ABOUT NISA NISA is an independent investment management firm and is registered in the United States as an investment adviser with the SEC and as a Commodity Trading Advisor with the National Futures Association (“NFA”). NISA is also registered as a Portfolio Manager in the Canadian provinces of Ontario, Alberta, British Columbia, Manitoba, and Quebec, and as a Commodity Trading Manager in Ontario. NISA began advising clients in April 1994. NISA is a wholly owned subsidiary of its parent company, NISA, LLC, whose ultimate principal owners and Managers are:  David G. Eichhorn, through Orr Holdings, Inc., Orr-D, Inc. and Orr-L, Inc.,  Kenneth L. Lester, through Ridgewood, Inc., and  Anthony R. Pope, through Shiawase Holdings, Inc. NISA is 100% employee owned and as such we have a long-term view with respect to our business. We view being privately-held as a key differentiator and competitive advantage versus our peers. As such, NISA intends to remain employee owned. NISA’s Management Committee, comprised of an experienced team of senior personnel, is responsible for overseeing the firm’s business initiatives and governance. Since the founding of NISA (including an ownership transition within the employee base), we have deliberately sought to align our culture, systems and incentives in support of our Mission, Vision and Values. NISA’s Mission is to “Collaborate with clients to develop creative and thoughtful customized investment management solutions within a team-oriented culture.” Our Mission is supported by NISA’s Values:  Integrity – Operating with honesty, transparency, and reliability  Teamwork – Collaborating with others in a collegial environment  Accountability – Demonstrating an ownership mindset and taking personal responsibility  Intellectual Curiosity – Asking thoughtful questions, striving for improvement NISA’s culture seeks to reflect our Mission, Vision and Values, and we are gratified that “data” supports our approach. NISA’s Senior Team, which consists of approximately 45 team members, average over 15 years with NISA. The Senior Team in turn helps align these values throughout NISA. The design of our ownership structure is a prime example of how NISA aligns our culture with our Mission, Vision and Values. NISA views our two forms of ownership – membership in the LLC and participation interests in the Phantom Ownership Plan – as key components in building a workforce that is aligned in delivering results for our clients. The Phantom Ownership Plan was designed to promote retention and incentivize employees with grants of participation interests at all levels of the organization. A similar valuation formula is used to determine the value of LLC interests and Phantom Ownership Plan interests, such that participants share in both the economic upside and downside of NISA. This design allows NISA and our employees to take a long-term view and build upon the Values that are at the core of our culture and business. TYPES OF ADVISORY SERVICES NISA provides investment advisory services on a fully or partially discretionary basis primarily to institutional entities and, in certain circumstances, high-net-worth investors. Refer to Item 16 – Investment Discretion for more information about the F O R M A D V P A R T 2 A | N I S A I N V E S T M E N T A D V I S O R S , L L C | P A G E 8 requirements for NISA to accept discretion for client assets. INSTITUTIONAL ENTITIES NISA primarily offers investment management services to institutional entities through separately managed accounts. We also offer several of our strategies to eligible retirement plan clients through collective investment funds (“CIFs”) under the NISA Collective Investment Trust. NISA provides investment management services to the CIFs as sub-adviser, and Global Trust Company (“GTC”) serves as the trustee. HIGH NET WORTH INVESTORS Additionally, NISA’s equity strategy is offered indirectly to high-net-worth investors through financial intermediaries. NISA does not offer services directly to high-net-worth investors. In some cases, NISA provides discretionary investment advice to such high-net-worth investors through wrap and/or managed account programs and other platforms (“Managed Account Programs”) sponsored by third-party investment advisers, banks, or other financial intermediaries (“Sponsors”). A client in a Managed Account Program typically receives discretionary investment advisory services with respect to their account assets through one or more investment advisers (including NISA) participating in the program, and trade execution, custodial, performance monitoring, reporting and other services through the Sponsor, for a single, all- inclusive (or “wrap”) fee charged by the Sponsor based on the value of the client’s account assets. NISA does not act as a Sponsor for any Managed Account Programs. NISA presently participates or may in the future participate in the following types of Managed Account Programs:  “Single Contract” programs in which NISA enters into a contract with a Sponsor to provide discretionary advisory services to the Sponsor’s clients;  “Dual Contract” programs in which NISA enters into a contract directly with the client to provide discretionary advisory services to the client, and the client enters into a separate contract with the Sponsor; and NISA typically receives a portion of the wrap fee that clients pay for management of such accounts. NISA may also pay certain platform or data analytics fees where contractually agreed upon with the Sponsor. If a client receives investment management services from NISA through a Managed Account Program, the client should refer to the wrap brochure provided by the Sponsor for important information concerning the program and its fees. When participating in Managed Account Programs, the Sponsor is typically responsible for determining the suitability of the Managed Account Program, including NISA and our investment strategy, for the client. We typically are only responsible for managing client assets in accordance with the designated investment strategy. In certain Managed Account Programs, Sponsors may limit the information that is available to us about the client, the client’s other investments or risk tolerance, and other information that would be relevant to determining whether the investment strategy or certain specific investments would be suitable for the client. Likewise, we may be restricted