EVENTIDE ASSET MANAGEMENT, LLC

Even de Asset Management, LLC (“Even de”) is a Delaware limited liability company that has been registered with the U.S. Securi es and Exchange Commission (“SEC”) as an investment adviser since May 2008. Even de provides investment advisory products and services to a diverse client base, on a discre onary and non-discre onary basis, based on ethical values inspired by the Chris an faith and rooted in a biblical worldview. Even de manages a broad range of investment strategies, seeking to invest in companies iden fied as having strong fundamentals and crea ng value for stakeholders (customers, employees, supply chain, community, environment, and society). As of December 31, 2025, Eventide’s discretionary assets under management totaled $7.4 billion and non-discretionary assets under advisement totaled $155 million.

Principal Ownership There are two principal owners of Even de (greater than 25% ownership): Dr. Finny Kuruvilla, Even de’s Co-Chief Investment Officer, a Senior Por olio Manager and Managing Director of Even de’s private funds and Mr. Robin John, Even de’s Chief Execu ve Officer. Further informa on on Even de’s ownership structure is provided in Part 1 of Form ADV.

Investment Strategies, Products and Services When evalua ng investment opportuni es and construc ng por olios, Even de seeks to iden fy companies with strong fundamentals and posi oned to create value for stakeholders (customers, employees, supply chain, community, environment, and society). Even de applies its faith-based investment framework to a wide range of strategies, products and services offered on a discre onary and non-discre onary basis. Eventide uses its screening processes in connection with other fundamental research processes to help establish each strategy’s eligible investment universe. Securities are generally ineligible for purchase within a strategy, unless Eventide’s research indicates that the faith-based screens are met. If Even de’s research iden fies events and/or business changes sugges ng that a por olio company no longer meets the faith-based criteria, accounts managed within the strategy may hold the company’s securi es while Even de performs addi onal research, including possible direct engagement with the company to assess prac ces. The Adviser’s faith-based screening process for poten al investments does not apply rela ve weights between values-based factors and financial factors. Although there is no guarantee that Eventide will be able to successfully screen out all companies that are inconsistent with the following principles, Eventide seeks to invest in companies that reflect the following values:

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Respecting the value and freedom of all people: this includes the right to life at all stages and freedom from addictive behaviors caused by gambling, pornography, tobacco and alcohol. Demonstrating a concern for justice and peace: this includes fair and ethical relationships with customers, suppliers, and business partners and avoidance of products and services that promote weapons production and proliferation. Promoting family and community: this includes protecting children from violent forms of entertainment and serving low-income communities. Exhibiting responsible management practices: this includes fair dealing with employees, communities, competitors, suppliers, and customers as demonstrated by a company’s record regarding litigation, regulatory actions against the company, and its record of promoting products and services that improve the lives of people. Practicing environmental stewardship: this includes practices considered more sustainable than those of industry peers, reduction in environmental impact when compared to previous periods, and/or the use of more efficient and cleaner energy sources.

Securities might be sold when Eventide believes they no longer represent relatively attractive investment opportunities or when Eventide believes the underlying company is no longer consistent with Eventide's faith-based values. Application of Eventide's screening criteria could cause an Eventide strategy to underperform similar strategies that do not have such screening criteria. This could be due to ethically acceptable companies falling out of favor with investors or failing to perform as well as companies that do not meet Eventide's screening guidelines. As of the date of this Firm Brochure, Even de’s fundamental investment strategies include, but are not limited to, the following:

Balanced Strategy Core Bond Strategy Dividend Growth Strategy Dividend Value Strategy Healthcare & Life Sciences Strategy Large Cap Core Strategy Limited-Term Bond Strategy Strategic Growth Strategy Technology Strategy

Even de offers dis nct Healthcare & Life Sciences strategies, across different product types as described below.

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As of the date of this Firm Brochure, Even de also manages a range of systema c investment strategies. In these strategies, Even de monitors the por olio and uses research and quan ta ve modeling and risk tools to reasonably adjust the ac ve weight of por olio securi es in order to improve the account’s ability to meet its investment objec ve and reduce ac ve risk compared with its Strategy Benchmark. While ac vely managing the por olio, Even de u lizes quan ta ve tools as an input to the management of posi on sizes on a forward-looking basis, including to help mi gate the impact of individual sectors, industries, and stylis c factors (e.g., quan ta ve factors such as growth, momentum, quality and value) on ac ve risk and the account’s ability to perform in a manner that is similar to the performance of the Strategy Benchmark before account fees and expenses. As of the date of this Firm Brochure, Even de’s systema c investment strategies include, but are not limited to, the following:

Interna onal Strategy Large Cap Growth Strategy Large Cap Value Strategy Small Cap Strategy US Equity Market Strategy

Upon client request, Even de can also implement strategies based on guidelines of the United States Conference of Catholic Bishops (“USCCB”), such as for separately managed accounts (“SMAs”). Even de’s advisory services are generally tailored to the investment products it manages and services it offers as described below. Types of Client Accounts Eventide’s clients generally fall within one of the four account types and service levels below: 1. Unrestricted Accounts: This account type reflects discretionary institutional clients for which Eventide maintains full discretion over portfolio and brokerage decisions. This includes determining trade execution strategies for pooled investment vehicles and SMAs unencumbered by any trading-related restriction, direction or other limitation required by clients. For instance, Eventide determines the time and price of transactions, broker-dealer selection, and whether to effect transactions using soft dollar commissions, commission sharing arrangements (“CSAs”), or through other means. 2. Managed Account Programs: This account type reflects clients that Eventide services through various managed account programs sponsored by third parties. Examples include wrap account programs and so-called “dual contract” arrangements in which end-clients access SMA strategies

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by contracting with their program sponsor and with money managers such as Eventide. Eventide generally provides investment strategies to these clients by delivering model-based portfolios directly to the program sponsor for implementation. Managed account programs generally serve a range of client types, including institutions and retail investors (e.g., entities and individuals). Program sponsors generally define requirements for trade implementation within their respective platforms. 3. Restricted Accounts: This account type reflects discretionary institutional clients of Eventide that either: i.) direct Eventide to effect trades with one or more specific brokers; ii.) restrict or otherwise limit Eventide’s discretion to effect trades such as with certain brokers; iii.) restrict or otherwise limit Eventide’s discretion to effect transactions using soft dollar commissions or commission sharing agreements (“CSAs”); and/or iv.) otherwise impose service levels that impinge Eventide’s ability to seek best execution in the opinion of Eventide. 4. Non-Discretionary Accounts: This account type reflects institutional clients such as program sponsors electing to receive non-discretionary portfolios delivered by Eventide after NYSE market close, periodically as determined by clients (e.g., weekly, quarterly, etc.). Program sponsors maintain full investment and trading discretion over transactions in their client accounts, including determining whether to implement all, some, or none of Eventide’s recommendations. Products and Services Mutual Funds. Even de provides discre onary por olio management for mutual funds (the “Mutual Funds”) registered under the Investment Company Act of 1940, as amended (the “1940 Act”). Even de manages the Mutual Funds as described in each Mutual Fund’s prospectus and statement of addi onal informa on. Such documents explain in greater detail how each Mutual Fund u lizes Even de’s applicable investment strategies, risks, fees, and other factors to consider before inves ng (please see even defunds.com). As of the date of this Firm Brochure, Even de manages the following Mutual Funds:

Even de Balanced Fund Even de Core Bond Fund Even de Dividend Growth Fund Even de Exponen al Technologies Fund Even de Gilead Fund Even de Healthcare & Life Sciences Fund Even de Large Cap Focus Fund Even de Limited-Term Bond Fund

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The Mutual Funds are generally managed by Even de according to the strategies iden fied above. Even de’s fixed-income strategies are delivered in coordina on with a fixed-income sub-adviser hired to manage all or a por on of assets in certain Mutual Funds, as disclosed in the applicable prospectuses. As more fully described in each Mutual Fund’s prospectus and statement of addi onal informa on, there is no guarantee that any Mutual Fund will achieve its objec ve. Investment markets are unpredictable and there will be certain market condi ons in which Mutual Funds will not meet their objec ves. Each Mutual Fund’s net asset value and returns will vary. Investors could lose all their money on their investments. Private Funds. At the me of filing this Firm Brochure, Even de provides discre onary investment advisory services to two (2) private funds, the Even de Healthcare Innova on Fund I LP (“Fund I”) and the Even de Healthcare Innova on Fund II LP (“Fund II,” each a “Private Fund” and together, the “Private Funds”). The Private Funds are each offered pursuant to Regula on D of the Securi es Act of 1933 (the “Securi es Act”). Fund I and Fund II are excluded from the defini on of an investment company under Sec ons 3(c)(1) and 3(c)(7) of the 1940 Act, respec vely. Even de manages the Private Funds as described in each Fund’s limited partnership agreement and private placement memorandum (“PPM”). The Private Funds’ investment strategies are dis nct from Even de’s Healthcare & Life Sciences strategy referenced above. The Private Funds’ investment strategies overlap with a por on of the investment strategy u lized by certain Mutual Funds. Even de maintains policies, procedures, and controls to help address poten al conflicts of interest associated with side-by-side inves ng, as described more fully within this Firm Brochure, applicable Mutual Fund disclosure documents, and each Private Fund’s PPM. There is no guarantee that either Private Fund will achieve its objec ve. Investors should understand and be able to bear the significant risks of inves ng in each Private Fund, have a limited need for liquidity, and be capable of withstanding a loss of their en re investment. An investment in a Private Fund is suitable only for ins tu ons and individuals that sa sfy the condi ons set forth in the applicable subscrip on documents. Exchange-Traded Funds. As of the date of this filing, Even de provides discre onary por olio management for exchange-traded funds (“ETFs”) registered under the 1940 Act. Even de manages its ETFs as described in their respec ve prospectus and statement of addi onal informa on. Such documents also explain in greater detail each ETF’s strategy, risks, fees, and other factors to consider before inves ng (please see Even deETFs.com). As of the date of this Firm Brochure, Even de manages the following ETFs:

Even de High Dividend ETF ( cker “ELCV”) Even de Interna onal ETF ( cker “ESIM”)

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Even de Large Cap Growth ETF ( cker “ESLG”) Even de Large Cap Value ETF ( cker “ESLV”) Even de Small Cap ETF ( cker “ESSC”) Even de US Market ETF ( cker “ESUM”*)

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Even de’s fee schedules vary from product to product based on a variety of factors, including but not limited to, the por olio manager, investment vehicle, strategy, degree of servicing required, and marketplace condi ons. Even de charges a performance-based fee to investors in its Private Funds that are “qualified clients,” as defined by Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”). For more informa on on Even de’s performance-based fee, please see Item 6 Performance-Based Fees and Side-By-Side Management. As of the date of this Firm Brochure, Even de is paid a management fee from each Mutual Fund, the Private Funds, each ETF, and SMA, as described more fully below. For Managed Account Program or Non-Discre onary Accounts inves ng in Even de’s SMA strategies, Even de is paid a por on of the wrap or UMA fee, as applicable. For more informa on on the fee structure associated with each strategy and product, please see below.

