Eventide Asset Management, LLC: investment adviser

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

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

E V E N T I D E _____________________________________________________________________________________________________________________

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

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

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

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

E V E N T I D E _____________________________________________________________________________________________________________________

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

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

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

E V E N T I D E _____________________________________________________________________________________________________________________

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

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

E V E N T I D E _____________________________________________________________________________________________________________________

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

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

E V E N T I D E _____________________________________________________________________________________________________________________

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

*Ticker changed from “EUSM” effec ve September 1, 2025. As more fully described in each ETF’s prospectus and statement of addi onal informa on, there is no guarantee that the ETF will achieve its objec ve. Investment markets are unpredictable and there will be certain market condi ons in which the ETF will not meet its objec ves. ETF shares are bought and sold at market prices on the ETF’s primary exchange, and may trade at a premium or discount to their net asset value. Even de’s ETFs trade on the NYSE Arca exchange (the “Exchange”). ETF shares are not individually redeemed from the issuer. ETF redemp ons are limited and commissions are o en charged on each trade. An ETF’s net asset value, market price and returns will vary. Investors could lose all their money on their investments. Separately Managed Accounts (“SMAs”). At the me of filing this Firm Brochure, Even de provides discre onary and non-discre onary investment advisory services through SMAs, available to Unrestricted, Restricted, Managed Account Program, and Non-Discre onary clients. Even de’s SMA clients will generally execute an investment management agreement (“IMA”), including a Statement of Investment Objec ves and Restric ons that describes the strategy’s investment objec ve and approach, the types of investments in which a strategy will invest, any applicable investment or brokerage restric ons requested by the client, and applicable risks associated with inves ng in the strategy. Management fees are nego ated between Even de and its SMA clients as described in Item 5 – Fees and CompensaƟon. Each of Even de’s SMA clients is unique, and their investment needs and service requirements can vary. As such, Even de’s investment strategy may be modified as necessary to meet specific client investment objec ves. Prior to opening the client account, Even de will review any client requested investment restric ons, and work with the client to meet their needs while providing Even de with adequate flexibility to manage the account. Client restric ons, if accepted by Even de, are typically set forth in the IMA and will apply un l changed or withdrawn by the client. Client-imposed restric ons might affect the investment performance and diversifica on of the client’s account, and could cause the account’s performance to differ from the performance of other similarly managed accounts in the strategy that are not subject to such restric ons. Clients should consider this risk, and the other risks set forth in the IMA, before signing. SMA clients should understand and be capable of bearing the significant risks of inves ng in such accounts, including the risk of losing their en re investment. Even de manages SMA strategies side-by-side with commingled funds in which Even de or its employees have an economic interest, and proprietary accounts. For more informa on on how E V E N T I D E _____________________________________________________________________________________________________________________

Even de manages associated conflicts, please see item 6 – Performance Based Fees and Side-By-Side Management. Even de delivers SMA strategies in the form of model por olios comprised of individual securi es, to two of its client types. For Managed Account Program clients (i.e., clients that Even de services through various managed account programs sponsored by third par es), Even de delivers SMA strategies directly to a program sponsor for implementa on. For Non-Discre onary clients (i.e., where a program sponsor maintains full investment and trading discre on over transac ons in the sponsor’s client accounts, including determining whether to implement all, some, or none of Even de’s recommenda ons), Even de delivers SMA strategies a er the NYSE market close on a client-selected frequency. As a result of these differences, a Non-Discre onary Account client inves ng in an Even de SMA strategy will experience different results, compared to the results experienced by Managed Account Program clients inves ng in the same SMA strategy. Similarly, a Non-Discre onary Account client inves ng in an Even de SMA strategy might experience different results, compared to other NonDiscre onary Account clients inves ng in the same SMA strategy. A er all por olios in a strategy are updated in Even de’s por olio management system, a por olio is uploaded to Even de’s analy cs system before Even de’s Trading team ini ates delivery to Managed Account Programs. Contemporaneous with ini a ng the delivery of por olios to Managed Account Programs, Even de’s Trading team will begin to handle trade orders on behalf of Unrestricted Accounts and Restricted Accounts for which the applicable restric on is not relevant to the transac on at hand. As simultaneous delivery to all Managed Account Program clients is not possible, Even de will deliver updates to these clients in an order assigned by a randomiza on program, to help ensure that no one client is systema cally advantaged or disadvantaged. However, due to the randomiza on program and the fact that a sponsor typically retains trading discre on over Managed Account Program clients, it is possible that a Managed Account Program client account inves ng in a SMA strategy will experience different results from another Managed Account Program client account inves ng in the same SMA strategy. Further, because Even de delivers updated SMA por olios to Managed Account Program clients contemporaneously with the me it begins handling trade orders on behalf of its Unrestricted Accounts (and any Restricted Accounts for which the applicable restric on is not relevant to the transac on at hand), there is a risk that client accounts in all three categories may receive less favorable transac on execu on quality than they would otherwise receive. For Non-Discre onary Account clients, Even de delivers updated model por olios to the third-party sponsor periodically as determined by clients (e.g., weekly, quarterly, etc.). Even de expects there will be a delay between the transac ons Even de ini ates on behalf of its Unrestricted, Managed

E V E N T I D E ____________________________________________________________________________________________________________________

Account Program, and/or Restricted client accounts, and Even de’s delivery of updated SMA por olios to Non-Discre onary Accounts. These circumstances can lead to less favorable transac on execu on quality for Non-Discre onary client accounts, and may nega vely impact the performance of Non-Discre onary client accounts, as compared to other Even de accounts pursuing the same investment strategy. As Even de does not maintain discre onary authority over these accounts, and the financial intermediary can choose to accept or reject all or any por on of the recommenda ons in Even de’s SMAs, a Non-Discre onary Account client will generally experience different results than other Non-Discre onary Accounts invested in the same SMA strategy. For more informa on on the delivery of non-discre onary SMA por olios, please see Item 12 – Brokerage PracƟces. Tailoring of Services Even de’s advisory services are generally tailored to the investment products it manages and services it offers. The way Even de manages one of its investment strategies for one client account may vary from the way it manages the same strategy for another client or account. For instance, Even de will tailor its management of Mutual Funds to generally include transac ons in private companies or other illiquid securi es, including par cipa on in IPO transac ons or secondary offerings, transac ng in deriva ves, short sales, or transac ng in income-genera ng securi es typically reported on IRS Schedule K-1s, as appropriate to par cular strategies. Also, consistent with Even de’s values, the Mutual Funds may invest in domes c and/or foreign fixed-income securi es, such as notes (including standalone notes not rated by any agency), to help fund community development ins tu ons and projects aimed at serving human needs such as those of low-to-moderate income families and communi es. Conversely, Even de will tailor its management of SMA products in the same strategy to prohibit such securi es and transac ons, except in circumstances where clients and Even de have expressly agreed otherwise. Generally, Even de will maintain a proprietary SMA account for each strategy. These accounts generally represent what Even de believes are the most accurate representa ons of each strategy, its composi on and its performance, and such accounts are generally used as the representa ve account for each strategy performance composite. Even de will generally use these accounts as the basis for certain marke ng presenta ons for the strategies, including representa ve holdings, characteris cs (sector alloca on, etc.). Composite performance is generally used for the purposes of marke ng each strategy’s performance. While SMAs are managed similarly to other client accounts and account types inves ng in the same strategy, Even de may modify investment strategies as necessary to meet specific client investment objec ves and/or restric ons. Further, Even de u lizes an investment strategy for its Private Funds that is dis nct from the Healthcare & Life Sciences strategy referenced above, as appropriate for Private Fund clients with different liquidity considera ons and as outlined in each Private Fund’s PPM.

E V E N T I D E ____________________________________________________________________________________________________________________

Incidental Consulting Services Even de offers investment consul ng and guidance services to financial intermediaries, including investment analyses, por olio illustra ons and educa onal content concerning faith-based inves ng. In addi on, Even de engages in public advocacy and educa onal ini a ves related to values- and faith-based inves ng. In certain cases, Even de provides sponsorships to support financial intermediary educa on and professional development aligned with faith-based inves ng. Even de’s consul ng and educa onal services o en reference faith-based viewpoints and/or investment services offered by third par es. Even de’s consul ng and educa onal services are incidental to its provision of investment advisory products and services. Even de generally does not charge a fee for these incidental services. Even de receives a financial benefit if investments are made in Even de products as a result of these incidental consul ng and educa onal services. Even de employees providing the incidental consul ng and educa onal services described in this sec on do not receive a direct financial benefit if investments are made in Even de’s products or services. Porƞolio IllustraƟons. Even de consults with financial advisors and/or intermediaries to provide faith-based model por olios based on Even de’s products and products of third-party managers that iden fy as inves ng according to values or faith-based principles. These model por olio solu ons are designed to educate financial intermediaries about the process and poten al impact of incorpora ng ethical principles in por olio construc on. Customized por olio illustra ons are provided upon request as part of Even de’s investment consul ng services designed for financial professionals. Por olio illustra ons may include Even de-only por olio illustra ons and/or illustra ons using mul ple asset managers as requested by financial professionals or assembled in Even de’s sole discre on. Por olio illustra ons are intended for discussion and not for investment implementa on in any account. Even de does not charge a separate fee for providing these services. Portfolio Solutions For financial intermediaries servicing clients that seek to integrate ethical considera ons and investment goals, Even de offers a variety of non-discre onary faith-based model por olios for considera on in developing and implemen ng por olios appropriate for their clients. Even de’s Asset Alloca on Team (“AAT”) is comprised of the Firm’s Co-CIOs and the Director of Asset Alloca on Services and is responsible for supervising Even de’s Target Risk Alloca on Models and Mul -Manager Por olio Solu ons (collec vely, “Even de Por olio Solu ons”). AAT has day-to-day investment management responsibility for these services, including development of alloca on frameworks and methodologies, construc on of model por olios based on each por olio’s return and risk objec ves, proprietary macro forecasts and research. AAT is also responsible for the E V E N T I D E ____________________________________________________________________________________________________________________

