SEGALL BRYANT & HAMILL, LLC

Firm Description Segall Bryant & Hamill, LLC (“SBH”) is a registered investment adviser based in Chicago, Illinois with additional offices in Denver, Colorado; Chesterfield, Missouri; Ardmore, Pennsylvania; and New York, New York. SBH was established in 1994. SBH is wholly owned by Corient Management LLC, which is wholly owned by Corient Holdings Inc. Corient Holdings Inc. is an indirect majority owned subsidiary of Mubadala Capital LP, which is ultimately owned by the Government of Abu Dhabi through various wholly owned intermediate entities. See SBH ADV Part 1 schedule B for the complete ownership structure. Investment Advisory Services SBH provides discretionary and non-discretionary investment management and advisory services of domestic and international equity, domestic fixed income, alternative investments and custom solutions to clients which include but are not limited to individuals, corporations, foundations, endowments, public funds, multi-employer plans through separate accounts, wrap programs, unified managed programs, U.S. registered investment companies and other commingled vehicles. SBH also provides sub-advisory services to other registered investment advisers. Our client base is geographically diverse with investors in the U.S. and several foreign countries. SBH manages client portfolios utilizing a diverse offering of investment strategies listed below. For more information on SBH’s strategies, please visit www.cisbh.com. These strategies are typically implemented through a separately managed account for clients, although certain strategies listed are also available through, SBH’s proprietary family of mutual funds - the Segall Bryant & Hamill Funds, collective investment trusts (“CITs”), private funds, an exchange-traded fund (“ETF”), Corient Registered Alternatives Fund (“CoRA Fund”), a closed-end management investment company registered under the Investment Company Act of 1940, separately managed wrap programs (“Wrap Fee Programs"), private investment funds, and model portfolios. Clients should read the prospectus or offering memoranda for these investment vehicles before investing.

EQUITY STRATEGIES

FIXED INCOME STRATEGIES

Small Cap Core Small Cap Value

Short Term Fixed Income Short Term Plus Fixed Income

Small Cap Value Select Small Cap Growth

Intermediate Fixed Income 1-10 Year Managed Municipal Fixed Income Enhanced Intermediate Municipal Fixed Income Core Fixed Income Core Plus Fixed Income

SMID Cap All Cap Select Equity Form ADV Part 2A – September 2025

OTHER INVESTMENT STRATEGIES Alternative Investments

EQUITY STRATEGIES

FIXED INCOME STRATEGIES

All Cap Core – Thematic Emerging Markets Small Cap Emerging Markets International Small Cap Global All Cap

Current Income Portfolio Preferred Securities Portfolio Quality High Yield Liability-Driven Investing Tax Advantaged Municipal Fixed Income Intermediate Fixed Income Managed (Taxable Ladder) Municipal Short Maturity Fixed Income

Quantitative U.S. Small Cap Global Small Cap

OTHER INVESTMENT STRATEGIES

International Equity

Registered Investment Companies SBH provides investment advice to domestic and international open-ended mutual funds and an ETF. In addition, SBH provides investment advice to the CoRA Fund, the shares of which are not registered under the Securities Act of 1933 (the “Securities Act”) and will be issued solely in private placement transactions that do not involve any “public offering” within the meaning of Section 4(a)(2) of, and/or Regulation D under, the Securities Act. SBH also sub-advises several other open-end mutual funds (each, a “Fund,” and collectively, the “Funds”). SBH manages the assets of the Funds in accordance with the Funds’ investment objectives, policies and restrictions set forth in its registration statements. A portion of the CoRA Fund is managed by Churchill Asset Management LLC subject to the oversight of SBH and the board of the CoRA Fund. The services that SBH provides to the Funds can present conflicts of interest as SBH can be incentivized to use the Funds based on compensation rather than the client’s needs. To help manage that conflict of interest, SBH has implemented various controls including maintaining a Code of Ethics which details SBH’s fiduciary duties, monitoring of portfolio holdings versus client objectives, along with the controls mentioned above. This document should not be considered an offering document for the Funds. Please see the respective Fund’s offering materials such as the Prospectus, Statement of Additional Information, Offering Memoranda, and other reports to investors for complete disclosures relating to each Fund. Collective Investment Trusts SBH provides investment advice to collective investment trusts. The Segall Bryant & Hamill International Small Cap Trust, Segall Bryant & Hamill Emerging Markets Trust, Segall Bryant & Hamill Emerging Markets Small Cap Trust, Segall Bryant & Hamill Quality High Yield Trust, Segall Bryant & Hamill All Cap Trust, Segall Bryant & Hamill Small Cap Core Trust, Segall Bryant & Hamill Small Cap Growth Trust, Segall Bryant & Hamill SMID Cap Trust, and the Segall Bryant & Hamill Core Plus Trust (the “SBH Trusts”) are trusts for the collective investment of assets or participating tax qualified pension and profit-sharing plans and related trusts, and governmental plans as more fully described in the Declaration of Trust. As bank collective trusts, SBH Trusts are exempt from registration as an investment company. The SBH Trusts are managed by SEI Trust

Company, the trustee, based on the investment advice of SBH, the investment adviser to the trusts. If these SBH Trusts are held in a client account, the value of the investment in the SBH Trusts is excluded from the billing value for the purpose of calculating the client’s periodic fee due SBH. Private Funds SBH provides investment advice to several privately offered non-registered investment vehicles:

Segall Bryant & Hamill Emerging Markets Small Cap Fund, LP Segall Bryant & Hamill Emerging Markets Fund, LP; and a related offshore fund Segall Bryant & Hamill Private Opportunities Fund, LP; and a related offshore fund (no longer accepting new investors) Segall Bryant & Hamill Private Opportunities Fund 2020, LP; and a related offshore fund (no longer accepting new investors) Segall Bryant & Hamill Private Opportunities Fund III, LP; and a related offshore fund (no longer accepting new investors)

