Global X Management CO LLC

Global X is a Delaware limited liability company with its principal offices located at 605 Third Avenue, 24th and 43rd floors, New York, New York 10158, 1 Gateway Center, Newark, NJ 07102 and 201 South Biscayne Blvd, St 2850 Miami, FL 33131. Global X started operations in 2008. The Adviser is registered as an investment adviser under the Advisers Act. The Adviser serves as the investment adviser of the Global X Funds (the “Trust”) and each series of the Trust (the “Global X U.S. ETFs”), the Global X Venture and Innovation Fund and investment manager for the Global X ETFs ICAV, a UCITS fund range with segregated liability between each UCITS fund, registered in Ireland and authorized by the Central Bank of Ireland (each a “Global X UCITS ETF” and collectively with the Global X U.S. ETFs, the “Global X ETFs”). Global X Digital Assets, LLC (“GXDA”) is a Delaware limited liability company with its principal offices located at 605 Third Avenue, 43rd Floor, New York, NY 10158. GXDA’s focus is on the development, operation and management of digital asset exchange traded products offered in Europe. GXDA is an affiliate of Global X Management Company LLC and has no dealings with its principal business. However, the two entities share some internal resources such as portfolio management, operations, legal, and compliance. GXDA acts as arranger to a crypto exchange traded product program (the “Program”) for the issue of undated, limited recourse, non-interest bearing exchange traded debt securities issued by Global X Digital Assets Issuer Limited (the “Issuer”). The Issuer is incorporated and registered in Jersey under the Companies (Jersey) Law 1991 (as amended), with registered number 139150 and GXDA provides certain administrative and operational services in respect of the Program. GXDA is paid a fee by the Issuer in respect of such services. As of December 31, 2025, Global X had approximately $77,099M assets under management, nearly all of which on a discretionary basis. Adviser to the Trust Global X serves as the investment adviser and the administrator for the Trust. The Trust is a registered open-end management investment company registered under the Investment Company Act of 1940 as amended (the “1940 Act”) that currently consists of one hundred fifteen exchange-traded funds, one hundred three of which are operational. The shares of each currently operational Global X U.S. ETF are listed on a U.S. national securities exchange such as the Cboe BZX, NYSE Arca, Inc. or the NASDAQ. Certain of the Global X U.S. ETFs could be registered in non-U.S. jurisdictions or cross-listed on non-U.S. exchanges. Subject to the supervision of the Trust’s Board of Trustees, Global X is responsible for managing the investment activities of each Global X U.S. ETF and its business affairs and other administrative matters. The Adviser has created both passively managed ETFs that attempt to track either proprietary or non-proprietary indexes (each, an “Underlying Index”) and actively managed ETFs designed to provide exposure to U.S. and global options, fixed income, commodity, digital assets and equity markets. The Trust includes, but is not limited to, ETFs pursuing the following general investment strategies:

Thematic. Solutions focusing primarily on emerging and disruptive technologies. Income. Aiming to deliver alternative, higher-yielding income solutions. Core. Portfolio building blocks that aim to deliver exposure to specific values or factors. International Access. Solutions designed for investors seeking to chart a different course. Commodities. Exposure to metals and mining companies. Global X also works with sub-advisers to facilitate portfolio management of certain Funds.

Global X UCITS ETFs The Adviser acts as the investment adviser and the global distributor for the Global X ETFs ICAV, a series of UCITS Irish domiciled funds, regulated by the Central Bank of Ireland pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 as amended by European Union (Undertakings for Collective Investment in Transferable Securities) (Amendment) Regulations 2016 as may be amended or replaced. Information about the Global X UCITS ETFs, including a description of the management fees and investor eligibility, is generally contained in each fund’s prospectus, key investor information document and supplements, which can be found on the Global X UCITS ETFs’ website as applicable. Sub-advisory Services As compensation for the sub‐advisory services provided to the Funds, the Adviser may pay to the applicable sub‐adviser a sub‐advisory fee based upon a percentage of that Fund’s daily net assets. The level of the sub‐advisory fee paid with respect to a Fund is negotiated between the Adviser and the applicable sub‐adviser and will vary, depending on, among other things, the types of assets in which the Fund invests. Sub‐advisory fees are generally accrued daily and are billed and paid in arrears. In some cases, the Sub-Adviser may be an affiliate of the Adviser. Conversely, the Adviser serve as sub-advisers to other investment vehicles. In these arrangements, the level of the sub‐advisory fee paid to the Adviser is negotiated between the Adviser and the counterparty and will vary, depending on, among other things, the types of assets in which the Fund invests. In some cases, the Adviser may act as a sub-adviser of an affiliate of the Adviser. Interval Funds The Adviser may serve as investment advisor or issue Interval Funds (“Interval Funds”) and may utilize a subadvisor, affiliated or otherwise, for the management of Interval Funds. The Interval Funds have a separate Board from the Trust. Model Portfolio Services Global X also creates, manages, and provides non-discretionary model portfolios, comprised of recommended allocations of individual exchange traded funds (“ETFs”), either regulated pursuant to the 1940 Act including, but not limited to, Global X ETFs (each, a “Model Portfolio,” and collectively, “Model Portfolios”). Each Model Portfolio is designed to pursue a particular investment strategy and to have a specified risk tolerance level. Each Model Portfolio is intended to achieve such strategy through investment in ETFs, in accordance with the target allocations established for the Model

