be found at www.ark-funds.com. All interested parties can obtain more information at www.ark-funds.com. Such webinars are published on the third Thursday following a quarter end at

4:30PM EST unless otherwise announced. Additional information regarding the services provided by ARK to the Venture Fund can be found in the Venture Fund prospectus and statement of additional information, which is publicly available at https://www.ark-funds.com/funds/arkvx, on the EDGAR Database on the SEC’s website (www.sec.gov) or by writing to the Venture Fund at ARK Investment Management, LLC, 200 Central Ave., Suite 220, St. Petersburg, Florida 33701, or by calling toll-free 888-511-2347. Separately Managed Accounts, Other Pooled Investment Vehicles and Clients ARK currently provides investment advisory services to certain separately managed accounts for U.S. institutions (which can include retirement plans, employee pension benefit plans, tax-exempt entities, limited liability companies, public funds, foundations, endowments, insurance companies and their separately managed accounts, emerging manager programs, and financial institutions and their customers and clients), non-U.S. institutions, high net worth clients (which can include individual investors, trusts and smaller employee benefit plans), pooled investment vehicles (including the Private Funds), Sub-Advised Funds (as described more fully in Items 4 and 5), retail clients and Other Registered Investment Companies (such as mutual funds and unit investment trusts). The Private Funds generally require a minimum investment commitment from investors. If investment minimums are imposed, ARK retains the ability to permit reduced investment minimums, as described in the offering documents. Wrap and UMA Programs ARK also offers investment advisory services to clients of wrap fee programs and provides nondiscretionary models to UMA programs sponsored by non-affiliates. ARK’s nondiscretionary services consist of furnishing model portfolios in various equity strategies, which the UMA program sponsor could choose to employ in its management of accounts under one or more managed account programs. The sponsors of these programs could impose minimums or other requirements for opening or maintaining an account, as described in more detail in the programs governing documents. For more information about the strategies that ARK can offer to wrap and UMA programs, please see Item 8. Non-Discretionary Sub-advisory and Sub-sub advisory Services ARK also offers sub-advisory and sub-sub advisory services to registered investment advisers that manage the Bitcoin ETF. ARK’s non-discretionary sub-advisory services consist of providing data, research, and, as needed, operational support to the Bitcoin ETF as well as marketing support services. This product is exchange-traded as described in more detail in the prospectus and statement of additional information that ais publicly available on the 21Shares website, SEC website and can be obtained through contacting 21Shares via phone. For more information about the strategies that ARK can offer as a sub advisor, please see Item 8.

ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ARK offers the following multi-sector, theme-based investment strategies to clients by, under normal circumstances, generally investing primarily in U.S. and non-U.S. equity securities of companies that are relevant to each differentiated theme, however, certain crypto themes invest exclusively in cryptoassets

or derivatives thereon while the Venture Theme can invest in early- to late-stage private companies, including private funds. In selecting companies that ARK believes are relevant to a particular investment theme, it seeks to identify, using its own internal research and analysis, companies capitalizing on disruptive innovation or that are enabling the further development of a theme (or elements of a theme) in the markets in which they operate. ARK’s internal research and analysis leverages insights from diverse sources, including social media, external research and the input of ARK’s Theme Developers, to advance and refine its investment themes and identify and take advantage of trends that could have ramifications for individual companies or entire industries. Currently, ARK focuses on the following themes: Theme FinTech Innovation Genomic Revolution Autonomous Technology & Robotics Next Generation Internet Disruptive Innovation 3D Printing Israel Innovative Technology Mobility-as-a-Service (MaaS) Space Exploration Cryptoasset Cryptocurrency Global Digital ‘ARK 10’ Early Stage Disruptors Positive Change Innovation (UN SDG) Metaverse Venture Bitcoin Defined Innovation Exposure Term (DIET) Artificial Intelligence & Robotics Active Autocallable Income

Portfolio Manager(s) Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood William Scherer William Scherer Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood Catherine D. Wood & William Scherer

ARK is supported by sub-advisers in providing certain of the themes above. Additional information about any sub-adviser used can be found in the relevant offering materials related to a given theme. ARK can manage accounts with investment themes that are different from those listed above. In such cases, each client account will be managed in accordance with the investment objective, guidelines, strategy or strategies, policies and restrictions established by each client and documented in a written investment advisory agreement (and related documents) with or on behalf of each client and ARK. ARK’s distinct investment process and methods of analysis are described more fully in response to Item 4. Please refer to Item 4 for more information. There is no guarantee that ARK’s investment process and strategies will meet the investment objectives and goals of its clients. Additionally, the investment

strategies and techniques ARK uses with respect to each investment theme might vary over time depending on various factors. ARK can give advice and take action for clients that can differ from advice given or the timing or nature of action taken for other clients with similar or different goals. ARK is not obligated to initiate transactions for clients in any security that its principals, affiliates or employees can purchase or sell for their own accounts or for other clients. ARK manages both discretionary and non-discretionary accounts. However, even where ARK has discretion, clients can place reasonable limitations and restrictions on the management of their accounts. Certain clients can also direct ARK to sell, or to avoid selling, particular securities for the purpose of realizing a capital loss or avoiding a capital gain. The investment objectives, principal investment strategies and material risks that are provided below are summaries and are presented for general information purposes in accordance with regulatory requirements. Consequently, these summaries are more fully explained and, in all instances, qualified and superseded by the descriptions of objectives, guidelines, strategies, limitations, restrictions, and risks, and any portfolio reports and other communications that are provided to each client in connection with the creation and maintenance of the client’s account with ARK. If there is a conflict between the information provided herein and the governing documents of your account, the governing documents of your account control. Additional detail about each theme can be obtained at no charge by contacting ARK at 1-727-810-8160 or through www.ark-invest.com/contact. Clients should bear in mind that ARK’s investment themes can involve moderately high turnover ratios. Thus, the potential for high volatility and increased transaction costs (including increased brokerage and taxes) exists. Wrap Fee and UMA Programs ARK offers versions of its strategies offered to ARK’s separate account and collectively managed vehicle clients to sponsors of wrap fee and UMA programs. ARK’s management of the strategies that it offers to Wrap Fee (including dual contract) and UMA programs is similar to ARK’s management of the strategies that it offers to non-wrap clients described above, except for the differences noted in Item 4. Risk of Loss Investing in securities involves the risk of monetary loss, and clients investing their money with ARK should be prepared to bear that loss. ARK is not responsible for ensuring your account is diversified, and there is no guarantee that a diversified portfolio would not incur losses. None of the accounts, investment vehicles, funds or investment companies for which ARK provides portfolio management services is a deposit in any bank, nor are those accounts, investment vehicles, funds or investment companies insured or guaranteed by the Federal Deposit Insurance Corporation or any other U.S. governmental agency. Tax Considerations Tax efficiency is generally a consideration in the management of ARK accounts, unless tax management for a particular account (or types of accounts) is not necessary or appropriate. Certain investments utilized can have unique and significant tax implications. Clients should consult with a tax professional prior to investing.

IRS Circular 230 Disclosure: ARK, its agents and employees are not in the business of providing tax, regulatory, accounting or legal advice. This Brochure and any tax-related statements provided by ARK are not intended or written to be used, and cannot be used or relied upon, by any such taxpayer for the purpose of avoiding tax penalties. Any such taxpayer should seek advice based on the taxpayer’s particular circumstances from an independent tax advisor. A brief description of each theme and the investment objective and general investment strategies typically used in managing client assets, including the methods of analysis, and the material risks associated with investing in each disruptive innovation theme are provided below. Note: The narrative discussion of each investment theme includes a list of the material risks associated with an investment in that theme. A description of each of the named risks is included at the end of this

ARK offers performance fee arrangements, a method of compensating an investment adviser based on a share of the gains or appreciation of the client’s assets under management. Generally, the fee structure will consist of a base fee and a performance fee. Performance fee rates generally will be negotiable. Generally, a client can negotiate the base fee rate, performance fee rate, and the index used to calculate the performance fee (if any). Performance fee arrangements are not necessarily available for all investment themes and must be approved by ARK on a case-by-case basis. Any performance fee that