Segall Bryant & Hamill Emerging Markets Small Cap Fund, LP invests in marketable securities, primarily common stocks with small market capitalizations tied economically to emerging market countries. Segall Bryant & Hamill Emerging Markets Fund, LP invests in marketable securities, primarily common stocks tied economically to emerging market countries. Segall Bryant & Hamill Emerging Markets Offshore Fund, LTD invests all of its assets, except those assets needed for cash-management purposes, into Segall Bryant & Hamill Emerging Markets Fund, LP. Segall Bryant & Hamill Private Opportunities Fund, LP and related offshore fund, and Segall Bryant & Hamill Private Opportunities Fund 2020, LP and related offshore fund, and Segall Bryant & Hamill Private Opportunities Fund III, LP, and a related offshore fund seek primarily to invest in nontraditional asset classes including private equity strategies, private debt strategies, and real asset strategies. Wrap Fee Programs SBH does not sponsor a wrap fee program. SBH does provide investment strategies to accounts under wrap fee programs sponsored by other firms or “wrap sponsors.” The wrap sponsors determine the suitability of the investment strategy as well as the suitability of the wrap structure and fee for each client. They recommend and assist clients in selecting an appropriate SBH investment strategy, taking into account their financial situation and investment objectives. SBH’s role is to manage the client’s account according to the strategy selected. In a wrap fee program, the wrap sponsor provides investment advisory, execution, and custodial services to clients in return for an all-inclusive—or “wrap”—fee paid to the sponsor. SBH receives a portion of the wrap fee for managing these strategies. SBH will allow reasonable investment restrictions if they do not differ materially from a strategy’s investment objectives. Clients who impose investment restrictions should be aware that the performance of their accounts may differ from that of the investment strategies not subject to investment restrictions.

Unified Managed Account “UMA” Programs (Model Portfolio Provider) SBH provides investment strategies via model portfolios to other investment advisers. As the model portfolio provider, SBH designs, monitors, and updates the portfolio. The investment advisers may then implement the model portfolio for their clients and adjust the model portfolio as recommended by SBH. Model portfolio providers may grant shared trading authority to SBH or “dual discretion” over the clients’ assets, whereby SBH has discretion to execute trades on behalf of the clients. Separate Managed Account Dual Contract Under these programs, a third-party adviser has a contract with a client to perform investment management and possibly custodian services. SBH may establish a contract directly with the client or contract with the third-party adviser on the client’s behalf. SBH may from time to time establish other such relationships. Legal Actions and Class Actions SBH does not take responsibility for filing class action claims on behalf of its clients. However, regarding class actions, SBH has retained an outside company to provide an option for clients to electronically file class action claims. Fees for this service are typically on a contingency basis, as a percentage of the proceeds received. Assets Under Management As of December 31, 2025, our total regulatory assets under management were $22,636,030,345. ($22,621,553,988 discretionary and $14,476,357 non-discretionary). There are $694,619,328 in Model UMA assets included in assets under advisement (“AUA”).

All fees are subject to negotiation. The extent and nature of the advisory services that SBH provides will vary depending on the specific arrangements it makes with each client. As a result, SBH’s fees will differ among its client accounts due to several factors such as the size of the account, relationships with other accounts, competitive pricing conditions at inception, the historical or projected nature of trading for the account, and the extent of supplemental client services provided to the account. Clients elect to be billed directly for fees or authorize their custodian to directly debit fees from client accounts. Under the terms of SBH’s standard form investment advisory agreements, the compensation of SBH is payable quarterly in advance and fees are calculated on market values following SBH’s valuation policies and procedures as of the last business day of the quarter. The standard form agreements do not have fixed termination or renewal dates but do provide for the termination of SBH’s services to the client by notice from either the client or SBH to the other within 30 days’

written notice. If at the time of termination and subject to the required notice period, SBH has not fully earned a fee amount prepaid by the client, the unearned portion (determined by proration on a daily basis) is refunded to the client. Accounts initiated or terminated during a calendar quarter will be charged a pro rata fee. In addition to the schedules of fees set forth below that apply to new clients, fee schedules with some clients may differ. From time to time, special requirements of clients will result in advisory contracts with terms or fee arrangements differing from those set forth in SBH’s standard forms. There are circumstances under which fees, including performance-based fee arrangements in compliance with Securities and Exchange Commission Rule 205-3 and applicable state securities laws and regulations, if any, may be negotiated. The minimum account size noted below may be waived or reduced when, for example, a new account is expected to grow rapidly in size, a relationship exists with a current client of SBH, or for other reasons, at the discretion of SBH. SBH may offer a discount from its standard fee schedules for accounts of persons associated with SBH, its affiliates, or members of their families. SBH’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. SBH strives to keep their fees to a minimum. In addition to SBH’s fees, clients may incur certain charges imposed by custodians, brokers, thirdparty investment and other third parties, such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. In circumstances where a client’s account includes mutual funds (not advised by SBH), clients should be aware that they are paying an investment management fee to the adviser of the mutual fund, which is disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to SBH’s fee, and SBH does not receive any portion of these commissions, fees, and costs. The Brokerage Practices section in Item 12 further describes the factors that SBH considers in selecting or recommending broker dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). INVESTMENT STYLE

MANAGEMENT FEE*

MIN. SEPARATE ACCOUNT SIZE

0.55% - First $25 Million 0.45% - Next $25 Million 0.30% - Over $50 Million 0.55% - First $25 Million 0.45% - Next $25 Million 0.30% - Over $50 Million 0.65% - First $50 Million 0.55% - Next $50 Million 0.50% - Over $100 Million 0.70% - First $50 Million 0.60% - Next $50 Million 0.55% - Over $100 Million 0.80% - First $50 Million 0.70% - Next $50 Million

$1 Million

Core Equity All Cap

Select Equity

Global All Cap

SMID Cap

Small Cap Core

$1 Million

$1 Million

$1 Million

$1 Million

INVESTMENT STYLE

MANAGEMENT FEE*

MIN. SEPARATE ACCOUNT SIZE

0.65% - Over $100 Million

Core Equity Thematic All Cap - Thematic

0.55% - First $25 Million 0.45% - Next $25 Million 0.30% - Over $50 Million

$1 Million

0.80% - First $50 Million 0.70% - Next $50 Million 0.65% - Over $100 Million

$1 Million

0.65% - First $50 Million 0.55% - Next $50 Million 0.50% - Over $100 Million 0.70% - First $50 Million 0.60% - Next $50 Million 0.55% - Over $100 Million 0.75% - First $50 Million 0.65% - Next $50 Million 0.60% - Over $100 Million 0.80% - First $50 Million 0.70% - Next $50 Million 0.65% - Over $100 Million

$50 Million

0.70% - First $50 Million 0.60% - Next $50 Million 0.55% - Over $100 Million 0.80% - First $50 Million 0.70% - Next $50 Million 0.65% - Over $100 Million

$50 Million

0.80% - First $50 Million 0.70% - Next $50 Million 0.65% - Over $100 Million 0.80% - First $50 Million 0.70% - Next $50 Million 0.65% - Over $100 Million