assessment and oversight of third-party managers and products u lized in its Mul -Manager Por olio Solu ons. Even de offers its por olio solu on services in three varie es described below. 1. Target Risk Allocation Models (“Eventide Solutions”). Even de offers non-discre onary,

model por olios comprised of Even de’s Mutual Funds and ETFs, in weighted alloca ons across five risk-based strategies. Even de’s Target Risk Alloca on Models seek to offer exposure to a diversified por olio of equity and fixed income asset classes using only Even de’s products. Each Target Risk Alloca on Model is based on a specific vola lity and risk profile similar to a selected benchmark comprised of both equity and fixed income securi es. Even de does not currently charge a separate fee for maintaining and distribu ng the Target Risk Alloca on Models. These models are made available to a.) financial intermediaries considering investments in Even de’s products on behalf of their clients; and b.) financial advisors and/or intermediaries via Even de’s Sales Team and on Even de’s website. Target Risk Alloca on Models are provided on a nondiscre onary basis, and Even de is not responsible for effec ng por olio transac ons or determining whether any Target Risk Alloca on Model or any Even de product is appropriate for a par cular investor or account. Financial intermediaries generally maintain discre onary authority over their client accounts and can choose to accept or reject all or any por on of Even de’s Target Risk Alloca on Models. As of the date of this Firm Brochure, Eventide offers the five (5) Target Risk Allocation Models below. The models are available across a range of risk profiles and are presented in an order indicating increasing levels of risk, including risk of loss of capital associated with each successive model.

Defensive Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 10% domestic equities and 90% fixed income assets. The Defensive Model seeks to provide current income with low levels of volatility.

Conservative Income Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 40% domestic equities and 60% fixed income assets. The Conservative Income Model seeks current income through exposure to a wide variety of income producing vehicles consistent with low to modest levels of return volatility.

Income & Growth Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 60% domestic equities and 40% fixed income assets. The Income & Growth Model seeks current income while maintaining the potential for long term capital

E V E N T I D E ____________________________________________________________________________________________________________________

appreciation and balances exposure to stocks and bonds to help moderate return volatility.

Growth Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 80% domestic equities and 20% fixed income assets. The Growth Model seeks long term growth through an allocation to stocks and bonds and seeks capital appreciation while accepting the potential for high levels of return volatility.

Aggressive Growth Model. Seeks income and price return through exposure to a diversified portfolio of equity and fixed income asset classes with a target risk similar to a benchmark composed of 95% domestic equities and 5% fixed income assets. The Aggressive Growth Model seeks long-term capital appreciation through an allocation to stocks across market capitalization and larger allocations to smaller capitalization growth stocks with very high levels of expected return volatility.

2. Multi-Manager Portfolio Solutions (“MMPS”). Using Eventide’s research and allocation

capabilities, the MMPS service integrates Eventide’s mutual funds and ETFs with funds offered by unaffiliated money managers that apply their own values and/or faith-based processes. Eventide provides the MMPS service solely on a non-discretionary basis. MMPS portfolios are made available to: a.) financial intermediaries upon request for consideration in developing and implementing portfolios appropriate for their clients; and b.) financial advisors and/or intermediaries via Eventide’s Sales Team and on Eventide’s website. MMPS portfolios are designed for use by financial intermediaries to supplement their own advice to clients after appropriate due diligence and assessment of their clients’ respective investment needs and circumstances. Intermediaries should carefully consider the investment objectives and financial situation of their clients before implementing any part of an MMPS portfolio. Eventide does not tailor MMPS portfolios to the personal investment goals, needs or financial circumstances of particular investors, and should not be considered recommendations or investment advice for any particular investor. Financial intermediaries generally maintain discretionary authority over their client accounts and can choose to accept or reject all or any portion of Eventide’s MMPS portfolios. Eventide evaluates third-party fund exposure to the areas above using proprietary tools, such as Eventide’s public-facing screening data. Rules for inclusion/exclusion of a third-party fund include considerations such as exposure determined on a percentage of holdings basis, number of holdings basis and/or exposure relative to the average peer basis as determined by the AAT. There may also be instances where a third-party manager does not employ values-based screening, but potential exposures to the controversies above are not applicable to the investment strategy (e.g., affordable housing bonds). There may be instances where a client directs Eventide to include managers that do not meet the screening standards outlined above based on factors such as fund

E V E N T I D E ____________________________________________________________________________________________________________________

availability, cost, or issues related to performance results. In such cases, AAT will use its best efforts to accommodate such client-directed customizations. In some instances, there may be a conflict in Eventide’s manager selection process. For instance, Eventide could have an incentive to include a particular money manager in an MMPS portfolio for reasons other than the performance of the manager or fund(s) (e.g., to influence that manager’s inclusion of Eventide in its own faith-based model or to favor Eventide funds). Eventide attempts to mitigate these conflicts through the AAT’s processes to design portfolios consistent with stated investment objectives, risks, and disclosures including disclosures in this brochure. Given AAT’s knowledge and experience with Eventide’s screening practices, investment processes and Funds, the MMPS services generally favor the inclusion of Eventide products when and appropriate for asset allocation needs within the MMPS portfolios and available on platforms used by financial intermediaries. Eventide does not currently charge a fee for providing the MMPS portfolios. AAT’s preference for using Eventide products raises a potential conflict of interest because Eventide can receive additional management fees if financial intermediaries choose to implement MMPS portfolios in the accounts of their clients. AAT does not set a minimum or maximum inclusion percentage (or weight requirement) for adding Eventide products within the MMPS portfolios with non-Eventide funds. This selection methodology may result in MMPS portfolios that primarily feature Eventide products, which could be more expensive than, or underperform, portfolios that limit or exclude Eventide products. In some cases, Eventide and an intermediary firm could agree to allow the intermediary to “cobrand” Eventide’s MMPS portfolios to its clients. 3. Customization. Eventide provides customized versions of its MMPS models upon request. In

some cases, financial intermediaries may ask Eventide to include investment products in a customized MMPS portfolio that would otherwise be inconsistent with Eventide’s MMPS research guidelines, and that are not included in Eventide’s MMPS. In such cases AAT will generally accommodate such requests, while highlighting potential concerns for the financial intermediary to consider. Portfolio illustrations are intended for discussion and are not investment recommendations by the Firm for investment implementation into any account. Any portfolio output from a customized illustration request remains subject to the recommendation and discretion of the financial intermediary, and should not be viewed as an investment advisory service provided by Eventide. Eventide does not charge a separate fee for providing this customization service. Eventide Center for Faith & Investing (“ECFI”). ECFI provides educa onal resources to serve both

financial intermediaries and individual investors interested in faith-based inves ng. ECFI shares faith-

E V E N T I D E ____________________________________________________________________________________________________________________

based perspec ves and learning resources through dedicated website pages, a Journal and Podcast for Faith & Inves ng, and educa onal courses designed to teach the biblical story of inves ng and methods for implemen ng faith-based inves ng principles. As a mission-focused firm providing values-based services rooted in a biblical worldview, Even de’s educa onal services o en reference faith-based viewpoints and/or investment services offered by third par es. As of the date of this Firm Brochure, ECFI offers its educa onal services at no cost. Course a endees are typically financial professionals or educators, however individual investors may be in a endance. For par cipants who successfully complete ECFI’s educa onal courses, Even de issues the “Chris an Theology of Inves ng” cer ficate upon request. This cer ficate does not convey a par cular level of skill, training or exper se with respect to inves ng, and in providing this cer ficate to individuals who meet Even de’s criterion, Even de is not implicitly or expressly endorsing the knowledge, skill or experience of any cer ficate holder. The term “Chris an Theology of Inves ng” is the intellectual property of Even de and may not be used without its prior wri en consent. Even de maintains policies and procedures to help ensure the appropriate supervision and oversight of ECFI’s ac vi es, including communica ons with financial advisors and investors through course instruc on. ECFI personnel do not recommend specific securi es for purchase and are not compensated based on the sale of Even de’s products. Even de’s Sales Team may engage with financial advisors to discuss ECFI’s courses, collect feedback, and assist financial advisors in evalua ng Even de’s products and services in the context of faith-based inves ng. Find An Advisor Program. Even de offers an Advisor Directory tool (the “Directory”) as a resource

to help individuals learn about faith-based inves ng and search for investment professionals familiar with faith-based considera ons in the context of inves ng. The Directory is made available through a data sharing agreement with Kingdom Advisors, Inc. (“KA”), the data owner and operator of the Cer fied Kingdom Advisors designa on (“CKA”)®. The Directory consists solely of investment professionals that have a.) earned the CKA designa on; b.) completed a faith-based inves ng course offered by ECFI; and c.) completed a faith-based inves ng a esta on. Even de may, in the future, broaden the faith-based inves ng course requirement to include educa onal content offered by Even de in other formats. Even de does not require compensa on from any investment professional, or the use of any Even de products or services, to include an investment professional in the Directory. Even de does not monitor or supervise the services provided by any investment professional in the Directory. Such individuals are not affiliated with Even de. An investment professional’s inclusion in the Directory does not cons tute an endorsement of his or her services or skills, or indicate that such services will be suitable.