ARK charges is intended to comply with requirements of Rule 205-3 under Advisers Act. Subject to certain limitations (such as loss carryforward provisions), the managing member and general partner of certain of the Private Funds are entitled to receive an allocation of net profits, as further described in the offering documents. Performance fee arrangements provide an incentive for ARK to seek to maximize the investment return of accounts paying performance fees by making investments that are subject to greater risk or are more speculative than would be the case if ARK’s compensation was not based upon the investment return of such accounts. Under such arrangements, ARK’s compensation is contingent upon the return experienced by the client, which generally is computed based upon a percentage of capital appreciation in the client's account. Accounts participating in a performance fee arrangement could pay ARK more compensation when compared to standard fee rates. Consequently, ARK would be incentivized to favor accounts that charge higher fees, including performance fee accounts, over accounts that do not pay such fees in allocating investments with higher return potential or to devote more resources toward such accounts’ management. Similarly, ARK can be incentivized to allocate opportunities to clients whose accounts are new or ramping if such accounts must meet a threshold prior to accruing fees. ARK seeks to mitigate the potential conflicts of interest that could arise from managing accounts that bear higher fees, including a performance fee, by monitoring and diligently enforcing its policies and procedures, including those related to investment allocation. Nonetheless, ARK does not consider higher fees in the allocation of investment opportunities. ARK has a fiduciary duty to act in the best interests of its clients. As part of ARK’s fiduciary duty, ARK owes a duty of loyalty to its clients. Nevertheless, because ARK has multiple clients, whose interests are not necessarily aligned, ARK’s duty of loyalty to one client could conflict with its duty of loyalty to another, including with respect to allocating trades. From time to time, an investment opportunity that is appropriate for multiple client accounts will not be available in a sufficient quantity to satisfy all clients. To address conflicts of interest that arise in the investment and trade allocation process, including potential conflicts between competing client interests and between client interests and ARK’s interests, ARK has adopted a trade aggregation and allocation policy intended to provide fair and equitable treatment of its clients over time, consistent with ARK’s duty of loyalty. ARK and its personnel endeavor to ensure that, over time: each client is treated fairly as to the securities purchased or sold for its account; each client is treated fairly with respect to priority of execution of orders; and each client is treated fairly in the allocation of investment opportunities. In any particular allocation of an investment opportunity, it is likely that certain client accounts will receive a smaller allocation than other client accounts, or not receive an allocation at all. ARK’s trade aggregation and allocation policy is intended to provide fair and equitable treatment over time. For additional information, see ‘Aggregation and Allocation Policies’ in Item 12 below. Because of the diversity of investment goals, risk tolerances, tax situations, and differences in the timing of capital investments/contributions and redemptions/withdrawals, investment positions in client accounts inevitably will differ among client accounts. All allocations of securities among client accounts are intended to be consistent with each client account’s investment goals and financial situation, and the foregoing principles. ARK intends to allocate investment opportunities among client accounts on a basis that is fair and equitable over time in light of the circumstances.

ARK Personnel Are Registered Representatives of a Broker Dealer Certain ARK management persons are registered representatives of a broker-dealer. Relationships with Affiliates ARK Invest Europe is located in the United Kingdom of Great Britain, and is a division of ARK Invest

Limited LLC, a separate legal entity under common control with ARK. ARK Invest Europe allows ARK to establish a European Undertaking for Collective Investment in Transferable Securities (“UCITS”) suite of its ARK ETF strategies, bringing these strategies to investors across Europe, the UK, and new markets globally. ARK Invest Europe launched its first European UCITS ETFs, where ARK acts as investment manager, including: ARK Innovation UCITS ETF; ARK Genomic Revolutions UCITS ETF; ARK Artificial Intelligence & Robotics UCITS ETF and ARK Space & Defence Innovation UCITS ETF. These strategies have an overlapping investment universe with ARK’s clients, including the ARK ETFs, and as such, can and will compete for investment opportunities. ARK Invest Europe aids in their distribution. ARK is responsible for the investment and trade execution related to these products and manages the execution of intra-day trades in respect of subscriptions or redemptions received from the manager, IQ EQ Fund Management (Ireland) Limited (“IQ EQ”), which is an unaffiliated Irish company authorized by the Central Bank of Ireland under the UCITS regulations to carry on the business of providing management and related administration services to UCITS. For purposes of investment and trade execution, ARK treats the ARK UCITS ETFs as a discretionary client as discussed in more detail in Item 11 below. While under common control, ARK is not privy to transaction decisions of ARK Invest Europe with respect to its other clients and ARK Invest Europe is only privy to the transaction decisions related to the ARK UCITS ETFs, as addressed in more detail in Item 11 below. ARK has additional affiliates that serve as the managing member or general partner to certain of its Private Funds, and in that role can receive performance-based fees, which presents conflicts of interest with clients. ARK is the sole owner of the ARK Cryptocurrency Fund MM LLC, the entity which serves as the managing member of the ARK Cryptocurrency U.S. Fund LLC and the ARK Digital Asset Revolutions U.S. Fund LLC, two of ARK’s Private Funds, and is entitled to receive an allocation of net profits, as further described in the offering documents. Conflicts related to performance-based fees and how they are addressed are discussed in more detail in Item 6 Performance-Based Fees and Side-By-Side Management. ARK Permits Certain Clients to Invest in Affiliated Products ARK permits the ARK ETFs to invest in the securities of affiliated ETFs managed by ARK, including the Bitcoin ETF. To eliminate duplicate Management Fees, ARK waives the portion of its Management Fees payable by an investing fund in an amount equal to the investment advisory fee portion of the management fee it earns as investment adviser to the underlying fund(s). Other ARK Manages Multiple Clients Accounts As described above, ARK is the investment adviser and provides management and supervisory services to the ARK ETFs and Venture Fund, the Private Funds, certain Sub-Advised Funds, separate accounts, and other clients. ARK’s services for the ARK ETFs, Venture Fund and Sub-Advised Funds and other clients can create conflicts of interest in certain circumstances. In respect of the clients that can invest in digital assets (and derivatives thereon) and related securities, ARK serves as an adviser to certain clients and provides non-discretionary sub-advisory services to the Bitcoin ETF. ARK faces conflicts related to side-by-side management of accounts invested in a similar strategy, which might have different fee schedules, as discussed in Item 6 Performance-Based Fees and Side-By-Side Management and in Item

12 Brokerage Practices under “Aggregation and Allocation Policies”. Relationships with Third Parties ARK has certain relationships with third-parties that are material to ARK’s advisory business, and can create conflicts of interest. ARK will, from time to time, have minority interests in certain third-party investment advisers and may have one or more employees sit on the boards of such investment advisers. An employee would preclear such activity in accordance with ARK’s Compliance Manual. ARK makes full disclosure to clients with respect to such interests prior to investing their assets in any investment products managed by these third-party investment advisers and does not adjust its clients’ Management Fee with respect to these investments. ARK recommends investment sub-advisers to certain clients. ARK has existing and may have potential future other business dealings or relationships with current or proposed sub-advisers or other service providers (or their affiliates) recommended by ARK. Such other business dealings or relationships present conflicts of interest that could influence ARK’s selection and retention or termination of subadvisers or service providers. For example, ARK has an incentive to hire as a sub-adviser or other service provider an entity with which ARK or one or more of its affiliates have, or would like to have, significant or other business dealings or arrangements, and ARK has a disincentive to recommend the termination of such a sub-adviser or service provider when doing so could be adverse to ARK’s relationships or other business dealings with such parties. Relationship with ARK Capital Markets and ARK Capital Investments ARK’s affiliates ARK Capital Markets, which is in the process of registering as a broker-dealer, and ARK Capital Investments, which is in the process of registering as an investment adviser, may provide investment banking, strategic advisory, or other services to public or private companies, and may enter into arrangements pursuant to which ARK Capital Markets will receive compensation based on amounts of capital invested in such companies. This creates significant conflicts of interest, which ARK may manage by restricting the ability of ARK to invest in certain of these companies. This may limit investment opportunities available for our clients. Alternatively, ARK may determine it would be inadvisable to exclude certain companies to which ARK Capital Markets or ARK Capital Investments provides services from client portfolios, which would potentially benefit ARK Capital Markets. ARK will seek to mitigate conflicts of interest arising from its relationship with ARK Capital Markets and ARK Capital Investments by basing all investment decisions on consideration of its clients’ best interest, consistent with its fiduciary duties. ARK has conflicts of interest as a result of the activities and relationships of ARK Capital Investments and ARK and the respective clients, affiliates, partners, members, shareholders, officers, directors and employees (current and former) of each, some of which are described in this Brochure. ARK Capital Investments, once it is registered, will provide investment advisory services to clients that may pursue strategies similar to existing clients of ARK and therefore will compete for the same opportunities. Further, ARK Capital Investments may also make investments on behalf of its clients in issuers in which ARK’s clients are also invested, including in a different part of the capital structure. While ARK will make investments on behalf of its clients in a manner that it believes is fair and equitable under the circumstances over time and considering relevant factors, and while ARK has adopted policies and procedures to mitigate conflicts of interest arising out of its relationship with ARK Capital Investments

