A. General Description of Advisory Firm Nia Impact Advisors, LLC, doing business as Nia Impact Capital (also referred to as “Nia”, the “Adviser”, “we”, or “us”) is a limited-liability company first organized in Delaware in February 2017 and 100% owned by Kristin Hull, Founder, and Chief Executive Officer. Erika Andraca Ramirez serves as Nia’s Chief Compliance Officer (“CCO”). The Adviser is an investment adviser registered with the Securities and Exchange Commission. We have prepared this Brochure to comply with regulatory disclosure requirements and to illustrate the advisory services that we provide to clients. Additionally, this Brochure discloses the Adviser’s fee schedule, investment strategy, risks of investment, and other important information about our operations. Investment Approach and Objective Nia Impact Capital invests in forward-thinking, solutions focused companies, all of which are poised to play a key role in our transition to an inclusive, just, and sustainable economy. We apply a gender-lens across our investment decision-making process, advocate for racial equity, and live our values as a women-led team of activist investors. At Nia, we go beyond the identification of strong products and services. Management practices, treatment of employees, and leadership composition matter. We select companies where the executive team demonstrates a commitment to diversity, transparency, employee engagement, and ecological sustainability. All Nia portfolio companies include women in leadership on the executive management team and/or serving on the board of directors. A product of Nia Impact Capital, the Nia Global Solutions Equity Portfolio aims to earn a competitive rate of return while adding value to society by investing in innovative companies, all of which are addressing large global risks and contributing to the solutions needed in our transition to the next, just, inclusive, and sustainable economy. Nia’s investment objective is to provide investors with long-term total return. Our advanced investment strategy strives to produce equity-like returns over a market cycle. This equity portfolio is not constrained to a geographic region or a specific benchmark, and is instead focused on solutions and innovation which have traditionally been sought by, and limited to, investors in private equity. Portfolio turnover is minimal as we keep our focus on the long-term viability and opportunity that each portfolio company provides, thus offering investors a tax- advantaged strategy. Our team researches companies that typically embody the following characteristics: ● Meet Nia’s strict high impact, solutions-focused social and environmental standards. ● Show strong growth characteristics not fully appreciated by the market. ● Deliver products or services with unique qualities, positioning them well for long-term growth. ● Operate in a manner that makes clear the company’s commitment to people, the planet and corporate social responsibility. Shareholder Engagement Program At Nia we invest only in what we believe to be the most positively impactful and responsible companies, and yet the opportunity for engagement still exists. Our team engages with our portfolio companies through a variety of approaches, such as: voting proxies on behalf of investors in a manner consistent with the highest aspirations of impact investors, meeting with portfolio company representatives whenever possible, engaging through advocacy letters, and filing shareholder resolutions. In addition to our activism, we are committed to donating a minimum of 5% of management’s profits to those nonprofit organizations doing change-making work, solving for our world’s largest inequality and sustainability issues. Our engagement strategy includes approaching all companies as allies – after all, our portfolio companies are selected because they incorporate best- practices along one or more of Nia’s six sustainability themes. We develop carefully researched ESG recommendations and pair this with educational materials tailored to each company. Outreach includes letters, phone calls, media placement, and when necessary, shareholder resolutions. Shareholder engagement, when done well and effectively, bridges two worlds; allowing civil society activists and the C-suite to find points of shared interest and mutual goals. Nia believes a well-designed shareholder engagement program considers which environmental, social and corporate governance (ESG) changes will be most beneficial to long-term stakeholder value. B. Investment Management, Mutual Fund Management, Portfolio Management, Sub- Advisory, and Financial Planning Services Investment Management Services The word “Nia” is of Swahili origin meaning intention and purpose. We build actively managed portfolios designed to harness the innovative social purpose of investment, seeking solutions focused companies whose executive teams demonstrate a high-level of commitment to diversity, transparency, employee engagement, and ecological sustainability. Nia typically manages separate accounts wherein we select equity securities with full discretionary authority. However, Nia may also accept client accounts on a non-discretionary basis in its sole discretion. By focusing our investment universe on publicly traded companies, we seek to build a portfolio of the most creative and positively impactful companies—those businesses that we believe most contribute to bettering our planet through real and tangible solutions to some of the world’s most critical equity and sustainability