William Blair & Company

Firm Description William Blair is a global investment firm offering investment management and related services to clients. The firm was founded in 1935 and is registered with the SEC as both an investment adviser and a securities broker-dealer. William Blair (a privately held company) is a wholly owned subsidiary of WBC Holdings, L.P., which is wholly owned by current William Blair employees (we also refer to employee owners as ‘partners’ in this Brochure). William Blair also is an affiliate of William Blair Investment Management, LLC, an investment adviser registered with the SEC (“WBIM”). WBIM provides institutional investment management business, separate from the other business lines within William Blair. Investment Advisory Services William Blair’s private wealth management division (“PWM”) and its advisors (“PWM Advisors”) provide discretionary and non-discretionary investment management services to clients for a fee. Clients pay us investment advisory fees based on fee schedules as described in Item 5. William Blair also manages accounts for wrap fee program clients. Our advisory services may include investments in affiliated or unaffiliated products, the retention of affiliated or unaffiliated investment managers or sub-advisers, and the use of models provided by affiliated or unaffiliated model providers. Our authority to invest in affiliated products, retain affiliated investment managers or sub-advisers, or use affiliated model providers depends on the terms of the client’s advisory agreement, any other authorization provided by the client, and applicable law. As a discretionary investment manager, we provide investment management services in accordance with each client's investment advisory agreement, investment guidelines and other account documentation. We accept reasonable investment restrictions if they do not hinder our ability to implement the applicable investment strategy. Subject to the client's governing documents and applicable law, we may invest in affiliated or unaffiliated investment products, retain affiliated or unaffiliated investment managers or sub-advisers, and use models provided by affiliated or unaffiliated model providers. According to a client's investment objectives and subject to reasonable investment restrictions, a PWM Advisor may also allocate all or a portion of a discretionary advisory client's assets to one or more our proprietary models ("William Blair Proprietary Home Office Models"). In certain cases, we provide investment guidance to clients on a non-discretionary basis (on either a portion of the assets held in the account or the entire account) with the client making final investment decisions. William Blair provides non-discretionary advisory services to other registered investment advisers by delivering model portfolios (“Non-Discretionary Model Portfolio Program”). With respect to the Non-Discretionary Model Portfolio Program, William Blair has no investment discretion, no knowledge of the underlying investment advisers’ clients, no authority to effect and/or execute trades on behalf of these registered investment advisers’ clients and no knowledge as to whether a registered investment adviser followed any of our non-discretionary investment recommendations. We provide non-discretionary investment advisory services to these registered investment advisers based on strategy model portfolios (similar to how we manage other separate accounts). William Blair has an indirect, minorityownership interest in certain investment advisers that participate in the Non-Discretionary Model Portfolio Program. Wrap Fee Program Clients William Blair serves as an investment manager to and sponsor of a comprehensive advisory fee program (also known as a wrap fee program), the “William Blair Wrap Program,” as described further in William Blair’s Form ADV 2A, Appendix 1, also known as our “William Blair Wrap Fee Program Brochure.” A wrap fee program is a program where a client is charged a specified “bundled” fee (generally, a percentage of assets under management) for discretionary investment management services and trade execution costs and sometimes other services such as custody, record keeping and reporting. In order to participate in a William Blair Wrap Program, an advisory client must maintain a brokerage account with William Blair, as introducing broker-dealer. As described more fully below, Fidelity Investments and/or its various affiliates including but not limited to National Financial Services and Fidelity Brokerage Services (collectively, “NFS”) acts as clearing broker and provides custodial, clearing, settlement and certain other services for William Blair Wrap Program advisory clients.

Our compensation under our William Blair Wrap Fee Program may be lower than our standard fee schedule; however, the overall cost of a wrap arrangement may be higher than a client otherwise would pay if the client paid our standard fee schedule and negotiated transaction costs and any other services (e.g., custody, record keeping and reporting) through a broker-dealer. William Blair’s wrap program fees and standard advisory fees are negotiable. Platform Clients William Blair has entered into agreements with certain asset management platform providers (each, a “Platform Provider”). These Platform Providers offer investment-management platforms through which William Blair may access investment advisers, sub-advisers, model portfolios, and related services (each, a “Platform”). For certain discretionary advisory clients, PWM Advisors may retain affiliated or unaffiliated investment advisers as sub-advisers (the “SubAdvisers”) through Platform Providers or directly through William Blair. A Sub-Adviser may directly manage allocated account assets on a discretionary basis or provide a model that is implemented by William Blair, a Platform Provider or another investment adviser. The authority to retain a Sub-Adviser or use a model, including one provided by an affiliate, is subject to the client’s advisory agreement, any other authorization provided by the client, and applicable law. Some Platform Providers and their underlying Sub-Advisers require information from clients, such as agreement to their standard terms & conditions, a client profile or application and other related documentation (including, in some instances, the opening of custodial and/or brokerage accounts). Your PWM Advisor will work with you to obtain any Platform required documentation. A client may impose reasonable restrictions on the management of account assets being managed on a Platform, such as the designation of particular securities or types of securities that should not be purchased or that should be sold if held in the account. As the client will not be able to communicate directly with any Sub-Adviser available through a Platform, the client should communicate these reasonable restrictions to their William Blair PWM Advisor. Sub Advisory Clients In some instances, certain entities hire William Blair to manage assets for their underlying clients. In these instances, William Blair acts in a sub-advisory capacity. In some instances, William Blair has discretion to buy, sell and hold securities in the underlying clients’ accounts. In other instances, William Blair acts in a non-discretionary capacity and the ultimate decision to buy, sell or hold securities is made by the registered investment adviser that hired William Blair. In some instances, the underlying client is able to communicate with William Blair while in other instances all communication is between William Blair and the entity. WBIM Sub-Advisory Accounts William Blair has entered into a sub-advisory arrangement with its affiliate, WBIM. Subject to the client's investment advisory agreement, investment guidelines, elections, other account documentation and applicable law, William Blair may retain WBIM as a Sub-Adviser to directly manage allocated assets on a discretionary basis or may use model portfolios provided by WBIM that are implemented by William Blair, a Platform Provider or another investment adviser. A client may restrict or prohibit our use of WBIM by providing written notice to William Blair, subject to our acceptance and ability to implement the restriction. William Blair MB Investments Program William Blair established the “MB Investments Program” to provide select clients with access to certain investment opportunities generated through William Blair’s proprietary, global relationship network. William Blair MB Investments GP, LLC, a William Blair affiliate, (“MB General Partner”), serves as the general partner to William Blair MB Investments, L.P., a Delaware series limited partnership (“MB Partnership”). The MB Partnership’s investments are made in (a) other investment funds (such as private equity, debt, venture capital, and real estate) and (b) direct investments in private capital and business combination transactions including private company financings (ranging from early-stage to late stage rounds), leveraged and unleveraged buyout transactions, and management buyout

transactions; and (c) co-investment opportunities (“Co-Investments”) (collectively, “MB Investments”). A new series will typically be formed to invest in each MB Investment (“Series”). An investor must independently and affirmatively elect to participate in the MB Investments Program and to invest in a Series and, if admitted as a limited partner, will receive interests in that Series (“Interests”). Interests in a Series are in Client’s name, and ownership is recorded in the books and records of the MB Partnership. In certain cases (e.g., where the Co-Investment is made through the sponsor’s investment vehicle), such Co-Investment will be held in Client’s name and ownership will be recorded in the books and records of the Co-Investment issuer. The MB Partnership is excluded from regulation under the Investment Company Act of 1940, and its securities are exempt from registration under the Securities Act of 1933. Accordingly, investors are not afforded the protections of those Acts. As discussed in the MB Partnership offering documents and in the non-discretionary investment advisory agreement, the MB General Partner uses its good faith efforts to determine the fair market value of Interests. To the extent a client participates in the MB Investments Program through a non-discretionary investment advisory account, William Blair earns an investment advisory fee based on the fair market value of the Interests. Our affiliate, the MB General Partner, values the Interests. The higher the fair market value of the Interests or Co-Investment, the more William Blair earns in advisory fees, creating a conflict of interest. The MB General Partner can delegate to William Blair certain management and administrative responsibilities including the authority to select investment opportunities and make investment-related decisions on behalf of the MB Partnership. Investment advice is provided directly to the MB Partnership and not individually to the limited partners. William Blair and PWM Advisors will not provide investment advice or recommendations to clients with respect to participation in the MB Investments Program or investing in any Series. A client independently decides to participate in the MB Investments Program and affirmatively elects to purchase Interests in each MB Partnership Series. A Series limited partner can contribute capital through a brokerage account, advisory account, bank account or otherwise. Once the client invests in any Series through a non-discretionary advisory account, William Blair will provide asset allocation, monitoring and performance reporting. Information regarding limited partner eligibility, fees, expenses, risks, conflicts of interest and terms and conditions are set forth in the MB Partnership offering documents as well as highlighted in this Brochure. Note that William Blair may also sponsor and / or manage other affiliated private funds separate from the MB Investments Program. Clients independently decide to invest in such private funds. Similar to MB Investments, investments in affiliated private funds are made in the Client’s name, and ownership is recorded in the books and records of the applicable partnership. Such private funds are excluded from regulation under the Investment Company Act of 1940, and its securities are exempt from registration under the Securities Act of 1933. Accordingly, investors are not afforded the protections of those Acts. Proxy Voting, Corporate Actions and Other Legal Matters Clients have the option of voting proxies directly or delegating proxy voting discretion to William Blair or a third party. In cases where William Blair has proxy voting discretion, Institutional Shareholder Services, Inc. (“ISS”) provides proxy voting, maintenance, reporting, analysis and recordkeeping services for William Blair with respect to proxies for companies whose securities are managed by William Blair on a discretionary basis. Assets under Management As of December 31, 2025, William Blair had approximately $64.3 billion in assets under management, of which, we managed approximately 90% on a discretionary basis and 10% on a non-discretionary basis.