(including the implementation of information barriers as described below), there can be no assurance that such conflicts will be fully mitigated. ARK Capital Markets and ARK Capital Investments may also acquire MNPI about companies to which either of them is providing services or considering providing services. ARK, on the one hand, and ARK Capital Markets and ARK Capital Investments, on the other, maintain an information barrier to isolate and prevent communication of MNPI between ARK and ARK Capital Markets or ARK Capital Investments except as expressly permitted by ARK’s information barrier policies and subject to appropriate oversight. The purpose of this information barrier is to, among other things, confine any MNPI obtained by either ARK or ARK Capital Markets and ARK Capital Investments such that the investment activities of the other entity are not restricted as a result of MNPI being imputed to that entity. As a result of the information barrier, ARK personnel may not be able to use, act on, or otherwise be aware of information that is known by or in possession of the personnel of ARK Capital Markets or ARK Capital Investments. Collaboration between ARK and ARK Capital Markets and ARK Capital Investments personnel may therefore be limited, and this may reduce potential synergies across ARK. ARK and ARK Capital Investments share supervised persons, including persons that control each firm. Such supervised persons of ARK are subject to potential conflicts of interest in allocating time and resources to ARK Capital Investments. In addition, ARK and its personnel are subject to potential conflicts of interest in allocating their time and activity between clients of ARK and clients of ARK Capital Investments, in allocating investments among clients and other entities, and in effecting transactions between clients and other entities, including ones in which ARK and its personnel have a greater financial interest. Restrictions on Client Trading Activities Resulting from the Acquisition of Material Non-Public Information ARK employees regularly acquire confidential information and ARK can enter into confidentiality and/or “standstill agreements” when assessing investment opportunities. By reason of its various activities, ARK and its employees can have access to material nonpublic information (“MNPI”) about an issuer. For example, ARK employees could acquire MNPI in the ordinary course of their investment activities, which acquisition would result in restrictions on a client’s ability to buy or sell a portfolio investment at a time when it might otherwise have done so, potentially for an extended period. Similarly, ARK could decline information that would be considered MNPI to the detriment of a client.

Code of Ethics and Personal Trading ARK has adopted a Code of Ethics in compliance with Rule 204A-1 under the Advisers Act that establishes personal trading guidelines and restrictions applicable to ARK employees, certain ARK consultants, and immediate family members (as defined by ARK’s Code of Ethics) (“Access Persons”). Access Persons are subject to pre-clearance requirements before buying or selling securities, other than certain exempt securities, as further detailed below. Access Persons must submit required initial, quarterly, and annual reports of securities (or furnish brokerage statements) and must certify, at least annually, receipt of and compliance with the Code of Ethics.

For a copy of ARK’s Code of Ethics please call 1-727-810-8160 or write to: ARK Investment Management LLC, Attn: Chief Compliance Officer, 200 Central Avenue, Suite 220, St. Petersburg, FL 33701. Note that ARK’s (and its affiliates) practices with respect to recommending or investing in the same securities, including at the same time, are addressed below. Personal Trading Rules Pre-clearance of Investments in Initial Public Offerings or Limited Offerings No Access Person may directly or indirectly acquire Beneficial Ownership in any Securities in an initial public offering (“IPO”) or Limited Offering without obtaining, in advance of the transaction, clearance from ARK’s Compliance Department (“Compliance”). The Investment Team is prohibited from investing in IPOs. Transactions in Funds Managed by ARK Access Persons are permitted to transact in ARK ETFs without obtaining pre-clearance. However, Access Persons may not purchase and sell the same actively managed ARK ETF within any period of 30 calendar days. In determining the 30-calendar day holding period, the “last-in, first-out” methodology will be applied. Access Persons must obtain pre-clearance before transacting in the Venture Fund. Transactions in the ARK Venture Fund will generally only be granted during open windows, which will occur at the discretion of Compliance. In order to obtain pre-clearance, Access Persons must submit a pre-clearance request to Compliance. Short positions, both direct and synthetic, taken against any of ARK’s funds, including the Venture Fund, or associated pooled vehicles are strictly prohibited. Pre-clearance of Public Securities ARK’s Access Persons are subject to pre-clearance requirements before buying or selling public securities, other than exempt securities (as defined by ARK’s Code of Ethics), for any account in which they have any direct or indirect beneficial ownership. As a matter of policy, no Access Person can buy a security that is held in an advisory client’s portfolio. Access Persons can continue to hold, or maintain, these positions however, are not permitted to add to them and will need to receive preclearance from Compliance prior to selling any securities held in an advisory client’s portfolio. Access Persons not on the ARK’s Investment Team (as defined by ARK’s Code of Ethics) are permitted to buy Public Securities, subject to pre-clearance by the CCO, unless such Security is held in an Advisory Client’s Portfolio. ARK has implemented a more stringent policy for Access Persons who fall within the Investment Team (as defined by ARK’s Code of Ethics). The Investment Team are prohibited from buying Public Securities within their Coverage Area (as defined by ARK’s Code of Ethics). They are permitted to hold, or maintain, existing public securities positions in their Coverage Area, however, cannot add to them and will need to receive pre-clearance from Compliance prior to selling. The Investment Team are permitted to buy public securities outside of their Coverage Area, subject to pre-clearance by Compliance, so long as such Security is not held in an advisory client’s portfolio. Additionally, the Investment Team is limited to twenty-five (25) pre-clearable trades per month.

Pre-clearance on the sale of securities typically will not be granted: (i) on a day when the security is being considered for purchase or sale by an advisory client; (ii) if such security is not included in an advisory client’s portfolio but notice has been given, or Compliance is aware, that such security will be added to an advisory client’s portfolio (or until such time as ARK completes such transactions for the applicable advisory client’s portfolio on the day of the trade request); (iii) if the security is included on ARK’s restricted list; or (iv) if Compliance reasonably determines that it is in the best interest of ARK or its clients. In determining whether to approve any trade, Compliance will consider, for example, whether the Access Person knew, or should have known, that the security was being considered for purchase or sale by ARK for an advisory client on the day of the trade request or that, as a result of a transaction, the Access Person would hold or sell more than 5% of the outstanding securities of the issuer in question. Pre-clearance of Exchange Traded Funds Not Managed by ARK Broad-Based Exchange Traded Funds (as defined by ARK’s Code of Ethics) not managed by ARK are exempt securities, therefore Access Persons are permitted to transact without pre-clearance. Transactions in Narrow-Based Exchange Traded Funds (as defined by ARK’s Code of Ethics) not managed by ARK are subject to pre-clearance. In order to obtain pre-clearance, Access Persons must submit a pre-clearance request to Compliance. If the transaction is approved, that approval is valid only for the day on which it is granted. Compliance may revoke a pre-clearance any time after it is granted and before the transaction is executed. Private Investments Access Persons must obtain pre-clearance before transacting in any Private Investment (as defined by ARK’s Code of Ethics). Private Investment pre-clearances do not expire after one day and are valid for a short window of time, generally not to exceed a week, after Compliance approval is granted to allow Access Persons time to complete any necessary wire payments. Compliance may revoke a pre-clearance any time after it is granted and before the transaction is executed. In determining whether to approve a transaction in a Private Investment, Compliance will consider if such investment may be in conflict with the activities or relationships of ARK and/or any funds managed by ARK, including the Venture Fund. Prohibition on Short-Term Trading Access Persons may not purchase and sell, or sell and purchase, within any period of 30 calendar days, a security, other than an exempt security. Additionally, Access Persons may not purchase and sell the same ARK ETF within any period of 30 calendar days. In determining the 30-calendar day holding period, the “last-in, firstout” methodology will be applied. Prohibition on Short Sales and Similar Transactions The Investment Team are prohibited from purchasing a put option or selling a call option, selling short or otherwise taking a short position, either directly or through any beneficial ownership, in any security. The remainder of the Access Persons are only permitted to partake in the aforementioned transactions if such transaction does not involve an issuer that is held in a client’s portfolio and is pre-cleared and approved by Compliance. Short positions taken against any of the ARK’s funds, including the Venture Fund, or associated pooled vehicles are strictly prohibited. Digital Assets Consistent with current laws and regulations, ARK does not deem digital assets, such as cryptocurrencies, to