E V E N T I D E ____________________________________________________________________________________________________________________

The Directory’s inclusion criteria focuses on an indica on of familiarity with faith-based inves ng principles. An investment professional’s inclusion in the Directory can in some circumstances present conflicts of interest to an investment professional, including that they might have an incen ve to offer Even de’s products or services or other faith-based investment adviser’s strategies, values-based inves ng principles, and products as a means of seeking inclusion in the Directory, without regard to their views or skills in applying such principles and strategies. Similarly, the Directory’s support for faith-based inves ng presents a poten al conflict of interest for Even de because the inclusion criteria can serve Even de’s financial self interest in promo ng faith-based inves ng, including Even de’s products and services generally. Personal Memoir. Robin John, a Founding Member of Even de and the firm’s Chief Execu ve Officer,

authored a book, The Good Investor, published in 2025. The book is a memoir about the story of Mr. John’s life, his role as a founder of Even de, and his core, personal convic ons related to values-based and faith-based inves ng. Certain expenses incurred in connec on with wri ng the book will be shared by Even de. Revenue from the book will generally be used to promote the book’s messages regarding values-based and faith-based inves ng. Even de and Mr. John an cipate that the book will provide benefits to Even de by helping to explain considera ons and poten al benefits associated with more purposeful inves ng. Practice Management. Even de provides financial professionals and advisory firms with certain

prac ce management resources designed to support the integra on of values-based inves ng within their client rela onships and business prac ces. These resources may include por olio screening tools, client proposal and por olio construc on tools, investor values assessments, educa onal content, and marke ng materials intended to help advisors communicate investment philosophy perspec ves to clients. These services are offered as part of Even de’s broader effort to educate and support financial professionals, are provided at no fee, and are not con ngent upon the sale or recommenda on of any par cular product. Portfolio Screening Tool. Even de provides a proprietary faith-based por olio screening tool (the

“Screening Tool”), designed to provide values-based informa on about securi es issuers (including equi es, mutual funds, and exchange-traded funds). The Screening Tool is designed to provide a general overview of an issuer’s level of exposure to the produc on, distribu on or support of services for Alcohol, Gambling, Tobacco, Pornography or Abor on. Eventide may, in the future, include additional types of exposure related to its faith-based principles. Eventide designed the Screening Tool to help educate users about potential ethical considerations associated with certain investments and the opportunity to consider faith-based principles when investing. The Screening Tool does not express a complete assessment of Eventide’s investment research or opinions on particular issuers or their affiliates. The Screening Tool highlights certain faith-based considerations for investing and does not assess investment performance or future prospects of any issuer. The Screening Tool does not

E V E N T I D E ____________________________________________________________________________________________________________________

provide investment advice and should not be considered a recommendation or offer to purchase or sell any security or financial product. Information provided by the Screening Tool is provided for educational and informational purposes only. Additional information, including Eventide’s approach to inclusion of unaffiliated faith-based funds in the Screening Tool, can be found at www.goodinvestor.com. Registered Representatives. Certain employees of Even de are registered representa ves (“RRs”)

of Foreside and are compensated through Foreside to facilitate the distribu on of the Mutual Funds, the Private Funds, or the ETFs. Compensa on for sales of the Mutual Funds is paid through Foreside, with certain payments origina ng from NLD, the Mutual Funds’ 12b-1 Distribu on Plan, and/or Even de's legi mate profits. Compensa on associated with purchases of the Private Funds and the ETFs is paid through Foreside from Even de’s legi mate profits. In addi on, RRs (and other Even de employees) might receive certain gains and/or distribu ons made from the Private Funds in connec on with performance-based fees charged to Private Fund investors. RRs also stand to receive compensa on from Even de in connec on with investments made in SMAs and subscrip ons to Even de Por olio Solu ons. The RRs interact primarily with financial intermediaries such as investment advisers, but might, from me to me, meet together with financial intermediaries and their clients or meet directly with prospec ve Even de clients or ins tu onal investors. RRs can also respond to general inquiries from members of the public. Generally, interac ons are for educa onal and informa onal purposes and the RRs do not purport to provide investment advice addressing the specific circumstances, goals, and investment needs of financial intermediaries’ clients or other investors.

For Managed Account Program or Non-Discre onary Accounts inves ng in Even de’s SMA strategies, Even de is paid a por on of the wrap or UMA fee, as applicable. For more informa on on the fee structure associated with each strategy and product, please see below.

E V E N T I D E ____________________________________________________________________________________________________________________

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

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

E V E N T I D E ____________________________________________________________________________________________________________________

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

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

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

E V E N T I D E ____________________________________________________________________________________________________________________

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

$10 million

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

$25 million

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

$25 million

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

$25 million

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

$25 million

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

$50 million

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

$50 million

E V E N T I D E ___________________________________________________________________________________________________________________

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

$50 million

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

$50 million

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

$50 million

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

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

Other Compensation Details As noted above, certain Even de employees hold securi es licenses and serve as RRs of Foreside to facilitate the distribu on of the Mutual Funds, Private Funds, and ETFs. RRs are compensated for sales efforts that result in purchases of the Funds, with such compensa on paid through Foreside. Compensa on for sales of the Mutual Funds is paid through Foreside, with certain payments origina ng from NLD, the Mutual Funds’ 12b-1 Distribu on Plan, and/or Even de's legi mate profits. Compensa on associated with purchases of the Private Fund and the ETFs is paid to RRs through Foreside from Even de’s legi mate profits. RRs also stand to receive other compensa on from Even de in connec on with investments made in SMAs and subscrip ons to Even de Por olio Solu ons. Certain RRs (e.g., those involved in leadership) can receive certain gains and/or distribu ons made from the Private Funds in connec on with performance-based fees charged to Private Fund investors. Accordingly, the RRs can be more likely to engage in sales, consul ng, and educa onal discussions involving Even de’s investment products, including those they view as providing increased opportuni es for personal, financial compensa on, compared with other available products or services. Eventide has issued certain classes of ownership shares to certain employees, and former employees. Eventide has also issued Revenue Rights to current employees, including the RRs, as part of its incentive plans. These Revenue Rights provide current employees with an opportunity to share in a portion of Eventide’s annual revenues. This creates an incentive for holders of Revenue Rights to promote investments in Eventide’s products and services, in order to increase Eventide’s revenue. This presents the potential for conflicts of interest given that Revenue Rights provide incentives for current employees with Revenue Rights, including RRs, to favor and recommend Eventide’s investment products or services, including those with higher fees. To help mitigate the risks of such conflicts, Eventide monitors its Code of Ethics and other policies requiring employees and RRs to place the needs and interests of clients before personal interests or the interests of Eventide.

E V E N T I D E ___________________________________________________________________________________________________________________

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

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

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

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

E V E N T I D E ___________________________________________________________________________________________________________________

in a security for a Mutual Fund, where another account pursuing the same or a similar strategy might be advised to purchase or hold the shorted security. Even de seeks to ensure equitable treatment of clients across strategies. However, there can be no assurance that the price of a security would not be nega vely impacted by Even de’s specific trading or investment strategies implemented only for certain accounts. Private Funds. As described above, the investment strategies of Even de’s Private Funds par ally overlap the investment strategy of certain Mutual Funds. Even de’s approach to allocate investment opportuni es between the Mutual Funds and its Private Funds is discussed above. Even de does not currently intend to allocate investments among its Private Funds, as it intends to close the investment period of Fund I prior to commencing the investment period of Fund II. As described above, Even de’s alloca on process will generally result in fewer overall investment opportuni es for each client in the interest of trea ng different types of clients fairly. This could compromise performance returns compared with circumstances in which no client account is required to forego an investment opportunity. As noted above, Even de performs oversight to help ensure that no client account is systema cally disadvantaged over me due to alloca on processes. Even de’s Private Funds invest in the securi es of private companies and may also invest in private investment in public equi es (“PIPEs”). As of the date of this Firm Brochure, Even de generally prohibits investment or investment recommenda ons, as applicable, in the securi es of private companies or PIPES in its SMAs. Different fee structures and performance-based fee incen ves associated with the Private Funds create poten al conflicts of interest for Even de personnel who stand to receive increased compensa on from higher fees, including performance-based fees, given their compensa on and revenue sharing arrangements. These factors create incen ves for Even de’s personnel to favor performance-based fee accounts over other accounts when alloca ng staff resources, investment opportuni es, and me across various client accounts because enhanced performance of such accounts can generate higher fees and compensa on. ETFs. Even de’s management of ETFs might include securi es or transac ons excluded from other products or services pursuing the same strategy. The ETFs can par cipate in IPO transac ons or secondary offerings consistent with their par cular investment strategy and objec ve. Certain other accounts under Even de’s management inves ng in the same or similar strategies (e.g., SMAs) generally prohibit par cipa on in such transac ons. These circumstances might cause dispersion between the ETFs and other accounts pursuing the same strategy. Even de performs oversight to help ensure that no client account is systema cally advantaged or disadvantaged over me due to alloca on processes. E V E N T I D E ___________________________________________________________________________________________________________________