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Mutual Funds Even de is paid a monthly management fee for providing investment advisory services to the Mutual Funds based on the average daily net assets of each Mutual Fund as described in each Mutual Fund’s Prospectus. For certain Mutual Funds, Even de employs a sub-adviser to provide day-to-day management of all or a por on of a Mutual Fund’s assets, and Even de pays management fees to the sub-adviser. Even de has contractually agreed to waive fees and/or reimburse certain of the Mutual Funds’ expenses above a specified limit and Even de retains the ability to be repaid these amounts by the Mutual Funds as explained in each Mutual Fund’s prospectus. Such reimbursement arrangements can reduce a Mutual Fund’s payments for opera ng expenses and enhance its performance. Even de can also discon nue such reimbursement arrangements. Addi onal informa on regarding each Mutual Fund’s management fee and opera ng expenses is available in the applicable prospectus at even defunds.com. When investors access Even de’s investment services through the Mutual Funds, they generally purchase or sell Mutual Fund shares through financial intermediaries that are not affiliated with Even de. Even de pays, from its legi mate profits, servicing and/or distribu on fees to certain financial intermediaries who introduce, purchase, educate, or provide informa on about the Mutual Funds to their clients, pursuant to an agreement with Even de. Such servicing and/or revenue-sharing arrangements can differ with each financial intermediary, and transac ons in the Mutual Funds through a par cular intermediary can result in more or less profit to Even de depending on the agreement in place.

The Private Funds Even de is paid a management fee of 2% per annum for providing investment advisory services to each Private Fund. This management fee is based on the amount of commi ed capital during the investment period of the Private Fund, and on the amount of invested capital therea er. As described below in Item 6, each Private Fund is subject to a performance fee. Even de in its sole discre on can choose to waive or reduce certain fees for par cular investors, including waiving or charging lower management and/or performance fees for the Private Funds, or waiving catch-up interest provisions that would otherwise be applied to Private Fund investors. Even de can also waive account minimums for investors in its sole discre on, including Even de employees, por olio managers, affiliates or rela ves of such persons. Some investors in a Private Fund could enter into side le er agreements (“Side Le ers”) with Even de providing such investors with lower management fees or performance fees and other more favorable terms than other investors. Side Le ers can grant an investor addi onal vo ng or informa on rights concerning the Private Fund, such as access to commi ee mee ngs or other informa on that is not

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available to other investors. Side Le ers might also grant specific rights such as a right to make future co-investments alongside the Private Fund or en tle investors to share in a percentage of the performance fee. Side Le ers could also grant most favored na on (“MFN”) rights that allow an investor to elect to receive terms nego ated by other investors. Even de is not required to inform investors of Side Le ers or offer preferen al terms to all investors in a Private Fund. As such, certain terms available to one or more investors in a Private Fund are not available to all investors in that Private Fund. Investors in a Private Fund pay expenses in addi on to management fees and performance fees. As referenced in the applicable Private Fund documents and agreements, such expenses include, but are not limited to (i) organiza onal and forma on expenses, including costs, liabili es and obliga ons incurred to form the Private Fund and its general partner, and to offer Private Fund interests (including dra ing the private placement memorandum, limited partnership agreement, management agreement and subscrip on documents), (ii) ongoing expenses related to the Private Fund and its ac vi es, including due diligence of investments (and costs of contemplated transac ons never consummated) and other related expenses, legal, audi ng, accoun ng, third-party administra on, banking, custody, tax, and valua on services, indebtedness, mee ngs with investors and travel related thereto, liability insurance coverage for certain persons, as well as filing and/or financial repor ng fees and expenses, (iii) disposi on of the investments, distribu ons, and the termina on and dissolu on of the Private Fund, and (iv) extraordinary expenses such as li ga on, among other fees and expenses, as disclosed in the Private Fund’s documents. In connec on with the purchase and sale of por olio securi es in a Private Fund, investors also pay transac on costs such as commissions charged by brokers. As noted below in Item 12 – Brokerage PracƟces, Even de exercises discre on in the selec on of brokers to effect Private Fund por olio transac ons. This includes execu ng transac ons based on a range of factors, including Even de’s receipt of research, rather than obtaining brokerage services at the lowest possible execu on price. These expenses are typically allocated to investors on a pro rata basis according to each investor’s commi ed capital in the Private Fund. Even de has the authority to directly debit fees from the accounts of the Private Funds. These directly debited fees are calculated at the investor level and subtotaled at the Private Fund level by the Private Funds' third-party administrator. While this Firm Brochure includes informa on about the Private Funds, it is not intended to be a complete discussion of the features, benefits, risks, or conflicts associated with each Private Fund. More informa on about each Private Fund’s fees and expenses can be found in its offering documents, including the PPM, which prospec ve investors should review carefully before inves ng in the Private Fund. While this Firm Brochure may be provided to a prospec ve Private Fund investor

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together with the PPM and other related documents in connec on with a prospec ve investor’s considera on of a Private Fund, this Firm Brochure should not be considered an offer of interests in a Private Fund, and should not be solely relied upon in determining whether to invest in a Private Fund.

Exchange-Traded Funds (“ETFs”) Even de is paid a monthly management fee for providing investment advisory services to the ETFs based on the average daily net assets of each ETF as described in the ETF’s Prospectus. This management fee is structured as a “unified fee”, out of which Even de generally pays all rou ne expenses of the ETFs, except the management fee and certain other expenses outlined in the applicable prospectus available at Even deETFs.com. When investors access Even de’s investment services through the ETFs, they generally purchase or sell ETF shares through financial intermediaries that are not affiliated with Even de. Even de pays, from its legi mate profits, servicing and/or distribu on fees to certain financial intermediaries who introduce, purchase, educate, or provide informa on about the ETFs to their clients, pursuant to an agreement with Even de. Such servicing and/or revenue-sharing arrangements can differ with each financial intermediary, and transac ons in the ETFs through a par cular intermediary can result in more or less profit to Even de depending on the agreement in place.

SMAs Even de’s SMA clients will generally execute an IMA with a schedule of management fees that Even de will receive for managing the SMA. Even de maintains a procedure to help provide a framework for nego a on of fee excep ons, including the handling of MFN requests, to help ensure fair and equitable client treatment. Even de generally nego ates fees with prospec ve SMA clients on a case-by-case basis in light of a client’s specific circumstances, asset levels, service requirements or other factors, in Even de’s sole discre on, and Even de expects to nego ate different management fees for the same or similar SMA strategies. Even de is not required to inform poten al SMA clients of preferen al terms offered to other SMA clients. Terms available to one SMA client are not available to all SMA clients. Even de charges management fees up to 0.70% annually, specified below, based on client assets under management or as otherwise agreed with SMA clients. These management fees will exclude fees charged by financial intermediaries, brokerage commissions, transac on fees, and other costs and expenses incurred in implemen ng SMAs.

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Dividend Growth Strategy Up to $25 million Next $75 million Greater than $100 million Minimum Assets

$10 million

Dividend Value Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$25 million

Large Cap Core Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$25 million

Strategic Growth Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$25 million

Technology Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$25 million

US Equity Market Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$50 million

Small Cap Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$50 million

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Large Cap Growth Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$50 million

Large Cap Value Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$50 million

International Strategy Up to $75 million Next $25 million Greater than $100 million Minimum Assets

$50 million

Fees displayed above are for SMA clients categorized as Unrestricted or Restricted Accounts. Even de generally invoices such SMA clients on a quarterly basis in arrears for its investment management fees, or as otherwise agreed with clients. Such clients generally authorize Even de to bill their applicable custodian directly with respect to any fees, costs and expenses incurred by an SMA as provided in their IMA. Managed Account Program clients and Non-Discre onary Account clients are charged fees up to 0.60% annually, based on monthly SMA assets and the applicable strategy. Management fees are generally calculated and deducted from the financial intermediary or program sponsor’s client accounts by its authorized custodian or agent and paid to Even de monthly or quarterly. Even de's management fees for these clients do not include fees charged by a financial intermediary or program sponsor, brokerage commissions, transac on fees, and other costs and expenses incurred by a financial intermediary or program sponsor, or their clients, in connec on with implemen ng Even de’s SMAs. If Even de’s SMAs were to recommend the purchase of an Even de Mutual Fund or ETF, or an unaffiliated registered fund or ETF, then assets invested in such SMAs will be subject to addi onal advisory and other fees and expenses as set forth in the applicable fund prospectuses. Unless Even de provides a fee credit and/or waives such expenses, such underlying fund fees and expenses will be in addi on to any fees charged by a financial intermediary or program sponsor choosing to implement the SMA. Eventide’s SMAs managed for Managed Account Programs and for Non-Discretionary Accounts can E V E N T I D E ___________________________________________________________________________________________________________________

be subject to additional constraints in their implementation, such as minimum market caps or restricted securities, than a portfolio that is managed for other Account Types investing in the same strategy might not have, and will have different brokerage execution. Eventide cannot guarantee that the performance and composition of such SMAs will be similar to the performance results and composition of accounts in a comparable strategy managed by Eventide, and vice-versa, due to a variety of reasons, including the difference in the types, availability and diversity of securities that can be purchased, economies of scale, the timing of transactions, regulations and other factors applicable to the management of client accounts by Eventide and financial intermediaries or program sponsors.

