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Ci Global Investments Inc.: investment adviser

Ci Global Investments Inc. is an investment adviser registered with the SEC (file 801-72494, CRD 156752). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$14.7B
Discretionary
100%
Accounts
27
Employees
2
In advisory roles
2
Disclosures
2

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports no custody of client cash or securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles26$14.7B99.9%
Charities1$22.0M0.1%

How it is paid

  • Other: Approximately 110% of the advisor's expenses

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Ci Investments Inc.Company (outside the U.S.)OwnerE 75% or moreSep 1999Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
Ci Financial Corp.Ci Investments Inc.Company (outside the U.S.)E 75% or moreYes
Government of Abu DhabiMubadala InvestmentCompany (outside the U.S.)E 75% or moreYes
Mamoura Diversified Global Holding PJSCMubadala Capital LLCCompany (outside the U.S.)E 75% or moreYes
MC Accelerate Co-Invest LPMC AccelerateCompany (outside the U.S.)E 75% or moreYes
MC Accelerate Holdings LPMC Cif WealthCompany (outside the U.S.)E 75% or moreYes
MC Cif Wealth ManagementMC Accelerate Co-Company (outside the U.S.)E 75% or moreYes
MC Cif Wealth Management (UK) LtdCi Financial Corp.Company (outside the U.S.)E 75% or moreYes
MDC Capital Management LLCMubadala Capital LPCompany (outside the U.S.)E 75% or moreYes
Mubadala Capital LLCMDC CapitalCompany (outside the U.S.)E 75% or moreYes
Mubadala Capital LPMC Manager HoldcoCompany (outside the U.S.)E 75% or moreYes
Mubadala Investment CompanyMamoura DiversifiedCompany (outside the U.S.)E 75% or moreYes
MC Manager Holdco (UK) Cif LtdMC Cif WealthCompany (outside the U.S.)D 50% to 75%Yes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

What the firm disclosed under Item 11 of Form ADV. A disclosure is the firm's own report: pending matters are allegations, not findings, and many settlements are made without admitting or denying them. Text is quoted from the filing, set in sentence case.

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

  • Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?

Actions about affiliates (2)

  1. Mar 1, 2017
    Regulatory Action: Ontario Securities Commission FinalAbout an affiliate: Sentry Investments Inc.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.5M · Begun Mar 1, 2017 · Resolved Mar 1, 2017 · Settled

    Sentry Investments Inc. entered into a settlement agreement with staff of the OSC. The agreement was in respect of the firm's non-compliance with national instrument 81-105 - mutual fund sales practices. Pursuant to the settlement agreement, the firm agreed to pay an administrative penalty in the amount of $1,500,000, costs of the OSC investigation in the amount of $150,000 and other non-monetary terms, including submitting to a review of its practices and procedures by at third party consultant.

    Pursuant to the settlement agreement, the firm agreed to pay an administrative penalty in the amount of $1,500,000, costs of the OSC investigation in the amount of $150,000 and other non-monetary terms, including submitting to a review of its practices and procedures by at third party consultant. No information Filed

  2. Feb 10, 2016
    Regulatory Action: Ontario Securities Commission FinalAbout an affiliate: Ci Investments, Inc.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $8.0M · Begun Feb 5, 2016 · Resolved Feb 10, 2016 · Settled

    Ci Investments inc. self-reported a matter to the Ontario Securities Commission staff in connection with the failure to record interest within certain funds in a timely manner.

    The Ontario Securities Commission entered an order approving a no contest settlement agreement between Ci Investments inc. and the staff of the Ontario Securities Commission relating to the failure to record interest for certain mutual funds.

    Under this settlement agreement, Ci Investments inc. agreed to make a voluntary payment of c$8,000,000 towards the OSC's mandate of protecting investors, c$50,000 towards costs to the OSC investigation, and compensation to reimburse current and former clients affected which is equal to the full amount of the unrecorded interest, in the respective proportions to which they are entitled.

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

SEC Form ADV Part 2A, filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

Firm Description CIGI was founded in February 1997. CIGI acts a portfolio sub-advisor to CI Investments Inc. (“CII”) and provides discretionary investment management services for the investment portfolios of certain pooled investment vehicles (i.e. investment funds) offered to Canadian investors that are sponsored and managed by CII, as well as a Canadian charitable organization which is an institutional client of CII (collectively “Funds”). CII is registered under the Securities Act (Ontario) and other similar legislation in other Canadian provinces and territories. CI Global Asset Management (“CI GAM”) is a registered business name of CII. Principal and Indirect Owner CII, a company incorporated in Ontario, owns 100% of the shares of CIGI.