The ETFs can transact in deriva ves, make short sales, or transact in income-genera ng securi es typically reported on IRS Schedule K-1s. Other accounts pursuing the same strategy (e.g., SMAs) generally prohibit par cipa on in such transac ons. A por olio manager could effect or recommend a transac on for the ETFs that adversely impacts the value of securi es held by another Even de client. For instance, a por olio manager of an ETF could effect a short sale in a security for the ETF, where another account pursuing the same or a similar strategy might be advised to purchase or hold the shorted security. Even de seeks to ensure equitable treatment of clients across strategies. However, there can be no assurance that the price of a security would not be nega vely impacted by Even de’s specific trading or investment strategies implemented only for certain accounts. SMAs. Even de will effect por olio transac ons for Even de’s SMA strategies on an ongoing basis, as deemed necessary and appropriate by the applicable por olio managers responsible for managing the investment strategy to ensure adherence to the SMA’s investment strategies and objec ves. Even de considers overall market condi ons and trading volumes when making investment decisions. Generally, Even de’s SMAs will trade at the same me and in the same frequency as Even de’s Mutual Funds, the ETFs and other Unrestricted Accounts pursuing the same investment strategy. Even de will generally aggregate trade orders for all Unrestricted Accounts, as well as any Restricted Accounts for which the applicable restric on is not relevant to the transac on at hand. Other than as noted above, Restricted Accounts are generally traded a er Unrestricted Accounts. This order of trading may impair execu on quality for accounts that have elected to restrict Even de’s trading discre on. The implementa on of client imposed restric ons and limita ons may affect the investment performance and diversifica on of the client’s accounts, and may cause an SMA client account’s performance to differ from the performance of other similarly managed accounts in the strategy. In addi on, clients imposing restric ons of this nature should understand that (i) some of their transac ons will not be aggregated with similar transac ons being placed for Even de’s unrestricted discre onary ins tu onal client accounts, (ii) these transac ons will typically be placed a er the comparable transac ons for unrestricted discre onary ins tu onal accounts have been placed (as described below) and (iii) a client’s performance results may not be as favorable as the performance results experienced by other clients that are not subject to the restric on. In certain instances, an SMA client might select a custodian that imposes addi onal charges to the client, when por olio transac ons are executed away from the custodian. In developing an IMA with such clients, Even de and the client will together determine whether such client should be classified as Unrestricted or Restricted with respect to brokerage. Specifically, a client might elect that these charges are prohibi ve and request they be classified as Restricted Accounts. In such cases, Even de will disclose that, as with all Restricted Accounts, execu ng transac ons in this manner could impair

E V E N T I D E ___________________________________________________________________________________________________________________

the execu on quality of brokerage transac ons in the applicable client account. Such clients may pay materially disparate commissions, greater spreads, or other transac on costs, or receive less favorable net prices on transac ons than would otherwise be the case. Conversely, other clients might elect to provide Even de brokerage discre on, such that if Even de considers it is in the client’s best interest to execute a por olio transac on away from the custodian, it may choose to do so. For the avoidance of doubt, for these clients, Even de will typically execute through the specified broker, and generally will not aggregate trade orders with mutual funds, ETFs or other accounts with an overlapping eligible investment universe. However, as noted above, Even de may determine, in certain circumstances (e.g., where a broker offers natural liquidity or a large block), that aggrega ng a trade order with the Mutual Funds, the ETFs or other SMAs may be appropriate, even if addi onal execu on charges are incurred. Even de typically agrees to report from me to me to these SMA clients regarding brokerage transac ons. As part of Even de’s IMA process, these clients also represent that they will independently review ac vity, including trading ac vity, in their SMA. Even de generally manages SMAs side-by-side with other account types inves ng in the same investment strategy, including discre onary commingled funds in which Even de or its employees have an economic interest, and proprietary accounts. The ming and order of delivering updated SMA por olios to Managed Account Program and Non-Discre onary clients creates a conflict of interest. Specifically, third-party sponsors u lizing their trade discre on to effect por olio transac ons for their client accounts in accordance with Even de’s updated SMA could cause Even de to achieve less favorable trading execu on in execu ng trades for other accounts in the same investment strategy, including accounts where Even de or its employees have an economic interest, and proprietary accounts. This could create an incen ve for Even de to delay delivery of updated por olios to Managed Account Program and Non-Discre onary SMA clients, to achieve a more favorable execu on in certain other accounts, including accounts where Even de or its employees have an economic interest, and proprietary accounts. To help mi gate this conflict, Even de takes appropriate steps, including maintaining a policy and procedure to help ensure trade instruc ons are sent to Managed Account Program clients based on a randomized rota onal process that occurs contemporaneously with trading for its Unrestricted Account clients (and any Restricted Account clients to which the restric on is not applicable). For Non-Discre onary Account clients invested in SMAs, Even de does not have investment or trading discre on to implement updated por olio recommenda ons. As such, Even de expects there will be a delay between the contemporaneous process of a.) delivering por olio updates to Managed Account Program clients, and b.) commencing trading on behalf of Unrestricted Accounts (and any Restricted Account clients to which the restric on is not applicable); the subsequent process of commencing trading for any remaining Restricted Account clients; and the delivery of updated SMAs to Non-Discre onary Accounts. Financial intermediaries or third-party sponsors who choose to exercise their investment and trading discre on to implement a securi es recommenda on could

E V E N T I D E ____________________________________________________________________________________________________________________

receive less favorable execu on in the transac on, due to the possibility of orders being open in the public markets for the same securi es entered by Even de, its Managed Account Program clients, or other Non-Discre onary Account clients implemen ng recommenda ons in the SMA at the same me. Even de’s Non-Discre onary Account clients inves ng in SMAs generally receive updated por olio security weigh ngs and alloca ons in the SMA as of the close of business on a trading day based on a representa ve account in the investment strategy. Non-Discre onary Account clients can elect to receive updated model por olios on a frequency determined by mutual agreement between Even de and the client (e.g., weekly, quarterly, etc.). To help promote fairness, Even de generally provides all Non-Discre onary Account clients with updated model por olios in the elected frequency a er NYSE market close and prior to the market open on the following business day.

Examples include wrap account programs and so-called “dual contract” arrangements in which end-clients access SMA strategies by contrac ng with their program sponsor and with money managers such as Even de. Even de generally provides investment strategies to these clients by delivering model-based por olios directly to the program sponsor for implementa on. Managed account programs generally serve a range of client types, including ins tu ons and retail investors (e.g., en es and individuals). Program sponsors generally define requirements for trade implementa on within their respec ve pla orms. In some cases, Even de provides updated SMA por olios to third-party financial intermediaries or program sponsors that maintain full investment and trading discre on over transac ons in their client accounts, including determining whether to implement all, some, or none of the securi es recommended by Even de. Even de’s clients may include investors with re rement assets or pension plan clients that are covered under the Employee Re rement Income Security Act of 1974 (ERISA). Even de may be considered a “fiduciary” under ERISA in certain scenarios. Pursuant to both Even de’s fiduciary status as a SEC registered investment adviser and a fiduciary under ERISA, Even de must make

E V E N T I D E ___________________________________________________________________________________________________________________

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

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

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

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

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

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

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

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

E V E N T I D E ___________________________________________________________________________________________________________________

manage risks rela ng to these types of events are compromised, become inoperable for extended periods of me, or cease to func on properly, Even de may have to make significant investments to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interrup ons in Even de’s opera ons and could result in a failure to maintain the security, confiden ality, or privacy of sensi ve data, including personal informa on rela ng to investors. A cybersecurity incident could have numerous material adverse effects, including on the opera ons, liquidity, and financial condi on of Even de and others. Cyber threats and/or incidents could cause financial costs from the the of assets (including proprietary informa on and intellectual property) as well as numerous unforeseen costs including li ga on costs, preventa ve and protec ve costs, remedia on costs and costs associated with reputa onal damage, any one of which, could be materially adverse to Even de and/or client accounts. To the extent that any insurance is obtained to protect against cybersecurity losses, any losses may be outside the scope or exceed the amount of such coverage. Even de maintains policies, processes, and technology to help strengthen its business resiliency during unexpected events that may cause significant business disrup on, such as cyber incidents. Development Stage Company Risk. Even de’s investment strategies include development stage

companies that are not genera ng revenue. The prospects of such companies in the healthcare and life sciences sectors may depend en rely on the outcomes of research and development, clinical trials, and uncertain regulatory outcomes for a small number of products. If these fail, these companies can decline in value substan ally, and poten ally fail to remain in business. Emerging Markets Risk. Inves ng in emerging market securi es involves risks which are in addi on

to the usual risks inherent in foreign investments. Some emerging markets countries may have fixed or managed currencies that are not free-floa ng against the U.S. dollar. Further, certain currencies may not be traded interna onally. Certain of these currencies have experienced a steady devalua on rela ve to the U.S. dollar. Any devalua on in the currencies in which a client’s securi es are denominated may have a detrimental impact on their account. Some countries with emerging securi es markets have experienced substan al, and in some periods, extremely high, rates of infla on for many years. Infla on and rapid fluctua on in infla on rates have had and may con nue to have nega ve effects on the economies and securi es markets of certain countries. Moreover, the economies of some countries may differ favorably or unfavorably from the U.S. economy in such respects as rate of growth of gross domes c product, the rate of infla on, capital reinvestment, resource self-sufficiency, number and depth of industries forming the economy’s base, governmental controls, and investment restric ons that are subject to poli cal change and balance of payments posi on. Further, there may be greater difficul es or restric ons with respect to investments made in emerging markets countries. Companies in emerging market countries generally may be subject to less stringent regulatory, disclosure, financial repor ng,