William Blair provides discretionary and non-discretionary investment management services to clients and charges annual fees, payable quarterly either in advance or in arrears, depending on the terms of the applicable investment advisory agreement. We charge up to a 2.00% fee on account assets, subject to negotiation. The assets included in the advisory-fee calculation depend on the client’s advisory agreement, any other authorization provided by the client, the type of account and applicable law. For accounts that are not subject to the prohibited transaction provisions of ERISA or Section 4975 of the Internal Revenue Code (“Retirement Accounts”), we generally include assets invested in affiliated and unaffiliated products, directly managed by affiliated and unaffiliated Sub-Advisers, or managed using models provided by affiliated and unaffiliated model providers in the assets used to calculate our advisory fee. The account also bears applicable product-level fees and expenses, Sub-Adviser fees, model-provider fees and Platform Provider fees. For Retirement Accounts, we generally charge our advisory fee on assets invested in unaffiliated products, but generally waive our advisory fee on assets invested in affiliated products or directly managed by affiliated SubAdvisers. The account remains subject to applicable product-level or affiliated Sub-Adviser fees and expenses, and William Blair or its personnel may receive revenue sharing or other compensation from an affiliate based on those assets. If WBIM or another affiliate provides a model, the Retirement Account will not bear a separate fee for the model, although a Platform Provider fee and the fees and expenses of investments held through the model may apply. These arrangements are subject to the applicable advisory agreement, any other authorization provided by the client and applicable law. Please see Item 4 of our William Blair Wrap Fee Program Brochure and the applicable investment advisory agreement for additional information. Ongoing fees reduce the value of an investment portfolio over time. Because of the fees you pay, you have a smaller amount invested that is earning a return when the fee is debited from a portfolio’s assets. You are encouraged to discuss the impact of fees with your PWM Advisor. Note that William Blair is a private partnership; a primary factor in becoming a partner of the partnership, and the compensation paid to a partner, is the amount of revenue generated by a particular employee or partner, as the case may be. Employees and partners are therefore incented to increase revenue, which presents conflicts of interest between our employees and you. To mitigate these conflicts, we maintain our Code of Ethics (“Code”), which details our fiduciary duty to put our clients’ interests ahead of our own, and we conduct annual training on our Code. We also have established supervisory controls and procedures to oversee the actions of our employees and partners and their compliance with applicable law. Client’s custodian shall be responsible for valuing all assets in a client’s account; valuation is not the responsibility of William Blair. Securities without a readily available market price shall be valued as determined in good faith by custodian, as appropriate, to reflect their fair value. William Blair, Platform Providers and Sub-Advisers will cooperate with custodian in custodian’s good faith efforts to determine fair market value. With respect to client account assets in alternative investments (such as private funds), alternative investment managers and underlying vehicles are responsible for providing custodian with valuation in accordance with applicable laws. Payment of Fees Many of our clients elect to have their quarterly fees directly debited from their accounts while others choose to receive an invoice. We prorate fees based on the length of time we managed your account in the event you opened or terminated your account during the quarter. We will refund any fees prepaid but not yet earned or will request prompt payment for any fees earned but not yet paid. Other Fees and Expenses In addition to, and separate from, the investment management fee, our clients pay other costs and charges in connection with their accounts or certain securities transactions payable to William Blair or its affiliates or payable to

parties other than us. Depending on your arrangement with William Blair, these may include, among other fees and expenses, the following (also refer to Item 12 – Brokerage Practices):

Commissions and other charges for executing trades through broker-dealers;

Transaction fees for the purchase or sale of mutual funds in advisory accounts;

Dealer mark-ups, markdowns and spreads;

Auction fees;

Certain odd-lot differentials;

Exchange fees;

Taxes, duties and other governmental charges, such as transfer taxes;

Costs associated with international exchange transactions;

Electronic fund, wire transfer and other transfer fees;

Fees imposed for certain types of custody or brokerage accounts;

Fees imposed in connection with certain custodial, trustee or other account services;

Account maintenance or service fees; Fees in connection with transferring your account to another investment advisor or broker-dealer (“ACAT Exit Fees);

Regulatory transaction fees;

Securities lending fees;

Multi margin fees;

Non-purpose loan fees;

Platform Provider fee and Sub-Adviser fee;

Access Fees for certain private funds; Performance-based fee, if applicable, on certain MB Partnership Series;

Mutual fund redemption fees if shares are sold before the designated time period set forth in a prospectus;

Fees and expenses associated with mutual funds (including William Blair Funds), exchange traded funds and other commingled products (such as affiliated private funds including Blair Private Funds, William Blair MB Investments and other private funds sponsored and / or managed by William Blair);

Fees associated with separate accounts established with affiliated and unaffiliated registered investment advisers;

Pass-through or other fees associated with American Depositary Receipts;

Fees and charges related to reporting, including performance reporting;

Activity assessment fee;

Charges mandated by law or regulation; and

Fees in connection with the establishment, administration, maintenance, or termination of accounts (including retirement or profit-sharing plans or trust accounts).

Further information regarding the fees and expenses is found in your investment advisory agreement with William Blair as well as in other documents such as brokerage account documentation, other third-party service provider documentation, third party advisory and/or Platform Provider documentation and mutual fund and private fund offering documents. For more information regarding fees and expenses, please discuss with your PWM Advisor. Other Fees and Expenses Related to NFS, Platform Providers and Other Third-Party Providers William Blair has entered into agreements with NFS whereby NFS provides custodial, brokerage and certain other services for certain clients of William Blair. Clients who choose to use NFS’s services enter into the applicable custodial and/or brokerage agreements. Clients are not required to use NFS for these services, and clients are free to work with other custodians. Please note that not all custodians provide the same services or services at the same cost

as NFS. Each client who considers NFS is provided with the appropriate agreements and applicable fee schedules at that time. Third party managers utilized by the client through an asset management Platform Provider must maintain a custodial account with NFS and direct most, if not all trades, to NFS or William Blair. Pursuant to an agreement with NFS, in addition to a one-time payment by NFS to William Blair upon contract renewal in 2023, William Blair receives certain fees and credits including, but not limited to, those set forth in this section. NFS pays William Blair a fee in connection with moving new client assets to the NFS platform (the “Transition Credit”). In certain cases, the amount of the Transition Credit exceeds the amount of the fee charged by the prior custodian in connection with the transfer, and William Blair retains the excess amount. If William Blair terminates its agreements with NFS, William Blair repays NFS a portion of the Transition Fees. Also pursuant to an agreement with NFS, William Blair receives from NFS a portion of the fees it charges or credits it pays related to certain services, including securities lending, multi-margin accounts, non-purpose loans and certain fixed income trades executed through systems made available by NFS, among other services offered for certain types of client accounts as disclosed in applicable agreements for those services. If you choose to enter a multi-margin relationship, our advisory fees increase as the market value of your investment portfolio increases. Our offer to provide margin as a strategy creates a conflict of interest since we stand to receive increased advisory fees, and William Blair earns margin revenue from NFS based on your interest payments. If you choose to loan your securities, NFS pays you a fee based on the loan. NFS reduces the amount of the loan fee paid to you by the amount that NFS pays to William Blair. Our continued receipt of our advisory fee on the security as if it were not loaned as well as NFS paying us a portion of your loan fee creates a conflict of interest. In addition, because we receive this fee and have discretionary authority over purchases and sales of securities in your account, we are incented to purchase and hold securities that are available to be loaned (or generate a larger loan fee) instead of those that are ineligible to be loaned or garner a lower fee. PWM Advisors are compensated on multi-margin and securities lending. NFS offers non-purpose loans, for a fee, collateralized by assets in your advisory accounts. NFS shares with William Blair a portion of the interest earned on non-purpose loans. As with multi-margin, William Blair’s receipt of a portion of NFS’ interest fees on non-purpose loans creates a conflict of interest and incentivizes William Blair to recommend NFS over other providers. In addition, William Blair charges its advisory clients certain operational fees such as: “ACAT Exit Fees, fees for wire transfers, foreign exchanges, bounced checks, and IRA terminations, as well as other fees described in the client account documentation. The amount that William Blair charges its clients is higher than the amount that William Blair pays to NFS in connection with those services. William Blair keeps the difference between the fee its clients pay, and the amount paid to NFS for coordination and oversight of these services provided through NFS as well as to generate revenue. This presents a conflict of interest since setting a higher fee increases the revenue William Blair receives even though it results in you paying higher fees. These markups are in addition to the investment advisory fees you pay us, and you should consider the additional revenue that William Blair receives when evaluating the appropriateness of our investment advisory fees. NFS has also agreed to pay William Blair business development and technology development credits. If William Blair terminates its agreements with NFS, William Blair repays NFS a portion of these credits. These fees, charges and credits cause conflicts of interest because: 1) they incentivize William Blair to recommend clients utilize NFS custodial and other services instead of another custodian; 2) they incentivize William Blair to recommend securities lending, non-purpose loans and margin activity; and 3) they incentivize William Blair to maintain its relationship with NFS to avoid repayment of Transition Fees and business, infrastructure, technology development and other credits. To help manage these conflicts, we rely on controls including the following:

payments and credits as well as a description of conflicts are disclosed in documents including, but not limited to, this Brochure, Wrap Brochure, advisory agreements, the Customer Relationship Summary (“Form CRS”), prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms;

PWM Advisors are not compensated based on Transition Fees, or business, infrastructure, and technology credits (PWM Advisors are compensated on multi-margin and securities lending);

We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own, and conduct annual training on our Code; and

PWM Advisors are obligated to employ a standard of care and comply with clients’ investment guidelines and restrictions when selecting investments for clients’ accounts.

Read the rest in the brochure

Methods of Analysis William Blair is an active investment manager and utilizes a variety of methods and strategies to make investment decisions and recommendations. When evaluating investment opportunities, we employ fundamental and technical research methods using various resources such as financial news sources and websites; corporate data; ratings services; third party research; SEC filings (e.g., annual reports, prospectuses); company press releases; and proprietary research. The following describes our principal investment strategies as of the date of this Brochure. Descriptions of strategies are qualified in their entirety by reference to the applicable investment advisory agreement and related investment guidelines as well as by the applicable prospectus and statement of additional information for mutual fund investments and offering documents for private fund investments. 1.

Private Wealth Management Investment Strategies

William Blair offers custom wealth management based on each client’s individual needs and objectives. In choosing investments for clients, we consider a broad array of securities and investment vehicles, including but not limited to: common stocks, corporate, government and municipal fixed income securities, affiliated and unaffiliated mutual funds, private funds and money market funds. In addition, for certain clients, we have discretion to hire Sub-Advisors directly or through Platform, and WBIM may serve as Sub-Advisors when not otherwise restricted.