be reportable securities. Furthermore, ARK has not identified material conflicts between employee trading of digital assets and its fiduciary duties to its clients. As such, Access Persons are permitted to transact without pre-clearance. However, ARK continues to evaluate whether employee trading of digital assets could create conflicts and therefore requires reporting of investment transactions. On a quarterly basis, Access Persons must provide Compliance with all digital asset transactions that occurred during the previous quarter. Compliance will continue to evaluate whether employee trading of digital asserts creates material conflicts with the activities of the Adviser. Securities Held in Accounts Over Which an Access Person Has No Direct Influence or Control Compliance may grant a waiver of many of the pre-clearance requirements set forth above for any account over which an Access Person does not have direct or indirect influence or control. Immediate Family Members of Access Persons Immediate Family Members (as defined by ARK’s Code of Ethics) of Access Persons are covered under ARK’s Code of Ethics. Immediate Family Members are required to follow the same personal trading and pre-clearance rules as those Access Persons not on the Investment Team, as outlined above. The Investment Team may not influence, or direct, trades made by Immediate Family Members. Recommendations Involving Material Financial Interests ARK can effect (but not execute) transactions between client accounts. ARK will not effect a transaction between client accounts if one of the clients is an Employee Retirement Income Security Act of 1974 (“ERISA”) client. ARK can effect transactions between client accounts that are not registered investment companies subject to certain restrictions, including the requirements that ARK receives no compensation for effecting the transaction and the transaction is disclosed to the clients. ARK can effect transactions between clients that are registered investment companies subject to certain restrictions, including the requirement that the transaction is effected in compliance with Rule 17a-7 under the 1940 Act and any applicable procedures adopted by the registered investment company. There are certain relationships involving some of ARK’s Access Persons that present conflicts of interest. For example, ARK can effect transactions and/or recommend that the Venture Fund invest in certain private companies where Access Persons have had and could have direct ownership of equity or convertible instruments in the company; employment, advisory, trustee, board, or contractual relationships with the company; and/or material financial interests held by immediate family members. ARK believes that these relationships generally benefit the Venture Fund in that they provide investments and information that might not otherwise be available to ARK and the Venture Fund. Nonetheless, the relationships present conflicts of interest in that the relationship could provide an incentive for such Access Persons to influence ARK’s decision to recommend an investment in such company. To safeguard the objectivity and integrity of investment decisions, Access Persons with a material direct or indirect interest in a private company that is being evaluated for potential investment by the ARK Venture Fund, must recuse themselves from all discussions, analyses, recommendations, and votes regarding that investment opportunity. Any potential conflicts, including nonmaterial conflicts, shall be disclosed to the members of the ARK Venture Fund Investment Committee, the Principal Financial Officer of the Venture Fund (the “PFO”) and Compliance. Provided the preceding sentence is adhered to by the potentially conflicted member, the other members of the Investment Committee, with the

approval of Compliance, may request the opinions of the conflicted employee regarding the subject investment. The employee must promptly notify Compliance of any potential conflict. Compliance shall document the nature of the conflict and if the conflict is determined to be material, confirm that the employee has been recused from the decision-making process. Compliance will notify the ARK’s Conflicts Committee of such conflicts and the recusal of the employee. The PFO will also record such recusals and report any recusals taking place over the last quarter to the Conflicts Committee. The Conflicts Committee will reconcile that the recusals reported by Compliance and match those reported by the PFO. Compliance will maintain a log of all recusals. Any exceptions to recusals must be approved in writing by Compliance and documented with a detailed justification. ARK Invest Europe maintains its own Code of Ethics, including a personal trading policy, and Compliance Manual, adhering to applicable UK and EU regulations. Certain employees of ARK Invest Europe are designated as an Access Person of ARK and are required to comply with the policies of both entities.

Selection of Broker-Dealers to Execute Transactions in Client Accounts General Practices Clients can give ARK the authority to determine which broker-dealer will execute transactions. Other clients retain discretion to select which brokerage firms should execute their transactions. Some clients that designate ARK as the investment manager for their account nonetheless have the ability to place their own trades for their account. Some of ARK’s clients have the ability to select a broker-dealer to act as custodian for the client’s assets and direct ARK to execute transactions through that broker-dealer. It will not be ARK’s practice to negotiate commission rates with those broker-dealers. Where a client chooses to execute a trade or directs the trade to a particular brokerage firm, ARK is not responsible for the execution or the selection of broker-dealers for such trades. For accounts for which ARK has brokerage discretion, ARK's general policy is to use its best efforts to seek to obtain best execution for all client portfolio transactions, taking into account a variety of factors such as:

the security price; listed bids and asks; the opportunity for price improvement; liquidity; geographic location; access to new issues; the transaction costs and commission rates; the size and difficulty of the order and timing of the transaction; the experience of the broker-dealer; the reliability, integrity, creditworthiness and financial condition of the broker-dealer; the general execution, clearance, settlement, responsiveness and operational

capabilities of the broker-dealer; the confidentiality provided by the broker-dealer; and the number of trading errors committed by the broker-dealer.

In seeking best execution, an adviser need not select the broker with the lowest available commission rate where it believes that a broker or dealer charging a higher commission rate would offer better overall execution, including for example greater reliability or better price or execution. Transactions placed on behalf of ARK clients, and recommendations on behalf of nondiscretionary clients and model portfolios, could be a large portion of a security’s daily trading volume, and securities can therefore be subject to price movements, which could result in certain ARK clients that did not participate in an aggregate trade order as well as nondiscretionary clients or model portfolios receiving prices that are less favorable than the prices obtained by those ARK clients that participated in the aggregate order. Based upon the particular facts and circumstances of the order, ARK will determine whether and how best to execute such transaction to seek to achieve best execution. Additionally, ARK, in implementing an investment decision, could determine in light of the facts and circumstances that the value of completing transactions expeditiously outweighs potential market impact of being a large percentage of daily trading volume. Further, while ARK believes it takes reasonable steps to minimize the market impact caused by transactions for accounts over which ARK has investment or trading authority, ARK cannot control the market impact of such transactions to the same extent for accounts over which ARK does not have trading authority, including nondiscretionary clients and model trades as discussed further below. While ARK seeks best execution for discretionary brokerage transactions, ARK cannot assure that best execution will be achieved for each client transaction. ARK will maintain a list of approved broker-dealers it will use to place client trades for execution. ARK’s Best Execution Committee will periodically reevaluate these broker-dealers to confirm that they meet ARK’s criteria and standards, including that they provide trade execution services that ARK views as satisfactory. Upon reevaluation, ARK’s Best Execution Committee has the ability to add or remove brokerdealers to or from the list of approved broker-dealers. ARK pays, or is deemed to pay, commission rates higher than if ARK had paid for execution services only and ARK can “pay up” to receive research or brokerage services that ARK views as beneficial to client accounts. These services benefit ARK because ARK does not need to produce or pay for such research services, and as a result, the receipt of research in exchange for soft dollars creates a conflict of interest. ARK is incentivized to select or recommend a broker-dealer based on ARK’s interest in receiving research services, among the other factors that ARK considers, and this can conflict with the client’s interest to receive best execution. ARK will not agree to direct a specific amount of brokerage transactions or commissions to any broker-dealer in return for soft dollar or other benefits. Research or brokerage services ARK receives for conducting transactions in a client account can benefit other accounts and it is possible that a particular account will not benefit from services obtained related to transactions conducted through that account. ARK will not attempt to track or allocate the benefits of research or brokerage services it receives to the commissions associated with a particular account or group of accounts. Additionally, certain clients could bear more of the cost of soft dollar arrangements than other clients. Soft dollar arrangements are discussed in more detail below.

Research Services Received from Broker-Dealers ARK receives a wide range of research services from broker-dealers. These services can include information on the economy, industries, groups of securities, individual companies, statistical information, accounting and tax law interpretations, political developments, legal developments affecting portfolio securities, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, performance analysis, and analysis of corporate responsibility issues. ARK will receive research services primarily as written reports, computer generated services, and personal meetings with security analysts. Research services can also take the form of meetings arranged with corporate and industry spokespersons, economists, academicians and government representatives. The research services provided by broker-dealers can be used to supplement ARK’s own proprietary Open Research Ecosystem (as described in Item 4), so ARK has an incentive to seek such research as discussed above. Such research services will be subject to ARK’s intense internal analysis and review before becoming part of the ARK Open Research Ecosystem. Soft Dollar Arrangements with Brokers Who Furnish Research Services ARK has a brokerage allocation policy designed to comply with Section 28(e) of the Securities Exchange Act of 1934, as amended ("1934 Act"). This section permits an investment adviser to pay a broker-dealer that “provides brokerage and research services” to the adviser commission rates in excess of the amount another broker-dealer would charge for effecting the same transaction, if the adviser determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided, viewed in terms of either that particular transaction or the adviser’s overall responsibilities to that client or other client accounts and over which the adviser exercises investment discretion. ARK enters into arrangements whereby it obtains research products and services, in addition to brokerage execution, from broker-dealers in connection with client trades. These arrangements are sometimes referred to as a “soft dollar” arrangement and are common in the financial services industry. At this time, ARK uses a type of soft dollar arrangement referred to as a commission sharing agreement (a CSA) under which a broker retains a portion of the commissions attributable to execution and holds the remaining “soft” commission related to ARK’s order, which ARK directs the broker to send to ARK’s service provider (Virtu Financial Inc.) to aggregate the soft commissions, and then ARK can pay for external research of its choosing. For example, ARK can use commissions from transactions for client accounts to obtain quotation equipment and tools that can assist ARK in trade execution or provide ARK with important market related news and developments. The research products and services can either be proprietary (created and provided by the broker-dealer) or third party (created by a third party but provided to ARK by the broker) and include:

economic research; industry, security and company research; statistical information; accounting and tax law interpretations; political/legal developments; pricing and appraisal research; industry and company computer screening ability;

technical research; commodity research; portfolio management research; stock and bond quote services; and/or financial news and other publications.

