Stephens Investment Management Group LLC

Overview Stephens Investment Management Group, LLC ("SIMG") is an Arkansas limited liability company which was established in June 2005 and began providing investment advisory services in December 2005. We became registered with the Securities and Exchange Commission on September 2, 2005. Who Are Our Owners Our Firm is a subsidiary of Stephens Investments Holdings LLC, which is a privately held company owned by the Warren A. Stephens Trust which is controlled by Warren A. Stephens. Miles Stephens, John Stephens, and Laura Brookshire (née Stephens) also each hold minority financial positions and a 25 percent voting interest in the Firm via their respective trusts. Each is the sole beneficiary of his or her trust. Stephens Investments Holdings LLC holds the remaining 25 percent voting interest in the Firm. Certain key employees of SIMG are beneficiaries of an incentive plan and owners of “phantom shares” which entitles them to receive a percentage of the net profits of SIMG, but these key employees have no ownership interest in the voting shares of SIMG. Most of the beneficiaries of the incentive compensation plan previously owned non-voting B units of SIMG. These were repurchased and replaced by the current incentive plan and “phantom shares” in 2019. SIMG operates from two geographic locations—Houston, Texas and Little Rock, Arkansas. Investment management, trading, marketing, client service, and certain compliance and operations functions are located in Houston, Texas. Operations, administration, compliance and legal functions and additional client service functions are located in Little Rock, Arkansas. Our investment team initially joined Stephens Inc. in September 2004 and provided investment advice through Stephens Inc. through the end of November 2005. Advisory services began to be offered through SIMG in December 2005. Our Assets Under Management As of June 30, 2026, total assets managed and advised by SIMG were approximately $9.8 billion, with approximately $9.5 billion managed on a discretionary basis and approximately $221 million advised on a non-discretionary basis. The Types of Investment Advisory Services We Provide We provide investment advisory services to institutions, high net worth and other individuals, pension plans, foundations, corporations and other business entities, mutual funds and other types of clients. Our investment focus is on U.S. equity securities, although fixed income securities, mutual funds, exchange-traded securities, ADRs and other types of securities could be purchased for client accounts from time to time. We are a long only manager, and we do not generally use margin.

SIMG manages client assets under seven distinct investment management strategies described below. Although we do not tailor a customized investment program for the unique financial circumstances and objectives of a particular client, clients can impose reasonable investment restrictions on securities that would otherwise be traded in the strategy they select such as restrictions on investing in particular securities or types of securities and restrictions on investing in particular industries. Our Separately Managed Account Advisory Programs We offer investment management on a discretionary basis through separately managed accounts in the following seven strategies: • Small Cap Growth Our Small Cap Growth Strategy seeks long term growth of capital by investing primarily in small cap securities of U.S. companies which appear to us to have clear indicators of future earnings growth or appear to demonstrate other potential for growth. The applicable benchmark for this strategy is the Russell 2000® Growth Index. Our Small Cap Growth Strategy is available as a separately managed account advised by SIMG. • Mid Cap Growth Our Mid Cap Growth Strategy seeks long term growth of capital by investing primarily in mid cap securities of U.S. companies which appear to us to have clear indicators of future earnings growth or appear to demonstrate other potential for growth The applicable benchmark for this strategy is the Russell Midcap® Growth Index. Our Mid Cap Growth Strategy is available as a separately managed account advised by SIMG and in model programs offered through various affiliated and unaffiliated investment advisers. It is also available in wrap fee programs sponsored by various advisers. • Small and Mid Cap Core Growth (“SMID Core Growth”) Our Small and Mid Cap Core Growth Strategy is a diversified strategy which seeks long term growth of capital by investing primarily in small cap and midcap securities of U.S. companies which appear to us to have clear indicators of future earnings growth or appear to demonstrate other potential for growth of capital. The applicable benchmark for this strategy is the Russell 2500® Growth Index. Securities purchased for this strategy are predominantly securities of companies we perceive to be high quality, well managed businesses that have the potential for consistent, predictable revenue and earnings growth. Our SMID Core Growth Strategy is available as a separately managed account advised by SIMG, in a wrap fee program sponsored by Stephens Inc. for which SIMG acts as sub-adviser and in model programs offered through various affiliated and unaffiliated investment advisers. • Small and Mid Cap Select Growth (“SMID Select Growth”) Our Small and Mid Cap Select Growth Strategy is a diversified strategy which seeks long term growth of capital by investing primarily in small cap and midcap securities of U.S. companies which appear to us to have clear indicators of future earnings growth or appear to demonstrate other potential for growth of capital. The applicable benchmark for this strategy is the Russell 2500®

Growth Index. Securities purchased for this strategy are predominantly those perceived by us to have a significant positive business catalyst that may translate into accelerated earnings growth in the short term or long term. Our SMID Select Growth Strategy is available as a separately managed account advised by SIMG and in a model program offered through an unaffiliated investment adviser. • Leaders and Innovators The Stephens Leaders and Innovators Strategy is a diversified all-cap growth Strategy which seeks to invest in domestic companies, but can include international companies that we consider to be leaders and/or innovators in a particular industry and provides the opportunity to capitalize on the success of these companies. For comparison purposes this strategy is measured against the Russell 3000® Growth Index. Our Leaders and Innovators Strategy is available as a separately managed account advised by SIMG and in a model program through Stephens Inc., an affiliated investment adviser. • SMID Hybrid Growth The SMID Hybrid Growth Strategy invests primarily in small cap and mid-cap common stock of U.S. companies which appear to have near term catalysts for growth in addition to a consistent long term growth potential. This strategy is actively managed, and securities are frequently purchased and sold. For comparison purposes the composite is measured against the Russell 2500® Growth Index. Our SMID Hybrid Growth Strategy (previously known as the Hybrid Growth Strategy) is available as a separately managed account advised by SIMG. • Artificial Intelligence and Automation Our Artificial Intelligence and Automation Strategy invests primarily in securities of growth companies which provide artificial intelligence or automation technology, products, or services, or which sell technology, products, or services which enable the creation or delivery of artificial intelligence or automation solutions, or which are leveraging artificial intelligence or automation to enhance, improve, or grow their existing businesses. The portfolio is comprised largely of equity securities of US issuers, but can contain investments in a significant number of non-US issuers and nonequity investments. For comparison purposes the composite is measured against the Russell 3000® Growth Index. Since construction of this portfolio is focused on artificial intelligence and automation technology, its industry and sector exposure can vary greatly from that of the Russell 3000® Growth Index and we expect significant variances in returns. Our Artificial Intelligence and Automation Strategy is available as a separately managed account advised by SIMG and in a model program through Stephens Inc., an affiliated investment adviser. Investing in small cap and mid cap issuers involves greater risk than investing in more established companies and investors should only invest a portion of their total portfolio in these securities.

Our separate account business represents approximately 32% of the assets we advise as of June 30, 2026. This includes approximately 6% of the assets we advise in collective investments trusts (“CITs”). In separately managed accounts we advise, we have the discretionary authority to determine the securities, and the amount of securities, to be bought and sold for our clients without obtaining specific client consent. The discretionary authority regarding investments may, however, be subject to certain restrictions and limitations placed by the client on transactions in certain types of securities or industries. Any such limitations are to be agreed upon in advance with each client. Mutual Funds We Sub-Advise We sub-advise the American Beacon Stephens Small Cap Growth Fund and the American Beacon Stephens Mid-Cap Growth Fund. These funds use the same respective investment models that our advised separate accounts use for the Small Cap Growth Strategy and the Mid Cap Growth Strategy. Additionally, we serve as one of the investment advisers to the following multi-manager mutual funds using our SMID Select Growth Strategy or Small Cap Growth Strategy: • Vanguard Explorer™ Fund; • Bridge Builder Small/Mid Cap Growth Fund; and • First Trust Multi-Manager Small Cap Opportunities ETF. SIMG’s Small Cap Growth, Mid Cap Growth and SMID Select Growth Strategies are available to eligible investors through investments in collective investment trusts. Mutual fund assets represent approximately 68% of our assets under management as of June 30, 2026. Wrap Fee Accounts SIMG serves as a portfolio manager in various wrap fee programs sponsored by its affiliate, Stephens Inc., and by unaffiliated advisers. In these programs, SIMG receives a portion of the wrap fee as its advisory fee. SIMG’s investment advisory fee under these wrap fee or all inclusive fee arrangements may differ from that offered to other clients. The total investment advisory fees charged by the wrap fee program sponsor, a portion of which includes the fee paid to SIMG, can be higher than if SIMG advises the client directly. In evaluating these arrangements, a client should recognize that brokerage commissions or the execution terms of transactions in the client’s account are established by the sponsor and not by SIMG. In these wrap fee arrangements we are retained by the wrap fee program sponsor which, in turn, recommends or selects the advisory services of SIMG to one or more of its clients. Depending on the terms of the particular wrap fee program, we may or may not have investment discretion with regard to a particular program or account. In addition to other indicia of individual ownership, including the right to withdraw, hypothecate, vote, or pledge securities held in the wrap fee client’s account, a wrap fee client has the ability to place reasonable limitations and/or restrictions on the investments