E V E N T I D E ___________________________________________________________________________________________________________________

accoun ng, audi ng and recordkeeping standards than companies in more developed countries and, as a result, the nature and quality of such informa on may vary. Informa on about such companies may be less available and reliable and, therefore, the ability to conduct adequate due diligence in emerging markets may be limited, which can impede the Even de’s ability to evaluate such companies. Emerging markets typically have substan ally less volume than U.S. markets. In addi on, securi es in many such markets are less liquid, and their prices o en are more vola le, than securi es of comparable U.S. companies. Such markets o en have different clearance and se lement procedures for securi es transac ons, and in some markets, there have been mes when se lements have been unable to keep pace with the volume of transac ons, making it difficult to conduct transac ons. Delays in se lement could result in temporary periods when assets may not be invested. Se lement problems in emerging markets countries also could cause an account to miss a rac ve investment opportuni es. Sa sfactory custodial services may not be available in some emerging markets countries, which may result in an account incurring addi onal costs and delays in the transporta on and custody of such securi es. Equity Securities Risk. Even de might recommend investment in preferred or common stocks in

companies of varying size and opera onal experience. Investments in equity securi es of small or medium-sized market capitaliza on companies will have more limited marketability than the securi es of larger companies. All investments in stocks will be subject to normal market risks. Equity securi es rank lower in the capital structure of an issuer, and as a result such investments may subject investors to addi onal risks not applicable to debt securi es. A bankruptcy proceeding or corporate restructuring could have a substan al adverse effect on the value of equity securi es. ETF Authorized Participant Risk. The ETFs have a limited number of financial ins tu ons that may

act as Authorized Par cipants. An “Authorized Par cipant” is a par cipant in the Con nuous Net Se lement System of the Na onal Securi es Clearing Corpora on or the Depository Trust Company (“DTC”) and that has executed a Par cipant Agreement with the ETFs’ distributor (“Distributor”). To the extent these Authorized Par cipants exit the business or are unable to process crea on and/or redemp on orders and no other Authorized Par cipant is able to step forward to process crea on and/or redemp on orders, in either of these cases, shares of the ETFs may trade like closed-end fund shares at a discount to NAV and possibly face delis ng by the Exchange. ETF Structure Risks. Even de's products that are structured as ETFs and as a result are subject to

special risks, including the following:

Not Individually Redeemable. Shares are not individually redeemable and may be redeemed by

the ETF at NAV only in large blocks known as “Crea on Units.” ETF shares are typically bought and

E V E N T I D E ___________________________________________________________________________________________________________________

sold in the secondary market and investors typically pay brokerage commissions or other charges on these transac ons. Trading Issues. Trading in Shares on the Exchange may be halted due to market condi ons or for reasons that, in the view of the Exchange, make trading in the ETF's shares inadvisable, such as extraordinary market vola lity. There can be no assurance that the ETF's shares will con nue to meet the lis ng requirements of the Exchange. An ac ve trading market for the ETF’s shares may not be developed or maintained. Market Price Variance Risk. Market prices of ETF shares will fluctuate in response to changes in NAV and supply and demand for ETF shares and will include a “bid-ask spread” charged by the exchange specialists, market makers or other par cipants that trade the par cular security. There may be mes when the market price and the NAV vary significantly, and as a result, investors may pay significantly more or significantly less for ETF shares than the ETF’s net asset value. Please refer to each ETF’s prospectus for addi onal informa on.

Eventide Fundamental Analysis Risk. Different analyses can indicate very different prospects for a

security. Fundamental analysis a empts to es mate the appropriate valua on of securi es based on current and projected future financial condi on of underlying companies. Even de believes that over long me periods financial markets will tend to price securi es closer to their true underlying value. Thus, Even de prefers to hold securi es trading at prices below its es mate of true value, all else being equal. However, Even de might be incorrect in assigning a true underlying value to securi es and financial markets can retain prices far from what Even de believes to be true values for an extended period. Thus, Even de’s fundamental analyses can result in por olio securi es that lose value or gain less than other securi es. Even de uses its judgment to balance its analyses when selec ng por olio securi es for investment. Even de’s judgments might not be correct, including with respect to its ethical, values-based research of companies. This could lead to investor losses or missed opportuni es for gains and could increase trading costs if Even de divests a er determining that a por olio company’s ac vi es are inconsistent with Even de’s values-based standards. If Even de trades and/or rebalances por olios more frequently because of any form of analysis, including its assessment of values-based data, this generally increases transac on costs for investors. This could also produce more realized capital gains which could have nega ve tax consequences for investors in non-tax advantaged accounts. Part of Even de’s investment process includes reference to third-party industry analysts and experts. Even de believes that analyzing this type of informa on can lead to more consistent performance by providing addi onal data points for evalua on and helping to mi gate the risk of poten al gaps in Even de’s investment analyses.

E V E N T I D E ___________________________________________________________________________________________________________________

Fixed Income Securities Risk. Even de’s investment strategies include fixed income securi es. Key

risks associated with fixed income securi es include interest rate risk, credit risk, and infla on risk. Fixed income securi es increase or decrease in value based on changes in interest rates. If interest rates increase, the value of fixed income securi es generally declines. On the other hand, if rates decline, the value of fixed income securi es will generally increase. An environment of rising interest rates can increase vola lity and redemp ons which, in turn, could force the liquida on of por olio securi es at disadvantageous prices. Longer term fixed income securi es may be more sensi ve to changes in interest rates. Federal Reserve policy changes may expose fixed-income and related markets to heightened vola lity and may reduce liquidity for certain Fund investments, which could cause the value of the Fund’s investments and share price to decline. There is also a risk that issuers and counterpar es will not make payments on securi es they issue. The credit quality of securi es may also be lowered if an issuer’s financial condi on changes. Lower credit quality can lead to greater vola lity in the price of a security which may nega vely impact liquidity and the ability to sell the security. And, because infla on reduces the purchasing power of income produced by exis ng fixed income securi es, the prices at which fixed income securi es trade will be reduced to compensate for the fact that the income they produce is worth less. This poten al decrease in market value reflects infla on risk. Finally, many fixed income securi es allow the issuer to “call,” or redeem, all or part of the security prior to its maturity date. Upon selling a fixed income security, there is no guarantee that the proceeds can be invested in a security of equivalent quality or yield characteris cs. Even de may also invest substan al por olio assets in equity or preferred stock securi es in sectors or industries including real estate, u li es, infrastructure, and master limited partnerships, carrying risks such as sensi vity to rising interest rates and the risk of an adverse change in regula ons applicable to such investments, including changes to tax laws. In connec on with fixed income strategies, Even de’s investment process generally begins with a “top down” analysis to select a variety of asset classes and/or sectors believed to offer opportuni es for current income and/or capital apprecia on. Factors considered include an assessment of current income opportuni es, poten al for income growth, valua on, capital apprecia on poten al and/or por olio risk/return a ributes. If a strategy for alloca ng assets among different asset classes does not work as intended, the strategy might not achieve its objec ve or might underperform other investment products applying the same or similar investment strategies. Lower-quality or unrated bonds, known as “high yield” or “junk” bonds, present greater risk than bonds of higher quality, including an increased risk of default. An economic downturn or period of rising interest rates could adversely affect the market for these bonds and reduce a por olio’s ability to sell its bonds. The lack of a liquid market for these bonds could decrease a por olio’s value. Longer-term securi es may be more sensi ve to interest rate changes. Rising interest rates pose a heightened risk to the por olio’s longer-term fixed income securi es. Effec ve dura on es mates

E V E N T I D E ____________________________________________________________________________________________________________________

price changes for rela vely small changes in rates. If rates rise significantly, effec ve dura on may tend to understate the drop in a security’s price. If rates drop significantly, effec ve dura on may tend to overstate the rise in a security’s price. If interest rates rise, repayments of principal on certain debt securi es, including, but not limited to, floa ng rate loans and mortgage-related securi es, may occur at a slower rate than expected and the expected maturity of those securi es could lengthen as a result. Securi es that are subject to extension risk generally have a greater poten al for loss when prevailing interest rates rise, which could cause their values to fall sharply. Foreign Securities Risk. Investments in foreign securi es tend to be more vola le and less liquid

than investments in U.S. securi es because, among other things, they involve risks rela ng to poli cal, social and economic developments abroad, including economic sanc ons, as well as risks resul ng from differences between the regula ons and repor ng standards and prac ces to which U.S. and foreign issuers are subject. Inves ng in foreign securi es includes trading related risks (e.g., government supervision and regula on of foreign securi es and currency markets, trading systems and brokers maybe less than in the U.S., and foreign securi es may be subject to foreign governmental restric ons such as exchange controls). The risks of inves ng in foreign securi es are typically increased by inves ng in emerging market countries. Securi es denominated in foreign currencies may be adversely affected by changes in currency rates and by substan al currency conversion costs. Global and Political Risk. The global economic and poli cal climate is one of uncertainty and vola lity

that can rapidly impact markets and the value of securi es. Even de’s investment strategies may be materially affected by condi ons in the global markets and economic condi ons throughout the world, including the impact of climate change. These factors are outside of Even de’s control and Even de may fail to, or may not be able to, manage its exposure to these condi ons. Civil unrest, ethnic conflict, epidemics, regional hos li es, acts of terrorism, war, and the threat of other events and the fear of prolonged global conflicts can exacerbate vola lity in the financial markets and can cause consumer, corporate, and financial confidence to weaken, increasing the risk of a “selfreinforcing” economic downturn. This can have an adverse effect on the economy generally and on the performance of Even de’s investment strategies. Uncertainty increases the difficulty of modeling market condi ons, poten ally reducing the accuracy of financial projec ons. Health Crises and Pandemic Related Risk. Large-scale health crises such as pandemics (e.g., COVID-