$1 Million

0.25% - First $50 Million 0.20% - Next $50 Million 0.15% - Over $100 Million 0.25% - First $25 Million 0.20% - Next $25 Million 0.15% - Over $50 Million 0.25% - First $50 Million 0.20% - Next $50 Million 0.15% - Over $100 Million 0.30% - First $50 Million 0.25% - Next $50 Million 0.20% - Over $100 Million 0.25% - First $25 Million 0.20% - Next $25 Million 0.15% - Over $50 Million 0.25% - First $25 Million

$5 Million

Growth Equity Small Cap Growth

Quantitative International Equity

Quantitative U.S. Small Cap

Global Small Cap

International Small Cap

Emerging Markets

Emerging Markets Small Cap

$1 Million

$50 Million

$50 Million

$50 Million

Value Equity Small Cap Value

Small Cap Value Select

$1 Million

Fixed Income Intermediate

Intermediate Fixed Income Managed Account (Taxable Ladder) Core

Core Plus

Current Income Portfolio

Preferred Securities Portfolio

$250,000

$5 Million

$5 Million

$150,000

$200,000

INVESTMENT STYLE

MANAGEMENT FEE*

MIN. SEPARATE ACCOUNT SIZE

0.20% - Next $25 Million 0.15% - Over $50 Million Quality High Yield

0.50% - First $25 Million 0.45% - Next $25 Million 0.40% - Over $50 Million Liability-Driven Investing 0.25% - First $50 Million 0.20% - Next $50 Million 0.15% - Over $100 Million Short Term 0.25% - First $50 Million 0.20% - Next $50 Million 0.15% - Over $100 Million Short Term Plus 0.25% - First $50 Million 0.20% - Next $50 Million 0.15% - Over $100 Million Municipal - Tax Advantaged Fixed Income 0.25% - First $5 Million 0.20% - Over $5 Million Municipal – Short Maturity 0.25% - First $5 Million 0.20% - Over $5 Million Municipal: 1-10 Years Managed 0.25% - First $5 Million 0.20% - Over $5 Million Municipal – Enhanced Intermediate 0.25% - First $5 Million 0.20% - Over $5 Million * All fees noted represent institutional strategies unless specifically stated otherwise.

$5 Million

$5 Million

$5 Million

$5 Million

$500,000 $250,000 $250,000 $500,000

In most cases, each of the foregoing schedules of fees is applied to the fair market value of the assets under management by SBH, as reasonably determined by SBH, as of the end of each quarterly period. If these Funds are held in a client separate account, the value of the investment in the Funds is excluded from the billing value for the purpose of calculating the client’s periodic fee due SBH. Wrap Fee Programs The wrap sponsor contracts with the client to perform investment management and/or custodial services. Clients pay a single all-inclusive fee quarterly in advance to the wrap sponsor based on assets under management. From the all-inclusive fee, the sponsor will pay SBH a management fee. The wrap fee is set forth in the sponsor’s brochure. The fees payable to SBH are negotiable for these accounts. Unified Managed Account “UMA” Program (Model Portfolio Provider) The fees that SBH receives from third parties for providing its model portfolios are subject to negotiation.

Separate Managed Account Dual Contract Programs In dual contract programs, the end client pays a separate quarterly fee to SBH based on the market value of the account. The fees payable to SBH are negotiable but will generally not exceed the amounts set forth for a particular investment strategy above. Private Funds As is more fully described in the offering materials for the private funds, SBH receives a management fee from each of the private funds. The management fee is accrued in arrears on the same frequency as the private fund’s net asset value calculation, which is either monthly or quarterly. The standard management fee for the private funds is up to 1.2% per annum. Certain private funds may also have a performance fee. Certain private funds may have multiple classes that are offered to investors with different fee schedules. SBH reserves the right to apply a different management fee and/or performance fee to different investors and to waive any management fee and/or performance fee in whole or in part at its discretion, including SBH or affiliate employees and family members. Certain SBH Private Funds also will pay SBH an incentive fee equal to 10% of all distributions received by a limited partner in excess of the limited partner’s contribution to such investment. The incentive fee will remain provisional and unpaid until the calculation is considered final following a “realization event” as more fully described in the SBH Private Fund offering documents. SBH may, in its sole discretion, waive all or part of the incentive fee for any of the limited partners. When private funds are held in a client account, the value of the investment in private funds is excluded from the billing value for the purpose of calculating the client’s periodic fee due to SBH. Mutual Funds and ETF SBH receives annual fees from the SBH Funds for investment advisory and administration services provided to the Funds. SBH is paid a monthly management fee on average daily net assets at an annual rate up to 1.00%. SBH serves as the sub-adviser to mutual funds where it receives a fee from the adviser for its services. Specific advisory fees and expense-related information can be found in each Fund’s Prospectus, Statement of Additional Information, Annual Shareholder Report, Annual Financial Statements and Additional Information, Semi-Annual Shareholder Report, and Semi-Annual Financial Statements and Additional Information. If these Funds are held in a client separate account, the value of the investment is excluded from the billing value for the purpose of calculating the client’s periodic fee due SBH. Corient Registered Alternatives Fund (“CoRA Fund”) SBH receives two forms of compensation from CoRA, a standard management fee along with an incentive fee if certain criteria are met. CoRA pays SBH a management fee of 1.25% per annum as adviser to the fund. Management fees are paid quarterly and calculated and accrued monthly based on the value of the net assets as of the last day of each month. Both the management fee and incentive fee are described in CoRA’s offering documents.

A portion of CoRA’s assets are managed by a third-party sub-adviser. SBH pays a sub-advisory fee based on a tiered schedule agreed to in the sub-advisory agreement. The sub-adviser also receives an incentive fee if certain criteria are met. Specific fees and expense-related information can be found in the CoRA confidential private placement memorandum and financial reports. Collective Investment Trusts SBH receives a management fee from SBH Trusts for its investment advisory services. The trustee of Segall Bryant & Hamill Collective Investment Trust pays SBH a monthly management fee based on the average daily net assets of up to 1.25%. Specific advisory fees and expense-related information can be found in the Segall Bryant & Hamill Collective Investment Trust Disclosure Memorandum. If a SBH Collective Investment Trust Fund is held in a client separate account, the value of the investment is excluded from the billing value for the purpose of calculating the client’s periodic fee due SBH.