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Overview of Fee Arrangements SIMG offers investment advisory services to clients under two types of fee structures: (1) fees based solely on a percentage of assets under management (“asset based fee”); and (2) asset/performance fee arrangements which are hybrid fees based on both a percentage of assets under management and on the performance of the client’s account (“asset/performance fee”). Fees are negotiable and vary from client to client. Managing accounts for differently situated clients with differing fee structures and rates in the same strategy and with the same investment team presents conflicts of interest for SIMG. Please review important disclosures concerning these conflicts in Item 6- PerformanceBased Fees and Side-By-Side Management Asset Based Fees for Separately Managed Accounts SIMG typically charges clients an investment advisory fee based on the value of the assets in the client’s account. Where we act as investment adviser to a client in a separately managed account, our maximum fee is as follows: Small Cap Growth Strategy Mid Cap Growth Strategy SMID Core Growth Strategy SMID Select Growth Strategy Leaders and Innovators Strategy SMID Hybrid Growth Strategy Artificial Intelligence and Automation Strategy

1.25% of assets under management 1.00% of assets under management 1.00% of assets under management 1.10% of assets under management 1.00% of assets under management 1.25% of assets under management 1.00% of assets under management

In each instance fees are negotiable and vary depending on the size of the investment, the nature of the services to be rendered by SIMG to the client, and other factors. Fees are typically invoiced quarterly, in arrears. We provide investment advisory services to our

affiliates, their officers, directors, employees and their family members at fee levels that are less than those noted above. Sub-Advisory Relationships In some instances we are retained to act as sub-advisor for a client’s assets in a separately managed account. In these situations the nature of the overall services we render to the particular client differs from those advisory relationships where we act as the sole investment adviser to a client and interface with the client directly. Consequently, our fees in these sub-advisory relationships are generally lower than the fees we charge where we act as the client’s sole investment advisor. Sub-advisory fees are negotiated on a case-by-case basis, and SIMG’s sub-advisory fees do not include the advisory fee charged by the client’s investment adviser. Asset/Performance Based Fee Arrangements On occasion, SIMG enters into fee arrangements whereby we are compensated under hybrid asset/performance based fee arrangements. Only certain clients qualify for asset/performance fee arrangements which compensate SIMG based, in part, on the performance of the client’s account. SIMG only enters into asset/performance fee arrangements with Qualified Clients (as defined in Rule 205-3 under the Investment Advisers Act of 1940) and in accordance with the requirements set forth in applicable laws, rules, and regulations. When suitable clients choose asset/performance fee arrangements, SIMG charges an asset based fee plus we receive a performance fee if SIMG’s net performance exceeds an agreed upon benchmark. The asset component of the asset/performance fee is computed and charged quarterly in arrears. The performance component of the asset/performance fee arrangement is computed and is paid annually in arrears. Additionally, the Vanguard Explorer™ Fund and SIMG have entered into an investment advisory agreement wherein we are paid an asset based fee plus a fulcrum performance fee based on SIMG’s average performance versus the benchmark over a five year period. The current benchmark utilized is the Russell 2500® Growth Index. It is not typical for SIMG to enter into asset/performance fee arrangements with clients. When we do enter into such arrangements, the terms of these arrangements are negotiated with clients on a case by case basis, and the structure of these arrangements will likely differ significantly from client to client. The particular fee arrangement chosen may not be the most advantageous to the client in all circumstances. We will reject any fee arrangement in instances where: (1) the Qualified Client standard is not met; (2) where we reasonably believe the investor lacks the necessary financial sophistication to enter into such an arrangement; (3) where a client purports not to fully understand our method of compensation and the nature of its risks; or (4) where we otherwise deem the client to be unsuitable for a hybrid asset/performance fee arrangement.

Pooled Vehicles SIMG’s fee schedule for investment companies, collective investment trusts and other pooled vehicle accounts may be higher or lower than the fees noted above for separately managed accounts depending on the circumstances of the client relationship. Such fees are negotiated on a case-by-case basis and are based on the assets in the mutual fund or the collective investment trust and can also include a performance component. The advisory fees for the mutual funds and collective investment trusts we advise or subadvise are set forth in each fund’s and trust’s prospectus or disclosure document. Payment of Fees Our advisory fees for our separately managed accounts are paid quarterly in arrears. If an account is custodied at Stephens’ clearing broker, Pershing, we typically arrange for our fee to be deducted from the client’s assets pursuant to an authorization from the client. Where client accounts advised by SIMG are custodied away from Stephens Inc.’s clearing broker-dealer, Pershing, we typically bill clients for fees incurred. For mutual funds which are sub-advised by SIMG, we typically submit an invoice for our fees to the adviser of the mutual fund. Other Types of Fees and Expenses Clients May Pay In addition to SIMG’s advisory fee, clients pay commission charges on each transaction executed in their account which is charged by the executing broker-dealer or execution facility. However, if a client’s account is under a wrap fee program such as the Stephens Small-Mid Cap Core Growth Program, commission charges are generally included as part of the wrap fee. This is more fully described in the brochure of the wrap fee program sponsor. Many of SIMG’s clients have engaged their own custodians, and they pay their custodian directly for any custodial charges. Certain clients of SIMG have selected custodians which are broker-dealers and which impose prime brokerage, trade away or account fees on trades or allocations that are not executed through their broker-dealer firm (“trade away fees”). These trade away fees are paid by the client to their custodian on each transaction in addition to the commission charged on the trade by the broker-dealer which executes the trade. SIMG does not charge custodial fees. For any mutual fund investment SIMG clients invest in, fees are also charged as more fully described in the mutual fund’s prospectus. These fees include the advisory fee and can include, if applicable, 12b-1 fees, interest, custodian and transfer agency fees, redemption fees, customary fund expenses and other charges. The mutual funds which SIMG sub-advises pay SIMG an investment advisory fee monthly or quarterly. Pre-Paid Advisory Fees SIMG does not itself charge clients fees in advance. However, SIMG advises certain wrap fee program sponsors which, under the terms of their particular wrap fee program, require their clients to pre-pay their advisory fees quarterly. After the wrap fee program clients pre-pay their advisory fees, SIMG is compensated based on an agreement with the wrap fee program sponsor which compensates SIMG based on a percentage of the assets

following its model portfolios. These programs include Unified Managed Accounts (UMAs) and separately managed accounts (SMAs). Please refer to the Form ADV brochure of the wrap fee program sponsor for a discussion of how clients may obtain a refund of pre-paid fees if the advisory contract is terminated before the end of the billing period. Compensation for the Sale of Securities and Investment Products None of our personnel receive revenues based on commissions from the sale of securities. However, our marketing personnel are compensated in part based on a percentage of the assets invested by clients in separately managed accounts or based on a portion of the revenues SIMG receives. Receiving a percentage of assets invested by clients or a percentage of the revenues SIMG receives from client investments presents a conflict of interest in that an SIMG employee who is recommending a particular investment strategy or mutual fund investment to a potential client receives compensation if the client ultimately invests in that strategy or fund rather than focusing on the specific client’s investment needs. However, SIMG does not tailor specific investment programs to any particular client’s financial needs and circumstances as clients hire SIMG for one of its specific investment strategies or funds. Further, SIMG does not advise clients with respect to investing in any mutual funds other than the funds we sub-advise. SIMG has policies and procedures and a Code of Ethics which address such conflicts. As an investment adviser our recommendations are confined exclusively to the accounts and mutual funds we advise or sub-advise. We advise or sub-advise both load and noload mutual funds, and these funds are available at net asset value in situations which meet the criteria set forth in the particular mutual fund prospectus. The mutual funds we advise or sub-advise are available through unaffiliated brokerdealers, through our affiliated broker-dealer and directly from the mutual funds’ distributor.