Portfolio. Global X will not be limited to using Global X ETFs in the Model Portfolios; however, a Model Portfolio may have up to a 100% allocation in Global X ETFs. The Model Portfolios are provided to or otherwise made available to investment advisers, brokerdealers and other financial intermediaries or platform providers (“Third-Party Providers”) for such Third-Party Providers to use at their discretion, or at the discretion of their clients, in the provision of investment advisory services to their own clients. Such Third-Party Providers may utilize software platforms to aid in their provision of investment advisory services and may choose to make the Model Portfolios available to clients as options on such platforms. Third-Party Providers and their respective clients have sole investment discretion with respect to the selection of underlying investment options for such investors’ accounts, including the recommendation, selection, and management of an investment strategy based on a Model Portfolio. Global X does not have investment discretion or trading responsibilities with respect to such arrangements and does not have an advisory relationship with Third-Party Providers’ clients or manage the implementation of Model Portfolios on the basis of the investment objectives of individual clients that participate in these programs. Third-Party Providers may use numerous strategies, including strategies of other investment advisers. The implementation of any such investment strategy, including one based on a Model Portfolio, will be conducted by the applicable Third-Party Provider or its respective clients. Third-Party Providers are responsible for using their own judgments with respect to the implementation of a Model Portfolio for an underlying client and, as such, may deviate from the allocations recommended for a Model Portfolio at their discretion. Global X may make updates to the recommended allocations to ETFs that comprise the Model Portfolios from time to time. In the event of an update to the Model Portfolios, Global X will make such update available to the Third-Party Providers, who in their sole discretion may determine whether to implement such updates on behalf of their clients. Global X may receive compensation from ThirdParty Providers for use of the Model Portfolios and will be indirectly compensated by investments in the Global X ETFs based on the Model Portfolios. For a further discussion, see Item 5 of this brochure.

Global X’s fees will vary depending on various factors, including the type of service offered and the strategy utilized. The fees and compensation associated with the investment advisory services Global X offers are detailed below. Adviser to U.S. ETFs Global X provides or causes to be furnished, all supervisory, administrative and other services reasonably necessary for the operation of the Funds which are part of the Global X ETFs issued by the Trust (“Global X U.S. ETFs”). Global X also bears the costs of various third-party services required by the Global X U.S. ETFs, including audit, certain custodial, portfolio accounting, legal, transfer agency and printing costs. The Supervision and Administration Agreement also requires Global X to provide investment advisory services to the Global X U.S. ETFs pursuant to an Investment Advisory Agreement. Both the Supervision and Administration Agreement and the Investment Advisory Agreement are subject to annual review and approval by the non-interested members of the Trust’s Board of Trustees. Each Global X U.S. ETF pays Global X a fee (“Management Fee”) in return for providing investment advisory, supervisory and administrative services under a unitary fee structure. The fee is based on the daily net asset value of each Global X U.S. ETF and is deducted from the Global X U.S. ETF’s assets in arrears on a monthly basis. The fee is negotiated with, and subject to approval by, the Board of Trustees of the Global X U.S. ETFs. Each Global X U.S. ETF's prospectus sets forth the applicable Management Fee, which generally ranges from 0.02% to 0.90%. Global X may earn a profit on the Management Fee paid by the Global X U.S. ETFs.