Read the rest of Item 4 (414 more words)

CII is registered under the securities legislation of: (i) each province and territory of Canada as a portfolio manager and exempt market dealer; (ii) Ontario, Québec, and Newfoundland and Labrador as an investment fund manager and under the Commodity Futures Act (Ontario) as a commodity trading counsel and a commodity trading manager. In turn, CII is a wholly owned subsidiary of CI Financial Corp., a company incorporated in Ontario. On August 12, 2025, MC Accelerate LP, an entity managed by Mubadala Capital LP, indirectly, through MC Accelerate Holdings LP acquired all of the outstanding shares of CI Financial Corp., which is the 100% indirect owner of CIGI. Following the completion of this transaction, CIGI is an indirect majority owned subsidiary of Mubadala Capital LP, which is ultimately owned through various wholly owned intermediate entities by the Government of Abu Dhabi. CIGI is wholly owned by CII, a wholly-owned subsidiary of CI Financial Corp., which is wholly owned by MC CIF Wealth Management (UK) Ltd. MC CIF Wealth Management (UK) Ltd is an indirect majority-owned subsidiary of Mubadala Capital LP, through a series of intermediate entities including: MC Accelerate Holdings LP, MC Accelerate Co-Invest LP, MC CIF Wealth Management Holdings (UK) Ltd, and MC Manager HoldCo (UK) CIF Ltd. Mubadala Capital LP is an indirect wholly-owned subsidiary of Mubadala Investment Company PJSC through a series of wholly owned intermediate entities including: MDC Capital Management LLC, Mubadala Capital LLC, and Mamoura Diversified Global Holding PJSC. Mubadala Investment Company PJSC is ultimately owned and controlled by the Government of Abu Dhabi. Types of Advisory Services CII has appointed CIGI to manage all or a portion of the Funds’ investment portfolios

and CIGI has full discretion to make investment decisions in respect of them, subject to the investment objective and restrictions applicable to each Fund as set out in their investment policy statement, offering document, and/or as per securities legislation as applicable. More detailed information regarding CIGI’s advisory services, its method of analysis and investment strategies are set out in “Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss”. Subject to the oversight of CII, CIGI has the authority to determine, without obtaining specific consent, the securities to be bought or sold, and their amount. CII assumes responsibility for the investment advice given by CIGI in respect of the Funds. Assets under Management As of December 31, 2025, CIGI managed approximately US $14.7 billion of assets. CIGI manages all such assets on a discretionary basis.

Item 5. Fees and compensation

Description CIGI has entered into investment management agreements with CII for investment advisory services in respect of the Funds. The fees for such services are negotiated between CIGI and CII and are set forth in the applicable investment management agreement. Fees are generally charged monthly in arrears based on total expenses plus a 10% markup. From time to time, CIGI may agree to waive a portion of the fees otherwise payable to it. CII may, in its sole discretion, waive all or any portion of the Management Fee with respect to any investor. In addition to the advisory fees, the funds CIGI manages will incur additional fees, such as custodial fees, auditor fees for annual financial statement audits, brokerage fees, etc.

Read the rest of Item 5 (36 more words)

A full list of fees and expenses is available in the limited partnership agreement for each fund. CIGI’s supervised persons are not registered with a broker-dealer and thus do not receive compensation for executing client trades.

Item 6. Performance-based fees and side-by-side management

CIGI does not charge performance fees or engage in side-by-side management.

Item 7. Types of clients

CIGI currently provides investment advisory services as a portfolio sub-advisor to the Funds, which include certain pooled investment vehicles (i.e. investment funds) offered

to Canadian investors that are sponsored and managed by CII, as well as a Canadian charitable organization which is an institutional client of CII, as noted under Item 4. CIGI does not require a minimum AUM to manage a Fund, however, the individual funds may have a minimum investment requirement to invest in each fund.

Item 8. Methods of analysis, investment strategies and risk of loss

Methods of Analysis and Investment Strategies Portfolio managers at CIGI use techniques such as underlying fundamental research and valuation analysis to assess growth and value potential, which includes evaluating the financial condition and management of each company, its industry and the overall economy. As part of the evaluation, the portfolio managers may analyze credit ratings, financial data and other information sources, assess the quality of management and conduct company interviews, where possible. When deciding to buy or sell an investment, the portfolio managers would consider whether the investment is good value relative to its current price.