We manage the following investment strategies: • Small Cap Growth Strategy • Mid Cap Growth Strategy • Small and Mid Cap Core Growth Strategy • Small and Mid Cap Select Growth Strategy • Leaders and Innovators Strategy • SMID Hybrid Growth Strategy • Artificial Intelligence and Automation Strategy The American Beacon Small Cap Growth Fund we sub-advise utilizes the same investment model as our Small Cap Growth Strategy, the American Beacon Mid-Cap Growth Fund we sub-advise uses the same investment model as our Mid Cap Growth Strategy and the assets in the Vanguard Explorer™ Fund and the Bridge Builder Small/Mid Cap Growth Fund we sub-advise utilize the same investment model as our Small and Mid Cap Select Growth Strategy. Our investment strategies are premised on our belief that earnings growth drives stock performance. We believe that the small-cap and mid-cap markets are relatively inefficient due in part to less available information about many of the issuer companies in these markets. Lack of sell-side research coverage and lack of expertise at research providers to cover the vast universe of smaller capitalized companies contributes to these market inefficiencies. This in turn leads to opportunities to invest in these companies before they are more widely followed by research analysts. These markets contain securities with the potential to appreciate more quickly than other segments of the market with larger capitalized companies. We employ a bottom up investment selection process whereby we screen potential investments through a process of fundamental analysis on the potential investment and then apply quantitative screening to identify companies that we believe exhibit the potential for superior earnings growth. In analyzing potential investments, we seek to identify emerging companies or established high growth companies at an early stage of their lifecycle. Our investment process combines both “core growth” holdings and “earnings catalyst” stocks. Core growth companies are companies that exhibit fundamental traits such as consistent, high level of earnings growth, high returns on capital, experienced management teams, high barriers to entry and competitive edges in the industry. We also seek to own “earnings catalyst” stocks. Earnings catalyst securities are those companies where there is some

identifiable event that we believe should cause a period of accelerating earnings growth for the company such as a management change, an acquisition, a new product cycle or loss of a viable competitor. Our investment decision making process includes, among other things, some or all of the following steps: an analysis of each company’s business model and financial statements, attendance at presentations by and about the company at investment conferences, quantitative analysis on the company, meetings with company management and detailed industry due diligence. We many times speak with companies we are not considering for investment in order to gain better understanding of the company’s business, industry, competitors, suppliers and/or customers. We frequently utilize channel checks for companies we have invested in or that we are considering for investment. Most of our research on companies we are considering for investment is done internally through fundamental financial analysis on the company, quantitative screening and meetings with management. Our research process involves a team approach by our five member investment team composed of our Chief Investment Officer and our Portfolio Managers. Each member of our investment team specializes in industry sectors in order to provide our investment team with an in-depth knowledge of our entire portfolio composition. The Portfolio Manager responsible for a specific sector or industry will typically present an idea to the five member investment team for discussion. Stocks are typically discussed at various stages of the research process as a group and may be added or rejected based on several factors. The decision making process typically involves all members of the team. We utilize sell side research extensively, but it is never the sole basis of our investment decision making process. Other sources of information we utilize can include industry data composed of First Call reports, company filings, street research and models. Our primary investment database and screening tool is FactSet which we have been using since prior to the inception of SIMG. While FactSet is a software application, many of the screening tools we use within FactSet are proprietary applications we have developed. We utilize Bloomberg for real-time news and pricing. We currently use Thomson for some data feeds and research services. We frequently supplement this research by utilizing outside sources such as sell-side research and industry research. Additionally, we utilize artificial intelligence as part of our investment research process. Artificial intelligence is just one of several resources we use in our research process, and we do not base any investment decision solely on research obtained or derived using artificial intelligence. See below for additional discussion of the risks associated with the use of artificial intelligence. We also utilize various quantitative reports that measure such things as price changes, growth rates, profitability, valuation, earnings surprises and earnings revisions. These quantitative reports are used to help identify new stocks that meet our investment criteria and to monitor existing holdings.

We do not have a specific risk target for our portfolios or for our individual investments. Our risk objective is to surpass the performance of the benchmarks for our respective strategies with lower standard deviation, lower beta and a moderate tracking error to the appropriate benchmark. In constructing our portfolios, diversification is one of our primary tools for risk management. We monitor the level of investment in each sector relative to the sector weights of the respective benchmark, and our goal is to attempt to stay within a 50% band of the benchmark’s weight. For sectors with very small weights, this does not always hold true. Trading Costs For each of our seven investment strategies and the mutual funds we advise or subadvise, investors pay commission charges on the trades we enter with the broker or execution facility executing their trades unless the investor’s investment is made through a wrap fee program sponsored by an affiliated or unaffiliated investment adviser SIMG is advising. Since we frequently enter orders in most of our investment strategies and funds, commission charges can be substantial and will negatively affect an investor’s net investment return. Material Risks Investing in securities involves risk of loss, and clients should be prepared that they could lose all or a portion of their investment. The material risks associated with our strategies are: Small Cap and Mid Cap Company Risk - Investing in small cap and mid cap issuers involves a significantly greater risk than investing in larger, more established companies. The daily trading volume for small cap and mid cap issuers can be much lower than for more widely held, established companies. There may be periods when it is difficult to invest in or liquidate portfolio investments for our various investment strategies. This is particularly the case when breaking news on a company occurs or when significant market forces and events occur. In addition, small and mid cap companies may be more vulnerable to economic, market and industry changes. Because smaller companies may have limited product lines, markets or financial resources, or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than larger capitalization companies. Investors should only invest a portion of their total portfolios in these securities, and investors should be prepared to lose their entire investments. Equity Market Risk – Overall stock market risks may affect the value of the investments in equity strategies. Factors such as U.S. economic growth and market conditions, interest rates, and political events affect the equity markets. Management Risk - Our judgments about the attractiveness and potential appreciation of a particular asset class or individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. The price of an individual security

can be more volatile than the market as a whole and our investment thesis on a particular stock may fail to produce the intended results. Risks Associated with Cybersecurity SIMG relies in part on digital and network technologies (collectively, “cyber networks”) to conduct our business. Such cyber networks are at risk of cyber-attacks that could potentially seek unauthorized access to digital systems for purposes such as misappropriating sensitive information, corrupting data, or causing operational disruption. Cyber-attacks can potentially be carried out by persons using techniques that could range from efforts to electronically circumvent network security or overwhelm websites to intelligence gathering and social engineering functions aimed at obtaining information necessary to gain access. SIMG and its affiliates maintain an Information Security Policy and certain technical and physical safeguards intended to protect the confidentiality of internal data. Nevertheless, cyber incidents could potentially occur, and might in some circumstances result in unauthorized access to sensitive information about SIMG or its clients. Risks Associated with Use of Artificial Intelligence The use of artificial intelligence is subject to certain risks. Large language model artificial intelligence may generate responses that are factually incorrect or lack important context. Large language models may also have built-in biases that they do not disclose. SIMG seeks to mitigate these risks by using artificial intelligence as just one resource in its investment research process. SIMG does not base any investment decisions solely on information obtained or derived from artificial intelligence. Artificial intelligence is also subject to data privacy concerns, including the risk that data entered into a large language model will become public. SIMG seeks to mitigate this risk by utilizing an enterprise version of a large language model that does not train the large language model on information SIMG inputs. SIMG also does not enter client-specific information into the large language model to mitigate data privacy risks. While SIMG seeks to mitigate the risks associated with the use of artificial intelligence, SIMG is unable to mitigate or eliminate all risks associated with the use of artificial intelligence.

SIMG is primarily an investment adviser to institutional accounts, high net worth individuals and to investment companies. We provide investment advice to individuals, trusts, boards and retirement systems for various governmental pension and retirement plans, corporate pension and retirement plans, various foundations and private entities and investment companies. Our investment focus is on equity securities, although fixed income securities, mutual funds, exchange-traded securities and other types of securities may be purchased for client accounts in our various strategies from time to time. The minimum account size for each strategy SIMG advises is as follows: Small Cap Growth Strategy Mid Cap Growth Strategy Small and Mid Cap (SMID) Core Growth Strategy Small and Mid Cap (SMID) Select Growth Strategy Leaders and Innovators Strategy SMID Hybrid Growth Strategy Artificial Intelligence and Automation Strategy

$3,000,000 $2,000,000 $1,000,000 $1,000,000 $1,000,000 $1,000,000 $1,000,000

We can waive these minimum account sizes in our sole discretion. If the value of an account declines below our minimum account size for any reason after the account is opened, it is our normal practice to continue to maintain the account. However, we reserve the right to accept or decline any account and in accordance with the terms of a particular account’s investment agreement, we reserve the right to close an account if appropriate in our discretion. For the mutual funds and collective investment trusts we advise or sub-advise, the minimum investment in the American Beacon Stephens Small Cap Growth Fund, the American Beacon Stephens Mid-Cap Growth Fund, the Bridge Builder Small/Mid Cap Growth Fund, the First Trust Multi-Manager Small Cap Opportunities ETF, the Vanguard Explorer™ Fund and the Stephens Collective Investment Trust Funds vary by the share class and are set out in each fund’s prospectus or disclosure document.