Each Global X U.S. ETF also bears other fees and expenses that are not covered by the Supervision and Administration Agreement, which may vary and will affect the total expense ratio of the Global X U.S. ETF, such as taxes, brokerage fees, acquired fund fees, commissions and other transaction expenses, interest and extraordinary expenses (such as litigation and indemnification expenses). Certain of the Global X U.S. ETFs also bear asset-based custodial fees not covered by the Supervision and Administration Agreement. Global X, and not Global X U.S. ETF shareholders, would benefit from any price decreases in third-party services, including decreases resulting from an increase in net assets, to the extent such third-party services are included in the all-in fee structure. The discussion of fees, costs and expenses provided above is a summary only. Please refer to the prospectus of the relevant Global X U.S. ETF for a more detailed discussion of the applicable fees, expenses and costs relating to an investment in the Global X U.S. ETF(s). Adviser to Global X UCITS ETFs The Adviser serves as Investment Manager and Global Distributor to the Global X UCITS ETFs and further sub-delegates the majority of these tasks to a group affiliate Global X Management Company (UK) Limited. The Management Fee (also described as the TER) is based on the daily net asset value of each Global X UCITS ETF and is deducted from the Global X UCITS ETF’s assets in arrears on a monthly daily basis. Each Global X UCITS ETF's prospectus documentation sets forth the applicable Investment Management Fee, which generally ranges from 0.07% to 0.68%. The excess of the Management Fee remaining after applicable fees and charges (denoted in the Prospectus) is paid by the Global X UCITS ETFs to the Management Company (Global X Management Company (Europe) Limited) which is also an affiliate of the adviser. The Management Company will then pay a transfer price to the respective affiliate for the services rendered. Global X may earn a profit on the Investment Management Fee paid by the Global X UCITS ETFs. Due to the services being sub-delegated by the Adviser to its UK based affiliate, Global X Management Company (UK) Limited, the UK based affiliate may earn a profit on the transfer price paid by the Management Company. The discussion of fees, costs and expenses provided above is a summary only. Please refer to the prospectus documentation of the relevant Global X UCITS ETF for a more detailed discussion of the applicable fees, expenses and costs relating to an investment in the Global X UCITS ETF(s). Model Portfolio Services Global X may receive a fee from Third-Party Providers to whom it provides Model Portfolios. The terms of Global X’s agreements with such Third-Party Providers may vary between Third-Party Providers and will be specified in the applicable agreement. Fees will be calculated and billed in accordance with the applicable agreement and may be in the form of a flat or asset-based fee. A Third-Party Provider may pay a flat fee to Global X for the use of the Model Portfolios in providing investment advice to its underlying clients. In other cases, Global X may charge an asset-based fee to Third-Party Providers based on the aggregate value of the underlying investor assets invested by the Third-Party Provider based on a Model Portfolio. Global X is not compensated directly by any investor the assets of which are invested based on a Model Portfolio; however, a Third-Party Provider, in its sole discretion or in connection with the applicable written agreement between Global X and the Third-Party Provider, may in some instances pass all or a portion of its costs, including fees due to Global X, on to the underlying investor. ThirdParty Providers may charge clients a fee for their services separate and distinct from any fees paid to Global X by the Third-Party Provider. Global X may from time to time, in its sole discretion, reduce or waive its fees for certain Third-Party Providers, which may result in a disparity in fees charged.

In addition, ETFs, including those ETFs in the Model Portfolios, pay certain fees and expenses including investment advisory, administrative, distribution, transfer agent, custodial, legal, audit, and other customary fees and expenses. Because certain of these expenses are ultimately borne by a Global X ETF’s shareholders, Global X will indirectly earn fees from Third-Party Providers’ clients that are invested in Global X ETFs based on the Model Portfolios. For a discussion of the conflicts inherent in this arrangement, see Item 8 of this brochure. Interval Funds The Adviser may serve as investment advisor or issue Interval Funds and may utilize a subadvisor, affiliated or otherwise, for the management of Interval Funds. The investment advisory fees received as investment adviser to the fund are described in the registration statement and financial filing for that fund.

Other Global X serves as portfolio manager of Fondo Bursatil Global X Colombia Select de S&P and Fondo Bursatil Global X Tes Colombia Local GBI EM ID ETF, ETFs domiciled and listed in Colombia, and receive the higher of a flat fee per annum or fee based on the net assets of the fund for such services. A separate unaffiliated entity serves as sponsor and administrator for these ETFs.

Adviser to ETFs Global X currently manages, or engages subadvisers to manage, ETFs that fit into 5 broad categories: Core, Income, Thematic, Commodities, and International Access.

For the majority of the Global X ETFs, Global X uses a “passive” or indexing approach for the ETFs that they manage to try to achieve the Global X ETFs’ investment objectives. Unlike many investment companies, these passive Global X ETFs do not try to “beat” the Underlying Index and do not seek temporary defensive positions when markets decline or appear overvalued. Each of these operational Global X ETFs uses a replication or representative sampling indexing strategy. Methods of security analysis employed in the sampling process may include charting, fundamental analysis, technical analysis, and credit analysis. For certain Global X ETFs, the Adviser or Sub-Adviser, who is generally an affiliate of the Adviser. employ an active management strategy. These ETFs do not seek to replicate the performance of an index, rather they strive to meet their investment objectives by employing research or proprietary models. Investment Strategies of the ETFs Equity Strategies The Adviser has created both index-based (based on either proprietary or non-proprietary indexes) and actively managed equity ETFs designed to provide exposure to U.S. and global equity markets, including strategies that incorporate environmental, social and governance (ESG) standards. Fixed Income Strategies The Adviser has created both index-based (based on either proprietary or non-proprietary indexes) and actively managed fixed income ETFs designed to provide exposure to U.S. and global fixed income markets. The Adviser works with affiliated third-party sub-advisers to facilitate portfolio management of such ETFs. Covered Call Strategies A covered call ETF uses a strategy called covered call writing to generate income for its investors. Covered call writing is a strategy in which an investor sells call options on a security they own in exchange for a premium. The premium received from selling the call option provides additional income for the investor. Covered call ETFs typically invest in a portfolio of stocks and then use the covered call writing strategy on a portion of their portfolio. By using this strategy, the ETF can generate additional income for investors while still providing exposure to the underlying stocks in the portfolio. Other Strategies The Adviser has created actively managed ETFs which provide exposure to other security types, such as bitcoin futures. Specific Investments The Adviser may invest in a wide range of investments in implementing the above strategies. These investments may include, but are not limited to: equity securities, fixed income securities, cash and cash equivalents, money market securities and money market funds, affiliated funds, cryptocurrency futures and derivatives in general. Global X ETF Risks