Companies selected for investment typically and ideally possess some or all of the following characteristics:

Healthy cash flows Strong balance sheet Leading industry or niche position Proven management Good future growth prospects.

Read the rest of Item 8 (1,578 more words)

The specific investment strategy in respect of a particular Fund would be based on the investment objective and restrictions as set out in the Fund’s offering document and/or as per applicable securities legislation. Risk of Loss Direct and indirect investing in securities involves a risk of loss. All investment and trading activities risk the loss of capital. Although CIGI will attempt to moderate these risks, no assurance can be given that the investment activities undertaken by CIGI will achieve the Funds’ investment objectives or avoid losses. The performance of any investment is subject to numerous factors which are neither within the control of nor

predictable by CIGI. CIGI does not represent or guarantee that its services or methods of analysis can or will predict future results or insulate the Funds from losses due to market corrections or declines. CIGI cannot offer any guarantees or promises that the Funds’ objectives will be met. Past performance is in no way an indication of future

performance. Except as may otherwise be provided by law, CIGI is not liable for: •

Any loss that the Funds may suffer by reason of any investment decision made or other action taken or omitted by CIGI in good faith; or

•

Any act or failure to act by a custodian or other third party in respect of the Funds’ accounts.

The information included in this Brochure does not include every potential risk associated with an investment strategy, technique or type of security applicable to a particular Fund. It is CII’s responsibility to give CIGI complete information and to notify CIGI of any changes in the Funds’ investment objectives. The following is a summary of certain significant risks associated with investment strategies pursued by CIGI on behalf of the Funds; however, depending on the specific investment strategy to be pursued by CIGI on behalf of the Funds, there may be additional risks that may be described in the Funds’ offering documents. The following is not meant to be a complete description of the risks:

Risks Related to Investments in Equity Securities: CIGI may, in respect of the Funds, invest in equity securities of companies that are generally acquired in a secondary market transaction. The value of such equities will rise and fall in response to activities of the company that issued the securities, general market conditions, and/or specific economic or political conditions. Equity investments, as the most junior security in a company’s capital structure, generally involve a high risk of loss.

Risks Related to Issuer Information: The investment strategies pursued by CIGI, which are based on a fundamental analysis of an issuer’s financial condition, rely to a material extent on the financial information made available by the management of the issuers of securities. CIGI generally does not have the ability to independently verify the financial information disseminated by the numerous issuers in which the Funds may invest, and accordingly is dependent upon the integrity of both the management of these issuers and such issuers’ financial reporting process in general. Past industry events have demonstrated that investors may incur material losses as a result of corporate mismanagement and

fraud, as well as accounting and reporting irregularities, by issuers of debt and equity securities.

Risks Related to Liquidity of Investments: From time to time, there may be little or no active market for some of the securities purchased on behalf of the Funds. Some of the securities purchased on behalf of the Funds may have been issued in private placement transactions and accordingly may be subject to legal or contractual restrictions on resale in accordance with applicable securities legislation. In some instances, the sale of such securities may require lengthy negotiations. In addition, a downturn or contraction in the overall economy or in the capital markets may further disrupt CIGI’s ability to effectively trade on behalf of the Funds. The presence of any of these factors may limit liquidity and consequently, CIGI may not be able to dispose of a portfolio investment when it desires to do so or at an attractive price.

Risks Related to Systems and Other Operational Disruptions: CIGI relies extensively on computer systems to trade securities transactions, to evaluate certain securities based on real-time trading information, to monitor the Funds’ portfolios, and to generate reports that are critical to the oversight of its

investment management activities. In addition, certain of CIGI’s operations interface with or depend on systems operated by third parties, including the Funds’ custodians and market counterparties. CIGI’s management of the Funds’ portfolios is susceptible to a defect or failure in any of these systems.

Changes in Legislation Risk: There can be no assurance that tax, securities and other laws or the interpretation and application of such laws by courts or government authorities will not be changed in a manner which adversely affects the Funds’ investments.

Risks Related to Investments in Bonds: Bonds that are callable carry an additional risk, namely call risk, because they may be called prior to maturity depending on current interest rates. There is also credit risk, as the price of a bond depends on the issuer’s credit rating, or perceived ability to pay its debt obligations. Consequently, increases in an issuer’s credit risk, may negatively impact the value of a bond investment.