Additionally, we advise wrap fee accounts in various programs sponsored by affiliated and unaffiliated investment advisers. The sponsor establishes a minimum account size for each program, and you should refer to the sponsor’s wrap fee brochure for a discussion of minimum account sizes and whether the minimum account size can be waived.

Potential Conflicts From Advising Different Types of Clients SIMG provides investment management advice to a variety of differently situated clients including institutional accounts, high-net-worth individuals, ERISA accounts, state pension plans and mutual funds. Certain types of clients and certain fee arrangements can create potential conflicts of interest for SIMG. For example, some accounts and funds pay performance fees to SIMG while other accounts pay only an asset based fee. Some accounts may have the ability to influence the placement of additional assets with SIMG. The beneficial owners of some accounts we manage are affiliates or owners of SIMG or members of their family. The same investment professionals at SIMG manage accounts with these potential conflicts on a “side by side” basis with accounts that do not have such characteristics. SIMG has an incentive to favor “conflicted” accounts over other accounts, and variations in performance compensation structures among clients can

create an incentive for SIMG to allocate securities to clients that pay performance compensation or pay higher fees than other clients. We are conscious of these potential conflicts. As a fiduciary, the goal of our policies and procedures is to act in good faith and to treat all client accounts in a fair and equitable manner over time regardless of their fee arrangements or the influence of their owners or beneficiaries. SIMG has adopted various written policies and procedures to address the fair allocation of investment opportunities across client accounts. SIMG policies utilize the following approach to help ensure that each client receives fair and equitable treatment in the investment process: •

Employee and Firm Interests. Accounts in which employees or affiliates have a beneficial interest, or in which SIMG has a conflict of interest are not to receive preferential treatment.

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Identification of Accounts for Participation. The decision on which accounts should participate in an investment opportunity, and in what amount, is based on the client’s strategy and whether or not that strategy is selected by the portfolio managers for inclusion in the investment opportunity. Once a strategy is selected to be included in an investment opportunity, the size of the order is computed based on the size of the client’s account. The decision to select a strategy for an investment opportunity is a qualitative decision that the portfolio managers make on a case by case basis. It is not subject to “bright line rules”, but it is influenced by the market capitalization of the security being purchased, whether or not there is available uninvested cash in the strategy and the client’s account, the exposure of the strategy and the account to the industry and to the sector of the issuer, the impact on the portfolio and on portfolio risk, whether the account has imposed or is subject to investment restrictions and other practical considerations.

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Aggregation of Client Interests. Portfolio managers are required to submit orders for all the participating accounts at the same time. Generally, all orders in the same security are aggregated to facilitate best execution and to reduce brokerage commissions and/or other costs.

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Allocation. Executions for aggregated orders are combined to determine an average price. The shares are then allocated to participating accounts pro rata based on the size of the order. However, when in the judgement of the portfolio managers an investment opportunity is de minimis or too limited to be meaningful to an account, the strategy is excluded from the allocation.

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Deviations from the Standard Methodologies. Under certain circumstances an allocation may not produce results consistent with the portfolio manager requirements, and an alternative allocation method may be used, which must achieve a fair, equitable and objective distribution of the shares.

Most of our fee structures are based solely on the assets the client has invested, but we can also manage accounts in hybrid fee structures that compensate SIMG based on the assets invested and the capital appreciation of the assets of the client’s account. Additionally, our Small and Mid Cap Select Growth separate account strategy utilizes the same model portfolio and investment strategy as the portion of the Vanguard Explorer™ Fund and the Bridge Builder Small/Mid Cap Growth Fund which we sub-advise. The Vanguard Explorer™ Fund pays SIMG an asset based fee plus a fulcrum performance fee. Having the same investment team manage client assets in the same strategy with different fee structures at the same time is known as side-by-side management and constitutes conflicts of interest. This conflict of interest consists of an incentive for our investment team: • • •

to favor accounts for which we receive a performance-based fee with investment opportunities where we do not receive the full amount of securities we seek to buy for all of our advised accounts to give favorable pricing to performance based fee accounts; and to prefer performance based fee accounts over asset based fee accounts in the trade entry process.

Certain clients have guidelines or restrictions imposed on their portfolios by law or regulations. This includes the Employee Retirement Income Security Act of 1974 (“ERISA”), the Investment Company Act of 1940, the Internal Revenue Code and other local or state laws. Clients with separately managed accounts may impose additional investment guidelines and restrictions on our discretion. These can include guidelines designed to reduce risk, single stock or sector restrictions, or socially responsible restrictions (such as no investments in a company domiciled in a rogue country). The client is required to inform SIMG of these guidelines and restrictions. Clients with separately managed accounts who wish to restrict certain issuers from their portfolios are required to provide us with the names of the proscribed issuers, which is then coded in the trade management system. If a client seeks to have industry-related restrictions, we generally will use issuer lists generated by third parties. As an investment advisor to separately managed account programs, SIMG accommodates reasonable restrictions imposed by the client on the management of the client. However we can decline to accept investment guidelines submitted by clients that we determine to be unduly restrictive in light of the investment strategy. Potential conflicts of interest exist where established market prices are not available and where SIMG must value such illiquid securities. Additionally, asset/performance fee arrangements provide an incentive for us to make investments that involve more risk and are more speculative than would be the case in the absence of an asset/performance based fee.

We have adopted policies, procedures and practices which are reasonably designed to mitigate these conflicts of interest so that all clients are treated fairly with respect to investment opportunities, pricing and trade entry priority over time depending on the particular strategy or fund in which they invest. For a more complete discussion of our trading practices with respect to the timing of the entry of orders for different strategies or for our mutual funds, please see Item 12 of this Brochure on Brokerage Practices below. Our Small and Mid Cap Select Growth Strategy utilizes the same model portfolio and investment strategy as the portion of the Vanguard Explorer™ Fund and the Bridge Builder Small/Mid Cap Growth Fund which we sub-advise. The Vanguard Explorer™ Fund pays us an asset and fulcrum performance fee

SIMG is a subsidiary of Stephens Investments Holdings LLC, which is owned by a trust controlled by Warren A. Stephens. Miles Stephens, John Stephens, and Laura Brookshire (née Stephens) also each hold minority financial positions a 25 percent voting interest in the Firm via their respective trusts. Each is the sole beneficiary of his or her trust. Stephens Investments Holdings LLC holds the remaining 25 percent voting interest in the Firm. SIMG is also affiliated with firms engaged in a wide variety of businesses including financial and non-financial products and services. SIMG is affiliated, through common ownership, with Stephens Inc., an investment banking firm which is registered as a broker-dealer, an investment adviser and a municipal adviser with the Securities and Exchange Commission and is an introducing broker. Additionally, Stephens Inc. performs pension consulting services for certain of its clients. Stephens Inc. is indirectly owned by various trusts controlled by Warren A. Stephens and certain members of his family. Some of SIMG’s executive, operations, legal, and compliance personnel perform services/functions for both SIMG and Stephens Inc. SIMG serves as advisor to Stephens Inc. or Stephens Inc. clients in a number of wrap fee programs sponsored by Stephens Inc. Many of the accounts advised or sub-advised by SIMG are introduced by Stephens Inc. to its clearing broker, Pershing, LLC, which performs custody and other services for Stephens Inc. clients. SIMG receives other services from Stephens Inc., or other Stephens affiliates, including human resources, legal, accounting, research, tax, informational and other technology services. In addition, Stephens Inc. may act as dealer, agent and/or broker-dealer with respect to portfolio transactions for and on behalf of SIMG’s clients. Stephens Inc. and its employees refer prospective clients to SIMG and may be compensated for any such referrals. Hotchkis & Wiley Capital Management, LLC is a registered investment adviser in which a minority ownership interest is ultimately owned by various trusts controlled by Warren A. Stephens. Hotchkis & Wiley Capital Management, LLC is not controlled by or under common control with SIMG. Affiliates of SIMG also own investments in other businesses in a wide variety of industries. SIMG, on behalf of its clients, may invest in securities of issuers in which affiliates of SIMG have an ownership interest. SIMG’s investment decisions on behalf of its clients are made independently from the investment decisions of its affiliates. Accordingly, SIMG’s investment decisions may be different from and/or inconsistent with investment decisions of its other affiliates. Many of the operational services performed for SIMG such as computer and technology support and communications services are performed by Stephens Inc. affiliates which are owned by Stephens Financial Services LLC. Stephens Financial Services LLC is owned by various trusts controlled by Warren A. Stephens and certain members of his family.