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Strategies and Risk of Loss Even de applies its faith-based investment framework to a wide range of investment strategies and services, including its discre onary and its non-discre onary services described above. Even de’s screening guidelines and processes help to establish the firm’s eligible investment universe for providing advisory services. Even de con nues to monitor industry changes and increased a en on to values-based investment ideals, including changes to available data and regulatory expecta ons

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for this type of inves ng. Even de expects that it will con nue to incorporate these changes for some me as the industry’s ecosystem for values-based inves ng becomes more clearly defined. This means that Even de will likely con nue to adjust its internal systems and processes to maintain focus on its values-based inves ng criteria. While ac vely managing the por olio for certain strategies, the Adviser will u lize quan ta ve tools as an input to the management of posi on sizes on a forwardlooking basis, including to help mi gate the impact of individual sectors, industries, and stylis c factors on ac ve risk and the strategy’s ability to reasonably limit tracking error compared to the strategy benchmark. Below are certain analyses, methods and risks associated with the types of securi es and strategies that Even de implements on behalf of its clients. It is not possible to outline all risks associated with Even de’s investment strategies. Please refer to the applicable offering documents (e.g., prospectus, PPM) for more informa on about par cular strategies and risks. Investors should be aware that inves ng in a strategy managed by Even de is not intended or designed as a complete investment program addressing all needs of any individual investor. Even de presumes that investors will not invest all their assets in a Mutual Fund, Private Fund, ETF, or SMA. Investors are responsible for appropriately diversifying their assets to guard against the risk of loss. Faith-Based Investing. Even de analyzes companies for poten al investment based not only on

financial strengths and outlook, but also for the ability to operate with integrity and create value for customers, employees, supply chain, host communi es, the environment, and society broadly using its faith-based screening criteria, inspired by the Chris an faith and rooted in a biblical worldview. While few companies can reach these ideals in every area of business, these principles reflect Even de’s highest expecta ons for corporate behavior and directly impact Even de's investment process. Even de seeks to invest in companies that reflect the following values:  Respec ng the value and freedom of all people: this includes the right to life at all stages and freedom from addic ve behaviors caused by gambling, pornography, tobacco and alcohol.  Demonstra ng a concern for jus ce and peace: this includes fair and ethical rela onships with customers, suppliers and business partners and avoiding products and services that promote weapons produc on and prolifera on.  Promo ng family and community: this includes protec ng children from violent forms of entertainment and serving low income communi es.  Exhibi ng responsible management prac ces: this includes fair-dealing with employees, communi es, compe tors, suppliers, and customers as demonstrated by a company’s record

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regarding li ga on, regulatory ac ons against the company and its record of providing products and services that improve the lives of people.  Prac cing environmental stewardship: this includes prac ces considered more sustainable than those of industry peers, reduc on in environmental impact when compared to previous periods, and/or the use of more efficient and cleaner energy sources. Even de’s process a empts to understand the long-term sustainable effects of a company’s products, services and prac ces on its stakeholders based on the belief that companies offering products, services and prac ces that can benefit stakeholders will have be er long-term outlooks and opportuni es for financial returns. Even de o en refers to this framework as Business 360®. However, Even de might not be able to correctly ascertain which companies best exhibit these characteris cs and there is no assurance that financial markets will reward such a process. Even de’s faith-based analyses can therefore underperform other forms of inves ng. Since companies that rate poorly based on Even de’s faith-based analyses are generally excluded from poten al investment, or divested based on Even de’s ongoing reviews, the investment universe for Even de’s advisory services is smaller than if faith-based analyses had not been applied, and addi onal por olio turnover and related costs could be realized from divestments. This could result in fewer opportuni es for por olio diversifica on and nega vely impact investment returns. Even de’s screening criteria could cause underperformance in its investment advisory services compared with investment advisory services provided by third par es that do not apply such screening criteria. This could be due to reasons such as ethically acceptable companies falling out of favor with investors or failing to perform as well as companies that do not meet Even de’s ethical screening guidelines. To supplement its efforts to meet faith-based ethical principles when inves ng, Even de may engage with por olio companies to encourage considera on of corporate strategies aligned with par cular values, including pricing and/or business prac ces that may be beneficial within par cular industries. Even de believes these ac vi es will help promote ethical and effec ve corporate governance and long-term strategy for companies, and poten ally create a posi ve effect on the par cular businesses and/or industries, their consumers, and Even de’s strategies. There is no guarantee Even de's corporate engagements and related-ac vi es will achieve their intended results. There is a risk that Even de's ac vi es in this regard could limit a strategy’s investment universe and reduce the amount of profits that could be realized by affected companies, limi ng the strategy's investment returns. Furthermore, the U.S. government or any agency thereof, may enact rules or legisla on that, directly or indirectly, materially impacts Even de's ac vi es in this regard, or materially affects the value of companies or opportuni es for investment within par cular industries.

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There is no guarantee that Even de will be able to successfully screen out all companies that are inconsistent with its principles. A security can be iden fied for sale when Even de and/or a subadviser, where applicable, believes it no longer represents a rela vely a rac ve investment opportunity or when the underlying company’s prac ces are no longer consistent with Even de’s values-based principles. Based on the prac ces of certain intermediary pla orms that distribute Even de’s SMAs to their clients, some SMA accounts will periodically hold ETFs that do not fully align with Even de’s stated values. This is due to tax loss harves ng and the approval of reasonable por olio restric ons imposed by clients, and pla orm expecta ons that securi es removed from por olios will be replaced with certain broad-based ETFs sa sfying specific product parameters other than values-based principles, such as pricing, liquidity, and performance tracking consistent with the par cular SMA strategy selected. The periodic presence of such ETFs in an SMA account is not an indica on that Even de has overlooked its values-based processes, but rather a reflec on of opera onal and/or structural program standards imposed by third par es. American Depository Receipts (“ADRs”) Risk. ADRs, which are typically issued by a bank, are

cer ficates that evidence ownership of shares of a foreign company and are alterna ves to purchasing foreign securi es directly in their na onal markets and currencies. ADRs are subject to the same risks as direct investment in foreign companies and involve risks that are not found in investments in U.S. companies. Although an ADR is priced in the U.S. dollar, movements in the exchange rate of the local currency versus the U.S. dollar are automa cally reflected in the price of the ADR in U.S. dollars. Therefore, even if the price of the foreign security does not change on its market, if the exchange rate of the local currency rela ve to the U.S. dollar declines, the ADR price would decline by a similar measure. Artificial Intelligence (“AI”) Risk. Even de uses AI in select, targeted applica ons. For example,

supervised persons may use AI to perform supplemental research, such as to gather investmentrelated publica ons or informa on about clinical trials. AI tools could be based on flawed algorithms, based on inaccurate or incomplete data sets, or reflect biases included in the data. As a result, AI tools could produce inaccurate, misleading or incomplete responses. This could lead to errors in our investment process and in our employees’ decision-making, por olio management or other business ac vi es, which could have a nega ve impact on investment results. Even de maintains AI policies and procedures that require that informa on gathered from search engines should not be the sole source of decision-making and must be further validated by the supervised person before arriving at their final work product or otherwise using outputs to inform business decisions. Even de may not be able to independently verify all data inputs used by AI tools. Even de’s third-party vendors may rely on AI models, to which Even de may have limited visibility, increasing Even de’s risk in relying on such vendors. The use of AI presents cybersecurity, confiden ality, and regulatory risks. The use of AI tools may increase exposure to cybersecurity risks, including unauthorized access, data breaches, and malicious a acks. Use of AI tools may involve the input of confiden al, proprietary, or sensi ve

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informa on. The regulatory environment surrounding use of AI is uncertain and rapidly evolving, which could lead to increased compliance costs, and the possibility that our ability to use AI could be restricted or altered, which could adversely impact client por olios. Company Capitalization Risks. Even de’s investment strategies include small, medium (mid) and

large capitaliza on companies. Investment in each type of investment can present unique risks. Large capitaliza on companies may be less able to adapt to changing market condi ons, and subject to more limited growth poten al than would smaller capitaliza on companies. Small and mid-sized companies may experience higher failure rates than larger companies. Small capitaliza on companies o en have a lower trading volume than larger companies, which may tend to make their market price fall more dispropor onately than larger companies in response to selling pressure. Small and midsized companies might have limited markets, product lines or financial resources and could lack management experience. They could also be less likely to weather business or cyclical downturns than larger companies. Currency Risk. As exchange rates for currencies fluctuate daily, fluctua ons in the U.S. dollar’s value

versus other currencies may erode or reverse gains from investments denominated in foreign currencies or widen losses. The combina on of currency risk and market risk tends to make securi es traded in foreign markets more vola le than securi es traded exclusively in the U.S. Foreign securi es are normally denominated and traded in foreign currencies. As a result, the value of a client’s foreign investments and the value of its shares may be affected favorably or unfavorably by changes in currency exchange rates rela ve to the U.S. dollar. Exchange rate fluctua ons also may impair an issuer’s ability to repay U.S. dollar denominated debt, thereby increasing credit risk of such debt. Cybersecurity Risk. Cybersecurity incidents can raise risks to business opera ons and informa on

security within Even de, its service providers, as well as por olio companies held in client accounts. Cyber incidents can result from deliberate a acks as well as uninten onal events and may arise from external or internal sources. Cyber incidents can disrupt business opera ons, result in regulatory ac on, and nega vely impact Even de’s ability to provide services. Similarly, security events such as cyber breaches can pose existen al threats to por olio companies held within Even de’s investment strategies. The internet and social media services may also be used to exploit vulnerabili es in capital markets and key pla orms, resul ng in unexpected price movements, trading halts, and por olio vola lity. Even de’s informa on and technology systems (and those of its service providers and por olio companies) may be vulnerable to damage or interrup on from computer viruses, network failures, computer and telecommunica on failures, infiltra on by unauthorized persons or en es and security breaches, and usage errors by their respec ve professionals. There can be no guarantee that Even de or others will be able to prevent or mi gate such incidents. If systems and measures to