19 and variants) can cause extended and widespread impact to human life as well as business, economic, poli cal, and social disrup on. Governmental ac ons, such as mandatory business closures, limita ons on public ac vity, travel restric ons and quaran nes, may have an adverse effect on global, na onal, and local economies. Disrup ons in supply chains and essen al services could lead

E V E N T I D E ___________________________________________________________________________________________________________________

to market vola lity and economic slowdowns and may nega vely impact Even de’s ability to provide services. Even de monitors its business and workplace needs, including support for remote work arrangements, and seeks to manage pandemic-related risks to its business opera ons and advisory services. Even de maintains policies, processes, and technology to help strengthen its business resiliency during unexpected events that may cause significant business disrup on, such as pandemic condi ons. Healthcare & Life Sciences Risk. Even de’s investment strategies can include investments in the

healthcare and life sciences sectors. Even de might recommend or invest a substan al por on of por olio assets in biotechnology and pharmaceu cal companies where it believes that expected investment benefits jus fy the risks and are consistent with investment strategies. Investors should be aware that biotechnology and pharmaceu cal companies can be heavily dependent on clinical trials with uncertain outcomes and decisions from the U.S. Food and Drug Administra on or other regulatory bodies. These companies are especially suscep ble to market, poli cal and regulatory risks involving perceived overvalua on, drug pricing and marketability. Biotechnology and pharmaceu cal companies might not be financially profitable or stable, thus subjec ng investors to addi onal investment risks. Industrial Company Risk. Even de investment strategies can include investments in industrial

companies. Industrial companies are affected by supply and demand both for their specific product or service and for industrial sector products in general. Government regula on, world events, exchange rates and economic condi ons, technological developments and liabili es for environmental damage and general civil liabili es will likewise affect the performance of these companies. Companies in the industrial sector generally carry various risks including, but not limited to, risk related to debt loads, intense compe on, and sensi vity to economic cycles. Liquidity Risk. Even de’s investment strategies can include securi es that can be difficult to sell, or

illiquid, par cularly during mes of market turmoil or due to certain restric ons imposed by issuers and/or underwriters. Even de could recommend securi es that, while liquid at the me of investment, become illiquid a er purchase. Certain Even de investment strategies may also purchase illiquid securi es, including private securi es, with no significant trading market and over which, in some circumstances, Even de’s ability to sell may be restricted. Illiquid investments could be difficult to value, especially in changing markets. If Even de is forced to sell an illiquid asset to meet redemp on requests or other cash needs, then client accounts may be forced to sell at a loss. Management Risk. The value of a por olio will change based on the performance of the securi es it

holds. Even de’s judgments about the a rac veness, value, and poten al apprecia on of par cular por olio securi es may prove to be incorrect and there is no guarantee that the por olio managers’ judgments will produce the desired results.

E V E N T I D E ___________________________________________________________________________________________________________________

Market Risk. Overall stock or bond market vola lity can also affect the value of a por olio. Factors

such as domes c and/or foreign economic growth and market condi ons, interest rate levels, poli cal events, war, and terrorism affect the securi es markets. Por olio values could decline if markets perform poorly. There is also a risk that a par cular investment strategy will underperform either the securi es markets generally or par cular segments of the securi es markets. Unexpected local, regional, or global events, such as war, acts of terrorism, financial, poli cal, or social disrup ons; tariffs or trade wars; natural, environmental, or man-made disasters; climate-change and climaterelated events; the spread of infec ous illnesses or other public health issues; a banking crisis, recessions and depressions; or other events could have a significant impact on a client account, and may impair market liquidity, thereby increasing liquidity risk. Such events can cause investor fear, which can adversely affect the economies of many companies, sectors, na ons, regions, and the market in general, in ways that cannot necessarily be foreseen. Material Non-Public Information Risk. In connec on with their Even de responsibili es, the firm’s

personnel may acquire confiden al and/or material, nonpublic informa on and become restricted from sharing informa on or transac ng in certain securi es. As a result of related legal and regulatory requirements, Even de could be restricted from ac ng upon relevant informa on or trading certain por olio holdings, and certain securi es could be deemed illiquid un l restric ons are li ed. Model and Data Risk. Like all quan ta ve analysis, the investment models u lized in connec on with

an index carry the risk that the ranking system, valua on results and predic ons might be based on one or more incorrect assump ons, insufficient historical data, inadequate design, or may not be suitable for the purpose intended. In addi on, models may not perform as intended for many reasons including errors, omissions, imperfec ons or malfunc ons. Because the use of models is usually constructed based on data supplied by third par es, the success of an index’s use of such models is dependent on the accuracy and reliability of the supplied data. Historical data inputs may be subject to revision or correc ons, which may diminish data reliability and quality of predic ve results. Changing and unforeseen market dynamics could also lead to a decrease in the short-term or longterm effec veness of a model. Models may lose their predic ve validity and incorrectly forecast future market behavior and asset prices, leading to poten al losses. No assurance can be given that a model will be successful under all or any market condi ons. Operating and Financial Risks of Portfolio Companies. Even de’s investment strategies will

recommend and hold securi es subject to the risks associated with the underlying businesses of those por olio companies, including market condi ons, changes in regulatory environment, general economic and poli cal condi ons, loss of key management personnel and other factors. The por olio companies may not achieve their expected opera onal objec ves, may experience substan al fluctua ons in their opera ng results or may otherwise deteriorate, including as a result of an adverse development in their business, a change in their compe ve environment or an economic downturn.

E V E N T I D E ___________________________________________________________________________________________________________________

As a result, any such company that Even de expected to be stable may operate at a loss or have significant varia ons in opera ng results, may require substan al addi onal capital to support their opera ons or to maintain their compe ve posi ons, or may otherwise have a weak financial condi on or be experiencing financial distress. In some cases, the success of the Fund’s investment strategy and approach will depend, in part, on the ability of Even de to effec vely execute a business plan, effect improvements in the opera ons of a company and/or recapitalize its balance sheet. The ac vity of iden fying and implemen ng business plans, opera ng improvements and/or recapitaliza on programs at por olio companies entails a high degree of uncertainty. There can be no assurance that Even de will be able to successfully iden fy and implement such business plans, opera ng improvements and/or recapitaliza on programs. PIPE Securities Risk. Even de’s investment strategies might par cipate in private investments in

public equi es transac ons (“PIPEs”). These investments include public company stocks quoted on stock exchanges or which trade in the over-the-counter securi es market. PIPE transac ons generally involve smaller capitaliza on public companies and could entail business and financial risks comparable to risks of inves ng in the publicly issued securi es of smaller capitaliza on companies. PIPE transac ons can also result in the acquisi on of restricted stock or an instrument that is conver ble into restricted stock. As with other investments in restricted securi es, such investments might be illiquid. Even de’s ability to dispose of PIPE securi es may depend on the registra on of such securi es for resale, and any number of factors may prevent or delay a proposed registra on. Alterna vely, it may be possible for securi es acquired in a PIPE transac on to be resold in transac ons exempt from registra on in accordance with Rule 144 under the Securi es Act, or otherwise under U.S. federal securi es laws. There is no guarantee that there will be an ac ve or liquid market for the stock of any small capitaliza on company due to the possible small number of stockholders. As a result, even if Even de is able to dispose of securi es acquired in a PIPE transac on, it may be unable to sell all such securi es on short no ce, and sales ac vity could have the effect of lowering the market price of the securi es. These factors could nega vely impact the value of client accounts. Private Securities Risk. Even de’s investment strategies include investments in private securi es.