As described in Item 4, “Advisory Business,” Global X currently manages ETFs that fit into 5 broad categories: Core, Income, Thematic, Commodities and International Access. All investments, including investments in the Global X ETFs, involve risk including risk of loss. The risks for each Global X ETF are described in detail in the relevant prospectus and Statement of Additional Information available at www.GlobalXETFs.com and www.GlobalXETFs.eu, which prospectus is delivered concurrently with the purchase of Global X ETF shares by a broker, investment professional, or other investor. Investing involves risk, including the possible loss of principal. Equity strategy risks can include possible loss of principal, including foreign investing risks, such as risk of loss from currency fluctuation or political or economic uncertainty. Investments in one region increase the impact of events and developments associated with the region, which can adversely affect performance. Investment in securities of some countries involves heightened risks, including expropriation and/or nationalization of assets, confiscatory taxation, political instability including authoritarian and/or military involvement in governmental decision-making, armed conflict, the impact on the economy as a result of civil war, and social instability as a result of religious, ethnic and/or socioeconomic unrest and, in certain countries, genocidal warfare. Some Funds may gain exposure to different asset classes by investing in different types of derivative instruments. Derivatives can be more sensitive to changes in interest rates or to sudden fluctuations in market prices than conventional securities, which can result in greater losses for the Fund. In addition, the prices of the derivative instruments and the prices of underlying securities, interest rates or currencies they are designed to reflect may not move together as expected. The price and performance of cryptocurrency futures should be expected to differ from the current “spot” price of cryptocurrency. These differences could be significant. Cryptocurrency futures are subject to margin requirements, collateral requirements and other limits that may prevent the ETF from achieving its objective. Margin requirements for futures and costs associated with rolling (buying and selling) futures may have a negative impact on the fund’s performance and its ability to achieve its investment objective. Investing in certain sectors increases a Fund’s vulnerability to any single economic or regulatory development, which may result in greater price volatility. Investments in emerging, offshore or frontier markets are generally less liquid and less efficient than investments in developed markets and are subject to additional risks, such as risks of adverse governmental regulation and intervention or political developments. Investments in small and mid-cap companies tend to be more volatile than those in large-cap companies because small and mid-cap companies tend to be more susceptible to adverse business or economic events than larger, more established companies. Funds that have a high concentration in some issuers can be adversely impacted by changes affecting those issuers. Narrowly focused investments may be subject to higher volatility. A Fund may be classified as a “non-diversified” investment company under the 1940 Act. As a result, the Fund is subject to the risk that it will be more volatile than a diversified fund because the Fund may invest its assets in a smaller number of issuers or may invest a larger proportion of its assets in a single issuer. As a result, the gains and losses on a single investment may have a greater impact on the Fund’s NAV and may make the Fund more volatile than more diversified funds. Index Funds invest in the securities included in, or representative of, its index regardless of their investment merit, and the Index Funds do not attempt to outperform their respective indexes or take defensive positions in declining markets. Model Portfolio Services Model Portfolio Strategies Global X provides Model Portfolios across the risk-reward spectrum, representing distinct investment strategies. Specifically, the Model Portfolios are currently comprised of the following: (i) a suite of risk profile based multi-asset portfolios (the Core Series) and (ii) a suite of single asset portfolios, including Thematic Disruptors, Digital Innovation and Equity Income. Although Global X intends to provide Model Portfolios representing the strategies outlined above in the immediate term, the strategies of