SIMG serves as sub-adviser to the American Beacon Stephens Small Cap Growth Fund and the American Beacon Stephens Mid-Cap Growth Fund and serves as adviser to the Vanguard Explorer™ Fund, the Bridge Builder Small/Mid Cap Growth Fund, and the First Trust Multi-Manager Small Cap Opportunities ETF for a portion of those Funds’ respective assets. Two SIMG employees are registered representatives of Stephens Inc., including Warren Simpson, who serves as a management person of SIMG. SIMG Industry Affiliations Stephens Inc. provides a variety of investment banking and other related services to various clients, including issuers of securities that SIMG may recommend for purchase or sale by clients. In the course of providing these services, SIMG and its affiliates may come into possession of material, nonpublic information that might affect SIMG’s ability to buy, sell or hold a security for a client account. SIMG and Stephens Inc. have adopted various policies that are intended to prevent the communication of material, nonpublic information to SIMG’s personnel. SIMG believes that the nature and range of clients to whom affiliates of SIMG render investment banking services is such that it would be inadvisable to exclude these companies from a client’s portfolio. Accordingly, unless a client advises SIMG to the contrary, it is possible that client holdings may include the securities of companies for which affiliates of SIMG perform investment banking services or other services. Moreover, a client portfolio may include the securities of companies in which affiliates of SIMG make a market or in which SIMG or its affiliates, or their respective directors, officers and/or employees, have positions. SIMG provides investment advisory services to one or more of our affiliates (including their personnel). With respect to the selection and timing of investment decisions, SIMG will endeavor to treat the advisory accounts of its affiliated clients in a manner that is substantially the same as the manner in which it treats the advisory accounts of its other clients who are similarly situated, absent account specific restrictions and/or limitations, but there can be no assurance that it will do so in all cases. SIMG may, from time to time, be restricted from buying or selling certain securities on behalf of its affiliated clients owing to the business activities of its affiliates. For example, SIMG may not be permitted to purchase certain securities for its affiliates if Stephens Inc. is in possession of material inside information. Additional information relevant to the conflicts presented by these affiliations is included in Item 11 below.

and Personal Trading Code of Ethics

SIMG has adopted a Code of Ethics pursuant to SEC rule 204A-1 that sets forth standards of conduct for SIMG’s employees and procedures for securities transactions by its employees in their personal accounts. Generally, under the Code of Ethics, portfolio managers and other “investment persons” must seek pre-approval of all transactions (subject to certain narrow exceptions). Investment persons may not purchase or sell any security which at the time is being purchased or sold, or to such person’s knowledge, is being considered for purchase or sale, by any client account and may not purchase or sell a security within 7 calendar days of a fund or advised account trading in the security. Short term trading is discouraged and investment persons and senior officers may not purchase and sell or sell and then purchase the same security within a 60 day period. These restrictions may be subject to certain de minimis provisions and may be waived upon consent of SIMG’s Compliance Department based on individual circumstances. In addition, SIMG’s investment persons must pre-clear all trades for personal securities accounts with compliance personnel, subject to certain exceptions (e.g. trades with respect to U. S. government securities, commodities, futures, exchange traded funds, options on futures and options on broadbased indices). SIMG’s personnel may not purchase initial public offerings. SIMG’s access persons are required to have duplicate copies of confirmations or statements with respect to every brokerage account they hold sent to SIMG in order to permit the monitoring of compliance with SIMG’s personal trading policies and restrictions. Personnel must report all personal securities transactions no less than quarterly. SIMG’s employees must report violations of the Code of Ethics to SIMG’s Chief Compliance Officer. All access persons are required to maintain their personal accounts and accounts in which they have a beneficial interest at our affiliated broker-dealer unless the account has been specifically exempt in writing from this requirement. No individuals enter trades directly in their personal accounts. A copy of SIMG’s Code of Ethics is available free of charge to any client or prospective client who requests a copy. SIMG may, from time to time, invest in securities issued by clients of the firm, and SIMG may invest in securities in which SIMG or one of our related persons has a material financial interest. SIMG’s investment team makes the decision to buy or sell a specific security through a process of consultation among the five members of our investment team. There are information barriers in place in accordance with our Code of Ethics and our procedures which prohibit communication of our investment decisions to others outside of SIMG. Therefore, SIMG operates somewhat independently of Stephens Inc. and its affiliates with respect to investment decisions. Sometimes, our investment decisions involve securities in which we or one of our related persons has a financial interest or an ownership position. This presents a potential conflict of interest with respect to our clients. Except for publicly available ownership disclosures to the SEC (Forms 3 and 4, Schedule 13D, 13G and 13F), SIMG is generally not aware of

investments Stephens affiliates have in a particular company until they rise to a 5% investment level or higher. Participation or Interest in Client Transactions From time to time, we may seek to effect a principal transaction between our firm (or an affiliate) and a client. Before buying any security from, or selling any security to, a client, we will obtain the client’s prior consent to the transaction and otherwise comply with applicable law concerning the transaction. Principal transactions in securities in which Stephens Inc. acts as a market-maker will only be effected for clients if Stephens Inc. matches or betters the highest bid/lowest ask prices as reflected on NASDAQ, if applicable, and the client’s prior consent to such transactions has been obtained. No mark-downs or mark-ups from the highest bid/lowest ask price will be charged. Stephens Inc., acting as a market-maker, has the potential for profit or loss on securities it, as principal, sells to or buys from such clients depending on the price at which the transaction is executed. Securities may be purchased for certain clients during an underwriting syndicate of which an affiliate of SIMG is a member or from an affiliate of SIMG as a private placement agent. Any such purchase for a client that is a registered investment company will be made in accordance with procedures adopted by the company’s board of trustees pursuant to Rule 10f-3 under the Investment Company Act of 1940. All such purchases for ERISA accounts will be made in accordance with Department of Labor Prohibited Transaction Exemption 95-83 (September 13, 1995). We may effect portfolio transactions in securities or other instruments through an affiliate on an agency basis subject to applicable restrictions under the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940 and ERISA. These transactions will be effected through an affiliate when, in SIMG’s judgment, they are consistent with obtaining best price and execution for the client. These transactions may be effected through affiliates of SIMG even though the total brokerage commission for a transaction may be higher than that which might have been charged by another broker for the same transaction. SIMG may effect “agency cross transactions” in which an affiliate of SIMG acts as agent for both the buyer or seller in the transaction and receives a commission from both the buyer and the seller. Any agency cross transaction will be effected in compliance with Rule 206(3)-2 under the Investment Advisers Act of 1940 and other applicable law. From time to time, we may deem it appropriate that one of our clients should purchase a particular security while another client should sell the same security. In this situation, it may be advantageous to both clients to cross the transactions internally between the two accounts by having the “purchasing” client purchase the securities directly from the “selling” client (“cross-trading”). Cross-trading can prevent both accounts from having to pay either the commission charges or the markups or markdowns that would be incurred if the trades were effected through broker-dealers in the open market. Cross-trading presents a potential conflict of interest between the firm and one or both clients in that

such trades could be effected for reasons other than the best interests of such clients. We follow specific procedures designed to ensure that any such trades, if effected, are done on a fair and equitable basis. For certain of our clients, such as clients subject to ERISA, we may be limited in our ability to purchase the securities of issuers in which SIMG affiliates have an ownership interest. SIMG may recommend to clients that they purchase shares of mutual funds we subadvise. Such clients, along with other fund shareholders, will bear a proportionate share of the expenses of those funds, including, to the extent permitted by law, the management fee paid to SIMG. In addition, we may have discretion to select money market mutual funds, or comparable investments, in which to hold cash reserves. Certain of these money market mutual funds may pay Stephens Inc. a distribution and/or servicing fee. Any such fees would be in addition to the fees that are paid to SIMG for advisory and/or other services.