In accordance with Section 28(e), ARK, in collaboration with Virtu Financial Inc. and its soft-dollar review software platform, will periodically review and seek to ensure that all soft dollar arrangements pay for bona fide research services. In some cases, the products or services ARK receives will not be used exclusively for research purposes. For example, certain systems and products that can be used by ARK provide “mixed use” functions, such as accounting and record keeping, in addition to marketing and investment research. ARK’s ability to determine mixed use allocations poses a conflict of interest. In those cases, ARK will not pay for the non-research portion of any “mixed use” service through any soft dollar arrangement. Instead, ARK will pay hard dollars for the non-research function. Evaluating Reasonableness of Brokerage Commissions ARK’s Best Execution Committee will periodically evaluate the reasonableness of brokerage commission rates in the marketplace for transactions executed on its clients’ behalf. ARK will consider:

the rates quoted by brokers and dealers; the size of a particular transaction, in terms of the number of shares, dollar amount, and number of clients involved; and the complexity of a particular transaction relative to execution and settlement.

Generally, it is not ARK’s practice to negotiate or monitor commission rates where a client has directed ARK to use a certain broker-dealer. Directed Brokerage and Commission Recapture Clients can direct ARK in writing to execute transactions with one or more specific broker-dealers at commission rate or rates agreed upon by the client and the broker-dealer(s). A client can direct ARK to use a particular broker-dealer for a variety of reasons, including:

the client’s relationship with the broker-dealer; the client’s evaluation of the broker-dealer and the quality of its trade execution; the discounts or other benefits the client receives from the broker-dealer; and/or the existence of a commission recapture program where the client receives the benefit of rebates or other benefits separately negotiated between the client and the brokerdealer.

Under such a directed brokerage arrangement, the client is responsible for negotiating terms for their account directly with the broker-dealer. ARK will only direct brokerage pursuant to instructions from the client and will generally have such instructions signed and dated by the client.

Clients subject to ERISA, who wish to participate in directed brokerage, must provide ARK with written instructions directing ARK to execute transactions with one or more specific brokers. The written notice must state that the services the broker(s) provide and the commission rate or amount is consistent with ERISA provisions and in the client’s best interest. If a client account is subject to ERISA and the client directs ARK to place all transactions for the client’s account with a particular broker-dealer, the following apply:

the client retains and accepts sole responsibility for determining whether the directed brokerage arrangement is reasonable in relation to the benefits the plan receives; the client acknowledges and represents to ARK that the directed brokerage arrangement is used solely and exclusively for the plan’s and the participants’ benefit; and the client acknowledges and represents to ARK that the directed brokerage arrangement is permissible under the plan’s governing documents.

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Economic Benefits Provided by Third Parties In transactions that involve brokerage commissions, as permitted by Section 28(e) of the 1934 Act, ARK can cause a client to pay a broker-dealer that provides “brokerage and research services” (as defined in the 1934 Act) a disclosed commission for effecting a securities transaction for the client in excess of the commission which another broker-dealer would have charged for effecting that transaction without the brokerage and research services. Other fees are disclosed more fully in Item 5 and other conflicts of interest with regard to the receipt of soft dollars are disclosed more fully in Item 12. ARK engages in activities designed to educate consultants, broker-dealers, and other financial intermediaries (collectively, “Consultants”) about its advisory services. These activities include sponsoring educational events or conferences where ARK’s representatives meet with Consultants and sometimes their clients. ARK uses its own resources to pay for part of the costs associated with educational events. Clients who desire additional information about payments to particular Consultants should contact ARK or the Consultant. Compensation to Non-Advisory Personnel for Client Referrals ARK has entered into written solicitation agreements with certain entities that introduce prospective clients to ARK. Under these agreements, the solicitor receives compensation related to the Management Fees ARK receives from certain investment management clients who engage ARK during the term of the agreement. As a result of these arrangements, a solicitor has a financial incentive to recommend ARK to a client which the solicitor might not otherwise recommend if there was no payment. ARK enters into solicitation agreements, and pays fees under these agreements, in accordance with Rule 206(4)-1

and, where the solicitation involves certain state or municipal entities, Rule 206(4)-5 under the Advisers Act. Some of ARK’s solicitors may include entities that hold an indirect, non-controlling interest in ARK. Additionally, ARK makes payments to the distributor of the ARK ETFs and Venture Fund to provide certain marketing services for the ARK ETFs and Venture Fund. ARK makes these payments from its own resources. In addition, the ARK ETFs currently do not, but could in the future, reimburse ARK for amounts it pays pursuant to plans and agreements that are adopted by the ARK ETFs pursuant to Rule 12b-1 under the 1940 Act (“Rule 12b-1 Fees”). The prospectuses and statements of additional information for the ARK ETFs contain information about Rule 12b-1 Fees. ARK makes payments to select financial intermediaries and/or firms that are strategic partners of ARK in connection with (i) the sale of shares of the ARK ETFs and Venture Fund and/or interests in other investment advisory products and services provided by ARK and (ii) the servicing of the accounts of shareholders in the ARK ETFs and Venture Fund or investors in other investment advisory products or services. Such payments are made by ARK and are not made or reimbursed by the ARK ETFs and Venture Fund. ARK receives benefits for making these payments including: placing the ARK ETFs and Venture Fund on the financial advisor’s funds sales system, possibly placing the ARK ETFs and Venture Fund on the financial intermediary’s preferred or recommended fund list, and access (in some cases on a preferential basis over other competitors) to individual members of the financial intermediary’s sales force or to the financial intermediary’s management. ARK compensates financial intermediaries differently depending on the level and/or type of services the financial intermediary provides.

Neither ARK, nor any of its management persons, have been the subject of any material legal or disciplinary action.

Frequency and Nature of Periodic Account Reviews The ARK Team, including its Portfolio Managers, Trading, and Compliance personnel, will monitor each client account and fund on a regular basis to seek to ensure portfolio level compliance (adherence to investment strategy and client guidelines) and to determine whether to take any action for that account based on its investment objective, strategy or strategies, guidelines, policies, and restrictions and, more generally, based on ARK’s review of economic and market conditions. The timing and nature of account reviews for the ARK ETFs and Venture Fund are further dictated by regulatory requirements including but not limited to the 1940 Act, Internal Revenue Code of 1986, as amended, and each ARK ETF’s and Venture Fund’s respective prospectus limitations and internal guidelines. The ARK ETFs and Venture Fund are reviewed by their third-party administrator as well as the ARK ETF Trust’s and Venture Fund’s CCO. Factors that Will Trigger a Non-Periodic Review of Separately Managed Accounts Generally, ARK will review each such account as agreed to with the client. In addition, factors that could trigger a non-periodic review of a separately managed account include the following: contributions or withdrawals of cash from an account; a determination to change an account’s cash level; a client's request for tax-loss selling; a client's direction to refrain from purchasing a particular security or class of securities for such client’s account; a client's request for information regarding the performance or structure of an account; changes in the investment objectives, strategy or strategies, guidelines, investment policies or investment restrictions; account performance; a client's pledge of an account’s assets as collateral

security; and requirements imposed by court order or regulatory decree (SEC, Department of Labor, etc.). Content and Frequency of Regular Reports For each separately managed account or other Sub-Advised Fund, ARK will provide, either directly or through a designated third party, all information it has agreed to provide to each such client and other persons or entities that they designate. ARK provides written reports to the Board and Venture Fund as well as ARK’s Board of Directors at least four times each calendar year. Shareholder reports for the ARK ETFs and Venture Fund are issued in accordance regulatory requirements. ARK provides audited financial statements to Private Fund investors on an annual basis as well as unaudited quarterly (or more frequent) performance reports. For the non-discretionary sub-advised Bitcoin ETF, ARK will provide, either directly or through a designated third party, all information it has agreed to provide to each such client and other persons or entities that they designate.