the Model Portfolios may change over time, additional Model Portfolios may be offered in the future, and Global X may cease to provide any Model Portfolio in the future. Global X looks at three main factors when considering ETFs for inclusion in our Model Portfolios: benchmark adherence, liquidity / ease of trading and the total cost of ownership. When thinking about benchmark adherence, Global X reviews the extent to which an ETF provides the desired exposure (thematic, sectoral, regional, duration, variable /fixed rate or credit segment), as well as the tracking error of the ETF to its underlying benchmark. Within liquidity / ease of trading it looks at the size of the ETFs, bid-ask spreads (%) and the average dollar volumes traded. While the predominant focus is on the 30 day spread and volumes, there is also review of the trends in these variables to get a better understanding of improvements in the ETF’s tradability as well as how it has tended to trade during spikes in market activity. The total cost of ownership takes into consideration the fund expense ratio, the bid-ask spread (%) as well as the ETF’s tracking error to its underlying benchmark. Additional factors that are considered when constructing the model portfolios include portfolio diversification, portfolio risk and return metrics as well as portfolio implementation limits. Global X does not use mutual funds nor does it select securities other than ETFs for inclusion in the Model Portfolios. The majority of the ETFs used within the model portfolios are passively managed; however, actively managed ETFs are available for portfolio inclusion and may be used where appropriate. Each Model Portfolio may include a substantial allocation to Global X ETFs, potentially up to 100% of the Model Portfolio. Each Model Portfolio will be periodically assessed by Global X for investment strategy drift. In connection with such assessments, Global X expects to suggest modified asset allocations in order that the Model Portfolio will continue to reflect the desired investment strategy. Model Portfolio and ETF Risks Although certain risks may be mitigated via the asset allocation process or by the diversified nature of the Model Portfolios, there are risks inherent in all investments, including ETFs and Model Portfolios, such as the loss of principal. Asset allocation does not guarantee profit and diversification and may not protect against loss. Fluctuations in the financial markets and other currency, economic, political, and business factors may cause declines in the value of the Model Portfolios or their underlying ETFs. The prior investment performance of underlying ETFs in the Model Portfolios does not guarantee future performance, and there is no guarantee that any particular asset allocation, strategy, or combination of ETFs will provide a given level of income or meet the stated investment objective. In a declining market environment, investment in a broad portfolio of ETFs may not protect against price volatility and diversification may not protect against loss. Investments made based on a Global X Model Portfolio will also be subject to the risks inherent in the underlying ETFs that comprise the Model Portfolio. ETF shares are listed on a national securities exchange and generally track a particular benchmark or index. ETFs may trade for less than their net asset value, and performance can deviate from the associated benchmark or index due to, among other factors, fees, expenses, management, and market volatility. ETFs are subject to investment advisory and other expenses which may result in a layering of fees for clients. Each ETF may pay investment advisory, administrative, distribution, transfer agent, custodial, legal, audit, and other customary fees and expenses, as set forth in the ETF prospectus. ETFs have exposures to various asset categories, including, among others, equities, fixed income, currencies, and international markets. The underlying securities of ETFs will therefore have different risks, and the risks of owning an ETF will generally reflect the risks of owning the underlying securities the ETF is designed to track, although lack of liquidity in an ETF may result in share price volatility. As a shareholder of an ETF, a Portfolio would bear its pro rata portion of the ETF’s expenses, including advisory fees, in addition to the fees and other expenses a Portfolio bears directly in connection with its own operations. Although certain risks associated with investing in an ETF and the underlying

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Global X provides portfolio management services to SEC registered open-end management investment companies, Interval Funds and UCITS funds. In connection with the marketing of Global X ETF shares, certain Global X employees review the portfolios of institutional investors and discuss how a Global X ETF could be added to the portfolio to optimize the institutional investors’ holdings. No fees are charged in connection with the portfolio reviews and Global X and the institutional investors have not entered into any investment advisory contract. Global X also provides Model Portfolios to Third-Party Providers who may utilize them to provide investment advisory services to their clients or make them available to other financial intermediaries for such use. Global X provides portfolio management or sub-advisory services to non-US registered funds, including, but not limited to, Fondo Bursatil Global X Colombia Select de S&P, Fondo Bursatil Global X Tes Colombia Local GBI EM ID ETF and the Global X UCITS ETFs.

Global X does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client).

On February 12, 2018, the Adviser entered into an agreement and plan of merger pursuant to which an indirect subsidiary of Mirae Asset Global Investments Co., Ltd. (“Mirae”) would be merged with and into the Adviser after which, the Adviser became a wholly-owned subsidiary of Mirae. As a result of the merger with Mirae, Global X is affiliated with a number of financial institutions, both domestically and internationally. Notably, the Adviser is an affiliate of Mirae Asset Global Investments (USA) LLC, a registered investment adviser under the Advises Act who also serves as a sub-adviser to select Global X U.S. ETFs as well as Mirae Asset Global Investments (Hong Kong) Ltd. and Mirae Asset Securities Co., Ltd. In the first quarter of 2020, Tokyo-based Daiwa Securities Group Inc. (“Daiwa”) purchased a $120 million convertible bond from Global X Management Company, Inc., the Adviser’s parent company, which Daiwa, elected to exchange into a minority equity stake in the Adviser effective February 21, 2025. The Adviser is under common control of Global X Investments Pte. Ltd. [Singapore], Global X Management Company (Europe) Limited [Ireland], Global X Management Company (UK) Limited [United Kingdom], Global X Digital Assets LLC, Global X Japan Co Ltd [Japan] and Global X (AUS) Pty Ltd. [Australia]. The Adviser is also an affiliate of Global X Investments Canada Inc. The Adviser has entered into a joint venture agreement with Tokyo-based Daiwa Securities Group Inc. and Daiwa Asset Management Co. Ltd. to expand access to ETFs for Japanese investors resulting in an entity named Global X Japan Co., Ltd., ("Joint Venture"). The Joint Venture is headquartered in Tokyo, Japan, and leverages Global X and Daiwa's involvement in offering USlisted ETFs suitable for the local investors, along with domestically-listed products. A full team of investment professionals are employed by the Joint Venture. The Adviser is registered as a commodity pool operator with the National Futures Association (NFA) and the Commodity Futures Trading Commission (CFTC). The Adviser also serves as Portfolio Manager and is part of the Investment Committee for the Fondo Bursatil Global X Colombia Select de S&P ETF and Fondo Bursatil Global X Tes Colombia Local GBI EM ID ETF registered in Colombia. The Adviser serves as an adviser to Foreign Funds, including Global X UCITS ETFs. The Adviser serves as an adviser to Interval Funds. The Adviser also engages affiliates as sub-advisers to certain of the Funds. As compensation for the sub‐advisory services provided to the Funds, the Adviser pays to the applicable sub‐adviser a sub‐ advisory fee based upon a percentage of that Fund’s daily net assets. The level of the sub‐advisory fee paid with respect to a Fund is negotiated between the Adviser and the applicable sub‐adviser,