issues. We invest primarily in exchange-listed securities. At times the firm will also invest in issuers whose securities trade in the U.S. in the form of American Depository Receipts (“ADRs”). Nia provides investment advisory services to numerous clients – including separately managed accounts, UMA platforms, and the Fund, that have substantially similar investment objectives and similar portfolio holdings and characteristics. However, Nia clients having substantially similar investment objectives will not have identical investment portfolios. Differing investment portfolios can be expected to result from several factors, including, without limitation, the following: regulatory constraints that apply to certain accounts but not to others; investment constraints imposed by the client; and the amount of cash available for investment at certain times. As a result, accounts may have a different investment portfolio and different performance results than other accounts even though the accounts have identical or substantially similar investment objectives. In addition, there may be circumstances when one account will sell a security while another account may purchase the security on the same day primarily due to cash contributions and/or withdrawals; however, Nia does not engage in cross trades between client accounts (i.e., when an investment adviser causes a trade to occur between two or more of its advisory clients' accounts). Mutual Fund Management Nia serves as the investment adviser to Nia Impact Solutions Fund (the “Fund”), an open-end mutual fund registered under the Investment Company Act of 1940. Nia continuously manages the Funds’ assets on a discretionary basis based on the investment goals and objectives as outlined in the Fund’s prospectus. Nia will at times recommend individual clients invest in the Fund, typically when such clients have accounts that may be too small to fully invest in the Nia Global Solutions Equity Portfolio, or as otherwise dictated by the client’s investment goals and objectives. The Fund consists of investments in certain securities that typically provide an overall balanced investment approach Equity securities include common stocks and American depositary receipts (“ADRs”) of companies of any capitalization size, including large-cap, mid-cap and small cap companies, that the Adviser believes present an attractive opportunity for long-term capital appreciation. . Further detail on the Fund, including the risks pertaining to such strategies and their underlying securities, is outlined below in this brochure under the heading “Item 8: Methods of Analysis, Investment Strategies and Risk of Loss”. Interested investors should refer to the Fund’s prospectus and statement of additional Information (“SAI”) for important information regarding objectives,

investment, time-horizon, risks, fees and additional disclosures before investing. The prospectus and SAI and other documents are available at https://niaimpactfunds.com/or by calling (833) 571-2833. Please read the prospectus and SAI carefully before you invest. Portfolio Management Services Nia provides investment advisory services in the form of a model portfolio to be utilized by a sponsor broker dealer in an overlay program. Under the unified managed account (“UMA”) programs, Nia has an agreement with the sponsor (“UMA Program Sponsor”) and does not have any contact with the end clients (“UMA Program Clients”). Nia participates in UMA programs with the following financial institutions: Morgan Stanley Wealth Management Select UMA, FolioDynamix, Adhesion, and UBS ACCESS. Under these UMA programs, the UMA Program Sponsor receives Nia’s model allocation and, based upon the model, the UMA Program Sponsor executes the model changes for each UMA Program Client’s portfolio. A model allocation is an asset allocation in the form of a weighted list of asset classes (i.e. securities, bonds, etc.) selected for and with parameters meant to guide the ongoing implementation of the asset allocation. Restrictions for client accounts in the UMA Programs are monitored entirely by the Sponsors. UMA Program Clients are responsible for evaluating whether the fee paid to the UMA Program Sponsor exceeds the cost for the same services if such services were provided separately. UMA Program Clients should consider the overall fees and the services received to determine if the product is appropriate. Due to the structure of most UMA programs, Nia does not provide the same level of client relationship services to UMA Program Clients as it does to other clients. Each UMA Program Sponsor has their own brochure which contains detailed information about its program. Copies of each brochure are available from the UMA Program Sponsor upon request. Each UMA Program Sponsor has retained Nia through a separate contract. Clients should note that Nia may execute transactions for their accounts through the UMA Program Sponsor. Transactions executed through a UMA Program Sponsor may be less favorable in some respects than Nia’s clients whose trades are not executed through the UMA Program Sponsor. Nia may be constrained in obtaining best execution for UMA Program Clients by routing trades to the UMA Program Sponsor. However, Nia will make every effort to obtain best execution within any constraints that may be set forth by UMA Program Clients and/or Sponsor. Clients should also be aware that Nia will not be provided sufficient information by the UMA Program Sponsor to perform an assessment as to the suitability of Nia’s services for the