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As described in Item 4, Even de provides values-based investment advisory services and products to a diverse client base on both a discre onary and non-discre onary basis. As of the date of this Firm Brochure, Even de’s ins tu onal clients include pooled investment funds such as the Mutual Funds, the Private Funds and the ETFs. Even de also offers its investment advisory services to ins tu onal clients, including pension and profit-sharing plans, charitable founda ons, endowments, corpora ons, and other en es eligible to invest in its SMAs on a discre onary basis. Even de provides investment advisory services through various managed account programs sponsored by third par es. Examples include wrap account programs and so-called “dual contract” arrangements in which end-clients access SMA strategies by contrac ng with their program sponsor and with money managers such as Even de. Even de generally provides investment strategies to these clients by delivering model-based por olios directly to the program sponsor for implementa on. Managed account programs generally serve a range of client types, including ins tu ons and retail investors (e.g., en es and individuals). Program sponsors generally define requirements for trade implementa on within their respec ve pla orms. In some cases, Even de provides updated SMA por olios to third-party financial intermediaries or program sponsors that maintain full investment and trading discre on over transac ons in their client accounts, including determining whether to implement all, some, or none of the securi es recommended by Even de. Even de’s clients may include investors with re rement assets or pension plan clients that are covered under the Employee Re rement Income Security Act of 1974 (ERISA). Even de may be considered a “fiduciary” under ERISA in certain scenarios. Pursuant to both Even de’s fiduciary status as a SEC registered investment adviser and a fiduciary under ERISA, Even de must make

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recommenda ons to its clients regarding their re rement assets that are in the best interests of the client. For clients that contract directly with Even de, Even de generally collects iden fica on documenta on and conducts other iden fica on verifica on procedures, including screening clients against mul ple jurisdic onal sanc on lists, such as the Specifically Designated Na onals and Blocked Persons list maintained by the U.S. Department of the Treasury’s Office of Foreign Asset Control (OFAC). Requirements and investment minimums for opening and maintaining investment accounts for the Mutual Funds are determined by the Mutual Funds and by financial intermediaries. Private Fund investors must meet minimum eligibility requirements as described in applicable subscrip on documents, and must pass applicable iden fica on verifica on procedures. The minimum capital commitment for each investor in a Private Fund is generally $1 million. The Private Fund’s offering documents generally allow Even de to waive or reduce this minimum commitment in its sole discre on. The ETFs only offer, sell, and redeem shares on a con nuous basis at NAV in large aggregations or “Crea on Units.” ETF shares are not individually redeemable. The ETFs are approved for lis ng and trading on the NYSE Arca exchange (the “Exchange”), and are available for purchase and sale through a broker-dealer at market price on each day that the Exchange is open for business. The market price of each ETF’s shares may trade below, at, or above the most recently calculated NAV per share of the ETF. As is the case of other publicly traded securi es, the purchase or sale of ETF shares in the secondary market will be subject to brokerage commissions which will be based on negotiated commission rates at customary levels. SMA management fees, including account minimums, are generally nego ated with SMA clients on an individual basis. For more informa on about Even de’s fee schedules and account minimums for SMAs, please refer to Item 5 – Fees and CompensaƟon above.

Performance-Based Fees Even de charges performance-based fees to certain investors in the Private Funds based on the performance of investments in each por olio. Performance-based fees are charged only to investors that are “qualified clients,” as defined by Rule 205-3 under the Advisers Act. Even de does not charge performance-based fees to other clients, or to Private Fund investors that are not qualified clients. The Private Funds’ performance-based fees are designed to comply with Rule 205-3 under the Advisers Act and, for ERISA accounts, relevant Department of Labor advisory opinions regarding the circumstances in which an investment manager may receive performance-based compensa on. Performance-based fees could create conflicts of interest in which Even de and its personnel seek to favor a Private Fund over other investment products, or to have a Private Fund make riskier investments. Even de generally manages the Private Funds, which have performance-based fees, from the same business loca on(s) and substan ally the same systems and staffing used to manage and support other client accounts, including the Mutual Funds, ETFs, and SMAs, which do not charge performancebased fees. Depending on performance, Even de’s employees serving as members of a Private Fund’s general partner, as well as investment personnel, can generate significantly higher fees and personal financial compensa on from the performance of the Private Funds than from the Mutual Funds, ETFs, or SMAs that are not subject to performance-based fees. The prospect of earning higher compensa on therefore creates an incen ve for certain Even de employees to seek to favor the Private Funds in the investment, research, trading and/or sales processes, over other Even de clients. This affects the alignment of interests (including with respect to the alloca on of me and a en on of the investment management team) and creates a conflict of interest with respect to how investment decisions are made (including with respect to the alloca on of investment opportuni es). In addi on, performance-based fees can create an incen ve for Even de to make riskier or more specula ve investments for a Private Fund than it might otherwise make in the absence of a performance-based fee. For example, because performance-based fees are payable only a er a certain performance return is a ained, investment personnel can be more inclined to invest in a more specula ve manner accompanied by a higher degree of investment risk than in the absence of performance-based fees.

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Finally, the Private Funds’ investments are valued in accordance with Even de’s policies, procedures and controls. Fees payable by the Private Funds to Even de are based in part on the value of each Private Fund’s investments. Even de benefits from an increased value in each Private Fund’s investments. This presents a conflict of interest in Even de assigning a value to a Private Fund’s investments, that Even de a empts to mi gate through its policies, procedures and controls regarding private fund valua ons, and through appropriate disclosure.

Side-By-Side Management Even de’s side-by-side management of client accounts inves ng in various products and services gives rise to poten al conflicts of interest. For instance, Even de’s por olio managers and investment personnel must allocate their ideas, oversight, me, and research across mul ple account types, strategies, products and services. Even de maintains controls to help mi gate conflicts of interest resul ng from side-by-side management of client accounts. Even de manages its investment resources and personnel under the supervision of its Co-Chief Investment Officers (“Co-CIOs”), Chief Execu ve Officer and Chief Financial Officer, supported by various oversight commi ees a ended by senior management and other personnel. Even de monitors work assignments, expenses and resources required to deliver investment management services across all clients. As a result of shared investment personnel across Even de’s products and services, me devoted to investment research for some products and services might not benefit other products and services, and performance returns could be nega vely impacted by such arrangements. In some circumstances, the investment strategy and eligible investment universe of Even de’s products and services will overlap with one another, resul ng in a poten al conflict of interest from this side-by-side management arrangement when investment personnel must determine how to allocate investment opportuni es. This can create incen ves to favor specific products or services based on opportuni es to enhance performance track records and/or increase personal compensa on, among other things. Even de’s por olio managers act independently to manage their assigned responsibili es and can trade the same security at different mes during the same trading session. Even de will generally aggregate orders for execu on when circumstances permit. This can present opportuni es to execute transac ons in a more mely, efficient and equitable manner, allowing Even de’s traders to seek lower overall transac on costs. Client accounts included in aggregated transac ons will generally receive an average share price and share equally in transac on costs on a pro rata basis. When markets indicate that supply or demand is insufficient to fill an aggregated order, Even de generally allocates transac ons on a pro rata basis in propor on to a client account’s ini al order size. Depending on the circumstances, such as de minimis order sizes and avoiding delays when entering E V E N T I D E ___________________________________________________________________________________________________________________

orders, Even de may not aggregate transac ons in the same security for execu on together. This could diminish clients’ execu on quality, increase trading costs, and lower overall performance returns. In addi on, securi es selected for a par cular client account could outperform securi es selected for another investment product managed by Even de. Even de has implemented policies and procedures to help ensure fair and equitable alloca on of investment opportuni es across client accounts over me. Even de monitors for poten al conflicts of interest associated with side-by-side management of various types of client accounts by reviewing performance and holdings dispersion for accounts managed in similar strategies. Even de also monitors its controls and applica on of its alloca on policies. This oversight is confirmed with Even de’s Investment Risk Commi ee, including members of Even de’s Investment, Opera ons, Trading, Legal and Compliance Teams, which could take or require further ac on to assess and resolve any poten al unfair treatment of client accounts. Even de’s por olio managers are generally permi ed to invest in the Mutual Funds, the Private Funds, the ETFs and SMAs for their own personal investment. Even de might serve as an ini al investor in its ETFs and might invest its own capital. Even de might be the sole or majority investor in any new ETF un l the ETF garners significant assets from unaffiliated outside investors. Even de has also provided capital to manage proprietary SMA accounts on a discre onary basis in certain investment strategies. Even de maintains policies and procedures to mi gate poten al conflicts of interest and to help ensure that its client accounts are treated fairly. Even de por olio managers and members of its investment team manage por olios for mul ple strategies and different types of client accounts. While managing an investment strategy, Even de might acquire confiden al or material, non-public informa on that causes Even de to be restricted from ini a ng transac ons in a par cular security, on behalf of any of Even de’s client accounts. The fact that Even de is restricted from ac ng on such informa on may create a conflict with respect to how Even de makes decisions for a par cular client account (e.g., with respect to the alloca on of investment opportuni es or decisions to transact in a security). Below is a discussion of some specific risks and conflicts of interest in Even de’s side-by-side management of products and services. Mutual Funds. As stated above, Even de’s management of Mutual Funds might include securi es or transac ons excluded from other products or services pursuing the same strategy. For instance, the Mutual Funds can invest in private companies and other illiquid securi es if such is consistent with the Mutual Fund’s investment strategy and objec ves, and provided that the amount of the investment remains within the regulatory limit imposed by the 1940 Act (i.e., 15% of the Mutual Fund’s net assets). Even de’s Private Funds each can hold a substan al por on of their por olios in E V E N T I D E ___________________________________________________________________________________________________________________