affiliated or otherwise, and will vary, depending on, among other things, the types of assets in which the Fund invests. The Adviser, subject to best execution, may place trades with its affiliated broker-dealers, Mirae Asset Securities (USA), Inc., Mirae Asset Wealth Management (USA) Inc., Mirae Asset Securities (HK) Ltd., Mirae Asset Securities (UK) Ltd., Mirae Asset Securities Vietnam, Mirae Asset Securities Co., Ltd. or others. The Adviser, or one of its Affiliates, acts as an index provider for indexes which are tracked by Funds managed by the Adviser. As a result, the Adviser has instituted policies and procedures which are in effect to mitigate any perceived conflict of interest. At its expense, Global X pays Foreside Fund Services, LLC (“Foreside”), an unaffiliated FINRA registered broker-dealer, a fee for sponsoring the registered representative licenses of certain employees of Global X to facilitate the marketing of the Funds. There are no sales charges or amounts payable by a Fund or its shareholders in connection with the offering of Fund shares as a result of such arrangement. Senior Management of Global X believe that the relationship and arrangements between Global X and Foreside do not create a material conflict of interest for Global X in its role as investment adviser and administrator for the Trust.

Global X has adopted a code of ethics (the "Code of Ethics") that establishes the standard of business conduct that all of its employees must follow. The Code of Ethics also addresses personal trading and investments by its employees who are deemed access persons. Employees are required to acknowledge in writing that they have received the Code of Ethics and each subsequent amendment thereto, that they comprehend the Code of Ethics, and that they have complied (as applicable) and will comply with the Code of Ethics. The Code of Ethics sets forth specific policies and procedures for its employees to follow regarding material, non-public information ("inside information") and other confidential information of clients and Global X. While Global X does not expect its employees to be in receipt of inside information, it requires any employee receiving inside information to refrain from trading on the information and to discuss the information only with the Chief Compliance Officer to determine an appropriate course of action. The Code of Ethics also details policies and procedures regarding personal securities transactions by employees. Employees who are access persons are required to provide initial, quarterly and annual securities transaction reports, which are reviewed by the Chief Compliance Officer or his designee. Access persons are required to pre-clear investments in limited offerings and securities that are included as a component of an Underlying Index or for which public notice has been given that such security will be added to, or deleted from, an Underlying Index. Access persons are not permitted to participate in investments in initial public offerings. A copy of Global X's Code of Ethics is available to clients and prospective clients upon request. Additionally, the Code of Ethics of all Sub-Advisers to the Funds may be obtained directly from that Sub-Adviser. The Code of Ethics allows Global X and its affiliates, as well as the personnel subject to it, to trade and invest for their own accounts in securities, including securities that may be held or purchased by a Global X ETF. Where any such conflict exists, portfolio managers will not make any such investment for a Fund without ensuring compliance with any relevant procedures set forth in the Code of Ethics.

Neither Global X nor any related person of Global X makes recommendations to clients, or buys or sells for client accounts, securities in which Global X or a related person of Global X has a material financial interest, except with respect to certain Global X ETFs included in the Model Portfolios. An ETF pays certain fees and expenses that are ultimately borne by its shareholders. Consequently, Global X will earn fees from investors who invest in Global X ETFs through the use of the Model Portfolios, which include Global X ETFs. For a further discussion of the conflicts of interest inherent in this arrangement, see Item 8 of this brochure. In addition, the Adviser maintains a 401(k) retirement plan for its employees. The plan includes certain Global X ETFs among the investment choices available to participants. From time to time, the Adviser and its affiliates have acquired shares in certain Global X ETFs and intend to continue to do so in the future.