2.

William Blair Platform Strategies

PWM Advisors select Sub-Advisers based on each client’s unique objectives, risk tolerance and financial profile and provide ongoing advice to clients. We emphasize asset allocation to help manage risk and return in portfolios. PWM Advisors access Sub-Advisers through Platforms or, in some cases, directly. In our investment process, we seek SubAdvisers who meet initial and ongoing due diligence standards for manager selection evaluation, as well as management style and performance track record. In most instances, William Blair does not independently conduct due diligence on Sub-Advisers available on the Platforms. In addition, certain clients authorize us to hire our affiliate, WBIM, as a Sub-Adviser. In other instances, we recommend that a client establish a WBIM Separate Account. We hire our affiliate as a Sub-Adviser or recommend our affiliate as an adviser in instances where a WBIM strategy meets a client’s unique objectives, risk tolerance and financial profile. We do not conduct any initial or ongoing due diligence on WBIM. Clients are provided the applicable Platform Providers’, Sub-Advisers’ and/or WBIM’s Form ADV Part 2A. 3.

Private Fund Investments

Based on each client’s individual needs and objectives, William Blair may recommend that the client invest in affiliated or unaffiliated private funds. Our investment process before recommending an unaffiliated private fund typically includes investment and due diligence reviews, including assessment of relevant investment and operational factors. As part of our investment process, we either conduct initial and ongoing due diligence internally and/or by employing external consulting and research resources. For private fund investments that are offered through certain external alternative investment platforms, we rely upon research and due diligence processes and materials developed by the third-party Platform Providers. The third-party Platform Provider relies either on proprietary research resources of the third-party platform or consultants employed by the third-party platform. We do not conduct independent initial or ongoing due diligence on unaffiliated private funds accessed through the third-party platforms. We do not conduct any initial or ongoing due diligence on Blair Private Funds. With respect to the MB Investments Program and other private funds sponsored or managed by William Blair, William Blair does not make any recommendations to clients regarding participation therein. However, the MB General Partner, the general partner of any private fund sponsored or managed by William Blair or William Blair conducts initial due diligence on the underlying investment opportunities. For example, the MB General Partner (or an affiliate, including William Blair) either conducts initial due diligence internally and/or employs external due diligence consulting and research resources when assessing relevant investment and operational factors related to potential MB investment opportunities. No initial or ongoing due diligence is conducted on William Blair Managed MB Investments. RISK OF LOSS All investments in securities involve a risk of loss of your principal (invested amount) and any profits that have not been realized (i.e., the securities have not been sold to "lock in" the profit). The value of securities in an account can go up or down, sometimes rapidly or unpredictably. Local, regional or global events such as war, acts of terrorism, the spread of infectious illness or other public health issue, recessions or other events could have a significant impact on the valuation of securities. Securities may decline in value due to factors affecting securities markets in general or particular industries represented in the securities markets. The value of a security may decline due to general market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. The value of a security may also decline due to factors that affect a particular industry or industries, such as labor shortages or increased production costs and competitive conditions within an industry. During a general downturn in securities markets, including those unrelated to financial markets (such as a global pandemic), multiple asset classes may decline in value simultaneously. If an Account is not diversified, a loss in a single position or group of positions with a concentrated, aggregate exposure could have a materially adverse impact on an Account. In addition, if you enter into securities lending, margin and/or non-purpose loans arrangements, there are additional risks to your principal, as more fully described in separate account documentation. There is no guarantee that any investment strategy will achieve its stated investment objectives. William Blair cannot guarantee any level of performance or that you will not experience a loss of account assets.

Common Risks Associated with Equity Investments Investments in equity securities can expose you to certain specific risks such as the following:

Equity securities. Equity securities (stocks) held in your portfolio may decrease in response to activities of companies or market and economic conditions.

Growth stocks. Growth stocks may be more sensitive to market movements because their prices tend to reflect future investor expectations rather than just current profits and may underperform value stocks during given periods.

Value stocks. Value stocks may perform differently from the market as a whole and may be undervalued by the market for a long period of time and may underperform growth stocks during given periods.

Small-capitalization companies. Small cap stocks may exhibit erratic earnings patterns, competitive conditions, limited earnings history, and a reliance on one or a limited number of products.

Initial public offerings. Initial public offerings (IPOs) are subject to high volatility and limited availability.

Private placements. Private placements may be classified as illiquid and difficult to value.

Options. Purchasing options involves the risk that the underlying instrument will not change price in the manner expected, so an investor loses their premium. Selling options involves potentially greater risk because the investor is exposed to the extent of the actual price movement in the underlying security, which could result in a potentially unlimited loss.

ESG Investing. Portfolios that select securities based on Environmental, Social and Governance (“ESG”) factors or similar criteria may forgo certain market opportunities available to portfolios or strategies that do not use these criteria. In this regard, the strategy will be precluded from purchasing, or required to sell, certain investments that otherwise meet its objective and strategy and that might otherwise be advantageous to hold. The application of the ESG factors could result in performance that is better or worse than the performance of a similar strategy, depending on the performance of the excluded investments and the investments included in place of such excluded investments. Integrating ESG analysis into investment decisions requires qualitative determinations and is often subjective by nature, and there can be no assurance that the process utilized, or any judgment exercised by William Blair, will operate as expected when addressing positive environmental or social benefits.

Common Risks Associated with Non-U.S. Investments Investments in non-U.S. securities can expose you to certain specific risks, including risks associated with equity investments previously described above, as well as the following:

Current market conditions. In recent years, debt and equity markets, domestic and international, have experienced increased volatility and turmoil, which can adversely impact your portfolio.

Liquidity in financial markets. The financial markets in the U.S. and elsewhere have experienced a variety of difficulties and changed economic conditions, which could adversely impact the value of your portfolio’s assets.

Government intervention and market disruptions. The global financial markets have undergone fundamental disruptions that have led to extensive and unprecedented government intervention that could prove detrimental to the efficient functioning of the markets and adversely impacting your portfolio.

International markets. International markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments.

International securities. International stocks are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets.

Emerging markets. Securities traded in certain emerging markets may be subject to risks due to the inexperience of financial intermediaries, the lack of modern technology, the lack of a sufficient capital base to expand business operations, and the possibility of temporary or permanent termination of trading. Political and economic structures in many emerging markets may be undergoing significant evolution and rapid development, and emerging markets may lack the social, political and economic stability characteristics of more developed countries.

International currency markets. Investments in international securities expose a portfolio to fluctuations in currency exchange rates, which may adversely affect the value of investments in international securities held in your portfolio.

Currency risks. Investments denominated in an international currency are subject to the risk that the value of a particular currency will change in relation to one or more currencies.

Common Risks Associated with Fixed Income Investments Investments in fixed income securities can expose you to certain specific risks such as the following:

Credit risk. Fixed income securities (bonds) are subject to the risk that the bond issuers may not be able to meet interest or principal payments when the bonds come due.

Below investment grade rated securities. Below investment grade bonds are subject to a higher probability that the issuers may not be able to meet payment of interest or principal on a timely basis or at all. These securities also may be less liquid than investment grade securities and experience higher price volatility. It may not be possible to sell these securities at the desired price and within a given time period.

High yield securities. High yield securities are rated in the lower rating categories by the various credit agencies and are subject to greater risk of loss of principal and interest than higher rated securities. High yield securities generally are considered predominantly speculative with respect to the issuer’s capacity to pay interest and repay principal.

Interest rates. Interest rates may adversely affect the value of an investment. An increase in interest rates typically causes the value of bonds and other fixed income securities to fall. Interest rates continue to be at historic lows. Investments with longer maturities, which typically provide higher yields than securities with shorter maturities, may subject a portfolio to increased price changes resulting from market yield fluctuations. Under extreme circumstances, a substantial decrease in interest rates may lead to a negative yield on investments.

Income risk. The income received by a portfolio may decrease as a result of a decline in interest rates.

Prepayment risk. There is a risk of prepayment in mortgage- and asset-backed securities. This risk arises when market interest rates are below the interest rates charged on the loans that comprise the securities. Elevated prepayment activity may result in losses in these securities.

Liquidity risk. Investments that trade less can be more difficult or more costly to buy, or to sell, than more liquid or active investments. It may not be possible to sell or otherwise dispose of illiquid securities both at the price and within a time period deemed desirable. Securities subject to liquidity risk include emerging market securities, below investment grade securities and other securities without an established market.

Read the rest in the brochure

William Blair provides investment advisory and management services to a number of clients including high net worth clients, individuals, small institutions, William Blair Wrap Program clients and registered investment advisers following our Non-Discretionary Model Portfolio Program. In addition, William Blair provides investment management services to the MB Partnership and other private funds sponsored and / or managed by William Blair (subject to the direction and control of their affiliated general parter) and not individually to any limited partner.

Investment Minimums For discretionary accounts, William Blair generally requests minimums as described below: Account Type/Relationship

Minimum

WBIM Sub-Advisory/WBIM Separate Accounts PWM Non-Wrap Program Accounts William Blair Wrap Program Accounts Platform Separate Accounts*

$2 million $50,000 $100,000 $100,000

*Certain third-party managers may be higher. We reserve the right to accept accounts below our stated minimums. We also accept lesser amounts for accounts in separately managed account programs sponsored by unaffiliated intermediaries (e.g., wrap programs). Private fund investment minimums vary by fund (including Blair Private Funds, the MB Partnership Series, and other private funds sponsored and / or managed by William Blair), however the managing member or general partner may, in its sole discretion, permit investments below the minimum amount set forth in each respective offering document. Interests in the Blair Private Funds, the MB Partnership, and other private funds sponsored or managed by William Blair are offered to “qualified purchasers” as defined under the Investment Company Act of 1940 or as a “qualified client” under the Advisers Act. In addition to these investor qualification requirements, in order to participate in the William Blair MB Investments Program, a client typically maintains $25 million in assets with William Blair. Redemption Limitations for Investments in Private Funds Unless otherwise noted in any underlying private fund offering document, investors in private funds typically redeem all or a portion of their investments from the private fund with limited frequency and upon prior written notice as specified in the applicable offering document.