illiquid investments such as private companies as well as publicly traded securi es that may be restricted (e.g., under provisions of the Securi es Act of 1933). The investment strategy of certain Mutual Funds par ally overlaps the investment strategy of Even de’s Private Funds. Investment opportuni es that meet certain criteria could be eligible for investment in both the Mutual Funds and a Private Fund. As restric ons imposed by the 1940 Act generally prohibit par cipa on by both clients in the same investment opportunity, Even de par cipates in the opportunity on behalf of either the Mutual Funds or a Private Fund. Even de’s policies and procedures allow for a poten al excep on to this process for follow-on offerings during the investment period of Fund II, with appropriate wri en approval prior to investment. Even de maintains policies and procedures to help ensure fairness, which considers many factors in making alloca on decisions, including as applicable, rota on and/or deal size methodology, as well as considera on of other objec ve factors such as investment ming, liquidity limits, and investment strategy limita ons. Even de maintains policies, procedures and controls to help ensure that no Fund is systema cally advantaged or disadvantaged as a result of its alloca on decision-making process. For the avoidance of doubt, Even de does not aggregate orders for the Mutual Funds, ETFs, and SMAs with orders for a Private Fund, effect joint transac ons with a Private Fund, or ini ate pro rata alloca ons in connec on with investments eligible for both the Mutual Funds, ETFs and SMAs and a Private Fund. From me-to- me, Even de may update its investment alloca on process, or make excep ons, to promote fair and equitable alloca ons to clients over me. Even de’s alloca on process described above will generally result in fewer overall investment opportuni es for each client in the interest of trea ng different types of clients fairly. This could compromise performance returns compared with circumstances in which no client account is required to forego an investment opportunity. As noted above, Even de performs oversight to help ensure that no client account is systema cally disadvantaged over me due to alloca on processes. The Mutual Funds can par cipate in IPO transac ons or secondary offerings in pursuing their investment strategy and objec ve. Certain other accounts under Even de’s management inves ng in the same or similar strategies (e.g., SMAs) generally prohibit par cipa on in such transac ons. These circumstances might cause dispersion between Mutual Fund accounts and other accounts pursuing the same strategy. Even de performs oversight to help ensure appropriate disclosures and that no client account is systema cally disadvantaged over me due to alloca on processes. The Mutual Funds can transact in deriva ves, make short sales, or transact in income-genera ng securi es typically reported on IRS Schedule K-1s. Other accounts pursuing the same strategy (e.g., SMAs) generally prohibit par cipa on in such transac ons. A por olio manager could effect or recommend a transac on for a Mutual Fund that adversely impacts the value of securi es held by another Even de client. For instance, a por olio manager of a Mutual Fund could effect a short sale

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Affiliations Even de’s Mutual Funds, Private Funds, ETFs, and SMAs can include investments in securi es in which certain private funds managed by Blackstone Group, LP and/or its affiliates (“Blackstone”) can also invest. Certain holdings within these private funds may include posi ons that were formerly managed by Dr. Kuruvilla through his prior employer, Clarus Ventures, LLC (“Clarus”), which Blackstone acquired. Dr. Kuruvilla is a former employee of Clarus, where he served in a research role from July 2008 through October 2016. A er his departure, Blackstone acquired Clarus. Dr. Kuruvilla currently serves as Even de’s Co-Chief Investment Officer. As of the date of this Firm Brochure, Dr. Kuruvilla serves as Senior Por olio Manager for three Even de Mutual Funds (Even de’s Gilead Fund, Healthcare & Life Sciences Fund, and Exponen al Technologies Fund), and as a Managing Director for the Private Funds. Dr. Kuruvilla also serves as a Senior Por olio Manager for two SMA strategies (Strategic Growth, and Technology). E V E N T I D E ___________________________________________________________________________________________________________________

As a result of personal investments Dr. Kuruvilla made while an employee of Clarus, through private funds later acquired by Blackstone, Dr. Kuruvilla expects to receive gains and/or distribu ons from Blackstone private funds that are independent of por olios managed by Even de. Dr. Kuruvilla does not receive compensa on from Blackstone based on any investments by Even de in the same securi es as Blackstone. As a result of investments made while at Wellington Management Company, Dr. I-hung Shih expects to receive gains or distribu ons from private funds managed by Wellington Management Company (“Wellington”), that are independent of the por olios she manages on behalf of Even de. Such private funds may invest in securi es that are also held by Even de, on behalf of the Even de Healthcare & Life Sciences Fund, the Even de Gilead Fund, Fund I or Fund II. Dr. Shih does not receive compensa on from Wellington based on any investment by an Even de por olio in the same securi es that are held by a Wellington por olio. From me-to- me, Even de’s por olio managers and/or research analysts engage in board service to support and oversee private companies in which clients invest. For example, one of Even de’s CoCIOs and a por olio manager and Managing Director on the Private Funds along with certain other members of Even de’s investment team responsible for evalua ng healthcare investments, may serve as Directors and/or Board Observers for private por olio companies held in a client account por olio. Even de investment personnel ac ng in such capacity owe fiduciary du es to the shareholders of such por olio companies and/or may be required to make decisions that they consider to be in the best interests of such por olio companies. Please see item 11 for more informa on about the associated conflicts of interest. Members of Even de’s investment team, including por olio managers, engage in public speaking events and discussions with financial intermediaries and others to advocate for values-based inves ng and Even de’s investment strategies. This ac vity generally raises conflicts of interest for members of the investment team because me spent promo ng advisory services is not focused on investment research and por olio management.

Registered Representatives As noted above, RRs are compensated for sales efforts that result in purchases of the Mutual Funds, Private Funds, and ETFs, with such compensa on paid through Foreside. Compensa on for sales of the Mutual Funds is paid through Foreside, with certain payments origina ng from NLD, the Mutual Funds’ 12b-1 Distribu on Plan, and/or Even de's legi mate profits. Compensa on associated with purchases of the Private Funds and ETFs is paid through Foreside from Even de’s legi mate profits. RRs also stand to receive compensa on from Even de in connec on with investments made in SMAs and subscrip ons to Even de Por olio Solu ons. Accordingly, the RRs can be more likely to engage in sales, consul ng, and educa onal discussions involving Even de’s investment products, and those E V E N T I D E ___________________________________________________________________________________________________________________

they view as providing increased opportuni es for personal, financial compensa on compared with other available products or services.

Client Transactions, and Personal Trading Even de has adopted a Code of Ethics (“Code”) to instruct employees, officers, and directors in their ethical and legal obliga ons related to handling confiden al informa on and to provide rules for personal securi es transac ons. Below is a summary of Even de’s Code. Even de will provide a copy of its Code to clients or prospec ve clients upon request. Even de’s employees, officers, and directors owe a fiduciary duty to Even de’s clients. Even de has implemented policies and procedures to help ensure that personal securi es transac ons by employees avoid actual or poten al conflicts of interest or the abuse of an individual’s posi on of trust and responsibility to clients of Even de. Generally, employees may not execute personal securi es transac ons within a specific number of days of a transac on in the same security by a Mutual Fund, a Private Fund, an ETF, or an SMA. Employees must obtain pre-clearance from Even de’s Compliance Team prior to their personal securi es transac ons in reportable securi es. Transac ons in ETFs that result from a pro-rata basket crea on or redemp on, however, would not be considered a “transac on” that triggers the specific number of days requirement under Even de’s Code. Personal securi es transac ons in a private placement or limited offering must be pre-approved by Even de’s Chief Compliance Officer (or delegate). In connec on with an employee’s proposed transac on in private securi es or limited offering, the Chief Compliance Officer (or delegate) generally coordinates with the Co-Chief Investment Officers to review whether the investment opportunity should be reserved for Even de’s advisory services and whether the opportunity might be offered to the employee due to the employee’s posi on with Even de. Even de imposes these restric ons to help avoid the possibility that an employee will profit from his or her posi on with Even de to the detriment of investors. Employees are prohibited from serving on the boards of publicly traded companies absent first receiving approval from one of Even de’s Co-Chief Investment Officers or a Managing Director with final approval needed from Even de’s CCO and General Counsel. If board service is authorized for a publicly traded company, employees serving as directors will be restricted from influencing other employees making investment decisions concerning the securi es of the company in ques on.