Due to certain potential fee billing arrangements, ARK might be deemed to have “custody” of certain client accounts within the meaning of the Custody Rule. If ARK is deemed to have custody over a client’s account, the client’s custodian will send the client periodic account statements (generally on a quarterly basis) indicating the amounts of any funds or securities in the client’s account as of the end of the statement period and any transactions in the account during the statement period. ARK encourages all its clients to review the custodial reports they receive directly from their broker-dealers, banks or other custodians, and to compare such reports to the reports, if any, they receive from ARK. Additionally, clients should contact ARK immediately if they do not receive account statements from their custodian on at least a quarterly basis or see discrepancies between reports. ARK is deemed to have custody of its Private Fund assets because the manager, managing member or general partner of the Private Funds is ARK or a related person of ARK. With respect to any Private Fund for which ARK is deemed to have custody, each Private Fund’s funds or securities will be held in properly designated accounts with qualified custodians to the extent required by the Custody Rule. Some cryptoassets held by Private Fund clients are not “funds” or “securities” and, therefore, will not necessarily be held in the same manner as “funds and securities.” However, ARK, as a fiduciary, takes appropriate steps to safeguard these cryptoasset holdings in a manner that it believes is reasonably designed to protect the Private Fund against loss or misappropriation of the cryptoasset interests. Investors in the Private Funds will receive annual audited financial statements barring any unforeseen circumstances or delays. The Private Funds generally distribute their audited financial statements to investors on an annual basis within 120 days of the calendar year end (or 180 days after the calendar year end for funds-offunds).

ARK accepts discretionary authority to manage securities accounts on behalf of its clients. Before accepting discretionary authority, ARK enters into a written investment advisory agreement, including an Advisory Agreement, with a client. In the case of a client with a separately managed account, this agreement can include investment guidelines or similar documents describing the client’s investment objective, strategy or strategies, policies, practices (e.g., securities lending), limitations, and restrictions on ARK’s management of the account, and a benchmark. See Item 4 Advisory Business for examples of the types of limitations and restrictions that a client can impose. ARK reserves the right not to enter into an agreement with a prospective client, or to terminate an agreement with an existing client, if, among other things, any proposed limitation or restriction is, in ARK’s view, likely to impair ARK’s ability to appropriately provide services to a client or ARK otherwise believes the limitations or restrictions to be operationally impractical or unfeasible. Certain investment restrictions can limit ARK’s ability to execute the investment strategy and reduce the account’s performance as a result. ARK will exercise discretionary authority with respect to the management of pooled investment vehicles, Sub-Advised Funds and Other Registered Investment Companies in accordance with the objective(s), strategies, guidelines, practices, policies, limitations, restrictions, and benchmarks set forth the prospectus (and statement of additional information if applicable) or offering document and/or disclosure document for each vehicle, fund or investment company. ARK exercises discretionary authority with respect to the ARK ETFs and Venture Fund in accordance with the Advisory Agreement, Sub-Advisory Agreement and Supervisory Agreement, if and as applicable, as well as the investment objective, strategies, policies, practices, limitations, and restrictions set forth in the ARK ETFs’ and Venture Funds’ prospectuses and statement of additional information, which are publicly available at www.ark-funds.com or on the EDGAR Database on the SEC’s website (www.sec.gov). Additional information regarding the ARK ETFs can be found by contacting the ARK ETFs’ principal underwriter, Foreside Fund Services, LLC at Three Canal Plaza, Suite 100, Portland, ME 04101 or by calling 855-406-1506. Further information regarding the services provided by ARK to the Venture Fund can be found by writing to the Venture Fund at ARK Investment Management, LLC, 200 Central Ave., Suite 220, St. Petersburg, Florida 33701, or by calling toll-free 888-511-2347.

ARK recognizes its fiduciary responsibility to vote proxies solely in the client’s best interests. ARK has adopted a Proxy Voting Policy reasonably designed to ensure that ARK votes shares owned by clients, which have delegated discretionary proxy voting authority to ARK, in the best interest of the clients considering all relevant factors and without regard to the interests of ARK or other related parties. For purposes of ARK’s Proxy Voting Policy, the “best interests of clients” means (unless with respect to a particular client, such client has otherwise specified) the clients’ best economic interests over the long term – that is, the common interest that all clients share in seeing the value of a common investment increase over time. ARK will accept directions from a client to vote the client’s proxies in a manner that could result in its proxies being voted differently than ARK might vote proxies of other clients over which ARK has full discretionary proxy voting authority. ARK believes such client directions should be treated as customized proxy voting guidelines and ARK’s Proxy Voting Policy does not

generally apply to customized proxy voting guidelines. ARK maintains responsibility for reviewing all proxies individually and making final decisions based on the merits of each case. ARK has retained Broadridge Investor Communication Solutions, Inc. (“Proxy Agent”) to provide proxy voting agent services. The Proxy Agent is responsible for ensuring that all proxy ballots received for securities held in ARK client accounts are submitted in a timely manner and also provides recordkeeping and reporting services. As part of ARK’s arrangement with the Proxy Agent it will provide research for each proxy and a recommendation as to how to vote on each issue based on the research of a third- party research provider (Glass, Lewis & Co., LLC) (“Research Provider”) with regard to the individual facts and circumstances of the proxy issue and the Research Provider’s application of its research findings to the Research Provider’s guidelines (“Guidelines”). ARK will utilize the Research Provider’s guidelines to help improve its understanding of the issues surrounding a company’s proxy proposals. Absent a client directive to vote a proposal a certain way or a determination to override the Research Provider’s recommendations, as set forth below, ARK will instruct the Proxy Agent to cast votes in accordance with the Research Provider’s recommendations (“Recommendation”). ARK will ultimately follow the voting guidelines outlined below. Voting Guidelines ARK has approved proxy voting guidelines applicable to the subject matters of common proxy proposals (the “Approved Guidelines”) based on the Research Provider’s guidelines. Depending on the subject matter of a proposal, ARK may vote in accordance with a Recommendation, override a Recommendation, and/or consider a proxy proposal on a case-by-case basis. ARK holds the right to override any Recommendation they deem fit, as long as it provides and documents valid reasoning. The decision to override remains the responsibility of each company's lead analyst, or his/her designee, as well as ARK’s Portfolio Manager for its indexed products (collectively referred to as the "Lead"). Among other things, ARK may choose not to vote proxies under the following circumstances: 1. if the effect on the clients’ economic interests or the value of the portfolio holding is indeterminable or insignificant; 2. if the cost of voting the proxy outweighs the possible benefit; or 3. if a jurisdiction whose laws or regulations govern the voting of proxies with respect to the portfolio holding impose share blocking restrictions which prevent ARK from exercising its voting authority. If for some other reason proxies are not voted for clients, ARK and/or a third-party will conduct an analysis to review whether the lack of voting would have had a material impact on the outcome of the vote. ARK will memorialize the basis for any decision to override a Recommendation or to abstain from voting, including the resolution of any conflicts, as further discussed below. Administrative matters beyond the ARK’s control can, at times, prevent ARK from voting proxies. Subject Matter Considerations Determinations on how to vote proxies will depend largely on the subject matter of the ballot item. When determining how to vote proxies, ARK will be guided by the Approved Guidelines set forth below. These general policies are intended to promote a consistent approach to proxy voting. 1. Executive, Director, and Employee Compensation