Emerging Market Risk: In emerging market countries, securities markets may be smaller than in more developed countries, making it more difficult to sell securities in order to take profits or avoid losses. The value of these securities may rise and fall substantially and fluctuate frequently from time to time.

Geopolitical Risk: The risk an investment’s returns could suffer as a result of political changes or instability in a country, including changes in government, legislative bodies, other foreign policy makers or military control.

Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.

Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.

Privacy/ Cybersecurity Risk: The risk of actual and attempted cyber-attacks, including denial-of-service attacks, and harm to technology infrastructure and data from misappropriation or corruption, and reputation harm. Due to CII’s, and indirectly CIGI’s, interconnectivity with third-party vendors, exchanges, clearing houses and other financial institutions, CII and thus indirectly the Funds, could be adversely impacted if any of them is subject to a successful

cyber-attack or other information security events. Although CII takes protective measures and endeavors to modify them as circumstances warrant, its computer systems, software and networks may be vulnerable to unauthorized access, misuse, computer viruses or other malicious code and other events that could have a security impact or render CII, and indirectly CIGI, unable to transact business on behalf of Funds.

Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues: Our business activities could be materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, Severe Acute Respiratory Syndrome (SARS), and/or other epidemics, pandemics, outbreaks of disease, viruses and/or public health issues. Specifically, COVID-19 has spread (and is currently spreading) rapidly around the world since its initial emergence in China in December 2019 and has severely negatively affected (and may continue to materially adversely affect) the global economy and equity markets (including, in particular, equity markets in Asia, Europe and the United States). Although the long-term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of disease cannot currently be predicted, previous occurrences of other pandemics, epidemics and other outbreaks of disease, such as H5N1 flu, H1N1

flu, SARS and the Spanish flu, had a material adverse effect on the economies and markets of those countries and regions in which they were most prevalent. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, communicable disease or virus or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition and operations of the Adviser. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to spread or materially impact the day to day lives of persons around the globe), the Adviser could be adversely affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or business and/or governmental actions limiting the movement of people between regions and other activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak).

Risks Related to War and Armed Conflict: Armed conflict, war, military actions, terrorism, or the threat of such events—whether declared or undeclared—can have significant adverse effects on global and regional economies, financial markets, and individual issuers. War and related geopolitical events may result in heightened market volatility, disruptions to trade, supply chains, energy markets, transportation networks, and financial systems, as well as the imposition of economic sanctions, export controls, capital controls, or other restrictive measures by governments or supranational organizations. Such events may negatively affect issuer operations, profitability, asset values, liquidity, and creditworthiness, particularly for issuers with direct or indirect exposure to affected regions. These risks may be difficult to predict, may escalate rapidly, and could result in material losses for the Funds.

Item 9. Disciplinary information

Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to CII’s evaluation of the investment advisor and each investment advisor representative providing investment advice to the Funds. There are no reportable material legal or disciplinary events related to CIGI.

Item 10. Other financial industry activities and affiliations

CIGI is an indirect, wholly owned subsidiary of CI Financial Corp., a diversified wealth management and asset management firm and holding company in Canada, with interests

in companies that are active in financial services and investment management. As such, CIGI is affiliated with a number of entities that are engaged in financial industry-related activities in Canada. The only related entities with which CIGI maintains arrangements that are material to CIGI’s advisory business is CII. CII is registered as an exempt market dealer and investment adviser in Canada. An exempt market dealer is a limited scope dealer that can only deal in exempt securities.

Read the rest of Item 10 (64 more words)

CII also operates as the investment fund manager and the portfolio manager to the pooled investment vehicles that CIGI serves as sub- advisor for. Neither CIGI nor any of its supervised persons is registered with any broker dealer although the Firm does have an affiliated broker dealer. Nor is CIGI or its access persons a registered municipal advisor, swap participant, commodities trading advisor, etc.

Item 11. Code of ethics, participation in client transactions and personal trading

Code of Conduct CIGI’s reputation for integrity and ethics is one of its most important assets. In order to safeguard this reputation, CIGI believes that it must maintain high standards of personal and professional conduct at all times. CIGI adopted CI Financial Code of Conduct (the “Code of Conduct”) which is designed to ensure that its conduct is at all times consistent with its fiduciary obligations to its Funds, as well as with industry and regulatory standards for investment advisers. The Code of Conduct requires compliance with applicable securities laws. It also details CIGI’s fiduciary responsibilities and prohibits the misuse of material non-public information and other unethical practices.