Performance-Based Fees William Blair does not generally offer performance-based fee arrangements to clients. As discussed above, however, William Blair’s affiliate, the MB General Partner, as well as other general partners to other private funds sponsored and / or managed by William Blair (each an “Affiliated General Partner”), may earn a performance-based fee, if applicable. As more fully described in any applicable offering documents, the Affiliated General Partner will be entitled to a portion of the profits of the limited partnership as “carried interest.” The amount of the performance-based fee and how it is calculated is fully disclosed in the applicable offering document. The amount of the performance-based fee may vary by series. Carried interest, where applicable, is indirectly borne by limited partners who are not affiliated with the Affiliated General Partner and/or William Blair. Limited partners should understand that the receipt of performance-based fees creates a conflict of interest as the Affiliated General Partner has the potential to receive higher compensation. Performance-based fees create an incentive for the Affiliated General Partner to pursue riskier or more speculative investments than might otherwise be the case in the absence of such arrangement. Additionally, the payment by some series, but not all series, or the payment of carried interest at varying rates, creates an incentive for the Affiliated General Partner to disproportionately allocate time, services, functions or investment opportunities to those series paying carried interest or paying carried interest at a higher rate. The Affiliated General Partner seeks to mitigate these conflicts through disclosures in this Brochure, and additional disclosures in the applicable offering documents, as well as by maintaining applicable policies and procedures, including those related to the allocation of investment opportunities. Side-by-Side Management of Multiple Portfolios William Blair typically makes investment decisions for multiple portfolios using various investment strategies depending upon clients’ guidelines and restrictions. Some of these same investment strategies serve as the basis for the Non-Discretionary Model Portfolio Program. In addition, according to a client’s investment objectives and subject to reasonable restrictions, a PWM Advisor may elect to allocate all or a portion of a discretionary advisory client’s assets to one or more William Blair’s Proprietary Home Office Models.

In connection with the MB Investments Partnership and other private funds sponsored and / or managed by William Blair, William Blair and the MB General Partner or other applicable general partner will encounter situations in which it must determine how to allocate investment opportunities. When an opportunity is identified, William Blair will make a good faith determination to present such investment opportunity to: (1) the MB Partnership and / or a private fund sponsored or managed by William Blair, (2) other investment vehicles utilized by partners and employees of William Blair to make investments in privately held companies, or (3) participants in the MB Partnership and / or investors of other private funds sponsored or managed by William Blair as co-investors. Such good faith determination is based on several factors including, but not limited to, the source of origination. The MB Partnership Not every investment opportunity will be presented to the MB Partnership or to other partnerships formed in connection with funds sponsored or managed by William Blair. In addition, the application of William Blair’s investment allocation methodology will often result in the MB Partnership or other private funds sponsored and / or managed by William Blair receiving an allocation on a non-pro rata basis. These investment management responsibilities create conflicts of interest. We seek to conduct ourselves in a manner we consider to be the most fair and consistent with our fiduciary obligations to our clients and make investment decisions and recommendations based on an account’s available cash, investment objectives, restrictions, permitted investment techniques and other relevant considerations. With respect to privately held investment opportunities, William Blair has adopted written policies and procedures that will not favor or disfavor, consistently or consciously, other investment vehicles utilized by partners and employees over the MB Partnership, other private funds sponsored and / or managed by William Blair, or other clients. The conflicts of interest that arise in managing multiple accounts include, for example, conflicts among investment strategies, conflicts in allocation of trades, conflicts in the allocation of investment opportunities (including MB Investments and other private funds sponsored and / or managed by William Blair), conflicts based on account type, or conflicts due to different fees. Some accounts have higher fees than others. Fees charged to clients differ depending upon a number of factors including, but not limited to, the particular strategy, the size of the portfolio being managed, the relationship with the client, the service requirements, or the account type (e.g., separately managed accounts and wrap accounts). Based on these factors, a client could pay higher fees than another client with the same PWM Advisor or in the same strategy. Also, clients with larger assets under management generate more revenue for William Blair than smaller accounts. These differences give rise to a conflict that a PWM Advisor may favor one account over the other or allocate more time to the management of one account over another. To help manage conflicts, we have implemented various controls, including the following:

We review the performance of accounts to identify performance outliers;

For accounts managed according to strategy-based model portfolios, we confirm differences relative to accountspecific guidelines; and

We have adopted trade order aggregation, trade allocation and allocation policy and procedures that seek to manage, monitor and, to the extent possible, minimize the effects of these conflicts.

William Blair Funds Our affiliate, WBIM, is an investment adviser and manager, and William Blair is distributor for the William Blair Funds. William Blair and WBIM are paid by the William Blair Funds for the services they each provide. As investment adviser and manager, WBIM manages the William Blair Funds’ investments, administers their business affairs, furnishes office facilities and equipment, provides clerical, bookkeeping and administrative services, and provides shareholder and information services. Partners and employees of William Blair and WBIM can serve (without compensation) as trustees or officers of the William Blair Funds if elected to such positions. As of December 31, 2024, investment management fees paid by the William Blair Funds ranged from 0.60% to 1.10% for all share classes. In addition to an investment management fee, each William Blair Fund pays the expenses of its operations, including a portion of the William Blair Funds’ general administrative expenses, allocated based on each Fund’s net assets. As of December 31, 2024, WBIM advised approximately $10.6 billion in assets for the William Blair Funds. PWM Advisors have discretion to buy and sell mutual funds, including the William Blair Funds, in their clients’ accounts and receive asset-based investment management fees. Clients can exclude the purchase of William Blair Funds in their accounts. As the William Blair Funds’ principal distributor, we also receive fees from the sale of William Blair Fund shares. As discussed above, our affiliate, WBIM compensates us up to 0.35% of our clients’ assets invested in William Blair Funds. These circumstances create a conflict of interest because we are incented to purchase or recommend the purchase of affiliated mutual funds over other types of investments or funds. To help manage any conflict, we have implemented controls, including the following:

We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code;

We monitor client portfolios to ensure they are consistent with each client’s objectives and investment strategy;

At account opening, we typically solicit client consent to invest in affiliated mutual funds;

WBIM’s conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, William Blair Funds’ prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms; and

For Retirement Accounts, we waive our investment advisory fee on assets invested in affiliated mutual funds, but the account remains subject to the affiliated fund’s internal management fees and other expenses. Please also refer to the William Blair Funds’ prospectuses and statements of additional information, which are available at www.williamblairfunds.com or by calling 1-800-742-7272.

Investment Adviser/Sub-Adviser for Other Pooled Funds Our affiliate, WBIM, serves as investment adviser or sub-adviser to other pooled funds including other U.S. mutual funds, Canadian trusts/funds, Australian trusts/funds, collective investment trusts, and UCITS 1 and receives investment management fees as described in WBIM’s Form ADV Part 2A. With respect to these types of pooled funds where our affiliate serves as investment adviser or sub-adviser, WBIM compensates us up to 0.35% of our clients’ assets invested in the pooled fund. Similar to the William Blair Funds, a conflict of interest exists as we are incented to purchase or recommend these pooled funds for purchase by our

William Blair has been appointed global distributor of the William Blair SICAV.

investment management clients over unaffiliated pooled funds. To help manage conflicts, we have implemented controls, including the following:

We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code;

We monitor client portfolios to ensure they are consistent with each client’s objectives and investment strategy;

We typically solicit client consent to invest in affiliated pooled vehicles;

Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms; and

For Retirement Accounts, we waive our investment advisory fee on assets invested in affiliated pooled vehicles, but the account remains subject to the pooled vehicle’s management fees and other expenses.

Blair Private Funds Our affiliate, WBIM, is the investment manager to a number of limited partnerships and limited liability companies, which are Blair Private Funds that are structured as hedge funds, funds-of-hedge funds, multi-advisor commodity pools or other pooled investment vehicles. These Blair Private Funds are offered only to accredited investors, qualified purchasers or qualified eligible persons. When we recommend the purchase of Blair Private Funds, we have a conflict of interest because we receive compensation from our affiliate, WBIM, based on the amount of assets invested in the Blair Private Funds. This creates conflicts of interest because we are incented to recommend these securities for clients over other suitable investment options. To help manage conflicts of interest, we make these investments available solely to certain William Blair partners and employees as well as select eligible investors. Because our affiliate, WBIM can receive performance fees for certain Blair Private Funds, our affiliate is incented to favor these accounts over other clients’ accounts; however, this incentive is mitigated by the illiquid nature of these investments. We have implemented controls, including the following:

We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code;

For Retirement Accounts, we waive our investment advisory fee on assets invested in Blair Private Funds, but the account remains subject to the Blair Private Fund’s management fees and other expenses;

Conflicts of interest are disclosed in Blair Private Funds’ offering documents;

A client may decline our recommendation with respect to Blair Private Funds;

Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, private fund offering documents, separate client account opening documentation and/or separate disclosure forms; and

We monitor client portfolios to ensure they are consistent with each client’s objectives and investment strategy.

WBIM Separate Accounts and WBIM Sub-Advisory Accounts Our affiliate, WBIM, manages a number of domestic and international fixed income, equity and alternative investment strategies and may also provide investment models. A “WBIM Separate Account” is a separately managed account for which the client hires WBIM directly pursuant to a separate investment advisory agreement with WBIM. By contrast, in a WBIM Sub-Advisory Account, William Blair retains WBIM as a Sub-Adviser under the client’s advisory relationship with William Blair. With respect to any recommendation that a PWM client open a WBIM Separate Account, or any decision to hire WBIM as a Sub-Adviser or use a WBIM model, we have conflicts of interest arising from the advisory fees, affiliate compensation and other economic benefits that William Blair, WBIM and their personnel may receive. For accounts that are not Retirement Accounts, William Blair generally charges its advisory fee on assets directly

managed by WBIM or managed using a WBIM model, in addition to WBIM’s applicable separate management or model-provider fee and any Platform Provider fee. For Retirement Accounts, William Blair generally waives its advisory fee on assets directly managed by WBIM, but the account remains subject to WBIM’s management fee and other expenses. If WBIM provides a model for a Retirement Account, the account will not bear a separate fee for the model, although a Platform Provider fee and the fees and expenses of investments held through the model may apply. The applicable authority and fee treatment depend on the client’s advisory agreement, any agreement with WBIM, any other authorization, the type of account and applicable law. To help manage conflicts of interest, we have implemented controls, including the following:

We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code;

For Retirement Accounts, we waive our investment advisory fee on assets directly managed by WBIM in WBIM Separate Accounts and WBIM Sub-Advisory Accounts, but the account remains subject to WBIM’s management fee and other expenses. If WBIM provides a model, the Retirement Account will not bear a separate fee for the model. For accounts that are not Retirement Accounts, we generally charge our advisory fee on assets directly managed by WBIM or managed using a WBIM model, in addition to WBIM’s applicable separate management or model-provider fee;

Conflicts of interest are disclosed in this Brochure, Form CRS, and in other documents;

A client may decline our recommendation with respect to WBIM Separate Accounts;

A client may restrict us from hiring WBIM as a sub-adviser;

Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, separate client account opening documentation and/or separate disclosure forms; and

We monitor WBIM Separate Accounts and WBIM Sub-Advisory Accounts to ensure they are consistent with our understanding of the client’s objectives in hiring a third-party manager or sub-advising a portion of their account.