Private securi es involve various risks including, but not limited to, lack of liquidity (including some trading restric ons that con nue for a me a er a public offering), capital commitment risk, tax and legal risks, and the risk that such securi es might not be valued accurately given the lack of readily available price quota ons. Such private securi es could include companies that are not financially profitable or stable and which have uncertain futures, thus subjec ng investors to addi onal investment risks. Certain private securi es may also result in significant fees and/or costs paid by clients, resul ng in lower overall returns. The availability of private securi es (and any related public offerings that may follow) depends on market factors and there is no guarantee that Even de will

E V E N T I D E ___________________________________________________________________________________________________________________

have access or consistent availability to par cipate in such investment opportuni es in the future or that the market for ini al public offerings will provide liquidity at a rac ve prices. Regulatory Risk. Changes in the laws or regula ons of the United States or other countries, including

changes to applicable tax laws and regula ons, could impair Even de's ability to achieve the investment objec ve of a par cular investment strategies and could increase opera ng expenses charged to clients or investors. In addi on, it is possible that changes to U.S. Tariff and Import/Export Regula ons could nega vely affect the value of a client’s account. Tariffs could increase the cost of produc on or reduce demand for certain products and have an adverse effect on their opera ons. Even de cannot predict whether, or to what extent, any tariff or other trade protec ons may affect its client’s investments. Developments in U.S. trade policies, trea es and tariffs could create significant uncertainty about the future rela onship between the U.S. and other countries and have a material adverse effect on global economic condi ons or the stability of global financial markets. This may significantly reduce global trade and, in par cular, trade between the impacted na ons and the U.S. Any of these factors could depress economic ac vity and have a material adverse effect on the performance of certain investment strategies. REIT Risks. Even de’s investment strategies can recommend investments in real estate investment

trusts (REITs). Inves ng in REITs involves certain unique risks in addi on to those associated with the real estate sector generally. REITs whose underlying proper es are concentrated in a par cular industry or region are also subject to risks affec ng such industries and regions. REITs (especially mortgage REITs) are also subject to interest rate risks. By inves ng a REIT, an investor bears expenses of the REIT in addi on to other expenses. An en ty that fails to qualify as a REIT would be subject to a corporate level tax, would not be en tled to a deduc on for dividends paid to its shareholders and would not pass through to its shareholders the character of income earned by the en ty. REITs are heavily dependent upon their management team and subject to heavy cash flow dependency, defaults by borrowers and self-liquida on. Risk Analysis. Risk analysis a empts to balance poten al return and risk to por olios managed by

Even de, seeking to maximize return rela ve to risk. Even de evaluates risk in terms of the broad stock market, the U.S. dollar and in the specific context of each por olio. To the extent Even de chooses to accept risks that are less market-correlated, Even de could ini ate more concentrated posi ons in securi es when it believes the expected benefits jus fy the risks. This can lead to por olios with rela vely low correla on to broad indices, allowing for both out-performance and under-performance versus broad market indices. This can cause investment returns to be more vola le. Inves ng in securi es involves the risk of loss that investors should be prepared to bear. Risks Related to Armed Conflict. As a result of increasingly interconnected global economies and

financial markets, armed conflict between countries or in a geographic region has the poten al to

E V E N T I D E ___________________________________________________________________________________________________________________

adversely impact investments in certain por olios. The nega ve impacts may be par cularly acute in certain sectors. The ming and dura on of such conflicts, resul ng sanc ons, related events and other implica ons cannot be predicted. The foregoing may result in a nega ve impact on an account’s performance and the value of a client’s por olio, even beyond any direct investment exposure an account may have to issuers located in or with significant exposure to an impacted country or geographic region. Securities Risk. The value of a client account may decrease in response to the ac vi es and financial

prospects of an individual por olio security or group of securi es. The value of certain types of securi es can be more vola le due to issuer, poli cal, regulatory, market, or economic developments, including cyber and other security-related events. There is no guarantee that securi es recommended by Even de will appreciate in value. Even de manages client accounts ac vely, and this can involve frequent trading that nega vely impacts investment performance while increasing transac on costs and taxes for investors. SMA Risk. As a result of differences in the delivery of SMA based on account type, accounts inves ng

in an Even de SMA will experience different results compared to other accounts inves ng in the same SMA strategy. Even de’s SMAs do not address or account for the individual circumstances of any specific investor, including, but not limited to, an investor’s financial needs, objec ves, goals, me horizon, and risk tolerance. A Sponsor must exercise its judgment and make decisions about its client’s investment objec ves, risk tolerance and income needs, among other things, and whether to implement any por on of Even de’s SMAs. Even de’s SMAs generally recommend long-only strategies. For SMAs delivered to Even de’s Non-Discre onary Accounts, Even de expects there will be a delay between the transac ons Even de ini ates on behalf of its Unrestricted, Managed Account Program, and/or Restricted client accounts, and Even de’s delivery of updated SMA por olios to Even de’s Non-Discre onary Account clients. These circumstances can lead to less favorable transac on execu on quality for Non-Discre onary Accounts, and nega vely impact the performance of Non-Discre onary Accounts, as compared with other Even de accounts pursuing the same investment strategy. Some alloca on to cash may be recommended in SMAs, as applicable, when deemed prudent by Even de’s investment team. Certain SMAs could invest or recommend investments in exchange-traded funds and/or closed end funds, requiring investors to pay addi onal fees and expenses associated with such funds. A security recommended in an Even de SMA may not be available for trading on all pla orms, including a pla orm used by Managed Account Program clients. Sub-Adviser Risk. Certain Even de investment strategies employ a sub-adviser to manage fixed-

income securi es. The sub-adviser’s judgments about the a rac veness, value and poten al apprecia on of par cular securi es may prove to be incorrect and there is no guarantee that the sub-

E V E N T I D E ___________________________________________________________________________________________________________________

adviser’s judgments will produce the desired results. The sub-adviser is described more fully in each Mutual Fund prospectus, or the account documents associated with other client accounts. Technical Analysis Risk. Technical analysis, including char ng and a variety of calculated metrics,

a empts to ascertain the most advantageous mes or prices for buying, holding, or selling securi es. Even de generally applies these methods in concert with other forms of analysis. Technical analysis does not work uniformly well with different securi es or in various market climates, leading to the possibility that the analyses can be misapplied. This could result in losses or missed opportuni es for investment gains. Venture Capital Investment Risk. The types of investments that the Private Funds an cipate making

involve a high degree of risk. In general, financial and opera ng risks confron ng por olio companies can be significant. The loss of all of an investor’s capital contribu ons is possible. The ming of profit realiza on is highly uncertain. Losses are likely to occur early in the Private Funds’ life, while successes o en require a long period of me for an investment to mature.

Kuruvilla serves as Senior Por olio Manager for three Even de Mutual Funds (Even de’s Gilead Fund, Healthcare & Life Sciences Fund, and Exponen al Technologies Fund), and as a Managing Director for the Private Funds. Dr. Kuruvilla also serves as a Senior Por olio Manager for two SMA strategies (Strategic Growth, and Technology). E V E N T I D E ___________________________________________________________________________________________________________________

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

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

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

Generally, employees may not execute personal securi es transac ons within a specific number of days of a transac on in the same security by a Mutual Fund, a Private Fund, an ETF, or an SMA. Employees must obtain pre-clearance from Even de’s Compliance Team prior to their personal securi es transac ons in reportable securi es. Transac ons in ETFs that result from a pro-rata basket crea on or redemp on, however, would not be considered a “transac on” that triggers the specific number of days requirement under Even de’s Code. Personal securi es transac ons in a private placement or limited offering must be pre-approved by Even de’s Chief Compliance Officer (or delegate). In connec on with an employee’s proposed transac on in private securi es or limited offering, the Chief Compliance Officer (or delegate) generally coordinates with the Co-Chief Investment Officers to review whether the investment opportunity should be reserved for Even de’s advisory services and whether the opportunity might be offered to the employee due to the employee’s posi on with Even de. Even de imposes these restric ons to help avoid the possibility that an employee will profit from his or her posi on with Even de to the detriment of investors. Employees are prohibited from serving on the boards of publicly traded companies absent first receiving approval from one of Even de’s Co-Chief Investment Officers or a Managing Director with final approval needed from Even de’s CCO and General Counsel. If board service is authorized for a publicly traded company, employees serving as directors will be restricted from influencing other employees making investment decisions concerning the securi es of the company in ques on.

E V E N T I D E ___________________________________________________________________________________________________________________

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

E V E N T I D E ____________________________________________________________________________________________________________________

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

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

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

E V E N T I D E ___________________________________________________________________________________________________________________

personnel may hold more than one role within Even de. For instance, a por olio manager may also serve as a Co-Chief Investment Officer or a research analyst, with various responsibili es in each role. As noted above, members of Even de also hold roles with organiza ons outside of Even de including but not limited to service as a director or observer of a board of directors of a privately held company in an Even de client’s por olio. Individuals holding mul ple roles must devote their limited resources across a range of responsibili es, including outside ac vi es, and this may reduce the level and/or quality they are able to provide to Even de’s clients, and poten ally impose addi onal restric ons on investments caused by receipt of confiden al informa on. In addi on to his Even de role, Dr. Kuruvilla is a founder, financial sponsor, Director and interim President of Sa ler College, a four-year college in Boston, Massachuse s opened in fall 2018. Dr. Kuruvilla contributes to the college in a limited faculty role. Even de maintains policies and procedures to help mi gate these poten al conflicts, including its Code and policies governing conflicts of interest, trade alloca on, outside business ac vi es, insider trading, and board service, among others. Even de’s management of a range of values-based investment strategies and products on a discre onary and non-discre onary basis leads to a wide range of client types. In some cases, Even de’s clients may invest in one or more of Even de’s products. In such cases, Even de may in its discre on offer more favorable terms to a client or investor in one product, as a result of its investment in another product type, and these terms are not necessarily available to other clients or investors. As described above, Even de generally buys and sells securi es for its discre onary client accounts at the same me it buys or sells the same securi es for its SMAs with proprietary seed capital investments. To help mi gate poten al conflicts, Even de maintains policies and procedures to ensure fairness, including trade alloca on policies and procedures. Generally, a poten al conflict of interest might involve any incen ves to favor one Even de client over another Even de client, or to put the interests of Even de or its employees ahead of the interests of an Even de client. As a fiduciary, Even de owes its investment advisory clients a duty of loyalty which includes a duty to eliminate, mi gate and/or disclose material conflicts of interest that may impact clients. Accordingly, Even de has adopted policies and procedures, including a Conflicts of Interest policy and procedure, trade alloca on policies and procedure, and other policies and procedures in its compliance manual, to help iden fy, monitor and address poten al conflicts of interest that may impact Even de and/or Even de’s clients. Where Even de cannot reasonably avoid all poten al conflicts of interest, it will seek to mi gate poten al and actual conflicts using policies, procedures and controls designed to avoid harm to clients. Even de reviews and updates its policies and procedures on an ongoing basis to help ensure their effec veness. This sec on should be read in conjunc on with other, more specific disclosures regarding conflicts of interest contained in this Firm

E V E N T I D E ___________________________________________________________________________________________________________________

Brochure. Although Even de seeks to disclose its poten al conflicts of interest, its explana ons regarding conflicts of interest in this Firm Brochure or elsewhere is not an admission that such conflict should be considered material to clients.