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In connec on with private investments held by the Mutual Funds, the Private Funds, or other client accounts, Even de permits certain employees to serve as a Director or Board Observer of private por olio companies to help guide and monitor the investments. The companies do not provide compensa on for this assistance. Serving in these board roles for a private por olio company gives rise to a conflict of interest given that an employee’s fiduciary du es or other obliga ons to the por olio company may conflict with the interests and du es owed to client accounts. An employee could learn confiden al informa on in connec on with their board service and this could restrict Even de’s ability to trade in a company’s securi es on behalf of client accounts. An individual’s receipt of confiden al board informa on, combined with differen al compensa on across investment products, presents poten al conflicts of interest because misusing confiden al board informa on may enhance performance returns and, ul mately, personal compensa on. Even de has established policies and procedures designed to manage and, to some extent, mi gate these actual and poten al conflicts of interest, including approval of board service, supervision, and monitoring of employees engaged in such ac vity, and training related to fiduciary obliga ons. In addi on, Even de has established controls to help restrict access to confiden al informa on acquired during board service. Even de employees must provide a securi es holdings report to Even de within ten days of employment and annually therea er. Employees are also required to provide quarterly transac on reports within thirty days of the end of each calendar quarter, reflec ng all personal accounts in which they have purchased or sold reportable securi es or reportable funds. Even de’s Compliance Team performs quarterly reviews of employees’ personal trading informa on to assess adherence to the Code. The Compliance Team iden fies all employees, informs them of their repor ng obliga ons, and maintains a record of current and former employees. Even de’s Chief Compliance Officer reports Code viola ons, including to the Board of the Mutual Funds and the ETFs, for oversight purposes. Even de may impose sanc ons such as reprimands, trading bans, penal es, and/or termina on of an employee’s rela onship with Even de and/or client accounts, among other things. Even de allows its employees to invest in securi es held by the Mutual Funds, Private Funds, ETFs, and SMAs subject to Even de’s Code. Even de’s Code is designed in part to help ensure that personal transac ons of employees do not disadvantage Even de’s clients. Certain personal transac ons effected by employees may result in posi ons that are inconsistent with posi ons implemented for Even de’s investment strategies.

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Participation or Interest in Client Transactions At mes, Even de’s personnel or other related persons could par cipate or have an interest in client transac ons which gives rise to certain conflicts of interest. Members of Even de could recommend to financial intermediaries, or buy or sell for client accounts, securi es in which Even de or its members have a material financial interest. A material financial interest may be present where, among other circumstances, Even de or a related person acts as a general partner in a partnership for which the investment adviser solicits a client or acts as the investment adviser for an investment company it recommends. In these cases, Even de or its related persons may have an incen ve to recommend or engage in transac ons on a client’s behalf that might conflict with its fiduciary du es to the client. To help mi gate these conflicts, Even de has adopted the Code and policies and procedures (e.g., conflicts of interest policy, trade alloca on policy, and other policies and procedures) which generally require that Even de and its related persons act in the best interests of clients and avoid poten al conflicts of interest where possible. Even de also discloses poten al conflicts of interest to clients.

Eventide Investment in Eventide Products From me to me, Even de provides seed capital in connec on with the launch of a new investment product or strategy. Even de has controls reasonably designed to ensure that all strategies, including those with seed capital investments, are managed in line with the objec ves and risk characteris cs disclosed to clients and investors, and that accounts with seed capital investments are not advantaged over client accounts that do not contain seed capital investments. Even de recognizes that Even de and its personnel might have the opportunity to benefit financially, either on behalf of Even de's accounts with seed capital investments, or as individuals, from Even de's access to informa on about trading ac vity regarding securi es in client accounts. Certain Even de personnel may also benefit personally, due to their ability to direct the investment or trading ac vity in Even de's client accounts. Opportuni es such as these create a risk that an individual uses confiden al client informa on for his or her own benefit, or for the benefit of an Even de account with seed capital investments, as opposed to the benefit of other Even de clients. Even de’s Code, in addi on to Even de’s policies and procedures, are designed to help Even de manage conflicts of interest associated with access to informa on about trading in client accounts. Even de Healthcare Innova on Fund I GP LLC serves as the general partner for Fund I, and Even de Healthcare Innova on Fund II GP LLC serves as the general partner for Fund II. Both are Delaware limited liability companies and affiliates of Even de. The general partner, and its affiliates are responsible to collec vely make a financial commitment to each Private Fund equal to the lesser of (i) 3% of the aggregate Commitments to the Fund, or (ii) $6 million. Even de believes this aligns the

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interests of Even de and its Private Fund investors. However, Even de’s financial contribu on to the Private Funds creates an incen ve for Even de or its personnel to favor Even de’s Private Funds over other Even de clients in which Even de does not have a financial interest. In some cases, Even de personnel may own a substan al amount of the interests in a Private Fund. These investments pose a risk that Even de, or an Even de supervised person able to control the alloca on of investment opportuni es to a Private Fund, will favor such Private Fund over another Even de client to obtain a personal benefit. Even de’s investment personnel generally receive some form of incen ve compensa on. That compensa on may be based on performance of an account against a benchmark return, applied to revenues received by Even de for the management of the client account. With respect to the Private Funds, such fee will also be based on receipt of a percentage of any performance-based fee paid to Even de for the management of that account. Even de believes that these incen ve compensa on arrangements play a valuable role in aligning the interests of our por olio managers and other investment team members with those of our clients. However, it creates an incen ve for Even de’s por olio managers and other investment team members to favor an account that has the poten al to provide higher incen ve compensa on for them as individuals. To help manage conflicts such as those created by these incen ve arrangements, Even de maintains policies and procedures regarding alloca on of investment opportuni es across client accounts, and conducts ongoing review of client accounts to help iden fy performance dispersion among clients with similar mandates but different fees and incen ve structures.

Conflicts of Interest Poten al conflicts of interest are inherent in investment advisory rela onships. Throughout this Firm Brochure, Even de describes certain poten al conflicts of interest, and how Even de a empts to mi gate, manage and disclose such conflicts. This sec on is designed to highlight specific actual or poten al conflicts of interest that may occur, but does not represent an exhaus ve list of all such conflicts. In some cases, certain conflicts are described elsewhere in this Firm Brochure, and not repeated in this sec on. Although some specific conflicts rela ng to the Private Funds are described in this Firm Brochure, addi onal detail can be found in each PPM. As described elsewhere in this Firm Brochure, Even de manages a range of values-based investment strategies and products that some mes share an investable universe of securi es. Certain investment products offer different compensa on incen ves to Even de’s investment personnel, and this could create a poten al conflict of interest for personnel who would stand to receive increased financial compensa on by favoring certain investment products over others. Likewise, certain Even de

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Even de generally maintains investment and brokerage discre on over the Mutual Funds, Private Funds, ETFs and SMAs. Even de selects a variety of brokers to execute por olio transac ons and considers a range of factors it deems relevant to execu on quality in the context of a par cular trade and its overall responsibili es. This includes accoun ng for a por olio manager’s order instruc ons addressing factors such as the speed of execu on or other considera ons. Even de’s primary objec ve in direc ng a trade to a broker is to seek best execu on under the circumstances, including considera ons of share price, quality of service, instruc ons to the broker, speed, anonymity, market

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impact, and commissions charged. Even de considers different factors in selec ng brokers and determining the reasonableness of their services and commissions. Research and execu on quality are prominent components of Even de’s assessments. Brokers that provide research generally charge higher commissions for transac ons. Consistent with its obliga on to seek best execu on, Even de weighs the benefits of investment-related research it receives in light of higher transac on costs for client accounts. Even de believes that using brokerage commissions paid by the Mutual Funds, Private Fund, ETFs and SMAs to obtain research and brokerage services through so-called “so dollar” prac ces serves to benefit clients. Brokers provide proprietary research to Even de via research reports, unsolicited emails, and phone calls to highlight available research. Proprietary research is generally stock-specific but might also focus on other topics such as market sectors, the macro-economic environment, and or values-based factors for investments. When Even de uses client brokerage commissions to obtain research, it receives a benefit because it does not need to produce or pay for that research. This creates an incen ve for Even de to select brokers and effect transac ons to obtain research rather than serving the interests of its clients in securing the most favorable execu on based on price or other factors. Even de's trading personnel, por olio managers, and Compliance Team review brokerage ac vity to help monitor Even de’s obliga ons regarding transac on execu on quality. Even de could cause client accounts to pay commissions higher than those charged by other brokers in return for so dollar benefits. In the last fiscal year, Even de received so dollar benefits such as bundled services from brokers, including proprietary research. Even de maintains formal so dollar arrangements with three brokers and could enter so dollar arrangements with other brokers in the future. Even de receives so dollar credits and uses those credits to pay third par es for research including market and economic data, values-based screening data, and access to subject ma er experts. Even de has also used so dollars to obtain tools and systems access used in evalua ng investment ideas, calibra ng investment-related models and expecta ons, and diagnosing por olios. If Even de’s use of so dollar credits also supports the firm’s typical overhead expenses, such as marke ng or compliance expenses rather than suppor ng the investment decision-making process, then Even de performs a mixed-use analysis to determine in good faith what por on of an expense should be paid directly by Even de via hard dollar payments. Mixed-use assessments create a poten al conflict of interest for Even de given its incen ve to a ribute only minimal overhead uses to services purchased with so dollars, thus reducing the firm’s expenses. Even de documents and monitors its mixed-use alloca ons. Even de generally uses research acquired with so dollars to service client accounts genera ng the trading ac vity, but this research also benefits Even de’s other advisory services. Even de does not maintain trading discre on for certain types of SMAs as described in Item 4 – Advisory Business, Types of Client Accounts, and, accordingly, they do not generate so dollars. So dollar benefits received