Corporate and Executive Services William Blair provides strategic advice and solutions for companies, corporate executives and other registered investment advisers. Examples of these services include the following:

Corporate cash management

Investment banking services

Corporate share repurchases

Directed share programs

Cashless stock option exercise

Retirement plans

Restricted stock coordination and sales

Officer and affiliate trading programs

Equity risk management Other services as deemed appropriate

A PWM Advisor will be restricted from trading in a public company’s securities if an executive officer, director or any insider of that company is also a client of the PWM Advisor. This means that clients of that PWM Advisor may experience less favorable performance than others who are clients of other PWM Advisors or financial professionals of other advisory firms who are not similarly restricted. Financial Planning, Consulting and Advisory Services William Blair provides financial planning, consulting and advisory services to high-net-worth individuals and families and works with you to help you determine the services that may be appropriate given your goals and circumstances. We also provide services to foundations, endowments, retirement plans and other registered investment advisers (including investment advisers where William Blair owns an indirect, minority ownership interest). We may charge a fee for these services that is separate from any investment advisory fees and transaction charges. In other cases, the

client is not charged a separate fee for these services. Examples of these services include the following:

Asset allocation

Retirement planning

Estate planning

Philanthropic strategies

Enhanced reporting services, including performance

Advisory services for foundations and endowments

Investment Consulting Research & Due Diligence Alternative Investments Retirement Plans

Read the rest in the brochure

William Blair has adopted a Code of Ethics, pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, that governs a number of conflicts of interest we have when providing our advisory services to clients. We have designed our Code to help ensure we meet our fiduciary obligation to our clients as well as to emphasize a culture of compliance within our firm.

We distribute our Code to each employee at the time of hire and annually thereafter. We provide annual training and monitor employee activity on an on-going basis.

According to our Code, employees must:

Report their transactions in reportable securities quarterly and disclose reportable securities holdings annually;

Disclose all securities accounts in which they have a beneficial interest (i.e., they are the account owner or have a present economic interest in the account);

Protect material non-public information;

Not purchase securities in an initial public offering (IPO) and obtain prior approval for participation in private placements;

Receive approval prior to engaging in outside business activities including serving on any Board of Directors of a public company;

Report gifts and business entertainment; and

Certify on an annual basis as to compliance with our Code.

If you would like a copy of PWM’s Code of Ethics, please contact our Compliance team at pwmcompliancegroup@williamblair.com or (312) 236-1600 or write to us at the following address: William Blair & Company, L.L.C. Attn: PWM Compliance 150 North Riverside Plaza Chicago, IL 60606 Securities in which William Blair has a Financial Interest Because of our diverse financial services activities, William Blair or its affiliates have financial interests in various securities including, but not limited to, the William Blair Funds, William Blair SICAV, William Blair Private Funds, and a partnership that holds minority interests in other registered investment advisers (some are clients in the NonDiscretionary Model Portfolio Program, purchase Equity & Consulting Research and/or pay us referral fees for insurance products) as well as securities of corporations to which we provide investment banking and other corporate and executive services. William Blair, its affiliates, partners and certain employees may have a pre-existing interest in, or may subsequently acquire an interest in, a MB Investment (or other private fund sponsored and / or managed by William Blair), or in investment opportunities that are offered to and/or evaluated by but rejected by the MB Partnership (or other affiliated partnerships). These interests may substantially differ in liquidation preference, voting rights or other investment terms and may result in investment interests that directly conflict with the interests of the MB Partnership (or other affiliated partnerships). We or our affiliates also have financial interests in securities for which WBIM serves as sub-adviser (such as other mutual funds or collective investment trusts).

We sometimes recommend to our clients that they purchase or sell securities in which we have a financial interest, or in cases where we have investment discretion, we may purchase or sell those securities on behalf of our clients. In addition, our participating affiliates, William Blair International, Ltd, William Blair B.V. and William Blair International (Singapore) Pte. Ltd., may recommend to or invest in the same securities for its own clients as securities in which William Blair or its clients have an interest. As discussed above, we receive compensation from our affiliate, WBIM, based on our clients’ assets invested in William Blair Funds, WBIM Separate Accounts, WBIM Sub-Advisory Accounts (except for WBIM Sub-Advisory Accounts and WBIM Separate Accounts where WBIM does not charge a separate advisory fee, and instead such assets are included in William Blair’s advisory fee, a portion of which is shared with WBIM) and Blair Private Funds. Certain PWM clients are offered the opportunity and independently elect to participate in the William Blair MB Investments Program (or other private funds sponsored and / or managed by William Blair) and invest in a MB Partnership Series (or similar affiliated investment). This creates a conflict because we are incented to promote or purchase these securities over others. A conflict of interest also arises in situations where we may restrict or refrain from making investment recommendations on particular securities because we are actively engaged in investment banking activities, issuing sell side equity research and institutional sales and trading for issuers of those corporate securities. To help manage these conflicts, we rely on various compliance controls including the following:

We maintain a Code, which reinforces our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code;

We have written policies and procedures that clearly prescribe processes for employees when recommending or managing investments for our clients;

We utilize technological trading and compliance tools to monitor portfolio activities;

We review portfolios to ensure investments are consistent with clients’ objectives, guidelines and restrictions;

We solicit client consent to invest in the William Blair Funds for their investment advisory accounts;

A client may decline to invest in William Blair Funds, Blair Private Fund or to open a WBIM Separate Account;

A client may restrict us from hiring WBIM as a sub-adviser;

With respect to the William Blair MB Investments Program (or other private funds sponsored and / or managed by William Blair), William Blair does not make any recommendation to clients with respect to participation in such investments. A client makes an independent decision as to whether to participate and affirmatively elects to invest;

If a client meets the minimum investment amount, the client may be able to invest directly in the MB Investment instead of through the William Blair MB Investment Program;

MB Partnership (and other affiliated private funds) have written policies and procedures with respect to the fair market value of such investments;

MB Partnership (and other affiliated private funds) have written policies and procedures with respect to allocation of investment opportunities;

For Retirement Accounts, we waive our investment advisory fee on assets invested in affiliated products or directly managed by affiliated Sub-Advisers, but the account remains subject to applicable product-level or SubAdviser fees and expenses;

For accounts that are not Retirement Accounts, we generally charge our advisory fee on assets invested in affiliated products or directly managed by affiliated Sub-Advisers, including assets in WBIM Separate Accounts and WBIM Sub-Advisory Accounts, in addition to applicable product-level or Sub-Adviser fees and expenses. For Retirement Accounts, we generally waive our advisory fee on affiliated products and assets directly managed by affiliated Sub-Advisers, and a Retirement Account will not bear a separate fee if WBIM or another affiliate provides a model;

We have information barriers in place to prevent dissemination of material, non-public information (including with respect to MB Investments and other similar affiliated private funds) between our various business groups;

We have allocation policies in place that seek to ensure fair and equitable access to investment opportunities for accounts over time;

We have trade rotation policies in place that seek to effect securities transactions of our clients and to disseminate Non-Discretionary Model Portfolios to our investment adviser clients in a fair and equitable manner; and

Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, William Blair Wrap Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, William Blair Funds’ prospectuses and other offering documents, Blair Private Funds’ and MB Partnership’s and other affiliate private funds’ offering documents, separate client account opening documentation and/or separate disclosure forms.

Personal Securities Trading Because William Blair permits employees to engage in personal securities transactions, our employees may buy or sell securities for their own personal accounts in a manner that is inconsistent with those purchased or sold in our clients’ accounts. As an example, an employee may buy a particular security that we recently have sold for clients. In addition, an employee or an employee of our affiliate, WBIM, may make a personal investment in the securities of our clients’ companies. These situations create conflicts of interest because employees could be motivated to favor their own investment interests or the interests of certain clients over other clients. To help manage these conflicts, we rely on various compliance controls including the following:

We maintain a Code, which reinforces our fiduciary duty to clients and conduct annual training on our Code;

In cases where we are purchasing or selling securities for clients’ accounts, we prohibit a client’s PWM Advisor from trading ahead in the same securities in his or her own accounts; and

We monitor employees’ personal securities transactions in an effort to identify patterns or improper activities.

Political Contributions We do not allow our employees to make or solicit political contributions to support political candidates or elected officials for the purpose of obtaining or retaining business with governmental entities. We permit employees to make personal contributions to support candidates for whom they are eligible to vote subject to William Blair’s political contributions policy.

Best Execution in Private Wealth Management Accounts In most instances, William Blair’s clients will maintain a brokerage account with William Blair, as the introducing/executing broker (cleared through and custody held by NFS). In effecting transactions for clients whose accounts are introduced or maintained by William Blair, as described above, all trades are directed to William Blair’s sell-side broker-dealer trade desk. In effecting transactions for clients whose accounts are introduced by William Blair, William Blair takes all reasonable steps to seek best execution of orders. William Blair’s sell-side broker dealer has policies and procedures that are designed to obtain the best possible execution result, subject to the nature of the order, any restrictions placed upon us in filling the order and the market in question. William Blair’s sell-side broker dealer takes into consideration a range of different factors which includes price but may also include such other factors as timely execution, the liquidity of the market, the cost of the transaction and the nature of the financial transaction. In some markets, price volatility may mean that the timeliness of the execution is a priority, where other markets that have low liquidity may mean the execution itself may constitute the best execution. In limited circumstances, a client will maintain their custodial account at another qualified custodian and give William Blair the ability to effect transactions through any broker-dealer. In effecting trades for these clients’ accounts, in most instances, trades will be directed to William Blair’s sell-side broker-dealer trade desk, as described above.