Selection of Broker-Dealers for Client Transactions SIMG is typically authorized to determine, without specific client consent, the broker or dealer for securities transactions in the client’s account. SIMG’s objective in selecting brokers and dealers and in effecting portfolio transactions is to seek to obtain the best combination of price and execution with respect to its accounts’ portfolio transactions. The best net price, giving effect to brokerage commissions, spreads and other costs, is normally an important factor in this decision, but a number of other subjective factors are considered as they are deemed relevant. SIMG frequently selects broker-dealers with which it has commission sharing arrangements and broker-dealers that have provided SIMG with research services as described in the sections below. SIMG maintains a list of approved broker-dealers to which we direct client trades. SIMG may consider the following factors, among others, in developing its Approved Broker List: quality of overall execution services provided by the broker-dealer; promptness of execution; creditworthiness and business reputation of the broker-dealer; research (if any) provided by the broker-dealer; access the broker-dealer facilitates with company management including research conferences and individual meetings; promptness and accuracy of oral, hard copy or electronic reports of execution; ability of the broker-dealer to use ECNs to gain liquidity, price improvement, lower commission rates and anonymity; the market where the security trades; any expertise the broker-dealer may have in executing trades for the particular type of security; commission charged by the broker-dealer; reliability of the broker-dealer; whether the broker-dealer gives clients of the Firm access to IPOs; soft dollar program of the broker-dealer; size of the order; financial condition of the broker-dealer; whether the broker-dealer can maintain and commit adequate capital when necessary to complete trades; whether the broker-dealer can respond during volatile market periods; the number of incomplete trades made by the broker-dealer; the broker-dealer’s level of trading expertise, including its ability to search

for and obtain liquidity to minimize market impact, accommodate unusual market conditions, complete trades, execute unique trading strategies, execute and settle difficult trades, and maintain the anonymity of the Firm; ability to account for its trade errors and correct them in a satisfactory manner; and overall commitment to technology and its access to a trading system with the following characteristics: order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and settlement process, and capacity to accommodate unusual trading volume. In selecting the broker-dealers to which an order will be routed for execution, SIMG does not consider any additional fees which a client’s broker-dealer custodian may charge on trades not routed to the client’s broker-dealer custodian. Trade away fees charged by the client’s custodian will negatively impact the net return which the client experiences. As discussed below, in selecting broker-dealers SIMG may use client commissions to effect portfolio transactions for client accounts in excess of amounts other broker-dealers would have charged for effecting similar transactions if we determine in good faith that the commissions paid are reasonable in relation to the value of the brokerage and research services provided to us by those broker-dealers, viewed either in terms of a particular transaction or SIMG’s overall duty to its discretionary accounts. Research and Other Soft Dollar Benefits When we believe more than one broker is capable of providing the best combination of overall price and execution, we frequently select the broker on a particular trade based upon the value of research services that firm has provided to us and our clients. Many of the brokerage firms SIMG uses provide us with their research and execute trades for our clients at rates which include bundled research and execution services. These bundled commission rates are typically higher than rates other broker-dealers would charge for execution only services. When investment advisers select a broker-dealer because of the value of the research services that broker-dealer provides, this is known as paying for those services with “soft dollars”. Because many of those research services benefit SIMG since we do not have to produce or pay for the research services ourselves and because the “soft dollars” used to acquire them are assets of SIMG’s clients, we face a conflict of interest in allocating client brokerage business. We have an incentive to select a broker-dealer based on our interest in receiving its research services rather than on our clients’ interest in receiving the most favorable execution or lowest commission rate. SIMG does not have any agreed-to levels of commissions which are due to any particular broker-dealer, but we understand that if over time we do not provide a sufficient level of revenue to the broker-dealer providing us with research services, the firm will discontinue providing its research to us. We use soft dollar benefits to service all of our clients’ accounts and the mutual funds and pooled investment vehicles we advise or sub-advise. Since we invest mostly in

small-cap and mid-cap equity securities, research we receive is generally beneficial to all of our clients, and we make no effort to limit or track which specific clients’ commissions have paid for a particular research service. Where it is appropriate we aggregate orders for client accounts, and research provided to us through soft dollar arrangements generally involves commissions from more than one of our advised accounts. Therefore, it is likely that research which benefits a particular client account may have been “paid for” through commissions generated by other clients of SIMG in various advised strategies. The types of research services provided to us include information as to particular companies and securities, as well as more general market, financial and economic information. Examples of research-oriented services for which SIMG might utilize client commissions include research reports and computerized financial data. If a research product provides both a research and a non-research function, then SIMG will make a reasonable allocation of the use and pay for the non-research portion with hard dollars. The allocation between research and non-research depends on the use of the product. Our evaluation of the reasonableness of the brokerage commissions paid is based primarily on the professional opinions of the persons responsible for the placement and review of the transactions. Their opinions are formed on the basis of their experiences in the securities industry and information available to them concerning the level of commissions being paid by other investors of comparable size and type. We may select broker-dealers based on our assessment of their ability to provide quality executions and our belief that the research, information and other services provided to us may benefit client accounts. It is not possible to place a dollar value on the special executions or on the research services SIMG receives from broker-dealers effecting transactions in portfolio securities. As part of SIMG’s review of its trading processes, SIMG evaluates the capabilities and brokerage and research services provided to SIMG by broker-dealers we have used and the commission rates charged by those broker-dealers for their services. Overall, trades are sent to broker-dealers considering these evaluations. Although we receive proprietary research and other services from Stephens Inc., our affiliate, the only client trades SIMG sends to Stephens Inc. for execution are for Stephens Inc. sponsored wrap fee programs in which orders are generally directed to Stephens Inc. under terms of the wrap fee program. SIMG also participates in commission sharing arrangement programs with certain of our executing broker-dealers. In these programs, the executing broker-dealer executes the order at a previously agreed rate (the execution charge) plus SIMG instructs the executing broker-dealer to add an additional amount as a research credit to compensate entities which provide SIMG with eligible research services. The amount charged to

execute the order is the sum of the execution charge plus the research credit. The amount of research credit added to the order may vary since SIMG determines the amount of the research credit on an order by order basis. Research credits accumulate at the executing broker-dealer and periodically, SIMG instructs broker-dealers with which it has commission sharing arrangements to compensate firms which have provided SIMG with eligible research services. These services include providing macroeconomic research, providing daily economic, political and accounting data, and newsletters which assist the portfolio management team with perspectives on global events and themes in positioning the portfolios. These services also include hard dollar payments for research services provided by sell-side broker-dealers. Brokerage for Client Referrals SIMG does not consider whether it has obtained client referrals as a criterion in its selection of a broker-dealer. Directed Brokerage From time to time some of SIMG's clients direct us to route their portfolio transactions through a particular broker-dealer at a commission rate agreed upon between the client and the broker. In such cases, SIMG typically does not negotiate commission rates with such broker-dealers unless we have been expressly requested to do so by the client. Clients are free to choose or change broker-dealers at their discretion unless there is reason to believe the chosen brokerage firm cannot offer adequate service. In such an event, SIMG might be unable to accept management of the account. A client who directs us to use a particular broker-dealer should carefully consider whether such a directed brokerage arrangement could result in additional costs or disadvantages to it. These costs and disadvantages include paying higher commissions and receiving less favorable executions. Accordingly, the client should satisfy itself that the broker-dealer it directs us to route their trades to can provide adequate price and execution of transactions. A client that directs us to use a particular broker-dealer can also be subject to certain disadvantages as discussed below regarding allocation of new issues, secondary offerings and aggregation of orders. SIMG may place orders for transactions in certain securities initially only for those accounts that are custodied at banks or at brokerage firms that permit SIMG to place trades for accounts custodied at that firm with other brokerage firms. Accounts custodied at brokerage firms that do not permit SIMG to place transactions with other brokerage firms may not be able to participate in the initial transaction and may not be able to participate in the same gains or losses as other clients whose accounts are not so restricted. In determining whether to direct SIMG to use a particular broker-dealer, the client should compare the possible costs or disadvantages of such an arrangement. SIMG will often purchase and/or sell the same securities for multiple client accounts. It is our practice, where appropriate, to aggregate or “bunch” orders for the purchase or sale of a particular security for the accounts of several clients for whom SIMG has discretion