Read the rest of Item 11 (541 more words)

Other detailed rules include provisions relating to a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of any receipt of an offer of an inappropriate gift, business entertainment items and political contributions. All supervised persons at CIGI must acknowledge the terms of the Code of Conduct annually, or as amended. Personal Trading by Related Persons and CIGI Employees CIGI’s employees and persons associated with CIGI are required to follow the Code of Conduct and CI GAM’s Personal Trading Policy (collectively the “Codes”). Subject to satisfying the Codes and applicable laws, officers, directors and employees of CIGI and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for the Funds. The Code of Conduct generally requires pre-clearance of all personal securities transactions, which is designed to ensure (a) the fair treatment of the Funds sub-advised by CIGI; and (ii) that the interests of the Funds are placed above the personal interests of employees. When a related person or an employee desire to execute a personal trade in an investment, if a portfolio manager believes that such

investment may also be appropriate for a Fund, a conflict of interest may arise, as such employee may have an incentive to place orders first in his or her personal account prior to making a corresponding recommendation in respect of a Fund. Similarly, employees may have an incentive to benefit from the market effect of trades made on behalf of the Funds by trading shortly thereafter in their personal accounts. In order to address these conflicts of interest, the Code restricts personal trading ahead of Fund trades and trading in close proximity to a Fund’s trading activity. CIGI also has internal compliance rules which restrict participation by employees in private placements, participation by employees in initial public offerings, and trading by employees in securities on the same day that there is a pending order to buy or sell the same security for a Fund. Investment management personnel are additionally prohibited from trading within one day before or five business days after the purchase or sale of the same security for a Fund. Permission is given for personal securities transactions

only if it is determined that such transactions will not negatively impact transactions made on behalf of the Funds. CIGI also reserves the right to disapprove any proposed transaction that may have the appearance of improper conduct. CIGI believes that the relevant provisions in the Code of Conduct (including the continuous monitoring of employee trading) effectively minimize these potential conflicts of interest. Participation or Interest in Fund Transactions Potential conflicts of interest may exist if a portfolio manager buys or sells on behalf of a Fund, securities in which the portfolio manager or a related person has a financial interest. In these cases, the investment personnel could benefit from the success of the Fund’s investments because of his or her interest in the issuer of the security. Employees are allowed to invest in the funds managed as well as invest in the same securities the funds invest in, subject to the restrictions noted in the section above. CIGI maintains the Codes and other procedures to mitigate these potential conflicts, including reviewing employee security transactions.

Item 12. Brokerage practices

The trades in the Funds are executed by CII, as the portfolio adviser of the Funds, based on the order instructions from CIGI, the Funds’ sub-advisor.

Selecting Brokerage Firms As a sub-advisor, CIGI does not select the brokerage firms to execute transactions for the Funds. CII determines whether a brokerage institution is added or removed from the group of firms used. CII seeks to select brokers who will execute transactions on terms that are overall most advantageous when compared to other available providers and their services. CII considers a wide range of factors. The selection of a broker for a particular trade

Read the rest of Item 12 (760 more words)

depends upon a number of possible factors, including the size and nature of the transaction, the execution capability of the broker for certain types of issues or industries, research services provided, and the capability and financial condition of the broker, all subject to obtaining best execution of orders. Research and Other Soft Dollar Benefits CIGI does not use “soft dollar” arrangements as it does not have direct relationship with broker-dealers. Where applicable, CII may use "soft dollar" arrangements whereby a broker-dealer with which CII does business may provide services or pay a third party directly for services received by CIGI with brokerage commissions. In addition, CII may receive other benefits from broker- dealers, including access to research platforms and duplicate statements. Investment management expenses are not necessarily reduced as a result of the services received by CII. When CII uses brokerage commissions to obtain research or other products or services, CII may receive a benefit because CII does not have to produce or pay for such research, products or services. CII’s soft dollar practices may result in commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits if completed in accordance with CII’s Soft Dollar Policy. Best Execution It is difficult to quantify a bundled product that requires qualitative analysis. The determinative factor for best execution is not necessarily the lowest possible commission cost, but whether the transaction represents the best quality of execution for the Funds’ accounts. Further, the amount of commission paid for brokerage may not be as important as the ability of the broker to obtain a fair price in a volatile market, the timing of the trade, and offering the securities that Funds invest in. In placing orders, CII will seek best execution for any securities transaction, taking into full account all relevant factors including price and promptness of execution. However, this responsibility does not obligate CII to solicit competitive bids for each securities transaction or to seek the lowest available commission cost, so long as CIGI reasonably believes that the brokers selected can be expected to obtain a best execution market price on the particular transaction and determines in good faith that the brokerage services are reasonable in relation to the value of the research and other services provided by the broker to CII.