Selecting Brokerage Firms and Best Execution The policy regarding purchases and sales of securities for each Fund is that primary consideration will be given to obtaining the most favorable prices and efficient executions of transactions. Consistent with this policy, when securities transactions are effected on a stock exchange, the policy is to pay commissions that are considered fair and reasonable without necessarily determining that the lowest possible commissions are paid in all circumstances. In seeking to determine the reasonableness of brokerage commissions paid in any transaction, Global X relies upon its experience and knowledge regarding commissions generally charged by various brokers and in various jurisdictions. Global X effects transactions for the Funds with those brokers and dealers that Global X believes provide the most favorable prices and are capable of providing the most efficient and best execution of trades. The primary consideration of Global X is to seek prompt execution of orders at the most favorable net price. Soft Dollars For certain of the actively managed ETFs or Accounts, the Adviser may effect transactions through a broker-dealer who furnishes brokerage and/or research services that result in the payment of a commission in excess of the commission another broker-dealer would have received for executing the transaction. The use of ETF brokerage commissions to obtain research or other products or services benefits the Adviser, because the Adviser does not have to produce or pay for the research, products or services received in exchange for the commissions. Subject to Best Execution analysis, the Adviser may have an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than receiving most favorable price. Any research service received through a broker-dealer may be used by the Adviser in connection with Accounts other than those Accounts that pay commissions to such broker-dealer. The Adviser and its affiliates do not currently participate in any soft dollar transactions with respect to the Funds, although the Adviser relies on Section 28(e) of the 1934 Act (“Section 28(e)”) in effecting or executing transactions for the Funds. Accordingly, in selecting broker-dealers to execute a particular transaction, the Adviser may consider the brokerage and research services [as those terms are defined in Section 28(e)] provided to the Funds and/or other accounts over which the Adviser or its affiliates exercise investment discretion. The Adviser may cause the Funds to pay a broker-dealer that furnishes brokerage and research services a higher commission than that which might be charged by another broker-dealer for effecting the same transaction, provided that the Adviser determines in good faith that such commission is reasonable in relation to the value of the brokerage and research services provided by such broker-dealer, viewed in terms of either the particular transaction or the overall

responsibilities of the Adviser to the Funds. Such brokerage and research services might consist of reports and statistics on specific companies or industries or broad overviews of the securities markets and the economy. Shareholders of the Funds should understand that the services provided by such brokers may be useful to the Adviser in connection with its services to other clients. Such research services may include, but are not limited to, the following: traditional research reports analyzing a company or stock, discussions with research analysts, meetings with corporate executives to obtain oral reports on an issuer, certain financial newsletters and trade journals relating to the subject matter of Section 28(e) that are not mass-marketed (see discussion below regarding massmarketed publications), quantitative analytical software, order management systems, and software that provides analysis relating to the subject matter of Section 28(e), corporate governance research (including corporate governance analytics) and corporate governance rating services if they reflect the expression or reasoning or knowledge and they relate to the subject matter of Section 28(e), market data reports, including stock quotes, last sale price reports, trading volume, company financial data, economic data, certain proxy services that provide reports and analysis on issuers, securities and the advisability of investing in securities if it relates to the investment function, and seminars and conferences where the content satisfies the above requirements. Order Aggregation Global X generally aggregates purchase and sale transactions for ETFs where appropriate. Appropriate instances may arise when multiple funds are trading the same name in the same direction with the same trading instructions/benchmark. It is possible that orders of such nature may not be aggregated if a potential candidate for aggregation is deemed deminimus with respect to volume/liquidity. The measure of deminimus would be a position that represents less than 5% of an average days trading volume. Model Portfolios Global X is not responsible for trading, and will not execute any brokerage trades, in connection with the provision of Model Portfolios to various Third-Party Providers. The applicable Third-Party Provider will have sole investment discretion and responsibility for the execution of trades for the underlying investors utilizing the Model Portfolios.

Global X has entered into certain arrangements with third-party platforms through which Global X pays out of its internal resources and profits certain trading, servicing, program and other fees related to the provision of advisory services with respect to its clients. These agreements generally may be terminated for any reason by Global X upon reasonable notice to the third-party platforms. Global X may also make payments out of its own internal resources and profits from all sources to other financial intermediaries to encourage the sale of shares of the Global X ETFs. The payments are intended to compensate financial intermediaries (including broker-dealers) for, among other things marketing shares of the Funds, including but not limited to: inclusion on preferred or recommended fund lists or in certain sales programs from time to time sponsored by the financial intermediaries; access to the financial intermediaries registered sales persons; and /or other specified services of persons intended to assist in the marketing of the Funds. Such payments may be based on various factors, including levels of assets and/or sales (based on gross or net sales or some other criteria). These payments may create an incentive for a financial intermediary to sell and recommend certain investment products, including the Funds, over other products for which it may receive less compensation. The Adviser and/or its affiliates may on occasion sponsor educational or due diligence meetings and related events for invited registered representatives. At these events, attendees can receive research and updates on the Adviser, its Funds, and the related indexes, as well as have access to investment and operations personnel of the Adviser. Invitation to and attendance by any representatives at such meeting or event is not conditioned upon any selling or purchasing of the shares of a Fund, although representatives who have expressed interest in the Funds may be more likely to be considered for an invitation. Attendance by a representative will not result in any change for any investor to a Fund’s share price, nor to any fees or costs related to the purchase or sale of the shares of the Funds. Subject to its policies and guidelines, the Adviser and/or its affiliates may reimburse the eligible costs related to such events incurred by those attending representatives. Those eligible costs may include the costs associated with travel, accommodations, meals and related events, provided that such payments are legitimate and are not excessive. Any such payments, including the reimbursement of eligible expenses, will be made exclusively by the Adviser and/or its affiliates from their own resources, and no payments or reimbursements will be made by any Fund.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Global X or the integrity of Global X’s management. Global X has no legal or disciplinary events to disclose.