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Neither SIMG nor any of our employees receives any economic benefit, sales awards or other prizes from any outside parties for providing investment advice to our clients. SIMG has a solicitation agreement with Stephens Inc. in accordance with Rule 206(4)-1 and 206(4)-5 under the Investment Advisers Act of 1940 whereby Stephens Inc. can receive compensation for referrals that representatives of Stephens Inc. make to SIMG. Compensation to Stephens Inc. typically involves paying some portion of the

management fee SIMG receives. Clients referred to SIMG by Stephens Inc. pay a higher fee rate than clients who are not referred by Stephens Inc. SIMG is affiliated with Stephens Inc. through common ownership. SIMG also compensates certain of its employees based in part on new client account relationships developed by them. This compensation to the employees is based on the amount of assets in these accounts under the management of SIMG. SIMG may from time to time provide additional compensation out of its own resources to financial intermediaries. This compensation can consist of support payments or compensation to financial intermediaries in connection with cooperative advertising, and client seminars and meetings at which the SIMG-advised products or services are discussed. SIMG can from time to time provide exhibit space or sponsor events which provide opportunities for SIMG-advised products and services to be discussed. SIMG occasionally gives clients gifts, entertains certain of its clients with meals or tickets to sporting events or other functions and makes contributions to charitable functions and events. Such contributions, payments, entertainment and gifts may provide intermediaries and their salespersons with an incentive to favor the SIMG-advised products and services over other products and services.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SIMG or the integrity of SIMG’s management. There are no legal or disciplinary events relating to SIMG or its management. Stephens Inc. is considered to be a “related person” to SIMG since it is under common control with us and certain of our employees are registered with Stephens Inc. However, Stephens Inc. is not an “advisory affiliate” of SIMG as defined in Form ADV and the instructions thereto. If your investment is made through Stephens Inc. or if you have an advisory relationship with Stephens Inc., please refer to Form ADV of Stephens Inc. for relevant information on legal and disciplinary events relating to Stephens Inc.

Ryan E. Crane as Chief Investment Officer is responsible for supervisory approval of new advisory accounts, the investment advice given by SIMG to each client, reviewing trading activity and reviewing client portfolios. The frequency and scope of client portfolio reviews depends upon the investment advisory agreement and the nature of the relationship between the client and SIMG. Trading and investment activity in client accounts and the client’s cash position is normally reviewed daily for all accounts. Additionally, portfolio reviews for client accounts are conducted on at least a quarterly basis by SIMG’s administrative and operational staff assigned to the account. SIMG’s Board of Managers meets periodically and reviews investment performance of the various strategies offered by SIMG, the composition of the various investment strategies, and other matters related to the investment operations of SIMG. Most clients receive monthly statements from SIMG on their account, but they can request that statements be sent quarterly. The frequency of other reports provided to clients by SIMG depends on the nature of the client and their reporting needs. For instance, many governmental retirement systems require customized reports and mutual fund clients require specialized reporting in order to allow the board of directors of the mutual fund to discharge its supervisory responsibilities. In addition to the reports clients receive from SIMG, clients receive reports directly from their qualified custodian that provide them with information regarding their investment holdings, transactions during the period covered by the report, management and other fees, investment performance, and portfolio valuation.

SIMG has authority from many of our clients to debit fees from client accounts. SIMG submits a request to its affiliate, Stephens Inc., to process the fee debits, and Stephens initiates the debits to the client accounts for those clients who have requested that their advisory fees be debited. For this reason, SIMG is deemed to have a limited form of custody of client assets. Stephens Inc. is an affiliated broker-dealer to SIMG through common ownership, and Pershing, LLC serves as the qualified custodian and clearing broker-dealer for Stephens Inc. Stephens Inc., also serves as wrap fee sponsor to certain SIMG client accounts. SIMG engages a certified public accounting firm (“CPA”) firm to conduct an annual surprise examination, on a sample basis, of client accounts for which SIMG or a related person has custody of client assets. The CPA firm submits the Form ADV-E, as required.

SIMG has discretionary investment authority over the accounts we manage. Clients execute an Investment Management Agreement with SIMG which provides us with discretionary authority to select the securities to be bought or sold in their account. In the Investment Management Agreement or a similar agreement or notification to SIMG, clients can impose reasonable restrictions on the type of investments SIMG can make in their account. Investment limitations and restrictions must be provided to SIMG in writing. Examples of restrictions clients have imposed on SIMG are no options or derivative securities, no securities of companies doing business with Sudan in furtherance of the Darfur initiatives and no foreign securities.

Proxy Voting and Corporate Actions Unless SIMG and a client have otherwise agreed, SIMG will typically vote proxies for the voting securities held in client accounts. Proxies will be voted in the best interest of SIMG’s clients in accordance with the SIMG’s Proxy Voting Policy (the “Policy”). SIMG has established a Proxy Committee that has responsibility for determining SIMG’s voting procedures, exceptions to the procedures and how SIMG will vote proxies on securities held in advisory accounts. SIMG has retained an independent proxy voting service provider to provide research, guidelines, recommendations and other proxy voting services for client proxies. Absent a determination by the Proxy Committee to override the independent provider’s guidelines and/or recommendations, SIMG’s client proxies will be voted in accordance with those guidelines and/or recommendations. SIMG is part of a large financial services organization that has investment banking and other business relationships with, and/or ownership interests in, many issuers of securities. Such relationships may, from time to time, create or give rise to the appearance of a conflict of interest between SIMG and its clients. SIMG has implemented procedures designed to help prevent conflicts of interest from influencing its proxy voting decisions. These procedures include information barriers and, most significantly, the use of an independent third party to assist in the proxy voting process. Clients may obtain a copy of SIMG’s Proxy Voting Policy and/or information on how SIMG voted the securities held in their account by sending SIMG a written request. Clients can instruct SIMG on how to vote the securities they hold by providing SIMG with instructions in writing. From time to time there may also be a variety of corporate actions or other matters for which shareholder action is required or solicited and with respect to which SIMG may take action that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the client. These actions may include, for example and without limitation, responding to tender offers or exchanges, bankruptcy proceedings and proposed class action settlements. However, SIMG will have no power, authority, responsibility or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in the client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets.

SIMG currently has the ability to meet all contractual obligations to our clients. We do not have any debt obligations, and we do not plan on borrowing any money in the future. A. We do not require prepayment of fees longer than three months in advance.

B. SIMG has discretionary authority over client accounts. There are no financial conditions that are likely to impair our ability to meet our contractual commitments to clients. C. SIMG has not been the subject of a bankruptcy petition at any time during the past ten years.

Part 2B of Form ADV Brochure Supplement for INVESTMENT TEAM Ryan E. Crane John M. Thornton Patricia (Kelly) Ranucci Samuel M. Chase John R. Keller

Stephens Investment Management Group, LLC 111 Center Street Little Rock, Arkansas 72201 (800) 458-6589 Stephens Investment Management Group, LLC Investment Team 9 Greenway Plaza, Suite 1900 Houston, Texas 77046

July 16, 2026 This brochure supplement provides information about the persons listed above that supplements the Stephens Investment Management Group, LLC brochure. You should have received a copy of that brochure. Please contact Michael W. Nolte, Chief Operating Officer at the above number if you did not receive Stephens Investment Management Group, LLC’s brochure or if you have any questions about the contents of this supplement. *Additional information about the persons listed above is available on the SEC’s website at www.adviserinfo.sec.gov.

Ryan E. Crane Executive Vice President Chief Investment Officer Education and Business Background Year of Birth: 1972 Education: University of Houston-BS 1994 Houston, TX Other Professional Designations: Chartered Financial Analyst* Business Experience: Stephens Inc., 9/2004 – 12/2023 Stephens Investment Management Group, LLC, 7/2005 - present Disciplinary Information None Additional Compensation: Mr. Crane is paid incentive compensation which compensates him in part based on the assets under management at SIMG which includes the level of assets in separately managed accounts and SIMG sub-advised mutual funds. Mr. Crane also receives incentive compensation under a plan which compensates him a portion of the net profits of SIMG. Supervision: Warren Simpson, Chief Executive Officer of SIMG supervises Ryan E. Crane’s advisory activities on behalf of our firm. Mr. Simpson can be reached at (501) 377-2000. Mr. Simpson is in direct contact with Ryan Crane on virtually a daily basis. Both Mr. Simpson and Mr. Crane are members of SIMG’s Board of Managers, and our Board meetings review investment activities of Mr. Crane and the SIMG Portfolio Managers. Both the Chief Compliance Officer and the Chief Operating Officer interface with Mr. Simpson to bring relevant issues to Mr. Simpson’s attention.