Research Process SBH uses a variety of investment strategies and techniques in managing accounts, both qualitative and quantitative, with emphasis on the use of proprietary investment research. Proprietary research involves analysis that is conducted on the business and characteristics of specific companies and when forming investment decisions. Proprietary research can include interviews with company management, customers, suppliers and industry analysts, analysis of a company’s historical financial statements, and creation of financial models of the company or issuer’s projected financial performance, among other things. SBH makes substantial use of various quantitative screening techniques through its own proprietary models. The research professionals at SBH consider environmental, social, and corporate governance (“ESG”) policies of the issuing entities when forming investment decisions alongside other considerations for each investment strategy. With respect to its quantitatively driven portfolios, SBH’s investment philosophy emphasizes a systematic, diversified and risk-aware process. Investment Strategies All Cap SBH focuses on companies that have strong management, broad resources and a competitive market position. The strategy seeks long-term capital appreciation. • Allocates assets opportunistically; not constrained by market capitalization or style parameters. • Invests in a portfolio of securities (primarily common stocks) across economic sectors. • Seeks high return on invested capital (ROIC) companies trading at a 20% discount to our proprietary intrinsic valuation. • Employ proprietary screens to limit the universe to companies with low embedded expectations. • Utilizes a low turnover approach to active management.

Select Equity SBH focuses on companies that have strong management, broad resources and a competitive market position. The strategy seeks long-term capital appreciation through a concentrated portfolio. • Invests in 20 highest conviction holdings from the All-Cap strategy, as defined by weight, determined by our analyst team. The portfolio is rebalanced on a monthly basis to reflect deviations due to conviction levels or market movements. • Seeks high return on invested capital (ROIC) companies trading at a 20% discount to our proprietary intrinsic valuation. • Employ proprietary screens to limit the universe to companies with low embedded expectations. • Utilizes a low turnover approach to active management. All Cap Core – Thematic SBH’s All Cap Core – Thematic strategy invests primarily in common stock of all investment styles and market capitalizations. At the heart of our investment philosophy is thorough, independent, fundamental research. We attempt to identify structural changes, whether they might be economic, political, social, demographic, or industry-specific, which are translated into long-term investment themes. The goal of our risk management approach is to seek to reduce the portfolio’s downside market exposure while allowing for its participation in up-markets. Small Cap Core Equity SBH uses in-depth proprietary research to uncover investments that have the potential to offer consistent returns over the long term and downside protection through market cycles. SBH believes combining a focus on high or improving return on invested capital (ROIC) with niche market companies that have defendable competitive advantages and target smaller overall markets allows companies to compound value over time by generating strong free cash flow, reinvesting that cash at high rates of return, which results in compounding free cash flow and can ultimately lead to an increase in equity value. • Utilizes a core investment approach consisting of companies with a market capitalization that does not typically exceed those in the Russell 2000® Index. • Employ proprietary screens to limit the universe to companies with low embedded expectations. • Leverages our investment process with the goal of identifying catalysts of change for improved returns while guarding for risk. SMID Cap Equity SBH uses in-depth proprietary research to uncover investments that have the potential to offer consistent returns over the long term and downside protection through market cycles. SBH believes combining a focus on high or improving return on invested capital (ROIC) with niche market companies that have defendable competitive advantages and target smaller overall markets allows companies to compound value over time by generating strong free cash flow, reinvesting that cash at high rates of return, which results in compounding free cash flow and can ultimately lead to an increase in equity value.

Utilizes a core investment approach consisting of companies with a market capitalization that does not typically exceed those in the Russell 2500TM Index. Employ proprietary screens to limit the universe to companies with low embedded expectations. Leverages our investment process with the goal of identifying catalysts of change for improved returns while guarding for risk.

Small Cap Value SBH uses in-depth proprietary research to uncover investments that have the potential to offer consistent returns over the long term and downside protection through market cycles. SBH views significant improvement in Return on Invested Capital (or ROIC) and its by product, free cash flow, as the ultimate driver of underlying equity value. SBH looks for companies with management teams focused on driving improvements in ROIC that also have defendable competitive advantages and low embedded expectations. This combination leads us to companies capable of compounding value over time by generating strong free cash flow, reinvesting that cash at increasing rates of return, which results in increasing equity value.

Utilizes a fundamental, bottom-up approach designed to identify companies with improving business models that have the capability to generate significant improvement in ROIC over the investment horizon. Employ proprietary screens to limit the universe to companies with low embedded expectations. Leverages our investment process with the goal of identifying catalysts of change for improved returns while guarding for risk.

Small Cap Value Select SBH uses in-depth proprietary research to uncover investments that have the potential to offer consistent returns over the long term and downside protection through market cycles. SBH views significant improvement in Return on Invested Capital (ROIC) and its byproduct, free cash flow, as the ultimate driver of underlying equity value. SBH looks for companies with management teams focused on driving improvements in ROIC that also have defendable competitive advantages and low embedded expectations. This combination leads us to companies capable of compounding value over time by generating strong free cash flow and reinvesting that cash at increasing rates of return, which results in increasing equity value. • Invests in 30 to 40 of the highest conviction holdings from the SBH Small Cap Value strategy. • Utilizes a fundamental, bottom-up approach designed to identify companies with improving business models that have the capability to generate significant improvement in ROIC over the investment horizon. • Employ proprietary screens to limit the universe to companies with low embedded expectations. • Leverages our investment process with the goal of identifying catalysts of change for improved returns while guarding for risk. Global All Cap SBH focuses on companies that have strong management, broad resources and a competitive market position. The strategy seeks long-term capital appreciation.

Allocates assets opportunistically; not constrained by market capitalization or style parameters. Invests in a portfolio of securities (primarily common stocks) across economic sectors. Seeks high return on invested capital (ROIC) companies trading at a 20% discount to our proprietary intrinsic valuation. Employ proprietary screens to limit the universe to companies with low embedded expectations. Utilizes a combination of fundamental and quantitative analysis to invest in wellestablished companies, both in the U.S. and developed foreign markets. Utilizes a low turnover approach to active management.