The Global X Portfolio Managers are currently responsible for the day-to-day management of the Global X ETFs portfolios. The accounts managed by the Adviser are under continuous review by the Portfolio Managers. The Adviser reviews the activities of each subadviser on a daily basis and more thoroughly on a quarterly basis. With respect to the Global X ETFs, additional reviews of a Global X ETF's account may be triggered by changes in such ETF's Underlying Index or by updates in the Prospectus. Quarterly reports regarding each Global X ETF’s operations are provided to the applicable Board of Trustees or Board of Directors. In addition, the Global X ETFs' daily and quarterly performance is posted on the applicable ETFs' website. The Global X ETFs' website also publishes quarterly factsheets, semiannual reports, and audited annual reports for each ETF. Portfolios are also reviewed by members of our Compliance team to monitor compliance with the applicable trading mandate and any applicable risk and/or operating guidelines.

Model Portfolio Services Global X will periodically review the allocations in the Model Portfolios; however, clients of Third-Party Providers invested based on the Model Portfolios do not maintain accounts with Global X and therefore Global X has no responsibility for review of such accounts. Global X does not have, and will not have, trading authority over any underlying client account of a Third‐Party Provider, including any such client account which is based on a Model Portfolio and any trading effected by a Third‐Party Provider or its underlying client may incur tax consequences, commissions and other costs. Third‐Party Providers may use multiple strategies, including strategies of other investment managers. The implementation of any such investment strategy for an underlying client of a Third‐Party Provider, including one based on a Model Portfolio, will be conducted by the applicable Third‐Party Provider, who is responsible for making its own independent judgment as to how to incorporate any Model Portfolio information for any underlying client of such Third‐Party Provider. Global X provides periodic reports with respect to Model Portfolio performance to the Third-Party Providers utilizing such Model Portfolios. Periodic reports are also available on the Global X website.

Global X may be deemed to have custody based solely on the ability to debit a Fund’s advisory fees. Account Statements Global X does not maintain shareholder accounts; therefore Global X does not send out account statements. Performance Reports Global X maintains a public website which provides daily, monthly and quarterly performance information for each Fund. Net Worth Statements Global X does not maintain shareholder accounts; therefore Global X does not send out net worth statements. Global X Digital Assets Global X Digital Assets is deemed to have custody of client assets because it has the authority to obtain client assets, for example, by deducting advisory fees from each Fund permitting advisory fees to be paid directly from the Fund’s custodian account to GXDA. Account statements related to clients are sent by qualified custodians to GXDA. GXDA is subject to Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). However, it is not required to comply (or is deemed to have complied) with certain requirements of the Custody Rule with respect to each Fund because it complies with the provisions of the so-called “Pooled Vehicle Annual Audit Exception,” which, among other things, requires that each Fund be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and requires that each Fund distribute its audited financial statements to all investors within 120 days of the end of its fiscal year. All of the Client’s assets are held with one or more “qualified custodians” as defined in the Custody Rule. One qualified custodian that GXDA places Client’s digital assets in custody with is Coinbase Custody, an institutional-grade service optimized for storing large amounts of crypto currency on a framework designed to be highly secure. Coinbase Custody is licensed under New York State Banking Law to operate as an independent Qualified Custodian, operating as a Limited Purpose Trust Company chartered by the New York Department of Financial Services (NYDFS).

Global X has discretionary authority to manage the Global X ETFs’ securities accounts. In all cases, however, such discretion is to be exercised in a manner consistent with each ETF's investment objective. In managing most of the ETFs, Global X uses a "passive" or indexing approach to try to achieve each ETF's investment objective. The fund complex also includes actively managed ETFs, some, but not all of which are subadvised by other investment advisers. Global X does not have discretion over the assets held in the ETFs associated with the Model Portfolios, except to the extent that such ETFs are Global X ETFs. While Global X is responsible for

establishing the recommended allocations in each Model Portfolio, Global X does not have investment discretion with respect to the implementation of any Model Portfolio for any underlying investor.

As required under Rule 206(4)-6 under the Advisers Act, Global X has adopted proxy voting policies and procedures. Under these policies, Global X does not have authority to vote proxies with respect to any ETFs held in an underlying investor’s account based on a Model Portfolio. Global X has authority to vote proxies with respect to securities owned by the Global X ETFs. Global X has retained Glass Lewis & Co. to provide in-depth proxy research and to provide vote execution and the record keeping services necessary for tracking proxy voting for the Global X ETFs. Depending on the investment objective of each Fund, ESG, Catholic Values or other flavored voting policies may be utilized. Additionally, each Sub-Advised Fund relies on the proxy voting policies of each SubAdviser. This may result in instances where Global X ETFs may vote on the same issue in different fashions. Information on how the Global X ETFs voted proxies relating to portfolio securities is available: (1) without charge, upon request, by calling 1-888-493-8631 or on the website www.globalxetfs.com; and (2) on the SEC’s website at www.sec.gov. A copy of Global X’s proxy voting policy also is available upon request.

Registered investment advisers are required to provide you with certain financial information or disclosures about their financial condition. Global X has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. Global X has not included a balance sheet because it does not require or solicit prepayment of fees.