John M. Thornton Senior Portfolio Manager Education and Business Background Year of Birth: 1973 Education: Vanderbilt University Nashville, TN-B.E. 1995 University of Texas, Austin, TX-M.B.A. 2000 Other Professional Designations: Chartered Financial Analyst* Business Experience: Stephens Inc., 9/2004 – 12/2023 Stephens Investment Management Group, LLC, 7/2005 - present Disciplinary Information None Additional Compensation: Mr. Thornton is paid incentive compensation which compensates him in part based on his performance as a portfolio manager which includes the success of his investment ideas. He is not compensated based on sales or the level of assets under management. Mr. Thornton also receives incentive compensation under a plan which compensates him a portion of the net profits of SIMG. Supervision: Ryan E. Crane, Chief Investment Officer of SIMG supervises John M. Thornton’s advisory activities on behalf of our firm. Mr. Crane can be reached at (713) 9934200. SIMG’s investment decisions are made by the five member Portfolio Management team which is headed by Mr. Crane as Chief Investment Officer and includes SIMG’s four Portfolio Managers of which Mr. Thornton is a member. Information concerning portfolio holdings and potential investments for SIMG’s clients is shared among members of our Portfolio Management team and it is the collective Portfolio Management team which makes investment decisions for our clients. As head of the Portfolio Management team, Mr. Crane is fully integrated into all phases of investment advisory activities of Mr. Thornton.

Patricia (Kelly) Ranucci Senior Portfolio Manager Education and Business Background Year of Birth: 1971 Education: Texas A&M University-B.B.A. 1993 College Station, TX University of Houston Houston, TX-M.B.A. 2003 Other Professional Designations: Chartered Financial Analyst* Business Experience: Stephens Inc., 9/2004 - 12/2023 Stephens Investment Management Group, LLC, 7/2005 - present Disciplinary Information None Additional Compensation: Ms. Ranucci is paid incentive compensation which compensates her in part based on her performance as a portfolio manager which includes the success of her investment ideas. She is not compensated based on sales or the level of assets under management. Ms. Ranucci also receives incentive compensation under a plan which compensates her a portion of the net profits of SIMG. Supervision: Ryan E. Crane, Chief Investment Officer of SIMG supervises Patricia (Kelly) Ranucci’s advisory activities on behalf of our firm. Mr. Crane can be reached at (713) 993-4200. SIMG’s investment decisions are made by the five member Portfolio Management team which is headed by Mr. Crane as Chief Investment Officer and includes SIMG’s four Portfolio Managers of which Ms. Ranucci is a member. Information concerning portfolio holdings and potential investments for SIMG’s clients is shared among members of our Portfolio Management team and it is the collective Portfolio Management team which makes investment decisions for our clients. As head of the Portfolio Management team, Mr. Crane is fully integrated into all phases of investment advisory activities of Ms. Ranucci.

Samuel M. Chase Senior Portfolio Manager Education and Business Background Year of Birth: 1977 Education: Washington and Lee University-B.A. 1999 Lexington, VA, Southern Methodist University-M.B.A. 2004 Dallas, TX Other Professional Designations: Chartered Financial Analyst* Business Experience: Stephens Inc., 9/2004 - 12/2023 Stephens Investment Management Group, LLC, July 2005 - present Disciplinary Information None Additional Compensation: Mr. Chase is paid incentive compensation which compensates him in part based on his performance as a portfolio manager which includes the success of his investment ideas. He is not compensated based on sales or the level of assets under management. Mr. Chase also receives incentive compensation under a plan which compensates him a portion of the net profits of SIMG. Supervision: Ryan E. Crane, Chief Investment Officer of SIMG supervises Sam Chase’s advisory activities on behalf of our firm. Mr. Crane can be reached at (713) 9934200. SIMG’s investment decisions are made by the five member Portfolio Management team which is headed by Mr. Crane as Chief Investment Officer and includes SIMG’s four Portfolio Managers of which Mr. Chase is a member. Information concerning portfolio holdings and potential investments for SIMG’s clients is shared among members of our Portfolio Management team and it is the collective Portfolio Management team which makes investment decisions for our clients. As head of the Portfolio Management team, Mr. Crane is fully integrated into all phases of investment advisory activities of Mr. Chase.

John R. Keller Portfolio Manager Education and Business Background Year of Birth: 1978 Education: University of Puget Sound-B.A. 2000 Tacoma, WA Tulane University-M.B.A. 2005 New Orleans, LA Other Professional Designations: Chartered Financial Analyst* Business Experience: Stephens Inc., 8/2009 - 12/2023 Stephens Investment Management Group, LLC, September 2013 - present Disciplinary Information None Additional Compensation: Mr. Keller is paid incentive compensation which compensates him in part based on his performance as a Portfolio Manager which includes the success of his investment ideas. He is not compensated based on sales or the level of assets under management. Mr. Keller also receives incentive compensation under a plan which compensates him a portion of the net profits of SIMG. Supervision: Ryan E. Crane, Chief Investment Officer of SIMG supervises John Keller’s advisory activities on behalf of our firm. Mr. Crane can be reached at (713) 9934200. SIMG’s investment decisions are made by the five member Portfolio Management team which is headed by Mr. Crane as Chief Investment Officer and includes SIMG’s four Portfolio Managers of which Mr. Keller is a member. Information concerning portfolio holdings and potential investments for SIMG’s clients is shared among members of our Portfolio Management team and it is the collective Portfolio Management team which makes investment decisions for our clients. As head of the Portfolio Management team, Mr. Crane is fully integrated into all phases of investment advisory activities of Mr. Keller.

________________________________________________________________ *The Chartered Financial Analyst designation is awarded to investment professionals who have successfully completed the requirements set forth by the CFA Institute (formerly known as the Association for Investment Management and Research, or AIMR). The CFA Institute is an international non-profit organization whose stated mission is to promote and develop a high level of educational, ethical and professional standards in the investment industry. To be eligible for the CFA designation, candidates must pass 3 examinations that test the academic portion of the CFA program, possess a bachelor’s degree from an accredited educational institution or equivalent, and have 48 months of acceptable professional work experience. The CFA curriculum includes the following subject areas: Ethical and Professional Standards; Quantitative Methods (such as the time value of money, and statistical inference); Economics; Financial Reporting and Analysis; Corporate Finance; Analysis of Investments (such as stocks and bonds); and Portfolio Management and Analysis (asset allocation, portfolio risk, and performance measurement).

Privacy Notice Stephens Investment Management Group, LLC (“SIMG”) FACTS

WHAT DOES SIMG DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Social Security number and account transactions • Account balances and assets • Transaction and purchase history

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons SIMG chooses to share; and whether you can limit this sharing.

Does SIMG Share?

Can you limit this sharing?

For our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We do not share

For our affiliates’ everyday business purposes – information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes – information about your creditworthiness

No

We do not share

For nonaffiliates to market to you

No

We do not share

Reasons we can share your personal information.

Visit us online: http://www.stephensimg.com

To limit our sharing

PLEASE NOTE: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share our information as described in this notice. However, you can contact us at any time to limit our sharing.

Privacy Notice

Questions?

Contact us at: http://www.stephensimg.com California residents only: You have the right to request the deletion of your personal information.

What we do. How does SIMG protect my personal information?

To protect your personal information from unauthorized access and use, we utilize security measures that comply with federal law. These measures include computer safeguards, secured files and buildings.

How does SIMG collect my personal information?

We collect your personal information, for example, when you: • Open an account • Seek advice about your investments • Buy securities from us or sell securities to us • Give us your contact information • Enter into an investment advisory contract • Make deposits or withdrawals from your account

Why can’t I limit all sharing?

Federal law gives you the right to limit only: • Sharing for affiliates’ everyday business purposes information about your creditworthiness • Affiliates from using your information to market to you • Sharing for nonaffiliates to market to you • State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices apply to everyone on your account.

Definitions Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include Stephens Inc., Stephens Insurance, LLC, Stephens Wealth Planning and Strategy Group Inc. and Stephens Shared Services LLC.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with include our outsourced back office SEI Global Services, Inc.

Joint marketing

Read the rest in the brochure