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by some clients might not be propor onal to the so dollar benefits they generate. For example, the Even de Gilead Fund may generate more so dollars than another client account, but it could benefit more or less than the other accounts in terms of research received. Similarly, research received through so dollars generally benefits all of Even de’s clients and not only the accounts genera ng so dollars. Even de does not seek to allocate so dollar benefits to par cular client accounts in propor on to the so dollars they may have generated. Even de receives proprietary research and third-party research, as noted above, through brokerage commissions paid by the Funds and other accounts over which it has investment and trading discre on. Even de does not a empt to link so commissions generated by a client’s trading ac vity to research services that are specifically used by the investment professionals making investment decisions for that client’s por olio. Rather, Even de uses the pool of so commissions generated by all eligible client trading ac vity to pay for research services consumed by any of its investment professionals. While Even de believes that all of its clients benefit from its robust investment discussion across asset classes and investment approaches, some clients contribute more directly to the cost of obtaining research services than other clients contribute. Even de’s investment team evaluates the overall value of a broker’s research and brokerage services. The investment team also sets commission targets for brokers based on their services and perceived value. Even de’s traders direct orders to brokers consistent with their execu on quality obliga ons as noted above. Commissions for so dollar trades are typically higher than those charged by brokers for execu on-only trades where research or other eligible services are not bundled together in the commissions charged. Even de’s investment team, trading personnel, and the Compliance Team review commissions paid to brokers to review for consistency with applicable targets and requirements. Even de maintains a desktop procedure outlining its process for redemp ons in kind associated with por olio management decisions within the Mutual Funds. Even de does not receive client referrals for selec ng or recommending brokers to execute transac ons for the Mutual Funds, Private Funds, or ETFs. Nevertheless, Even de could trade through brokers that recommend its products. Although Even de could accommodate a client's desire to trade through specific brokers in the future, no clients currently direct Even de’s brokerage transac ons. As noted above, however, certain SMA clients might select a custodian that imposes addi onal charges to the client, when por olio transac ons are executed away from the custodian. In developing an IMA with such clients, Even de and the client will together determine whether such client should be classified as Unrestricted or Restricted with respect to brokerage. Specifically, a client might elect that these charges are prohibi ve and request they be classified as Restricted Accounts. In such cases, Even de will disclose that, as with all Restricted Accounts, execu ng transac ons in this

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manner could impair the execu on quality of brokerage transac ons in the applicable client account. Such clients may pay materially disparate commissions, greater spreads, or other transac on costs, or receive less favorable net prices on transac ons than would otherwise be the case. Conversely, other clients might elect to provide Even de brokerage discre on, such that if Even de considers it is in the client’s best interest to execute a por olio transac on away from the custodian, it may choose to do so. For the avoidance of doubt, for these clients, Even de will typically execute through the client’s specified broker, and generally will not aggregate trade orders with the Mutual Funds, the ETFs or other SMAs with an overlapping eligible investment universe. However, as noted above, Even de may determine, in certain circumstances (e.g., where a broker offers natural liquidity or a large block), that aggrega ng a trade order with the Mutual Funds, the ETFs or other SMAs may be appropriate, even if addi onal execu on charges are incurred. If an Even de por olio manager enters trades in the same security for the benefit of more than one Mutual Fund, ETF and/or SMA on the same day, the por olio manager and/or trading personnel typically assess whether the circumstances support aggrega ng the trades for execu on with a broker so that each client account receives the same weighted average price. If trades are not aggregated, client accounts trading later in the day may experience diminished execu on quality and higher trading costs. If an aggregated order is par ally executed, each par cipa ng client account generally receives a pro rata alloca on, subject to adjustments for rounding or de minimis alloca ons, in accordance with Even de’s policies and procedures designed to promote fair and equitable treatment of clients. As noted above, Even de does not aggregate trade orders for the Private Funds together with other accounts. Instead, Even de applies a rota on and/or deal size methodology to help promote fair and equitable alloca on of investment opportuni es to clients over me. Subject to applicable law, including Sec on 206(3) of the Advisers Act, which requires a client’s prior wri en consent, and Rule 17a-7 under the 1940 Act, Even de could effect cross trades between client accounts, including with registered investment companies. This is generally permissible where Even de believes that such transac ons can benefit the client accounts, such as by reducing transac on costs consistent with their investment objec ves. Cross trades must be pre-approved by Even de’s Chief Compliance Officer. Delivery of SMA to Managed Account Programs and Non-DiscreƟonary Accounts As described above, Even de delivers its SMAs differently depending on the type of client account. For Managed Account Program clients, Even de delivers updated model por olios directly to the third-party sponsor for implementa on by the sponsor pursuant to the sponsor’s trading discre on. A er all por olios in a strategy are updated in Even de’s por olio management system, a por olio is uploaded to Even de’s analy cs system, and then Even de’s Trading team ini ates delivery to

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Read the rest in the brochure

Even de typically does not compensate others for referring clients to Even de. As noted above, RRs are compensated for sales efforts that result in purchases of the Mutual Funds, Private Funds, and ETFs, with such compensa on paid through Foreside. Compensa on for sales of the Mutual Funds is paid through Foreside, with certain payments origina ng from NLD, the Mutual Funds’ 12b-1 Distribu on Plan, and/or Even de's legi mate profits. Compensa on associated with purchases of the Private Funds and the ETFs are paid through Foreside from Even de’s legi mate profits. RRs also stand to receive compensa on from Even de based on assets and revenues generated in connec on

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with SMAs and subscrip ons to Even de Por olio Solu ons. A financial advisor previously employed with Even de also receives a por on of Even de’s revenue, along with employees of Even de, pursuant to specific terms. Even de also pays certain unaffiliated third par es in connec on with the sale and/or servicing of the Mutual Funds and ETFs, as applicable.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to evalua ng the adviser or the integrity of the adviser’s management. Even de has no informa on to report regarding this Item.

Even de's por olio managers review the investments of the Mutual Funds, Private Funds, ETFs, SMAs, Target Risk Alloca on Models, model strategies, and Mul -Manager Por olio Solu ons Program on an ongoing basis for adherence to applicable investment objec ves and requirements. Even de's Compliance Team monitors each Mutual Fund’s prospectus and statement of addi onal informa on requirements daily, supported by a compliance report that is also distributed to the investment team and traders, among others. The Compliance Team also reviews periodic Compliance Reports provided by the Mutual Funds' Administrator, as well as the Semi-Annual and Annual Reports provided to Mutual Fund shareholders. Even de provides quarterly oversight disclosures and annual compliance and other ques onnaires to the Board of the Mutual Funds. This helps the Board of the Mutual Funds evaluate Even de’s performance in fulfilling its fiduciary du es. The investment team reviews net asset values (NAVs) calculated by the Mutual Funds’ accoun ng team daily. Members of the investment team also review trades and commissions. Even de follows a similar process to monitor investment strategies and guidelines relevant to other types of client accounts when applicable. For each Private Fund, its Investment Commi ee approves transac ons and oversees the implementa on of the investment strategy. Private Fund investors receive quarterly statements of their investment as well as periodic capital call no ces describing the amount of investments being called and the use of proceeds. Even de seeks to provide quarterly updates to investors, and investors will receive audited financial statements annually no later than 120 days following each Private Fund’s fiscal year end. For the ETFs, Even de's Compliance Team monitors prospectus and statement of addi onal informa on requirements daily, supported by a compliance report that is also distributed to the investment team and traders, among others. The Compliance Team also reviews periodic Compliance Reports provided by the ETFs’ Administrator, as well as the Semi-Annual and Annual Reports provided to ETF shareholders. Even de provides quarterly oversight disclosures and annual compliance and other ques onnaires to the Board of the ETFs. This helps the Board of the ETFs evaluate Even de’s performance in fulfilling its fiduciary du es. The investment team reviews net asset values (NAVs) calculated by the ETFs’ accoun ng team daily, as well as market and trading informa on provided to ETF shareholders on the ETFs’ website. For SMA clients, Even de seeks to manage strategies in accordance with the Statement of Investment Objec ves and Restric ons as agreed with the client and contained in the client’s applicable IMA. Even de recognizes that par cular facts unique to par cular accounts, such as investment objec ves and cash availability, will affect investment decisions. To the maximum extent permissible, purchases, E V E N T I D E ___________________________________________________________________________________________________________________

sales and investment advice are based upon the judgment of the por olio manager supervising the par cular account. Even de does not have any obliga on to purchase or sell or to recommend for purchase or sale, any security which Even de, or its affiliates, or its or their shareholders, directors, officers or employees may purchase or sell for its or their own account(s) or for the account of another Even de client. Even de, its affiliates and employees may sell or recommend the sale of a par cular security for certain accounts (including accounts in which they have an interest) and may buy or recommend the purchase of such security for other accounts (including accounts in which they have an interest) and accordingly, transac ons in a par cular account may not be consistent with transac ons in other accounts or investment recommenda ons. Even de may give advice and take ac on with respect to any of its other clients or for its own account which may differ from the ming or nature of ac on taken by Even de with respect to other accounts. It is Even de’s policy, to the extent prac cable, to allocate investment opportuni es to the accounts on a fair and equitable basis rela ve to other discre onary managed accounts. Even de will seek to allocate or rotate investment opportuni es equitably, but comparable accounts may not have comparable results. As noted, to the extent an SMA client might restrict or limit brokerage ac vity to a certain broker or dealer will limit Even de's ability to seek best execu on in connec on with por olio transac ons, poten ally impairing an account’s overall performance. Financial intermediaries such as sponsors of wrap fee programs, consultants, or other intermediaries that offer or use Even de’s SMAs, Target Risk Alloca on Models and/or Mul -Manager Por olio Solu ons are generally responsible for administering trading, commissions management, fees, performance repor ng, proxy vo ng, repor ng, reasonable restric ons, and other func ons applicable to their clients.