client. Nia will rely on the UMA Program Sponsor who, within its fiduciary duty, must determine not only the suitability of Nia’s services for the client, but also the suitability of the program for the client. Financial Planning Services Nia provides financial planning services, either on a standalone basis or as part of its provision of investment management services. Nia’s financial planning services include, in all or part, yet are not limited to, the preparation of a financial plan by Nia or an associated person of Nia for a client which may include an annual or periodic review of a financial plan, the monitoring of a client's investments under a financial plan, and the provision of information and/or advice to a client regarding the purchase and/or sale of securities. Nia does not receive compensation (e.g., commissions or fees) from the sale of securities, insurance, real estate or other products or services that will at times be recommended in a financial plan. However, Nia would receive investment management fees if the financial plan incorporates a recommended allocation of the client’s assets to Nia. Such a recommendation, if made, would present a conflict between the interests of Nia, and the interests of the financial planning client. Financial planning clients are under no obligation to act upon any recommendation made by us, including a recommendation to allocate assets to Nia. If the client elects to act on any of the recommendations we make, the client is under no obligation to effect transactions through Nia, our representatives, or affiliates. Sub-Advisory Services At times, Adviser will provide services under sub-advisory agreements with other non-affiliated third party registered investment advisers (“TPA’s”) who have engaged Adviser to manage the holdings in their clients' portfolios. Both Adviser and the TPA will be granted dual trading authority in such situations. Adviser typically has discretionary authority over a portion of a sub advised client’s assets to buy and sell securities based on such client's individual needs. As discussed in Item 12 below, at times Adviser will bunch its client trades together with trades for other clients of those TPA’s for whom Advisor is serving as a sub-adviser, if doing so is deemed to be in the best interest of the Client. Fees for such services are negotiable and will be included as part of an agreement entered into by and between Adviser and the respective TPA. Written Agreement Investment management services are governed by a written investment management agreement (“Investment Management Agreement”) between Nia and the client which outlines the terms of service and applicable fees. Financial planning services are governed by a written consulting agreement (“Consulting Agreement”) between Nia and the client which outlines the terms of service and applicable fees. C. Educational Seminars and Workshops Dr. Hull, as a founder and/or co-founder of social enterprises, is invited to present at conferences, forums, panels, meetings, and universities to share her expertise in racial equity investing, starting not for profit businesses, social enterprises, and in the field of impact and gender lens investing. The content of such presentations is general in nature, does not contain securities or sector recommendations, nor solicit investment advisory business or clients. The Adviser’s Chief Executive Officer does not charge a fee for speaking at such events, although certain sponsors of these events may waive any fee due from the Adviser for participating. D. Use of Third-Party Service Providers To help manage client accounts, Nia utilizes the technology platform of Orion Advisor Services, LLC (“Orion”). Additionally, Nia has contracted with HIP Investor, LLC (“HIP”), an unaffiliated SEC registered investment adviser, to provide administrative services on behalf of client accounts via Orion’s platform. Specifically, HIP’s administrative services support Nia in maximizing the benefits of Orion’s platform to perform functions such as data reconciliation, performance reporting, client database maintenance, quarterly performance evaluations, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement Orion and HIP will have access to client accounts and information but will not serve as an investment adviser to Nia clients. Nia pays HIP a flat monthly fee for their services. E. Availability of Customized Services Nia does offer the ability to tailor our investment management services to clients. On a client-by-client basis, we allow clients to impose reasonable restrictions on investing in certain securities or types of securities. Such restrictions must be provided to us in writing. F. Wrap Fee Programs Nia has not and does not currently participate in any wrap fee programs. G. Client Assets Amount of Client Assets Managed As of February 29, 2024, the following represents the amount of client assets under management by the Firm on a discretionary and non-discretionary basis: Type of Account Assets Under Management Discretionary $409,249,022 Non-Discretionary - Total $409,249,022 1. Assets Under Advisement Nia also provides investment and financial advice for assets that are not directly managed by the Firm (“Assets Under Advisement” or “AUA”), such as a UMA (unified manager account), model delivery programs, and assets advised by the firm related to investment decisions or granting and donation plans. As of February 29, 2024, the following represents the amount of AUA by Nia: Type of Account Assets Under Advisement Total $56,247,837