Small Cap Growth SBH utilizes a fundamental research process focused on being early in identifying companies that exhibit fundamentally stable growth prospects. The strategy seeks to achieve long-term capital appreciation. • Seeks to invest in companies with fundamentally stable growth prospects that offer a measurable competitive advantage by leading or disrupting industries. • Invests in companies that we believe are attractively valued relative to future growth opportunities. • Uses a proprietary quantitative risk screening tool to systematically flag stocks at risk of underperforming and to reduce behavioral biases. • SBH believes the sell decision is as important as the buy decision in small cap growth investing. International Small Cap The portfolio is comprised of companies with traditional value characteristics coupled with positive company momentum factors. SBH utilizes an investment approach that is systematic, diversified, and risk aware. The strategy seeks long-term capital appreciation. • Utilize quantitatively driven process with stock selection model based on valuation, profitability and momentum factors. • Focus on stocks that meet our valuation criteria but also have positive earnings and price momentum. • Utilizes an optimization process that seeks to maximize returns while minimizing risk by taking calculated risk where alpha can be systematically captured and aiming to avoid uncompensated risk. • Displays diversified exposure with geographic and sector neutrality. Emerging Markets The portfolio is comprised of companies with traditional value characteristics coupled with positive company momentum factors. SBH utilizes an investment approach that is systematic, diversified, and risk aware. The strategy seeks long-term capital appreciation. • Utilizes a quantitatively driven process with a stock selection model based on valuation, profitability, and momentum factors. • Focuses on stocks that meet our valuation criteria but also have positive earnings and price momentum.

Utilizes an optimization process that seeks to maximize returns while minimizing risk by taking calculated risk where alpha can be systematically captured and aiming to avoid uncompensated risk. Displays diversified exposure with geographic and sector neutrality.

Emerging Markets Small Cap The portfolio is comprised of companies with traditional value characteristics coupled with positive company momentum factors. SBH utilizes an investment approach that is systematic, diversified, and risk aware. The strategy seeks long-term capital appreciation. • Utilizes a quantitatively driven process with a stock selection model based on valuation, profitability, and momentum factors. • Focuses on stocks that meet our valuation criteria but also have positive earnings and price momentum. • Utilizes an optimization process that seeks to maximize returns while minimizing risk by taking calculated risk where alpha can be systematically captured and aiming to avoid uncompensated risk. • Displays diversified exposure with geographic and sector neutrality. International Equity SBH’s International Equity philosophy utilizes a systematic, objective methodology that focuses on three main components: quantitative analysis, valuation and intelligent risk taking. The systemization of SBH’s investment methodology also allows this rigorous investment process to be applied effectively over broad investment universes, such as the international equity space. SBH concentrates its focus on where it can be most effective and where the largest payoff is expected, while correspondingly limiting exposure that could introduce an excessive amount of risk for the associated return. Strict adherence to its disciplines—including neutrality to region and sector exposures—aims to give the portfolio attractive risk/return characteristics. Quantitative U.S. Small Cap SBH’s Quantitative U.S. Small Cap philosophy utilizes a systematic, objective methodology that focuses on three main components: quantitative analysis, valuation and intelligent risk taking. The systemization of SBH’s investment methodology also allows this rigorous investment process to be applied effectively over broad investment universes, such as the U.S. small cap space. SBH concentrates its focus on where it can be most effective and where the largest payoff is expected, while correspondingly limiting exposure that could introduce an excessive amount of risk for the associated return. Strict adherence to its disciplines—including neutrality to sector industry group exposures—aims to give the portfolio attractive risk/return characteristics. Global Small Cap SBH’s Global Small Cap philosophy utilizes a systematic, objective methodology that focuses on three main components: quantitative analysis, valuation and intelligent risk taking. The systemization of SBH’s investment methodology also allows this rigorous investment process to be applied effectively over broad investment universes, such as the global small cap space. SBH concentrates its focus on where it can be most effective and where the largest payoff is expected, while correspondingly limiting exposure that could bring an excessive amount of risk for the associated return. Strict adherence to its disciplines—including neutrality to

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SBH provides its investment management services to many types of clients including: ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪ ▪

Individuals, including high net worth individuals; Corporations; Educational institutions, charitable organizations, religious organizations and healthcare organizations; Insurance companies; Unions and Taft-Hartley plans; Health and Welfare Plans; ERISA, pension, profit-sharing plans and other benefit plans or retirement plans; Trusts, estates, and endowments; State or local government entities; Pooled investment vehicles, registered investment companies and other investment entities.

The minimum conditions for opening or maintaining an account are as follows: Institutional Relationships:

Minimum relationship size based on investment strategy is noted above.

SMA Wrap Fee Accounts:

Minimum $100,000.

The minimum account size may, however, be modified by mutual agreement with a client as determined on a case-by-case basis. The investment objective, strategy or guidelines of the account, the expectation of future cash inflows into the account for new investment, the present or expected business relationship with the client, and similar considerations can affect the minimum initial account size agreed upon. For registered investment companies, collective investment trusts, and private fund investments, clients should review the offering documents for qualifications and minimum investment/subscription requirements.

Performance-Based Fees In some cases, SBH has entered into performance fee arrangements with qualified clients: such fees are subject to individualized negotiation with each client. SBH will structure any performance or incentive fee arrangement subject to Section 205(a)(1) of the Investment Advisers Act of 1940, as amended, (the “Advisers Act”), in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205-3. In measuring clients’ assets for the calculation of performance-based fees, SBH shall include realized and unrealized capital gains and losses. Performance-based fee arrangements create an incentive for SBH to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. SBH has procedures designed and implemented to ensure that all clients are treated in a fair and equitable manner, and to prevent this conflict from influencing the allocation of investment opportunities among clients. Performance-based fees also create an incentive for SBH to overvalue investments that lack a market quotation. To address this possible conflict, SBH has adopted policies and procedures that require SBH to “fair value” any investments that do not have a readily available market value. Certain SBH private funds and the CoRA Fund charge performance/incentive fees. Refer to the offering materials of each Fund for further information.

Side-by-Side Management In some cases, SBH manages clients in the same or similar strategies. This gives rise to potential conflicts of interest if the funds and accounts have, among other things, different objectives, benchmarks, or fees. For example, potential conflicts arise in the following areas: • The portfolio manager must allocate time and investment ideas across funds and accounts, • Funds or accounts orders do not get fully executed, • Trades get executed for an account that may adversely impact the value of securities held by a fund, • Certain accounts or funds receive an allocation of an investment opportunity when other accounts do not, and/or, • Trading and securities selected for a particular fund or account can cause differences in the performance of different accounts or funds that have similar strategies. SBH has adopted trade allocation policies and procedures and monitors such transactions to help ensure SBH is not favoring Funds or accounts over each other as well as to help ensure fair and equitable treatment over time for both the Funds and accounts. During periods of unusual market conditions, SBH may deviate from its normal trade allocation practices. There can be no assurance, however, that all conflicts have been addressed in all situations.