In other circumstances, a client will maintain their custodial account at another qualified custodian and direct us to place their order or a portion of their brokerage orders through specific broker-dealers, other than William Blair “Directed Brokerage.” Please refer to the Client Directed Brokerage discussion later in this section. Important Information about Best Execution and Trading Away for Certain Client Accounts Some PWM Advisors access and hire Sub-Advisers through the asset management Platform described in Item 4 – Advisory Services. In cases where a client’s account or a portion thereof is managed by third party investment managers or Sub-Advisers, the third party investment manager or Sub-Adviser, in its sole discretion, may place a client’s trade orders with a broker-dealer firm other than the custodian’s designated broker-dealer if the manager determines that it must do so to comply with its best execution obligations. This means that clients, even those in our Comprehensive Fee Program, who invest with third party investment managers or Sub-Advisers will most likely incur execution costs (whether in the form of commissions or markup/markdowns that are built into the net price of the security) in addition to the advisory account fees, which will not be reduced as a result of such costs. Clients should therefore take these costs into consideration when selecting and/or determining whether to remain invested in accounts managed by third party investment managers or Sub-Advisers. Research and Other Soft Dollar Benefits Under the limited circumstances where WBIM selects broker-dealers for WBIM Sub-Advisory Accounts or WBIM Separate Accounts, our affiliate may use broker-dealers that provide it research to execute client transactions, and WBIM may pay higher commissions to receive such research. Our affiliate receives research products and services from broker-dealers and third parties that are used to carry out its investment management responsibilities with respect to client accounts over which it exercises investment discretion (including WBIM Sub-Advisory and WBIM Separate Accounts). WBIM pays for these research products and services using a combination of direct payment (“hard dollars”), and client commission dollars (“soft dollars”), paying for independent third-party research with hard dollars while paying for broker-dealers’ proprietary research and services using both soft and hard dollars. WBIM uses both agency only brokers and broker-dealers, some of which provide us with research products and services to execute client transactions. WBIM pays all brokers execution only commission rates but also will participate in client commission arrangements and commission sharing arrangements with certain broker-dealers. Only broker-dealers who generate their own proprietary research are eligible to be compensated with soft dollars. Similarly, a Sub-Adviser may execute Platform account transactions through broker-dealers that charge higher commissions in order to receive such research. Section 28(e) of the Securities Exchange Act of 1934 permits a registered investment adviser such as WBIM and SubAdvisers to pay higher commissions if it can demonstrate the commissions are reasonable in relation to the research or brokerage services it receives. Registered investment advisers using soft dollars are incented to use client commission dollars to purchase research instead of having to pay for the research out of its profits. To the extent WBIM and Sub-Advisers use commission dollars to purchase research, it must use the commission dollars generated from accounts that have granted discretion for brokerage placement. Accordingly, commission dollars generated from accounts that grant brokerage placement discretion are likely to be used to purchase research that also benefits accounts that do not grant such discretion. To the extent that soft dollars are utilized, WBIM and Sub-Advisers are not required to use all products and services for the sole benefit of the clients whose commission dollars paid for the products and services. Research obtained from commissions paid by one account are most likely used to benefit all accounts. This creates conflicts because some clients get the benefit of research or services received due to another client’s commission dollars. For more information on our affiliate’s and Sub-Advisers’ soft dollar practices, see WBIM’s and Sub-Managers’ Form ADV.

Client Directed Brokerage In most instances, clients direct us to place their order through William Blair, as the introducing/executing broker (transactions cleared through NFS). In more limited instances, clients direct us to place their order or a portion of their brokerage orders through specific broker-dealers, other than William Blair (“Directed Brokerage”). This Directed Brokerage arrangement may include “expense reimbursement” and “commission recapture” arrangements, where certain broker-dealers will rebate a portion of a client’s brokerage commissions (or spreads on fixed income or principal trades) directly to their account, or apply the amount to an account’s expenses. In some instances, clients may direct us to place their order or a portion of their brokerage orders through “discount brokers.” We may deny client requests to direct brokerage, and we must accept direction before it will be effective. In selecting the directed broker, the client is solely responsible for negotiating commission rates and other transaction costs with the directed broker. Clients with directed broker arrangements may not receive best execution since the directed brokerage may result in higher commissions than might be the case if we were empowered to negotiate commission rates or select broker-dealers based on best execution. We are not required to execute any transaction through the directed broker if we reasonably believe that doing so could result in a breach of our fiduciary duty. By instructing us to execute transactions through the directed broker (including expense reimbursement and commission recapture arrangements), the client may not necessarily obtain commission rates and execution as favorable as those that would be obtained if we were able to place transactions with William Blair for execution through trading venues. The client also may forego benefits that we may be able to obtain for our other clients through, for example, negotiating volume discounts or block trades. In addition, directed brokerage can distract us from our normal trading process and represents a conflict of interest in our efforts to obtain best execution for all clients and to obtain adequate research. Also, if the directed broker played a role in introducing or referring the client to our firm, we face a conflict of interest that could be seen as reducing our incentive to obtain a lower commission. If the brokerage firm to which William Blair is directed by the client to execute trades is not on our approved list of brokers, the client may be subject to additional credit and settlement risks. Trade Order Aggregation for Private Wealth Management Clients In effecting transactions for our clients, we process orders as received by the various PWM Advisors. William Blair may enter and combine transactions in the same security for different client accounts for which discretionary authority is exercised and record the price for each client account as the average of the prices at which such transactions are executed (a “bunched trade” or “bunching”). We are not obligated to aggregate/bunch orders. Equity Trade Rotation Process We utilize a multi-tiered trade rotation process that seeks to effect equity securities transactions of our discretionary clients (including the Proprietary Home Office Model Program) and disseminate model portfolios to our NonDiscretionary Model Portfolio Program in a fair and equitable manner. The trade rotation process presents issues that include detrimental market impact (i.e., earlier trades can move the market causing subsequent trades to receive inferior prices), “signaling” concerns (i.e., broker-dealers anticipate additional trades in the same security and use this information to the detriment of the adviser’s client), and timing differences that result in clients obtaining different execution prices and performance dispersion among accounts. Such concerns are mitigated where the securities involved have significant trading volume and high liquidity. William Blair’s trade rotation tiers for client’s accounts not in the Proprietary Home Office Model Program, are as follows: 1.

First Tier Discretionary advisory clients are traded in the first tier.

2.

Second Tier We typically wait to trade second tier accounts until the “bunched” first tier trade is completed. We then execute trades for second tier accounts.

Clients included in the second tier are 1) clients that direct us to utilize specified broker-dealers; and 2) clients invested in certain securities markets or security types that make bunching impractical or would lead to unfair results. A client’s decision to utilize a broker as the custodian of its account can, even in the absence of an express direction to use that broker for executing securities transactions, have the same practical effect as a direction depending on the broker’s capabilities and charges. 3.

Third Tier Third tier accounts typically wait until the first tier and second tier trades are completed. Non-Discretionary Model Portfolio Programs are included in the third tier.

William Blair’s trade rotation tiers for client’s accounts in the Proprietary Home Office Model Program, are as follows: 1.

First Tier Proprietary Home Office Model Program advisory clients are traded in the first tier.

2.

Second Tier We typically wait to trade second tier accounts until the first tier trades are completed. We then execute discretionary advisory clients’ accounts whose PWM Advisor customizes the investment recommendations underlying a Proprietary Home Office Model Program strategy.

3.

Third Tier We typically wait to trade third tier accounts until all trades in the first and second tiers are completed. We then execute trades for third tier accounts. Clients included in the third tier are 1) clients that direct us to utilize specified broker-dealers; and 2) clients invested in certain securities markets or security types that make bunching impractical or would lead to unfair results. A client’s decision to utilize a broker as the custodian of its account can, even in the absence of an express direction to use that broker for executing securities transactions, have the same practical effect as a direction depending on the broker’s capabilities and charges.

Trade Allocation and Investment Allocation When the full amount of a bunched equity order is not executed, partially executed orders will typically be allocated among the participating client accounts on a pro rata basis in a fair and equitable manner in accordance with applicable policies and procedures. With respect to the William Blair MB Partnership Program and other private funds sponsored and / or managed by William Blair, William Blair has adopted written investment allocation policies and procedures. Please see Item 6-Performance Based Fees and Side-By-Side Management for more information. Trade Errors William Blair as an investment adviser employs a standard of care in the placement of trades for clients’ accounts. William Blair as the introducing broker-dealer on certain client accounts employs a standard of care in the execution of trades for clients’ accounts. Generally, William Blair considers any deviation from these standards a trade error. When we cause a trade error, we take prompt action to resolve the error with the objective to return the client’s account to the position that it would have been in had there been no error. We pay to correct an error and reimburse

