Clearwater Management Co. Inc. (CMC), founded in 1987, provides discretionary investment management and administrative services to Clearwater Investment Trust (the “Trust”), a registered investment company, and its separate series. CMC also serves as the investment adviser and general partner or manager to private investment funds. The Trust and its series and the private investment funds are the only clients for which CMC provides investment advisory services. The Clearwater International Fund, Clearwater Core Equity Fund, Clearwater Select Equity Fund and Clearwater Tax-Exempt Bond Fund (together, the “Funds”) is each a separate series of the Trust. CMC has entered into a management contract with the Trust, on behalf of each Fund, pursuant to which CMC is responsible for supervising the management of the Funds and overseeing the Funds’ subadvisory arrangements. CMC has retained various registered investment advisers to serve as sub-advisers to each Fund. Under the subadvisory agreements, CMC compensates each sub-adviser for its investment advisory services to the applicable sub-portfolio of each Fund. CMC and the Trust have also entered into a subadvisory agreement with Fiduciary Counselling, Inc., a registered investment adviser (“FCI”), pursuant to which FCI provides various investment-related services to the Funds in exchange for a subadvisory fee paid by CMC. FCI provides investment strategy advice, sub-adviser recommendations, review and reporting of investment performance of sub-advisers, asset allocation advice and other duties as designated

by CMC from time to time. FCI also provides compliance and administrative services to CMC with respect to the Trust. CMC serves as the general partner or manager to various private funds, including limited partnerships, limited liability companies, and a Cayman Islands exempted company (the “Cayman Fund”), a feeder fund in a master-feeder arrangement (collectively, the “Private Funds”). In its role as general partner or manager, CMC selects and oversees investments for the Private Funds. CMC generally invests the Private Funds’ assets in pooled investment vehicles, including funds-of-funds, or other investments overseen by independent investment management firms. FCI provides various investment-related services to CMC with respect to the Private Funds, including asset allocation advice, due diligence of portfolio investments and investment recommendations. FCI also provides compliance and administrative services to CMC with respect to the Private Funds. CMC tailors its advisory services based on the investment objective and strategies of the Funds and the Private Funds as set forth in the applicable offering documents. Investment restrictions applicable to the Funds and the Private Funds are set forth in the applicable offering documents and are overseen by CMC and, with respect to the Funds, the Board of Trustees of the Trust. CMC is owned by members of its board of directors and senior management. No shareholder owns 25% or more of the Company. As of December 31, 2023, CMC managed approximately $3.8 billion in assets on a discretionary basis.