Restrictions on Investment Activities Even de is subject to certain restric ons on its investment ac vi es due to factors such as securi es industry regula ons and guidelines applicable to its investment strategies. These factors could include, but are not limited to, restric ons imposed by Even de’s ethical screening process, or restric ons imposed by the 1940 Act, the Securi es Act of 1933, the Securi es Exchange Act of 1934, or other federal securi es laws. For instance, as described elsewhere in this Firm Brochure, certain restric ons contained in the 1940 Act restrict Even de from inves ng on behalf of both its Mutual Funds and a Private Fund. In such cases one of Even de’s clients will be required to forego a poten al investment opportunity it otherwise may have had, had Even de’s other client rela onship not existed. As a result, the available investment opportuni es available to either Even de client are reduced due to the restric ons on investment ac vi es imposed by the 1940 Act. As another example, due to the management of accounts for mul ple clients across several strategies, Even de’s personnel may come into possession of material, nonpublic informa on through permissible means (e.g., engaging in Board service for a private por olio company or execu ng confiden ality agreements to review investment opportuni es). To help mi gate the risk of misusing material, nonpublic informa on, Even de has established policies and procedures prohibi ng Even de and its personnel from using or disclosing such informa on in an unauthorized manner. For instance, Even de maintains a Restricted List of securi es that are restricted from trading by Even de and personnel to help mi gate risks associated with poten ally material, nonpublic informa on. These restric ons generally serve to limit Even de’s eligible investment universe and could have nega ve or posi ve impacts on investment returns of Even de’s clients.

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

E V E N T I D E ___________________________________________________________________________________________________________________

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

E V E N T I D E ___________________________________________________________________________________________________________________

Managed Account Programs. Contemporaneous with ini a ng the delivery of por olios to Managed Account Programs, Even de’s Trading team will begin to handle trade orders on behalf of Unrestricted Accounts and Restricted Accounts for which the applicable restric on is not relevant to the transac on at hand. As simultaneous delivery to all Managed Account Program clients is not possible, Even de delivers updates to these clients in an order assigned by a randomiza on program, to help ensure no one client is systema cally advantaged or disadvantaged. However, due to the randomiza on program and the fact that the sponsor retains trading discre on over Managed Account Program clients, it is possible that a Managed Account Program client account inves ng in an Even de SMA strategy will experience different results from another Managed Account Program client inves ng in the same strategy. Further, because Even de delivers updated SMA por olios to Managed Account Program clients contemporaneously with the me it begins handling trade orders on behalf of its Unrestricted Accounts (and any Restricted Accounts for which the applicable restric on is not relevant to the transac on at hand), client accounts in all three categories may receive less favorable transac on execu on quality than they would otherwise receive. For Non-Discre onary Account clients, Even de delivers updated SMAs to a financial intermediary or third-party sponsor, who maintains full investment and trading discre on over transac ons in its respec ve client accounts. The financial intermediary or sponsor will determine whether to implement all, some, or none of the securi es recommended by Even de. The financial intermediary or sponsor has the sole authority and responsibility for implemen ng the SMA on behalf of its clients, if in its investment discre on it chooses to do so. Responsibili es of the financial intermediary or sponsor include, but are not limited to, the selec on of broker-dealers and execu on of transac ons for the program sponsor’s client par cipant accounts. Even de is not responsible for placing trade orders or for giving trading instruc ons. Even de is responsible only for delivering updated SMA por olios to financial intermediaries or sponsors. Even de’s investment recommenda ons will generally overlap with the investment recommenda ons being made by Even de contemporaneously to Even de’s other clients, including clients where Even de has investment and trading discre on over the client account. There will be a delay between the transac ons Even de ini ates on behalf of its other client accounts and the delivery of updated SMA por olios to Even de’s Non-Discre onary Accounts. These circumstances can lead to less favorable transac on execu on quality for Non-Discre onary client accounts. The underlying securi es can be subject to price movements, par cularly with large orders rela ve to the given security’s trading volume, and this might result in the financial intermediary or sponsor's clients receiving prices that are less favorable than the prices obtained by Even de’s clients. This can nega vely impact the performance of NonDiscre onary client accounts, as compared with other Even de accounts pursuing the same investment strategy. As Even de does not maintain discre onary authority over these client accounts, and the financial intermediary can choose to accept or reject all or any por on of the recommenda ons in Even de’s SMAs, a Non-Discre onary Account client will experience different results than other Non-Discre onary Accounts invested in the SMA strategy. E V E N T I D E ___________________________________________________________________________________________________________________

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

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

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

Even de does not have custody over the assets of its Mutual Fund clients. To the extent that Even de is deemed to have custody of other discre onary client assets under the Custody Rule (e.g., for Unrestricted and Restricted Account SMAs), Even de will take steps to ensure that such client assets are maintained in accounts with a qualified custodian, as defined in the Custody Rule (each, a “Qualified Custodian”). Even de will ensure that such Qualified Custodian is designated to send account statements to either the client, the client’s investors or the client’s or investors’ independent representa ve(s), as applicable, no less frequently than quarterly. Even de also provides statements to these SMA clients quarterly. Even de’s statements for such clients are based on valua on policies and procedures implemented by Even de, and Even de’s records rela ng to the SMA, and may differ from account statements provided by an SMA client’s Qualified Custodian. Even de encourages Unrestricted and Restricted Account SMA clients to review their Qualified Custodian’s account statements carefully, compare them with any informa on sent by Even de, and to contact Even de in the event of any ques ons. Even de’s Unrestricted and Restricted Account SMA clients are generally responsible for selec ng and engaging custodians, and for ensuring that the assets in the SMA are maintained at a Qualified Custodian as defined in the Custody Rule. Such clients generally authorize Even de to bill the custodian directly with respect to any fees, costs and expenses incurred by an SMA as provided in their IMA. Title to assets within the account are generally held in the name of the SMA client (or the custodian or its nominee, for the benefit of the client) and segregated from all other custodial assets in the custodian’s possession. Even de may issue to the custodian such instruc ons as it deems necessary E V E N T I D E ___________________________________________________________________________________________________________________

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

In such cases, the program sponsors maintain full investment and trading discre on over transac ons in their client accounts, including determining whether to implement all, some, or none of the securi es recommended by Even de. Even de seeks to observe the investment policies, limita ons and restric ons applicable to client accounts. Even de seeks to manage the Mutual Funds as disclosed in each Mutual Fund’s prospectus and statement of addi onal informa on. Even de seeks to manage the Private Funds as described in each Private Fund’s PPM and limited partnership agreement. Even de seeks to manage the ETFs as disclosed in each ETF’s prospectus and statement of addi onal informa on. Even de seeks to manage SMAs in accordance with the Statement of Investment Objec ves and Restric ons in Even de’s applicable IMAs. As each of its SMA clients are unique and their investment needs will vary, Even de’s investment strategies may be modified as necessary to meet specific client investment objec ves. Even de’s SMA clients will execute an IMA iden fying the investment objec ves and restric ons. E V E N T I D E ___________________________________________________________________________________________________________________

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

Instead, clients should obtain proxies from the custodian, transfer agent or another third-party service provider such as a proxy service. Even de addresses the vo ng of proxies with its SMA clients in the IMA. Generally, for Even de’s Unrestricted or Restricted Account SMAs, Even de will vote or cause the vo ng and execu on of proxies, waivers, consents and other instruments with respect to the assets in the Accounts. In connec on with any equity securi es held in these SMAs, Even de will generally vote proxies for such securi es in accordance with Even de's current policies regarding proxy vo ng as described in this Firm Brochure. Even de's obliga on to vote proxies for a par cular SMA client shall be con ngent upon (i) receipt of proxies from the SMA's applicable custodian or the client in a mely manner, and (ii) the lack of any legal and/or contractual encumbrance in the investment management to vo ng, including any securi es lending or similar program. Even de’s proxy vo ng guidelines incorporate values-based considera ons and inform Even de’s proxy vo ng concerning key corporate objec ves, shareholder interests, elec on of Board Directors, approval of independent auditors, and equity-based compensa on plans, among other topics. Even de’s proxy vo ng guidelines are set forth in Even de’s Proxy Vo ng Policy Summary, which is provided to Even de’s SMA clients. For the Mutual Funds and ETFs, these guidelines are set forth in each fund’s respec ve statement of addi onal informa on. Even de’s approach to proxy vo ng is described in each Private Fund’s PPM, and Even de’s Proxy Vo ng Policy Summary is available to Private Fund investors upon request.

E V E N T I D E ___________________________________________________________________________________________________________________

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

E V E N T I D E ___________________________________________________________________________________________________________________

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