Other Financial Industry Activities or Affiliation Corient Private Wealth LLC (“Corient”) and other affiliates are also registered investment advisers, tax preparation service companies, and other financial services-related companies located in the U.S. and Canada. Some affiliates manage or advise private funds, investment companies or other investment vehicles as disclosed in their respective Form ADV’s. To the extent that SBH clients are referred to other affiliates, additional disclosures are provided below. For both its US domiciled private funds and its non-US domiciled private funds, LWF, Inc., a wholly owned subsidiary of SBH, serves as the managing member of such funds. For its non-U.S. domiciled SBH private funds, two employees of SBH hold a position on each non-U.S. SBH private fund’s board of directors. SBH has entered into investment advisory and/or co-administration agreements with Segall Bryant & Hamill Funds, within the Segall Bryant & Hamill Trust. Pursuant to these agreements, SBH provides investment advisory services and/or certain administrative, management and record keeping services for these funds. Individuals associated with SBH serve as officers of the Funds within the Segall Bryant & Hamill Trust. In addition, SBH employees may own securities held in one or more of these mutual funds, subject to the SBH Code of Ethics. SBH has entered into an investment advisory agreement with Corient Registered Alternatives Fund. Pursuant to this agreement, SBH provides investment advisory services and/or certain administrative, management and record keeping services for these funds. Individuals associated with SBH serve as officers of the CoRA Fund. In addition, SBH employees may own securities held in the CoRA Fund, subject to the SBH Code of Ethics. Certain employees of SBH are registered representatives with Foreside Fund Services, LLC (“Foreside”). As registered representatives, the employees are authorized to sell the SBH Funds and receive compensation in connection with such activities. SBH is not affiliated with Foreside. Such registered representatives have an incentive to sell SBH’s products over other products where such registered representatives do not receive compensation. Certain employees serve as dual employees of SBH and Corient Private Wealth and are under common control. SBH and Corient Private Wealth both have supervisory responsibilities over these dual employees. Each dual employee is subject to SBH’s and Corient Private Wealth’s Code of Ethics and policies and procedures.

Code of Ethics SBH has adopted a Code of Ethics (the “Code”) and compliance policies that require our employees to follow a high standard of business conduct and emphasize our fiduciary duty to our clients. The Code requires employees to acknowledge the Code and other compliance policies annually and when amended. Employee Personal Trading The Code is designed to seek assurance that the personal securities transactions, activities, and interests of the employees of SBH (including all beneficial ownership) will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. In addition, the Code requires pre-clearance of many transactions and restricts trading in close proximity to client-trading activity. The code of ethics permits employees to invest in the same securities as clients, so there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code to reasonably prevent conflicts of interest between SBH and its clients. SBH employees, including investment professionals having direct responsibility for investment decisions, may have an interest or position in a certain security or group of securities which may also be recommended to a client. To address potential conflict of interests, SBH employees must pre-clear their personal securities transactions (including all beneficial ownership) and are subject to the Code de minimis requirement. Compliance monitors employees’ personal trading activity on an ongoing basis to ensure compliance with the Code. SBH requires prompt reports on all transactions and holdings covered by the Code on a quarterly basis and annual basis. SBH buys, sells, and performs research on or through companies for whom a client may be the company, an employee, officer, or director. Certain SBH employees that meet eligibility requirements may invest directly in SBH private funds or participate in private placements offered by the underlying manager(s) of the SBH private funds directly after receiving pre-clearance to ensure that there are not any material conflicts of interest relating to those investments. Employees may invest in opportunities that are not suitable for SBH clients or that cannot be offered to our clients. In certain instances, employees of Corient and other affiliates may be considered Access Persons as defined in SBH’s Code and will also be subject to the Code. SBH will provide a copy of the Code of Ethics to any client or prospective client upon request

Brokerage Selection Unless other negotiated, SBH has authority to determine, without obtaining specific client consent, the securities to be bought or sold, the amount of the securities to be bought or sold, whether transactions should be combined (blocked) with similar trades for other accounts, the broker dealer to be used, and the commission rate to be paid, unless otherwise negotiated. SBH’s policy regarding selection of brokers and payment of commissions is to seek "best execution" with respect to all portfolio transactions. This principle recognizes that commissions on portfolio transactions must be utilized for the ultimate benefit of SBH’s clients. In selecting a broker for any transaction, SBH considers both qualitative and quantitative characteristics of each broker, including: • Financial strength, stability, and reputation • Efficiency of execution and error resolution • Block trading and block positioning capabilities • Experience of traders • Access to multiple trading algorithms • Research relating to the particular transaction SBH maintains and periodically updates a list of approved brokers and dealers which, in SBH’s judgment, are capable of providing best execution. SBH’s traders are directed to use only brokers and dealers on the approved list, except in case of client designations of brokers or dealers to effect transactions for such clients’ accounts. SBH receives a benefit when it uses client commissions to receive research, because SBH does not have to pay for such services on its own. SBH has an incentive to select or recommend a broker-dealer based on its interest in receiving research from a broker-dealer or third party, rather than the client’s interest in seeking favorable execution. However, as described below, SBH trading practices are designed to achieve best execution for its clients even when it is receiving research services from broker-dealers. Research and Other Soft Dollar Benefits (including Commission Sharing Arrangements) SBH may pay commission rates on equity transactions at commission rates that exceed those that a broker might charge for effecting the same transaction because of the value of the eligible brokerage and/or research products or services (“Research”) that such broker or third party provides. This practice is allowable under Section 28(e) of the Securities and Exchange Act of 1934 if SBH determines, in good faith, that the commission paid is reasonable in relation to the value of the Research provided. SBH utilizes brokerage commissions for the purpose of obtaining research, research-related products, and other brokerage services. This practice is known as soft dollars. When SBH uses soft dollars to obtain these benefits, it is possible that the client may pay a higher cost for execution services. Use of these products generally benefits SBH clients because the products and services obtained through soft dollars assist in the formulation of investment advice.