ARK supports efforts by companies to adopt compensation and incentive programs to attract and retain talent. In instances where the Recommendation is against a compensation-based proposal, the Lead will review the proposal and generally override the Recommendation. 2. Auditors ARK agrees with the Research Provider’s guidelines to support auditor ratification except when the nonaudit fees exceed the audit fees paid to the auditor. Therefore, ARK will vote in line with the Recommendation on auditor-focused proposals. 3. Election of Directors and Committee Members ARK predominately believes that company management is in the best position to choose which individuals to elect and re-elect to the company’s board of directors and committees. In instances where the Recommendation is against the election or re-election of a director, the Lead will review the proposal and the Research Provider’s reasoning against the election and generally override the Recommendation. 4. Shareholder Rights and Governance ARK agrees with the Research Provider’s guidelines to support proposals increasing or enhancing shareholder rights such as declassifying the board, eliminating supermajority voting, allowing shareholders to call a special meeting, and adopting majority voting for the election of directors. ARK also agrees with voting against proposals to eliminate or reduce shareholder rights. Therefore, ARK will vote in line with the Recommendation on shareholder rights proposals. 5. Mergers, Acquisitions and Contested Meetings ARK believes that proposals related to mergers, acquisitions and contested meetings should be examined on a case-by-case basis. The Lead will review the facts of each merger, acquisition and contested meeting ballot item and have the option to override the Recommendation if they deem fit. 6. Shareholder Proposals: Environment ARK believes that shareholder proposals asking the issuer to adopt a certain practice or take certain actions, to cause a particular practice or to cease certain practices or take certain actions related to a company’s activities or operations should be reviewed on a case-by-case basis. Such proposals include those seeking to cease a certain practice or take certain actions related to a company’s activities or operations, seeking enhanced environmental disclosure and reporting, including those seeking sustainability reporting and disclosure about company’s greenhouse gas emissions, as well as those advocating compliance with international environmental conventions and adherence to environmental principles. The Lead will review the facts of each environmental-based shareholder proposal and have the option to override the Recommendation if they deem fit in the best interests of ARK’s clients. 7. Shareholder Proposals: Social ARK believes that shareholder proposals requesting companies adhere to labor or worker treatment codes of conduct, such as those espoused by the International Labor Organization, relating to labor standards, human rights conventions and corporate responsibility at large conventions and principles, should be reviewed on a case-by-case basis. ARK also agrees to review proposals seeking disclosure concerning the rights of workers, impact on local stakeholders, workers’ rights and human rights in general and proposals seeking to increase reporting and review of a company’s political and charitable

spending as well as its lobbying practices on a case-by-case basis. The Lead will review the facts of each social-based shareholder proposal and have the option to override the Recommendation if they deem fit in the best interests of ARK’s clients. 8. Other Categories The Research Provider’s guidelines are not all-encompassing and do not include all subject matters. The items listed below are subject matters not covered by the Research Provider’s guidelines, that ARK has drafted Approved Guidelines for: a. Employment/Service Agreements of Employees Generally, ARK supports efforts by companies to adopt employment and service agreements for employees to attract and retain talent and will vote with management on such ballot items. In instances where the Recommendation is against a proposal regarding an employment and/or service agreement, the Lead will review the proposal and generally override the Recommendation. b. Approval/Ratification of Company Documents ARK generally votes with the recommendation of company management on ballot items relating to the approval and/or ratification of company documents (i.e. financial statements, Articles of Association, bylaws) based on the view that management is typically in a better position to assess these matters. Therefore, in instances where the Recommendation is against a proposal regarding these items, the Lead will review the proposal and generally override the Recommendation. c. Approval of Allocation of Income and Dividends ARK generally votes with the recommendation of company management on ballot items relating to the approval of allocation of income and dividends based on the view that management is typically in a better position to assess these matters. Therefore, in instances where the Recommendation is against a proposal regarding these items, the Lead will review the proposal and generally override the Recommendation. If a ballot item is related to subject matter outside of those described above, the Lead will review the ballot item and Recommendation on a case-by-case basis and with the option to override the Recommendation if they deem fit. ARK will review, and update, if necessary, the Approved Guidelines, periodically and upon major updates to the Research Provider’s Recommendations. Addressing Material Conflicts of Interest Prior to overriding a Recommendation, the Lead must memorialize the determination by filling out a Proxy Vote Override Form and submit it to Compliance for determination as to whether a potential material conflict of interest exists between ARK and the clients on whose behalf the proxy is to be voted (“Material Conflict”). Each Lead has an affirmative duty to disclose any potential Material Conflict known to them related to a proxy vote. Material Conflicts may exist in situations where ARK is called to vote on a proxy involving an issuer or proponent of a proxy proposal regarding the issuer where the ARK also: 1. manages the issuer’s or proponent’s pension plan; or

2. manages money for an employee group. Additional Material Conflicts may exist if an executive of ARK is a close relative of, or has a personal or business relationship with: 1. 2. 3. 4. 5.

an executive of the issuer or proponent; a director of the issuer or proponent; a person who is a candidate to be a director of the issuer; a participant in the proxy contest; or a proponent of a proxy proposal.

Material Conflicts based on business relationships will only be considered to the extent that the Lead has actual knowledge of such business relationships. Whether a relationship creates a Material Conflict will depend on the facts and circumstances. Even if these parties do not attempt to influence ARK with respect to voting, the value of the relationship to ARK can create a Material Conflict. If Compliance determines that there is no potential Material Conflict, the Lead may override the Recommendation and the proxy issue can be voted as he/she determines is in the best interest of clients. If Compliance determines that there exists or may exist a Material Conflict, Compliance will consider the facts and circumstances of the pending proxy vote and the potential or actual Material Conflict and make a determination as to how to vote the proxy – i.e., whether to permit or deny the override of the Recommendation, or whether to take other action, such as delegating the proxy vote to an independent third party or obtaining voting instructions from clients. In considering the proxy vote and potential or actual Material Conflict, Compliance may consider the following factors: 1. 2. 3. 4.

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ARK does not require or solicit pre-payment of fees six months or more in advance and is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients.

ADDITIONAL INFORMATION Privacy Policy ARK is committed to protecting the confidentiality of information clients send to us. Regulation S-P adopted by the SEC requires that we provide the following information to you. Information about you that we collect: We can collect non-public personal information about you and your transactions from the following sources: your account forms, through our website, through your transactions with us or others, email and social media. How we use your information: As permitted by law, we can share information about you with non-affiliated third parties that provide services to us or as necessary to service your account. These parties have agreed to treat your information as confidential and not to share such information with other parties. Otherwise, we do not disclose your non-public personal information unless authorized by you in writing or as otherwise permitted by law. This policy applies to non-public information about current, former or prospective clients who are natural persons. How we protect your confidential information: ARK has policies that restrict access to your non-public personal information to employees who need the information to provide investment services to you. We maintain physical, electronic and procedural safeguards to protect your non-public personal information. For additional information, please refer to ARK’s Privacy Policy available at: https://arkinvest.com/privacy-policy.

Part 2B of FORM ADV Brochure Supplement ARK Investment Management LLC 200 Central Ave | Suite 220 St. Petersburg, FL 33701 1-727-810-8160 www.ark-invest.com March 31, 2026 CATHERINE D. WOOD This Brochure Supplement provides information about Catherine D. Wood that supplements the ARK Investment Management LLC (“ARK”) Brochure. You should have also received a copy of the Brochure. Please contact us at 1-727-810-8160 or through www.ark-invest.com/contact if you did not receive ARK’s Brochure or if you have any questions about the contents of this Brochure Supplement.

Name: CATHERINE D. WOOD Year of Birth: 1955 Item 2‐ Educational Background and Business Experience Formal education after high school: Bachelor of Science, summa cum laude, in Finance and Economics from the University of Southern California Business background and experience for preceding years: ARK Investment Management LLC 2014-present Managing Member, Founder, Chief Executive Officer and Chief Investment Officer Chief Executive Officer, Chief Investment Officer ARK ETF Trust 2014-present and Trustee Senior Vice President and Chief Investment AllianceBernstein L.P. 2001-2013 Officer of Global Thematic Portfolios Tupelo Capital Management 1998-2001 Chief Investment Officer Chief Economist, Equity Research Analyst, Jennison Associates 1980-1998 Portfolio Manager and Director Item 3 ‐ Disciplinary Information None Item 4 ‐ Other Business Activities Ms. Wood is involved in nine Other Business Activities: (1) Founder of the ARK Education Initiative, a private foundation equipping vulnerable populations with information to access and advance innovation through education, mentorship, and opportunity; (2-6) Director to five NexPoint Advisors funds - NexPoint Diversified Real Estate Trust (NXDT), NexPoint Homes Trust (NXHT), NexPoint Real Estate Finance Inc. (NREF), NexPoint Residential Trust Inc. (NXRT) and VineBrook Homes Trust Inc. NexPoint Advisors is an alternative investment advisor; (7) Board Member to SpARK Labs, a nonprofit with a charitable purpose of serving as the focal point of innovation for the State of Florida and the Tampa Bay Region; (8) Board Member of The Tiffin Group LLC, a platform that conceives, creates, and operates fintech companies in the areas of wealth management, investments, and personal finance; and (9) Advisor to LayerZero Labs Ltd. Item 5 ‐ Additional Compensation Ms. Wood will receive a salary, and is the principal owner of ARK, currently controlling approximately 72% of all equity interests in ARK, and can receive earnings from ARK. She is also eligible to receive a bonus based on the quality of the advisory services and the overall financial performance of ARK. Item 6 ‐ Supervision Ms. Wood reports to the ARK ETF Trust and ARK Venture Fund Board of Trustees’ Independent Trustees as well as ARK’s Board of Directors on various business-related and non-investment matters. Also, Ms. Wood is a supervised person of ARK under its Compliance Manual and Code of Ethics wherein she is obligated to comply with ARK’s policies and procedures in terms of her conduct and activities. Among other things, ARK’s Compliance Manual mandates that such Supervised Persons act within the best interest of ARK’s clients in making suitable investment decisions for ARK’s clients. Mr. D. Forest Wolfe, General Counsel, is ultimately responsible for supervising Ms. Wood’s advisory activities on behalf of ARK, and he can be reached at telephone number: 727-387-5086.