Even de might, due to certain arrangements giving it or an affiliate control over or access to other client assets, be deemed to have custody of such assets for purposes of Advisers Act Rule 206(4)-2 (the “Custody Rule”). Even de, through its affiliated general partners of the Private Funds, is deemed to have custody of each Private Fund’s assets under the Custody Rule. Investors in the Private Funds will receive annually, within 120 days of the applicable Private Fund’s fiscal year end, audited financial statements prepared in accordance with generally accepted accoun ng principles. Investors in the Private Funds should contact Even de if they have ques ons about their financial statements or fail to receive them in a mely manner. Even de does not have custody over the assets of its Mutual Fund clients. To the extent that Even de is deemed to have custody of other discre onary client assets under the Custody Rule (e.g., for Unrestricted and Restricted Account SMAs), Even de will take steps to ensure that such client assets are maintained in accounts with a qualified custodian, as defined in the Custody Rule (each, a “Qualified Custodian”). Even de will ensure that such Qualified Custodian is designated to send account statements to either the client, the client’s investors or the client’s or investors’ independent representa ve(s), as applicable, no less frequently than quarterly. Even de also provides statements to these SMA clients quarterly. Even de’s statements for such clients are based on valua on policies and procedures implemented by Even de, and Even de’s records rela ng to the SMA, and may differ from account statements provided by an SMA client’s Qualified Custodian. Even de encourages Unrestricted and Restricted Account SMA clients to review their Qualified Custodian’s account statements carefully, compare them with any informa on sent by Even de, and to contact Even de in the event of any ques ons. Even de’s Unrestricted and Restricted Account SMA clients are generally responsible for selec ng and engaging custodians, and for ensuring that the assets in the SMA are maintained at a Qualified Custodian as defined in the Custody Rule. Such clients generally authorize Even de to bill the custodian directly with respect to any fees, costs and expenses incurred by an SMA as provided in their IMA. Title to assets within the account are generally held in the name of the SMA client (or the custodian or its nominee, for the benefit of the client) and segregated from all other custodial assets in the custodian’s possession. Even de may issue to the custodian such instruc ons as it deems necessary E V E N T I D E ___________________________________________________________________________________________________________________

or appropriate in connec on with the se lement of transac ons ini ated by Even de, or the execu on of proxy vo ng or consent decisions made by Even de including to: a.) pay cash for assets delivered to the custodian for an account; b.) deliver assets from an account against payment or receipt; c.) communicate to issuers or other relevant par es decisions made with respect to proxies, consents and similar ma ers; and d.) deliver assets and cash to such brokerage accounts as Even de may designate for collateral or margin purposes. Even de will generally make instruc ons in wri ng, or orally if confirmed in wri ng as soon as prac cable therea er. Even de will not have any authority to cause the custodian to deliver any SMA asset (including cash) to Even de, except pursuant to a duly rendered invoice as set forth in the IMA. With respect to any accounts in SMA strategies that Even de has provided seed capital, Even de has engaged a Qualified Custodian to safeguard the account’s assets and will ensure quarterly statements are received.

Even de maintains investment discre on over the Mutual Funds, Private Funds, ETFs, and SMAs in the Unrestricted and Restricted Account categories, pursuant to applicable IMA agreements. In addi on, certain Managed Account Program clients, under the terms of their respec ve programs, may delegate full, par al or shared investment discre on to Even de in connec on with managing client accounts. Even de also employs sub-advisory services, as noted above, to perform day-to-day investment management for all or a por on of certain Mutual Funds. Even de can also employ sub-advisory services within SMA strategies. Even de generally exercises investment discre on on behalf of client accounts; however, financial intermediaries may elect to receive SMAs from Even de on a nondiscre onary basis. In such cases, the program sponsors maintain full investment and trading discre on over transac ons in their client accounts, including determining whether to implement all, some, or none of the securi es recommended by Even de. Even de seeks to observe the investment policies, limita ons and restric ons applicable to client accounts. Even de seeks to manage the Mutual Funds as disclosed in each Mutual Fund’s prospectus and statement of addi onal informa on. Even de seeks to manage the Private Funds as described in each Private Fund’s PPM and limited partnership agreement. Even de seeks to manage the ETFs as disclosed in each ETF’s prospectus and statement of addi onal informa on. Even de seeks to manage SMAs in accordance with the Statement of Investment Objec ves and Restric ons in Even de’s applicable IMAs. As each of its SMA clients are unique and their investment needs will vary, Even de’s investment strategies may be modified as necessary to meet specific client investment objec ves. Even de’s SMA clients will execute an IMA iden fying the investment objec ves and restric ons. E V E N T I D E ___________________________________________________________________________________________________________________

Prior to the opening of the client account, Even de will review any requested investment restric ons and work with the client to refine them as necessary in order to meet the client’s needs, as well as provide Even de with adequate flexibility to manage the account. Such will be reflected in the Statement of Investment Objec ves and Restric ons.

Proxy Voting Even de votes, or makes arrangements to vote, proxies as agreed with its clients. Pursuant to Rule 206(4)-6 and Rule 204-2 under the Advisers Act, Even de maintains policies and procedures to help ensure that it votes proxies in the best interests of clients. For Mutual Funds and ETFs, Even de votes proxies and a summary of its proxy vo ng guidelines is included in the Mutual Funds’ and ETFs’ statement of addi onal informa on. Even de’s other clients may retain proxy vo ng responsibility or delegate such responsibility to Even de as agreed. To the extent clients elect to vote proxies themselves, clients will not receive informa on about their proxies from Even de. Instead, clients should obtain proxies from the custodian, transfer agent or another third-party service provider such as a proxy service. Even de addresses the vo ng of proxies with its SMA clients in the IMA. Generally, for Even de’s Unrestricted or Restricted Account SMAs, Even de will vote or cause the vo ng and execu on of proxies, waivers, consents and other instruments with respect to the assets in the Accounts. In connec on with any equity securi es held in these SMAs, Even de will generally vote proxies for such securi es in accordance with Even de's current policies regarding proxy vo ng as described in this Firm Brochure. Even de's obliga on to vote proxies for a par cular SMA client shall be con ngent upon (i) receipt of proxies from the SMA's applicable custodian or the client in a mely manner, and (ii) the lack of any legal and/or contractual encumbrance in the investment management to vo ng, including any securi es lending or similar program. Even de’s proxy vo ng guidelines incorporate values-based considera ons and inform Even de’s proxy vo ng concerning key corporate objec ves, shareholder interests, elec on of Board Directors, approval of independent auditors, and equity-based compensa on plans, among other topics. Even de’s proxy vo ng guidelines are set forth in Even de’s Proxy Vo ng Policy Summary, which is provided to Even de’s SMA clients. For the Mutual Funds and ETFs, these guidelines are set forth in each fund’s respec ve statement of addi onal informa on. Even de’s approach to proxy vo ng is described in each Private Fund’s PPM, and Even de’s Proxy Vo ng Policy Summary is available to Private Fund investors upon request.

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Even de generally votes proxies through a third-party vo ng service and oversees the vo ng ac vity to help ensure consistency with Even de’s proxy vo ng guidelines. Generally, proxy vo ng is not directed by the Board of the Mutual Funds or the ETFs, a commi ee of a Private Fund, or an SMA client. If Even de iden fies a proxy vote presen ng a material conflict of interest between Even de’s interests and the interests of its clients, Even de will take appropriate steps to help ensure proxies are voted in the best interest of the client. Specifically, for clients other than the Mutual Funds and the ETFs, if the recommenda on is consistent with Even de’s proxy vo ng guidelines, Even de will direct vo ng of the proxy in a manner consistent with those guidelines. If Even de’s recommenda on is not consistent with its proxy vo ng guidelines, Even de’s proxy vo ng commi ee will be convened to determine how to vote the proxy in the best interest of the client. If Even de iden fies a material conflict of interest for a proxy for the Mutual Funds or the ETFs, Even de will forward all proxy vo ng materials to the Mutual Funds’ or ETFs’ respec ve Board of Trustees, to enable them to make a vo ng decision. In exercising Even de’s fiduciary duty to review all proxies, Even de may make a determina on to abstain from vo ng if, in Even de’s por olio managers and/or Co-CIOs opinion, doing so would be in the best interest of its clients. For instance, Even de may, in its discre on, decline to vote proxies if Even de agrees in principle with a ma er in a shareholder proposal but does not believe that a vote for the item is in the best interest of Even de’s clients, or in the case of foreign issuers where costs, burdens or poten al detriments to clients outweigh the an cipated benefits of vo ng (e.g., transla on services, power of a orney requirements, share blocking/liquidity restric ons, etc.). Even de maintains records reflec ng proxies received, votes cast, and informa on material to its vo ng decisions. Clients can obtain a copy of Even de’s proxy vo ng guidelines or obtain informa on on how Even de voted proxies by submi ng a request in wri ng to: Even de Asset Management, LLC, One Interna onal Place, Suite 4210, Boston, MA 02110 or by calling 1-877-771-3836, or by visi ng Even de’s website at www.even deinvestments.com. Class Actions To the extent that Even de has been authorized by a client to do so, Even de will par cipate in class ac on recoveries on behalf of the applicable Even de client. Even de u lizes an independent thirdparty service provider to assist with iden fying poten al class ac on recoveries for securi es held by Even de’s clients. This third party is compensated based on a percentage of the proceeds recovered from a class ac on filing. A er compensa on of the third party, the net amount of the class ac on proceeds is credited to clients who held the securi es during the relevant se lement class period. While exercising Even de’s fiduciary duty, Even de may make a determina on to not par cipate in a class ac on if, in Even de’s por olio managers and co-CIOs’ opinion, doing so would be in the best interest of its clients. For instance, in the case of foreign issuers where costs, burdens or poten al detriments to clients outweigh the an cipated benefits of par cipa on in a class ac on (e.g., loss of

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por olio liquidity, costs of transla on services, jurisdic ons requiring public disclosure of all plain ffs, onerous documenta on requirements, or other burdens that Even de may not view as commensurate with the poten al benefits for shareholders). Even de provides addi onal details regarding class ac ons with respect to its clients, in its IMAs.

Registered investment advisers are required to provide certain financial informa on or disclosures about their financial condi on. Even de has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and Even de has not been the subject of a bankruptcy proceeding. Even de does not require or solicit payment of fees in advance of services rendered.

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