The source of the Research can be categorized as either “proprietary” or “third party.” When the broker-dealer that executes a trade also provides SBH with internally generated research in exchange for one bundled per share commission price, that Research is referred to as “proprietary.” “Third party” Research involves the executing broker providing independent Research generated by a third party in exchange for commission dollars. In these cases, SBH negotiates the execution cost with the executing broker. SBH also has arrangements where it receives certain non-research products and services from unaffiliated third parties providing trading and custody services. These products and services include assistance in administering clients’ accounts, providing pricing information and other market data and assistance with back-office functions, recordkeeping, and client reporting. This practice is allowable under Section 28(e) of the Securities and Exchange Act of 1934 if SBH determines, in good faith, that the commission paid is reasonable in relation to the value of the Research provided. The Research obtained normally benefits many accounts rather than just the one(s) for which the order is being executed, and in some cases is not used in connection with the account which actually paid the commissions to the broker providing the Research. SBH does receive a benefit because SBH does not have to produce or pay for the Research. There is an inherent conflict of interest in these arrangements where an incentive exists for SBH to select a broker-dealer based on the firm’s interest in receiving the Research, rather than on a client’s interest in receiving most favorable execution. SBH has addressed these conflicts of interest by periodically evaluating: • The commission rates paid by clients against industry benchmarks given the size and nature of SBH’s trading • The value of the Research obtained to SBH’s investment processes • Monitoring trade execution The following products and services acquired by SBH through Research arrangements are as follows: • Research services and reports • Economic and market information • Technical data • Research conferences • Consultations • Benchmark index data • Company specific data • Trade order management software • Quotation services On a quarterly basis, the Equity and Fixed Income Best Execution committees, each review the quality of research and execution services of the various broker-dealers and independent research firms. In addition, the Equity Best Execution committee also evaluates the commission rates negotiated with the various brokers to make a good faith determination that they are reasonable in relation to the value of products and services provided.

Client-Directed Brokerage Arrangements Clients can direct SBH in writing to affect portfolio transactions for their accounts through specified brokers or dealers. Such a direction may be conditioned upon the broker or dealer being competitive as to net price and execution of each transaction or may be subject to varying degrees of “restriction,” i.e., an instruction to use the particular broker or dealer whether or not competitive as to net price and execution, or at specified commission rates which are less favorable than otherwise might be obtainable by SBH. Clients sometimes wish to restrict brokerage to a particular broker or dealer in recognition of custodial or other services (including, in some cases, referral of the client to SBH for investment advisory services) provided to the client by the broker or dealer. A client which chooses to designate use of a particular broker or dealer completely or on a “restricted” basis, including a client which designates a broker or dealer as custodian of the client’s assets, should consider whether such a designation may result in certain costs or disadvantages described below regarding priority of execution, allocation of new issue purchases and aggregation of orders. In determining whether to instruct SBH to use a particular broker or dealer on a “restricted” basis, the client may wish to compare the possible costs or disadvantages of such an arrangement with the value of the custodial or other services provided. Clients who restrict brokerage for their accounts may be disadvantaged in obtaining allocations of securities which SBH purchases or recommends for purchase in other clients’ accounts. In order to execute client orders most efficiently, SBH’s traders may assign a lower priority to execution of orders for client accounts which have restricted brokerage. Accordingly, the execution of orders for accounts which restrict brokerage may be less timely than the execution of orders for other client accounts. This priority of execution may or may not result in any consistent price disadvantage, depending upon the market activity in the security to be purchased or sold. Trading for wrap programs is typically executed by the program sponsor. Wrap sponsors charge a combined fee to clients which includes execution services and trading away from such sponsors causes clients to incur additional execution charges. SBH follows its trade aggregation and allocation policies with respect to wrap program trading, however in certain circumstances following contractual arrangements, wrap program trades may be executed after “unrestricted” and “restricted” trades are executed. Where SBH determines to seek to obtain best execution away from such wrap sponsor, such trades will generally be executed with other non-restricted and unrestricted trades. For those strategies that have SMA Wrap / UMA Model platforms with contractual requirements of fair and equitable trading over time, a random trade rotation is assigned across the three types of relationships: Institutional/SMA Wrap (discretionary) and Model (non-discretionary) platforms. SMA Wrap trades are directed to the wrap trading desk for each wrap sponsor and trades are communicated to the model sponsor via the sponsor’s established processes and requirements.

Trade Aggregation and Allocation SBH may place purchase or sale orders for a single security with a broker dealer for an aggregate group of similar clients when determined that it is consistent with the best interest of clients to do so. In instances where the purchase or sale order for a single security cannot be aggregated across all clients, SBH maintains aggregation policies and procedures to ensure the order of execution is fair and equitable over time among all clients that granted SBH full discretionary trading authority or clients that have a contractual requirement through certain wrap programs. To the extent that an aggregated order is filled at different prices during a trading day, each participating account will receive the same average price and pay the same average commission for the transaction. Should an aggregated order be partially completed during a trading day, securities will be allocated pro rata based upon each participating account’s percentage of the entire order. If the pro rata allocation would result in numerous accounts receiving small positions, SBH has fair and equitable procedures in place to allocate such “partial fills” to accounts. Generally, fixed income securities will be aggregated and allocated in a fair and equitable manner taking into account that such securities may be available in limited quantities that preclude pro-rata allocation and the fact that other fixed income securities of equal quality and yield may be suitable substitutes. SBH engages in “step-out” brokerage transactions subject to best price and execution. In a “stepout” trade, one broker-dealer executes the transaction, while a second broker-dealer clears and settles the transaction. The first broker-dealer then shares part or all of its commission with respect to the transaction with the second broker-dealer. SBH engages in step-out transactions primarily (1) to satisfy directed brokerage arrangements of certain of its client accounts and/or (2) to pay commissions to broker-dealers that supply research or analytical services to the Adviser. Shares traded via step-out are traded on a pre-determined cost per share, which is netted into the trade regardless of account type. The cost varies by broker. Cross Trades It is SBH’s policy to not engage in principal or agency cross transactions. Initial Public Offering (“IPO”) SBH does not currently maintain strategies that purchase securities which are part of an initial public offering (“IPO”).

Additional Compensation SBH from time to time may compensate, either directly or indirectly, any person for client referrals. SBH is aware of the requirements under Section 206(4)-1 (The “Marketing Rule”) of the Investment Advisors Act of 1940 and endeavors to comply therewith. SBH maintains written agreements and client acknowledgements for each relationship.

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

Accounts are reviewed on a continual basis by the portfolio manager and their respective teams. There is no specific sequence in which accounts are reviewed. Rather, an ongoing review process is in place. Additional reviews are initiated when market conditions dictate, client circumstances warrant, or any other pertinent factors surface. Thus, the frequency of reviews may vary. Reviews are undertaken in context of the applicant’s current investment policy guidelines, individual security analysis, and/or client investment considerations. Institutional accounts frequently

utilize a consulting firm which SBH’s professionals work closely with in servicing the account. The level of review on individual accounts within a third-party wrap program, where SBH serves as a portfolio manager, is typically limited subject to the agreement with the wrap program sponsor. Reporting is customized based on the needs of each client. Clients and/or client representatives receive written information via mail or electronic information via a client portal on performance, portfolio appraisal, transaction history and portfolio characteristics on a periodic basis which is typically either monthly, or quarterly. SBH relies on the sponsor of the wrap programs for any wrap program client reporting. See Custody section for information on the frequency of client reports.