CII takes great care and pride in its obligation to seek best execution on behalf of the Funds. Any brokerage institution with which CII trades is expected to charge competitive commission rates, regardless of whether or not CII receives research services. CII may consider the following to determine the quality of execution: market impact of the trade;

total cost of execution; competitiveness of commission rates and spreads; size of order; the ability to execute block trades; back-office capabilities; commitments of capital by the broker; the availability of directed brokerage or soft dollar arrangements; and the nature or difficulty of the trade. CII reviews its trading activities on a periodic basis to determine whether its fiduciary responsibility to obtain best execution has been fulfilled. CII does not direct brokerage to broker-dealers in return for client referrals. Directed Brokerage The Funds CIGI sub-advises are not allowed to direct brokerage to a specific broker dealer. Order Aggregation From time to time, CII may aggregate transactions. Transactions are aggregated when CII believes a security transaction is in the best interests of more than one fund and such transactions are settled with the same custodian. In such circumstances, where orders for multiple Funds are aggregated and submitted together, each Fund will generally receive its pro rata share of each fill, where possible. There may be times where allocation by a method other than pro rata rule may produce a fairer and more reasonable result than application of strict pro rata allocation rule. In such circumstances, such other allocation methods may be permitted provided they are reviewed and approved by CII’s Trade Oversight Committee prior to implementation. Consideration of the cash position, mandate or general composition of each Fund, cost of the execution, size of the order, market impact of the transactions, liquidity, commission and the brokers’ ability to execute are some of the factors CII may consider when deciding whether to aggregate transactions. When transactions are aggregated, there is no assurance that aggregation will benefit all Funds equally, and in some instances combined orders could adversely affect the price or volume of a security.

In situations where CII does not aggregate, the transaction cost to one Fund may differ from another and one may be higher than another.

Item 13. Review of accounts

Periodic Reviews CIGI assigns portfolio managers, as well as other investment professionals, with the requisite skills to manage the particular type of Fund. As a general rule, portfolio managers review their Fund portfolios daily. Fund portfolios are reviewed for current market value,

asset allocation, exposure, compliance with investment restrictions, recent transactions and other factors affecting investment decisions with respect to the portfolios. Regular Reports CII receives detailed written reports no less frequently than quarterly from the Funds’ custodians. Such reports contain portfolio information for such period as well as details such as cost and current market value. CII may request an off-cycle report at any time. As the sub-advisor, CIGI does not provide reports to the Funds’ investors.

Item 14. Client referrals and other compensation

CIGI does not receive compensation or other economic benefit for providing advisory services to the Funds other than the soft dollar benefits mentioned in Item 12 above or our advisory fees mentioned in Item 5 nor does CIGI compensate any third party for referring clients to CIGI or CII.

Item 15. Custody

CIGI does not have custody of the Funds’ portfolio assets. CIGI serves as a sub-advisor to the Funds only.

Item 16. Investment discretion

CIGI has full discretionary authority to manage the Funds’ portfolios. This authority is granted to CIGI in the relevant investment management agreement. CIGI has the authority to determine, without obtaining specific consent, the securities to be bought or sold, the amount of the securities to be bought or sold. CIGI exercises discretion in a manner consistent with the Funds’ investment objectives and restrictions. Such restrictions may limit CIGI’s authority to invest in particular issuers or may set a maximum percentage (relative to the overall size of the portfolio) with respect to investments in single issuers, industries or a certain type of security.

Item 17. Voting client securities

CIGI does not vote proxies for the Funds managed. CII will receive electronic proxy notifications through an independent proxy voting service provider. Proxies will be voted in accordance with CII’s Proxy Voting Policy and in the best interests of the Funds. CII

maintains proxy voting records and make them accessible for review publicly on its website.

Item 18. Financial information

CIGI has not been involved in bankruptcy and has no financial condition that is likely to impair the firm’s ability to meet our contractual obligations.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.