Read the rest in the brochure

Referral Payments On occasion, we can enter into an agreement with unaffiliated third-party promoters in order to pay cash compensation to the promoter for referring advisory clients to our firm. To the extent we enter into such an arrangement, we will comply with the applicable requirements under Rule 206(4)-1 of the Investment Advisers Act pertaining to compensated “endorsements.” Clients that are referred to us through such arrangements are provided a disclosure document describing the terms and conditions of the arrangement, including the compensation paid to the promoter. The advisory fees paid by referred clients to us generally are based upon the revenue generated by the referred clients’ accounts, and the clients’ advisory fees are not higher than they would otherwise be because of the referral fees paid. Participation in Fidelity Wealth Advisor Solutions® William Blair participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which William Blair receives referrals from Strategic Advisers LLC (“Strategic Advisors”), a registered investment adviser and Fidelity Investments company. William Blair is independent and not affiliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise or control William Blair, and Strategic Advisors has no responsibility or oversight for William Blair’s provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a solicitor for William Blair, and William Blair pays referral fees to Strategic Advisers for each referral received based on William Blair’s assets under management attributable to each client referred by Strategic Advisers or members of each client’s household. The WAS Program is designed to help investors find an independent investment adviser, and any referral from Strategic Advisers to William Blair does not constitute a recommendation or endorsement by Strategic Advisers of William Blair’s particular investment management services or strategies. More specifically, William Blair pays the following amounts to Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” and “cash” assets by Strategic Advisers and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, William Blair has agreed to pay Strategic Advisers a minimum annual fee of $50,000 to participate in the WAS Program. These referral fees are paid by William Blair and not the client. To receive referrals from the WAS Program, William Blair must meet certain minimum participation criteria, however, William Blair was selected for participation in the WAS Program as a result of its other business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). Clients should refer to Item 5Advisory Business for important information regarding William Blair’s arrangements with NFS, an affiliated entity of Strategic Advisers and FBS. As a result of its participation in the WAS Program, William Blair has a conflict of interest with respect to its decision to use certain affiliates of Strategic Advisers, including FBS, for execution, custody and clearing for certain client accounts, and William Blair has an incentive to suggest the use of FBS and its affiliates to its advisory clients, whether or not those clients were referred to William Blair as part of the WAS Program. Under an agreement with Strategic Advisers, William Blair has agreed that it will not charge clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Pursuant to these arrangements, William Blair has agreed not to solicit clients to transfer their brokerage accounts from affiliates of Strategic Advisers or establish brokerage accounts at other custodians for referred clients other than when William Blair’s fiduciary duties would so require, and William Blair has agreed to pay Strategic Advisers a onetime fee equal to 0.75% of the assets in a referred client account that is transferred from Strategic Advisers’ affiliates to another custodian; therefore, William Blair has an incentive to suggest that referred clients and their household

members maintain custody of their accounts with affiliates of Strategic Advisers. However, participation in the WAS Program does not limit William Blair’s duty to seek best execution. Other Payments and Contributions Some of our clients and prospective clients retain investment consultants or financial advisors to advise them on the selection and review of investment managers. As a firm, we also may have other business relationships with these third parties. To the extent allowed under applicable law and our policies, we contribute toward expenses related to educational seminars, training programs, conferences or meals and entertainment incurred by third parties, financial advisors, and firms that use William Blair or affiliates as a sub-advisor or include us on a list of recommended investment advisers (including consultants). We also pay travel and lodging expenses relating to financial advisors' attendance at our due diligence meetings. We make charitable contributions or underwrite or sponsor charitable events at the request of others, including those who are affiliated with clients or program sponsors or consultants that may have referred clients to the firm. From time to time, we also buy from third parties certain services or products used in our investment advisory business (such as research services) or pay registration or other fees toward or assist in sponsoring such parties’ industry forums, seminars or conferences. We pay these contributions and payments out of our own resources. The amount of payments and the value of items and benefits may or may not be substantial. These payments, items and benefits give the recipients incentives to favor our private wealth management services and other William Blairaffiliated investment products and services over those of investment management firms that do not provide the same payments, items and benefits. Conversely, from time to time, third parties, including NFS and Platform Providers, defray costs of William Blair sponsored training events and conferences. These payments create a conflict of interest in that William Blair is incented to favor products and services offered by these third parties over those third parties that do not. However, these payments are subject to our internal policies that address and, in some cases, limit payments with the overall aim of avoiding compromising advice or recommendations given to clients by special incentives or compensation arrangements. Asset-Based Compensation William Blair receives compensation from clients whose assets are held in advisory accounts. The William Blair advisory fee may vary based on the underlying holdings, asset class, account type and applicable agreement. William Blair and its PWM Advisors therefore have conflicts of interest when recommending account types, products, investment managers, Sub-Advisers and model providers. Subject to the client’s advisory agreement, any other authorization and applicable law, for accounts that are not Retirement Accounts, William Blair generally charges its advisory fee on assets invested in affiliated and unaffiliated products, directly managed by affiliated and unaffiliated Sub-Advisers, or managed using models provided by affiliated and unaffiliated model providers. Additional productlevel, Sub-Adviser, model-provider and Platform Provider fees may apply. For Retirement Accounts, William Blair generally charges its advisory fee on assets invested in unaffiliated products, but generally waives its advisory fee on assets invested in affiliated products or directly managed by affiliated Sub-Advisers. If WBIM or another affiliate provides a model, the Retirement Account will not bear a separate fee for the model, although a Platform Provider fee and the fees and expenses of investments held through the model may apply. Depending on the relative advisory fees, product or provider fees, revenue sharing, expenses and other economic benefits, our financial interests may favor affiliated products or providers in some circumstances and unaffiliated products or providers in others. Please see Items 4, 5, 6, 10 and 11 for additional information. As described in Item 10, William Blair acts as distributor for the William Blair Funds and receives for its services a shareholder/distribution services fee from certain share classes of each Fund as described in the William Blair Funds’ prospectuses and statements of additional information. This constitutes a conflict of interest for William Blair in that its employees are incented to recommend investment in share classes subject to the above-described fees. William Blair’s registered representatives are responsible for understanding the availability of sales charge discounts to provide the client the opportunity to purchase a Fund under the most favorable terms available. Clients also have the option to invest in securities other than the William Blair Funds.

Clients should review the prospectuses and statements of additional information for the William Blair Funds. The William Blair Funds’ prospectuses are available on the William Blair Funds’ website at www.williamblairfunds.com or by calling 1-800-742-7272. Other Financial Incentives from William Blair to PWM Advisors William Blair pays investment professionals with financial incentives when they join William Blair and on an ongoing basis. PWM Advisors are eligible to receive incentives, including loans, back-end bonuses and/or other compensation (including expense accounts to cover certain expenses related to PWM Advisors’ business) if they reach certain asset levels within a specified period of time. These asset levels can be met by a combination of bringing client assets with them from their prior firm and/or garnering assets from clients new to them and William Blair. The amount paid to PWM Advisors under these arrangements is largely based on the size of the business serviced at their prior firm and the PWM Advisor achieving the target asset levels within a specific time period after joining William Blair, as well as certain qualitative factors. These payments are substantial and take various forms, including salary guarantees, loans, transition bonus payments and various forms of compensation to encourage financial professionals to join William Blair. Therefore, even if the fees you pay at William Blair remain the same or are less, the transfer of your assets to William Blair contributes to your PWM Advisor’s ability to meet targets. Your PWM Advisor’s continued employment is based on meeting these targets. These practices create an incentive and conflict of interest for your PWM Advisor to recommend the transfer of your account assets to William Blair since a significant part of their compensation is contingent on the PWM Advisor achieving a pre-determined level of assets at William Blair. Compensation from Retirement Accounts William Blair receives compensation from clients whose assets are invested in an Individual Retirement Account (“IRA”). William Blair and its PWM Advisors have a conflict of interest when they recommend that a participant roll money out of an employer retirement plan, such as a 401(k) plan, and into an IRA that will generate ongoing fees for the firm and the PWM Advisor. Even though William Blair and its employees are NOT compensated for making the recommendation, we will receive compensation for services under an investment advisory agreement should the retirement investor follow our recommendation to rollover their money into an IRA with William Blair. Investing assets in a William Blair IRA most likely will result in higher fees than investing through an employer’s retirement plan. To help manage this conflict of interest, we have implemented the following:

acknowledging that when we provide investment advice to a retirement investor (including a recommendation to rollover retirement assets into a William Blair IRA), William Blair and the PWM Advisor are fiduciaries within the meaning of ERISA and the Code;

William Blair and the PWM Advisor will act in the retirement investors’ best interest and not put our interest ahead of the retirement investors;

Conflicts of interest are disclosed in the Brochure, Form CRS, the “Retirement Investor Acknowledgement & Fiduciary Acknowledgement” form;

Retirement investor clients and prospects are provided with “Information Regarding Transfers, Distributions, and IRA Rollovers;” and

William Blair has policies, procedures and controls (including an annual, retrospective review) in place with respect to advisory accounts for retirement investors.

Similarly, NFS’ affiliate acts as a record keeper for certain retirement plans whose participants are pre-existing investment advisory clients of William Blair. Certain retirement plans allow their participants to grant discretion to investment advisers to manage assets within their retirement accounts. In these instances, William Blair and the PWM Advisor have a conflict of interest in that they will receive compensation for services under an investment advisory agreement should we be hired to manage the participant’s assets within their retirement account held at NFS’ affiliate.

Read the rest in the brochure

William Blair & Company L.L.C. and WBIM (collectively for purposes of this paragraph, William Blair) have entered into a settlement with the SEC in connection with the agency’s industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement requires William Blair to pay a civil monetary penalty of $10,000,000 and retain a compliance consultant for a period of one year, following the format for all other recent electronic communications settlements. William Blair cooperated with the government’s inquiry and has already taken significant steps to further strengthen the firm’s compliance environment as it relates to electronic communications. In May 2017, the SEC found that from 2010 until 2014, as a result of erroneous payments, William Blair negligently used mutual fund assets to pay for (i) distribution and marketing of fund shares outside of a written, board-approved rule 12b-1 plan and (ii) sub-transfer agent ("Sub-TA") services in excess of board-approved limits. These payments totaled approximately $1.25 million and rendered certain of William Blair Funds' disclosures concerning payments for distribution and Sub-TA services inaccurate. As a result of this conduct, the SEC found that William Blair violated Section 206(2) of the Investment Advisers Act and Section 34(b) of the Investment Company Act, and caused the William Blair Funds to violate Section 12(b) of the Investment Company Act and Rule 12b-1 thereunder. The SEC alleged that William Blair also failed to fully disclose to the William Blair Funds' Board of Trustees that William Blair (and not a third-party service provider) would retain a fee for providing shareholder administration services to the William Blair Funds under a shareholder administration services agreement between certain of the Funds and William Blair. As a result of this conduct, William Blair violated Section 206(2) of the Investment Advisers Act. Without admitting or denying the findings, except as to the SEC's jurisdiction over it and the subject matter of these proceedings, which are admitted, William Blair consented to the entry of an order instituting cease-and-desist proceedings, pursuant to Section 203(k) of the Investment Advisers Act and Section 9(f) of the Investment Company

Act, making findings, and imposing a cease-and-desist order. William Blair also was assessed by the SEC a civil money penalty in the amount of $4,500,000.