by Sponsors from communicating directly with clients; all communications, including communications with respect to the clients’ investment objectives, financial condition and reasonable investment restrictions, typically must be directed through the Sponsor. A full list of the wrap programs in which NISA participates as a Manager are listed in Section 5.I.2. of NISA’s Form ADV Part 1A. F O R M A D V P A R T 2 A | N I S A I N V E S T M E N T A D V I S O R S , L L C | P A G E 9 OTHER INVESTMENT ADVICE NISA also provides investment advice other than discretionary investment advisory services. This advice is frequently more general in scope than the advice normally given in a typical asset management assignment. Examples of this advice include asset/liability management, including glidepath monitoring and de-risking activity, rebalancing policy, and stable value wrap selection and administration. Typically, NISA tailors this advice to the client’s investment objectives and circumstances. NISA provides this type of advice on a discretionary or non-discretionary basis. The services provided by NISA and all of the fees to be paid by the client are detailed in the client’s Investment Management Agreement, as amended from time to time. INVESTMENT RESTRICTIONS AND INVESTMENT GUIDELINE VIOLATIONS NISA assists each client in developing investment guidelines tailored to the client’s specific needs (the “Investment Guidelines”). The Investment Guidelines generally specify a benchmark index and limits on the type and amount of securities held. The client sometimes specifies limits at the issuer, industry, rating or other level. NISA will accept other restrictions if we believe we can comply with them while still meeting the client’s objective. NISA views client acceptance of Investment Guidelines as the client communicating to NISA its specific objectives, preferences, legal requirements, and risk tolerances. NISA expects that each client, together with its consultants or other advisors as the client deems necessary, will independently approve the Investment Guidelines and overall investment strategy and objectives for the portfolio without relying as a principal basis on NISA. With respect to the Managed Account Programs, NISA and the Sponsor may agree to specific Investment Guidelines for the applicable strategy. NISA may also accept restrictions communicated by the Sponsor consistent with the Investment Guidelines and strategy objective. The universe of benchmark indices and Investment Guidelines available to Managed Account Program clients will be limited to investment strategies approved by each Managed Account Program’s Sponsor. Certain error definitions are contingent upon an Investment Guideline term being violated. Therefore, NISA has an incentive to negotiate Investment Guidelines with wide latitude bands in order to reduce the possibility of committing Investment Guideline violations or other errors. NISA uses automated systems and manual checks to seek to confirm that all client portfolios are managed in accordance with their stated objectives and restrictions. A trade that is inconsistent with a client’s objectives or restrictions that is detected and corrected prior to settlement of the trade at no cost to the client is not considered

an Investment Guideline violation. In addition, a passive market move that takes a portfolio over a limit is also not considered an Investment Guideline violation. For Investment Guidelines that apply based on current market value, to the extent a client-directed contribution to, or withdrawal from, a portfolio results in a breach of a guideline, NISA will trade to move the portfolio back into compliance in the near- term during the normal course of trading. For Investment Guidelines that apply at the time of purchase, NISA will determine, in its sole discretion, whether to execute trades to move the portfolio within the applicable guideline limit(s). In either case, such breaches are not considered Investment Guideline violations. Additionally, NISA relies on external data sources that we reasonably believe to be accurate and reliable. NISA will seek to F O R M A D V P A R T 2 A | N I S A I N V E S T M E N T A D V I S O R S , L L C | P A G E 1 0 promptly correct any Investment Guideline breached due to our reliance on an inaccurate external data source; however, such an issue is not considered an Investment Guideline violation and NISA is not responsible for such issues. NISA will notify clients of external data source issues that we identify and believe materially impact their portfolio(s). Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information about Cyber and Technology Risk. Market Disruptions. The manner, impact and magnitude of market disruptions is very difficult to predict, and therefore to mitigate prospectively. Moreover, no Investment Guidelines or investment management agreements contemplate scenarios in which global financial markets or economies experience severe dislocation. Accordingly, in such circumstances, it may be imprudent or impossible to comply with client Investment Guidelines or directions. If NISA reasonably believes that it is imprudent or impossible to comply with an Investment Guideline or direction, NISA intends to act (or not take an action) in a manner that we believe at the time to be in the best interests of our clients. Specifically, NISA may not promptly cure, or NISA may be prevented from promptly curing, passive guideline breaches resulting from external sources such as market movements, ratings downgrades, collateral exchange and similar events. NISA will seek to keep clients (or, in the case of Managed Account Programs, Sponsor(s)) apprised timely of such instances. Additionally, NISA suggests the following to clients during severe market dislocations:  Provide as much advance notice as possible for flows or exposure adjustments.  Understand that some physical markets may be more liquid than others and if cash is necessary, consider raising funds via these more liquid markets.  For clients accustomed to more frequent tactical trading, recognize that the ability to initiate and unwind positions may be compromised at times in the future – either because of market liquidity or impaired activities of market participants.  