Part 2B of FORM ADV Brochure Supplement ARK Investment Management LLC 200 Central Ave | Suite 220 St. Petersburg, FL 33701 1-727-810-8160 www.ark-invest.com March 31, 2026 BRETT M. WINTON This Brochure Supplement provides information about Brett M. Winton that supplements the ARK Investment Management LLC (“ARK”) Brochure. You should have also received a copy of the Brochure. Please contact us at 1-727-810-8160 or through www.ark-invest.com/contact if you did not receive ARK’s Brochure or if you have any questions about the contents of this Brochure Supplement.

Name: BRETT M. WINTON Year of Birth: 1978 Item 2 ‐ Educational Background and Business Experience Formal education after high school: Bachelor of Science in Engineering from the Massachusetts Institute of Technology Business background and experience for preceding years: ARK Investment Management LLC

2014-present

iamB Consulting

2012-present

Chief Futurist & ARK Venture Investment Committee Member Principal

AllianceBernstein L.P.

2007-2012

Research Analyst

Item 3 ‐ Disciplinary Information None Item 4 ‐ Other Business Activities Mr. Winton is involved with four Other Business Activities: (1) Principal of iamB Consulting, which conducts bespoke thematic research, specializing in the implications of theme-based disruptive innovation for select and approved start-up businesses; (2) Non-executive General Partner to Placeholder Ventures LLC, a venture fund in the cryptocurrency space; (3) Member of the Board of Trustees of Westland School, a nonprofit elementary school; and (4) strategic advisor to the Board of Directors of Eightco Holdings Inc., a digital asset treasury company. Mr. Winton’s activities could present a conflict of interest with the clients that also pursue thematic investing, but Mr. Winton is not permitted to take on projects or assignment through iamB Consulting that would conflict with his duties and responsibilities to ARK. Item 5 ‐ Additional Compensation Mr. Winton receives a salary at a competitive rate and owns a small equity interest (approximately 2.5%) in ARK. Mr. Winton receives standard employee benefits and is also eligible to receive a bonus based on the quality of the advisory services and the overall financial performance of ARK. Item 6 ‐ Supervision Mr. Winton reports directly to Ms. Catherine Wood and is a supervised person of ARK under its Code of Ethics. Ms. Wood is the Managing Member, Founder, Chief Executive Officer and Chief Investment Officer and can be contacted at 1-727-810-8160. Mr. Winton is also obligated to comply with ARK’s Compliance Manual and Code of Ethics in terms of his conduct and activities.

Part 2B of FORM ADV Brochure Supplement ARK Investment Management LLC 200 Central Ave | Suite 220 St. Petersburg, FL 33701 1-727-810-8160 www.ark-invest.com March 31, 2026 WILLAM SCHERER This Brochure Supplement provides information about William Scherer that supplements the ARK Investment Management LLC (“ARK”) Brochure. You should have also received a copy of the Brochure. Please contact us at 1-727-810-8160 or through www.ark-invest.com/contact if you did not receive ARK’s Brochure or if you have any questions about the contents of this Brochure Supplement.

Name: WILLIAM SCHERER Year of Birth: 1992 Item 2 ‐ Educational Background and Business Experience Formal education after high school: Bachelor of Science in Accounting from Bryant University Master of Business Administration from Baruch College’s Zicklin School of Business Business background and experience for preceding years: ARK Investment Management LLC TIAA-CREF

2014-present 2013-2014

Director of Operations Business Analyst Intern

Item 3 ‐ Disciplinary Information None Item 4 ‐ Other Business Activities None Item 5 ‐ Additional Compensation Mr. Scherer receives a salary at a competitive rate and owns a small equity interest (less than a half of a percent) in ARK. Mr. Scherer receives standard employee benefits and is also eligible to receive a bonus based on the quality of the advisory services and the overall financial performance of ARK. Item 6 ‐ Supervision In this capacity, Mr. Scherer reports directly to Ms. Wood and is a supervised person of ARK under itsCode of Ethics. Ms. Wood is the Managing Member, Founder, Chief Executive Officer and Chief Investment Officer and can be contacted at 1-727-810-8160. Mr. Scherer is also obligated to comply with ARK’s Compliance Manual and Code of Ethics in terms of his conduct and activities.

Part 2B of FORM ADV Brochure Supplement ARK Investment Management LLC 200 Central Ave | Suite 220 St. Petersburg, FL 33701 1-727-810-8160 www.ark-invest.com March 31, 2026 DAN WHITE, CFA This Brochure Supplement provides information about Dan White that supplements the ARK Investment Management LLC (“ARK”) Brochure. You should have also received a copy of the Brochure. Please contact us at 1-727-810-8160 or through www.ark-invest.com/contact if you did not receive ARK’s Brochure or if you have any questions about the contents of this Brochure Supplement.

Name: Dan White Year of Birth: 1991 Item 2 ‐ Educational Background and Business Experience Formal education after high school: Chartered Financial Analyst® (CFA®) 1 Bachelor of Arts in Finance from the University of Rhode Island Business background and experience for preceding years: ARK Investment Management LLC Bank of America

2021-present 2016-2021

Portfolio Manager V.P./Investment Strategist

Item 3 ‐ Disciplinary Information None Item 4 ‐ Other Business Activities None Item 5 ‐ Additional Compensation Mr. White receives a salary at a competitive rate and owns a small equity interest (less than a percent) in ARK. Mr. White receives standard employee benefits and is also eligible to receive a bonus based on the quality of the advisory services and the overall financial performance of ARK. Item 6 ‐ Supervision Mr. White reports directly to Ms. Wood and is a supervised person of ARK under its Code of Ethics. Ms. Wood is the Managing Member, Founder, Chief Executive Officer and Chief Investment Officer and can be contacted at 1-727-810-8160. Mr. White is also obligated to comply with ARK’s Compliance Manual and Code of Ethics in terms of his conduct and activities.

1 The Chartered Financial Analyst® (CFA®) designation is a globally recognized professional credential awarded by the CFA Institute. It

is earned by completing a three-level examination program covering investment management, financial analysis, economics, ethics, and portfolio management, and by meeting relevant work experience requirements.

Part 2B of FORM ADV Brochure Supplement ARK Investment Management LLC 200 Central Ave | Suite 220 St. Petersburg, FL 33701 1-727-810-8160 www.ark-invest.com March 31, 2026 Dr. CHARLES ROBERTS This Brochure Supplement provides information about Charles Roberts that supplements the ARK Investment Management LLC (“ARK”) Brochure. You should have also received a copy of the Brochure. Please contact us at 1-727-810-8160 or through www.ark-invest.com/contact if you did not receive ARK’s Brochure or if you have any questions about the contents of this Brochure Supplement.

Name: DR. CHARLES ROBERTS Year of Birth: 1977 Item 2 ‐ Educational Background and Business Experience Formal education after high school: Bachelor of Medicine and Bachelor of Surgery from the University of Dundee BSc of Psychology from the University College London Masters of Experimental Therapeutics from New College at the University of Oxford Business background and experience for preceding years: ARK Investment Management LLC

2023-present

Relation Therapeutics Ltd.

2019-present

Freenome Holdings Inc

2014-2023

Anthem, Inc. Juv Labs OSI (OxfordSciences) Agalimmune Altermune

2020-2021 2018-2021 2016-2018 2015-2016 2011-2016

Yourgene Health, Ltd.

2007-2016

Chief Investment Strategist, Private Equity & ARK Venture Investment Committee Member Co-founder; Chairperson Co-founder; Researcher; Chief Growth Officer; Board Observer Advisor to Digital Health Group Data Science Advisor Advisor Co-founder; Board Member Co-founder; CEO; Board member Co-founder (including formative company Premaitha Health Ltd.); Board Member

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