Account Reviews William Blair reviews clients’ accounts for appropriateness and relative value of investments. We meet periodically to discuss current developments and relative merits of investments. We appraise account holdings and review accounts for accuracy from an administrative, accounting and investment viewpoint. A member of PWM’s senior management reviews the appropriateness of investment holdings on an ongoing basis. We determine the frequency, depth and nature of reviews based on the terms of each client’s advisory agreement, mandate and particular needs as they may be communicated to us by the client. We may review accounts during other periods based upon certain trigger factors including significant market events, changes in a client’s investment objectives or guidelines or expected or unexpected material cash flow in an account. PWM Advisors conduct the reviews. William Blair’s Compliance Department also routinely assesses client accounts via electronic compliance monitoring systems. We use technological tools (as noted above) to assist with our reviews on both an account-by-account basis and on a securities holdings’ basis, as well as performance exceptions and other bases. We conduct reviews to determine if an account’s holdings are consistent with the investment objectives and restrictions imposed by the client. For our PWM clients, financial advisors typically construct custom portfolios based on a client’s unique objectives and restrictions and manage and review portfolios based on individualized parameters. Clients should communicate any changes in investment objectives and restrictions as well as changes in financial condition to their William Blair PWM Advisor. As clients will not be able to communicate directly with any Sub-Adviser available through a Platform or with WBIM for a WBIM Sub-Advisory Account, clients should communicate these reasonable restrictions to their William Blair PWM Advisor. Account Reports William Blair provides written reports to clients periodically. These reports may include portfolio performance and portfolio positioning as of the end of the period. Portfolio performance reports are provided to clients on at least an annual basis. We will include additional detail related to transactions or other information as may be requested by

clients. We also will provide reports on a monthly or other interim basis upon client request. For clients in wrap fee programs or other programs where the client has requested that a report not be sent because a report is being sent by the consultant, wrap program sponsor, or broker, we do not send a statement. Investors in private funds (including Blair Private Funds and MB Partnership) typically receive a copy of audited financial statements of the relevant private fund within 120 days after the fiscal year end of each such fund.

Clients choose which custodians will custody their assets. It is our understanding that certain such custodial agreements or other agreements or documents may contain provisions that could result in William Blair having inadvertent custody of client account assets as a result of language permitting us, as investment adviser, to withdraw client assets upon instruction to the custodian. Our agreements with our clients, however, are not intended to give us broad authority to withdraw client assets, and we disclaim such authority to the extent applicable. Our authority as it relates to custody should be considered to be limited in the ordinary course to customary trading and settlement of securities and investment transactions in the client’s account, typically on a “delivery vs payment” basis for securities transactions, as well as fee deductions in certain cases, as applicable. In limited circumstances, William Blair has custody of certain client assets and is therefore subject to a surprise annual audit with respect to such assets. Clients are not required to use NFS for these services and clients are free to work with other custodians. As discussed above, William Blair receives certain fees and credits from NFS. Most clients choose to custody their assets at NFS since William Blair has a clearing relationship with NFS as described in Item 5 – Fees and Compensation and Item 14 – Client Referrals and Other Compensation. William Blair has custody of client accounts since some clients authorize their custodian, including NFS, to deduct William Blair’s advisory fees from their client account. In addition, pursuant to a standing letter of authorization (“SLOA”) some clients grant William Blair limited discretion to disburse funds to one or more third parties, as specifically designated by the client. After granting William Blair with this limited authorization, the client then instructs the qualified custodian for the client's account to accept William Blair’s direction on the client's behalf to move money to the third party designated by the client on the SLOA. The qualified custodian takes that instruction in writing directly from the account holder (the client), and William Blair’s authority is limited by the terms of that instruction. We are authorized to act merely as an agent for the client. The client retains full power to change or revoke the arrangement. William Blair does NOT have discretion as to the amount, payee or timing of transfers under the SLOA. If clients’ interests in private funds cannot be held at a qualified custodian, the interests will be held in the client’s name, and ownership is recorded in the books and records of the issuer. For the avoidance of doubt, client’s Interests in any MB Partnership Series are held in the client’s name and recorded in the books and records of the MB Partnership Series while Co-Investments are held in the client’s name and recorded in the books and records of the Co-Investment issuer. The MB Partnership and other private funds sponsored and / or managed by William Blair are required to undergo an annual audit of their financial statements to comply with certain exemptions set forth in Rule 206(4)-2 of the Advisers Act. Investors in private funds, including Blair Private Funds, MB Partnership Series, and other private funds

sponsored and / or managed by William Blair, will receive audited financial statements. To the extent a private fund does not get its financial statements audited on annual basis and instead is subject to a surprise examination of its assets, the assets of such private funds are held by one or more custodial banks or broker-dealers, and such custodial banks or broker-dealers send account statements to investors in such private fund. You should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains your investment assets. Our investment account statements will vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. For tax and other purposes, your custodial statement is the official record of your account(s) and assets. We urge you to carefully review your custodian statements and compare them to the account statements that we provide to you as your investment manager. If you have any questions with respect to your custodial statement and account statements, please contact your PWM Advisor.

Investment Discretion William Blair maintains discretionary authority for the majority of assets we manage. In addition, William Blair will accept client accounts on a non-discretionary basis. As discussed above, William Blair provides a Non-Discretionary Model Portfolio Program where the underlying clients are other registered investment advisers. We typically receive an executed investment advisory agreement from the client providing the authority to manage their account assets. Subject to acceptance by William Blair, a client may request certain limitations on the management of their account as set forth in the agreement’s investment guidelines or otherwise in writing. These investment guidelines may restrict our discretion, for example, with respect to the securities of a particular country or industry. We typically request clients provide changes to their investment guidelines to us in writing and will confirm in writing any verbal changes provided by the client. We also request certain documentation in addition to an executed investment management agreement as may be needed (for example, to verify a client’s authority over the assets). Aggregate Ownership of Securities We monitor the aggregate ownership of equity securities across accounts and have adopted limits placed on aggregate ownership levels based on firm and regulatory considerations. The limits we place on aggregate ownership of securities across accounts can cause performance dispersion among accounts with similar investment guidelines if a security’s aggregate ownership has reached prescribed limits. This tends to be more common with accounts invested primarily in small and mid-capitalization stocks. In cases where a security has reached its ownership limit, PWM Advisors may seek to either substitute a similar security or omit the security and reallocate the portfolio.

Proxy Voting Practices In cases where William Blair has proxy voting authority, we will vote the proxies solely in the interest of our clients. We act with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. We are not responsible for voting proxies we do not receive in a timely manner. For clients participating in a securities lending program via their custodian, we will not be eligible to vote proxies for the portion of shares on loan. For clients where we vote proxies, unless a client otherwise notifies William Blair, in writing, contact information will not be distributed to third-party solicitors. Generally, when William Blair votes proxies, we rely upon a Proxy Administrator, Institutional Shareholder Services (“ISS”), to facilitate our proxy voting activities. ISS reviews all proxies received, subject to the requirement that all votes shall be cast solely in the best interest of the clients in their capacity as shareholders of a company. ISS votes the proxies according to the firm’s selected voting guidelines (domestic or international), which are designed to address

matters typically arising in proxy votes.2 Accordingly, if the voting guidelines indicate a vote “for”, ISS will vote in favor of the matter; if the voting guidelines indicate a vote “against,” ISS will not vote in favor of the matter. We do not intend for such voting guidelines to be exhaustive; hundreds of issues appear on proxy ballots and it is neither practical nor productive to fashion a guideline for each. Rather, such voting guidelines are intended to cover the most significant and frequent proxy issues that arise. In the rare instance where the voting guidelines have no recommendation or indicate a vote on a “case-by-case” basis, ISS will vote in the manner directed by William Blair, based on what we believe is in the best interest of our client. ISS is an independent third-party research provider that analyzes each vote from the shareholder vantage point. ISS provides proxy voting, maintenance, reporting, analysis and recordkeeping services. For information regarding proxy voting for private funds, including Blair Private Funds and MB Partnership, please see each fund’s offering materials. Share-Blocking Policy for International Markets In international markets where share blocking applies, we typically will not, but reserve the right to, vote proxies due to liquidity constraints. Share blocking is the “freezing” of shares for trading purposes at the custodian/sub-custodian bank level in order to vote proxies. Share blocking typically takes place between 1 and 20 days before an upcoming shareholder meeting, depending on the market. While shares are frozen, they may not be traded. Therefore, the potential exists for a pending trade to fail if trade settlement falls on a date during the blocking period. We do not subordinate the interests of participants and beneficiaries to unrelated objectives. Oversight of Proxy Administrator William Blair and its affiliate, WBIM, utilize ISS as their proxy administrator. William Blair relies on WBIM for oversight of ISS. For more information related to ISS oversight, please see WBIM’s Form ADV. We periodically review a random sample of votes for consistency with the voting guidelines. How to Obtain Proxy Records and Voting Policy We will make available to our clients a report on proxy votes cast on their behalf upon their request. Clients can contact us at 312-236-1600 or pwmcompliancegroup@williamblair.com for this information. Clients and prospects also can obtain a copy of our proxy voting policies and procedures upon request by contacting us at (312) 236-1600 or pwmcompliancegroup@williamblair.com. For information regarding how proxies were voted for the William Blair Funds, please refer to the William Blair Funds’ website at www.williamblairfunds.com and select Proxy Voting Information. The William Blair Funds’ proxy voting records also are available on the SEC’s EDGAR website at www.sec.gov/edgar.

As described in Item 15, William Blair is considered to have custody of clients’ assets because we have the ability to debit some of our clients’ accounts for investment management fees. William Blair has no known financial condition that we believe is likely to impair our ability to meet our commitments to our investment advisory clients. Additionally, we have not been the subject of any bankruptcy petition during the past ten years. You can obtain a copy of our most recent financial statement on our website at www.williamblair.com under Statement of Financial Condition.

The voting guidelines are available on ISS’s website at https://www.issgovernance.com/policy-gateway/voting-policies. William Blair typically follows the Benchmark Proxy Voting Guidelines. Clients also can instruct William Blair to follow other ISS proxy voting guidelines.