Clients with derivatives positions should take additional steps to ensure that there is sufficient collateral available in light of the potential for large market moves. ASSETS UNDER MANAGEMENT NISA calculates assets under management for use in our client and promotional presentations, public website, regulatory filings, consultant databases, composite presentations and for other similar uses. NISA’s assets under management calculation normally includes actively managed cash assets such as regular cash portfolios, including those that utilize derivatives to manage duration, temporary portfolios holding securities that are set aside to raise cash for upcoming withdrawals, actively managed cash collateral portfolios, and the marked-to- market value of:  derivatives used in cash securities portfolio management;  derivatives used to adjust the duration of a cash securities portfolio in which the use of derivatives is incidental to the investment strategy;  cash securities resulting from a repurchase agreement transaction; and  derivatives used in synthetic exposure portfolios that are secured by collateral. NISA generally excludes the following assets when calculating assets under management: F O R M A D V P A R T 2 A | N I S A I N V E S T M E N T A D V I S O R S , L L C | P A G E 1 1  derivatives in overlay-only engagements managed as part of an overlay of cash assets not managed by NISA;  derivatives in a duration overlay engagement;  the market value of accounts over which NISA no longer has discretion such as an account that has been liquidated for withdrawal or for which NISA has received a termination notice;  stable value assets for which NISA only provides wrap administrative services; and  collateral posted by a counterparty to a client. As of December 31, 2023, NISA managed the following physical assets under management: Discretionary $287,721,988,249 Non- Discretionary $2,504,901 Total $287,724,493,150 Additionally, as of December 31, 2023, NISA managed over $235 billion notional value in derivatives. To calculate derivatives notional under management for positions in markets where notional is measured in volatility exposure, NISA converts the instrument volatility exposure into an option market equivalent notional that matches the volatility exposure. Repurchase Agreements are reported in both physical assets and derivative notional value. In some cases, NISA chooses to combine physical assets and derivatives notional into one total measure of assets under management. The assets NISA manages are predominantly U.S. dollar denominated securities. NISA also manages some portfolios that hold Canadian dollar denominated securities and other non- U.S. denominated securities. In these cases, NISA uses the then-current exchange rate to convert the market value of these portfolios into U.S. dollars when calculating NISA’s assets under management. Additional Information with Respect to Regulatory Assets Under Management Found in Part 1 of this Form ADV. The SEC has created a classification of assets under management called “regulatory assets under management” or “RAUM.” NISA’s RAUM calculation, as defined by the SEC, includes more assets than NISA normally includes when calculating assets under management, particularly for accounts that utilize derivatives. In addition to requiring the inclusion of more assets, the RAUM also requires definitions of discretionary and non- discretionary assets that are different from those NISA uses when reporting assets under management. NISA’s RAUM includes the assets of all client accounts that meet the SEC’s definition of a securities portfolio, including cash and cash equivalents, for which NISA provides continuous and regular supervisory or management services. Some of these assets include, but are not limited to:  the absolute value of the marked-to- market positions of each derivative instrument, as well as cash and cash equivalents held in these accounts. Using the absolute value of these positions means NISA counts a negative marked-to-market value as a positive;  the market value of cash and cash equivalents (generally, Short Term Investment Fund (“STIF”) and/or Treasury Bills) set aside to meet derivative collateral requirements;  temporary portfolios holding securities that are set aside to raise cash for upcoming withdrawals; and  stable value assets for which NISA provides wrap administrative services. F O R M A D V P A R T 2 A | N I S A I N V E S T M E N T A D V I S O R S , L L C | P A G E 1 2 The following is a non-exhaustive list of assets that NISA does not include in RAUM:  the market value of broker-dealer owned collateral posted to client accounts; and  any measure of derivative notional exposure. RAUM is a higher number than the physical assets under management number NISA uses in our promotional materials. CLIENT COMMUNICATIONS NISA’s clients frequently communicate written instructions to NISA, including via email. NISA seeks to promptly acknowledge receipt of any written instruction. NISA does not consider any written instruction to have been delivered to NISA until a NISA employee acknowledges receipt of such instruction. NISA does not offer investment advisory services directly to high-net-worth investors, but only indirectly through external financial intermediaries or Sponsor(s) of Managed Account Programs. NISA is only authorized to take instruction from the financial intermediary or Sponsor. As such, high-net- worth investors should contact their financial intermediary, advisor or Sponsor with respect to the underlying portfolio managed by NISA. Please see NISA’s Form CRS (Client Relationship Summary), located on our website, www.nisa.com, for additional information. OTHER INFORMATION NISA provides similar services to many clients. NISA’s advice to one client frequently does not relate to, and often differs from, the advice given and/or timing of NISA’s advice to another client. As a result, NISA has the potential to be buying a security for one client while we are selling the security for another client. NISA has the potential to acquire material, non-public information or “inside information” about companies or their securities. If NISA believes we have inside information about a security or issuer, we will not trade based on that information. Having actual material, non-public information would limit the universe of securities in which NISA can invest for our clients. NISA does not believe that these restrictions will materially affect our ability to provide investment advisory services to our clients.