A qualified custodian holds all client certificated assets. Accordingly, clients should receive at least quarterly statements from a qualified custodian. Other than for the SBH Funds, CoRA Fund, and SBH private funds, SBH prepares and delivers to all clients, either hard copies or electronically via a secured client portal, valuations of their accounts at least quarterly, showing cash and all currently held investments categorized by maturity (fixed income investments) or industry (equity investments), market value and unit cost. A summary of transactions for the prior quarter accompanies the inventory. Clients may request more frequent or detailed reports in accordance with their individual needs. SBH has a reasonable belief that the custodian is sending statements in accordance with SEC’s Custody Rule. Reports or statements produced by SBH are provided to clients. The client should compare the information provided by SBH with the statements provided by the custodian. Investors in the SBH private funds receive written valuations of their account balances monthly from the fund administrator, however certain SBH private equity funds with certain underlying investments in private offerings with longer reporting time periods are generally sent on a quarterly basis once the necessary information has been received from the underlying fund/investment. In its capacity as manager of certain private funds, SBH is deemed to have custody of such fund’s assets. SBH maintains such private funds’ cash and securities with a qualified custodian and provides investors in these private funds with an annual audited financial statement within 120 days of the end of such private fund’s fiscal year. Certain SBH private funds meet certain exemptions based on the types of investments made by the fund which results in

the annual audited financial statement being delivered to investors within 180 days or 260 days of the end of such private fund’s fiscal year, depending on the types and amounts of investments within the SBH private fund.

SBH manages its clients on a discretionary basis. When a client chooses to grant investment discretion to SBH, SBH will have authority to supervise and direct the investments of and for the client’s account without prior consultation with the client. Pursuant to this discretionary authority, SBH will determine which securities are bought or sold for the account, the total amount of such purchases and sales, the brokers or dealers through which transactions will be affected, and the commission rates, if any, paid to affect the transactions. When selecting securities and determining amounts, SBH observes the investment policies, limitations, and restrictions of the clients for which it advises. SBH’s authority may be made subject to conditions imposed in writing by the client, e.g., where the client restricts or prohibits purchases of certain types of securities, or directs that transactions be affected through specific brokers or dealers. While SBH does not accept non-discretionary assignments, in those cases where a client does not choose to grant SBH investment discretion, SBH makes investment recommendations to the client as to which securities are to be purchased or sold, and the amounts to be purchased or sold. Upon approving the recommended transactions, the client may request that SBH direct the execution of purchase or sale orders to implement the recommended transactions for the client’s account. SBH then may be given authority to determine the brokers or dealers through which the transactions will be executed, and the commission rates, if any, paid to affect the transactions. As described above with respect to discretionary accounts, the client may direct that transactions are affected by specific brokers or dealers.

Policy SBH acts as a discretionary investment adviser for various clients, which includes clients governed by the Employee Retirement Income Security Act of 1974 (“ERISA”) and registered investment companies. SBH’s standard investment management agreement requires the client to delegate proxy voting authority to SBH SBH’s standard investment management agreement for accounts governed by ERISA (certain pension or retirement plans, non-IRA’s) require SBH to vote proxies unless an ERISA client specifically reserves the right, in writing, to vote its own proxies or to take shareholder action with respect to other corporate actions requiring shareholder actions. Procedures SBH uses an outside service provider, Institutional Shareholder Services (“ISS”), to vote proxies. ISS considers each proxy issue individually. ISS issues proxy voting guidelines which are available upon request.

As a general rule, the operations group will provide instructions to the custodian to forward all proxies to ISS. ISS receives all proxies and votes them in accordance with the standing instruction to vote with the ISS recommendation, unless instructions are provided to override the ISS recommendation. In the rare instance where our portfolio manager or analyst believes that an ISS recommendation would be to the detriment of our investment clients, we can and will override ISS’ recommendation through a manual vote. In the event of more than one SBH investment team holding the security, the decision to override should be authorized by a member of each SBH investment team. The final authorization to override an ISS recommendation must be approved by the CCO or their designee. A written record supporting the decision to override the ISS recommendation will be maintained. Conflicts of Interest By utilizing an independent service provider for proxy voting, SBH seeks to minimize conflicts of interest related to proxy voting. Limitations As described above, in accordance with a client’s investment advisory contract (or other written directive) or where SBH has determined that it is in the client’s best interest, ISS and/or SBH will not vote proxies received. The following are certain circumstances where ISS and/or SBH will limit its role in voting proxies: 1. Client Maintains Proxy Voting Authority: As is ordinarily the case, where a client specifies in writing that it will maintain the authority to vote proxies itself or that it has delegated the right to vote proxies to a third party, ISS and/or SBH will not vote the securities and will direct the relevant custodian to send the proxy material directly to the client. If any proxy material is received by SBH, it will promptly be forwarded to the client or specified third party. 2. Terminated Account: Once a client account has been terminated with SBH in accordance with its investment advisory agreement, ISS and/or SBH will not vote on any proxies received after the termination. However, the client may specify in writing that proxies should be directed to the client (or a specified third party) for action. 3. Limited Value: If ISS and/or SBH determines the value of a client’s economic interest or the value of the portfolio holding is indeterminable or insignificant, ISS and/or SBH may abstain from voting a client’s proxies. ISS and/or SBH also will not vote proxies received for securities which are no longer held by the client’s account. 4. Securities Lending Programs: When securities are out on loan, they are transferred into the borrower’s name and are voted by the borrower, in its discretion. However, where SBH determines that a proxy vote (or other shareholder action) is materially important to the client’s account, SBH may recall the security for purposes of voting.

5. Unjustifiable Costs: In certain circumstances, after doing a cost-benefit analysis, SBH may abstain from voting where the cost of voting a client’s proxy would exceed any anticipated benefits to the client of the proxy proposal. How to Obtain Proxy Records and Voting Policy Clients may obtain information on how proxies were voted with respect to the clients’ portfolio securities or a copy of our Proxy Voting Policy by writing to SBH at 10 South Wacker Drive, Chicago, IL 60606 or by emailing compliance@cisbh.com. For information regarding how proxies were voted for the Segall Bryant & Hamill Funds, please refer to www.cisbh.com/funds/literature and select Proxy Voting Record. The Segall Bryant & Hamill Funds’ proxy voting records also are available on the SEC’s EDGAR website at www.sec.gov/edgar/search.

SBH does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance.