Description of Aperio Aperio is a California limited liability company and an investment adviser registered with and regulated by the SEC under the Investment Advisers Act of 1940 (the “Advisers Act”). Aperio manages domestic, international, and global equity portfolios for individuals, high-net-worth individuals, institutions, and intermediaries such as wealth managers, consultants, and family offices. Aperio also advises a limited number of ERISA clients and provides sub-advisory investment management services to registered mutual funds and pooled investment vehicles, including private funds. Aperio was founded and has been in business since August 1999 and until early 2016, was entirely owned by its four partners: Patrick Geddes, Guy Lampard, Robert Newman, and Paul Solli. Principal Owners On February 1, 2021, BlackRock, Inc. (“BlackRock”), a publicly traded company, completed its acquisition of Aperio Holdings, LLC, and other equity interests related to Aperio Holdings, LLC, upon which BlackRock acquired all of the outstanding equity interests of Aperio Holdings previously held by Aperio insiders and Aperio’s majority investor, Golden Gate Capital, and thus acquired, indirectly, all equity interests in Aperio (the “Acquisition”). As a result of the Acquisition, Aperio is an indirect wholly-owned subsidiary of BlackRock, a global leader in investment management, risk management, and advisory services for institutional and retail clients. As used in this Brochure, the term the “Adviser” refers to Aperio, except where the context otherwise requires. References to “BlackRock” in this Brochure include BlackRock, Inc., together with its subsidiaries, including investment advisory and trust company subsidiaries (“BlackRock Investment Advisers” or the “Advisers,” which includes Aperio). Advisory Services Separate Account Management Aperio offers three (3) main equity investment strategies:  Active Tax Management,  Factor Tilts, and  Values-aligned investing. Aperio’s investment management services are offered (directly or indirectly through a sub-advisory arrangement with the client’s primary investment adviser) to U.S. registered investment companies, single-investor funds, discretionary and non- discretionary advisory programs, commingled investment vehicles, other investment advisers, and individuals and institutional investors through separate account management. The types of clients to which each Adviser provides investment management services are disclosed in each Adviser’s Form ADV Part 1A and summarized in Item 7 (“Types of Clients”) of this Brochure. Aperio creates customized separately managed equity portfolios using quantitative models and tools to incorporate client specifications for benchmark, factor tilts, tax management, and values-aligned preferences, including, without limitation, incorporating socially responsible investing considerations (“SRI”) or environmental, social, and governance (“ESG”) considerations. Clients also are able to customize their portfolios to meet specific requirements, such as holding restrictions, industry/country limitations, and situation-appropriate tax needs. While Aperio generally only implements long-only equity portfolios, certain clients that meet eligibility criteria established by Aperio may invest in long/short equity strategies. Benchmarks include broad market equity indexes representing domestic and/or foreign companies. Once a client has selected an investment strategy and benchmark, Aperio provides continuous supervision and management of the assets. Clients are responsible for informing Aperio of any changes to their investment objectives, individual needs, and/or restrictions. For clients implementing certain strategies and where internal Aperio systems support management, Aperio also offers the capability to integrate exchange-traded funds (“ETFs”) into Aperio’s management of client portfolios at the client’s direction. For information concerning costs associated with integrating ETFs into an Aperio account, please refer to Item 5 (“Fees and Compensation”), and for information regarding a potential conflict of interest concerning Aperio management of ETF holdings which may cause clients to pay fees to Aperio affiliates for providing management, administrative or other services (“Affiliated Funds”) that are in addition to any fees received by Aperio for providing discretionary investment services, please refer to Item 5 (“Fees and Compensation”), and Item 11 (“Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading”). Please refer to Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss for detailed information regarding Aperio strategies. Advisory Agreements Separate Accounts For all separate account clients, a written advisory agreement governs the terms of the relationship between Aperio and its clients. Aperio’s most common agreement types are its Master Sub-Advisory Agreement and individual Investment Advisory Agreement. Both types of agreements describe the advisory services to be provided, Aperio’s responsibilities, and the terms of engagement, including, but not limited to, fees and termination. Investment advisor intermediaries, consultants, and wealth managers (collectively, “Intermediaries,” and individually, an “Intermediary”) acting as the primary advisor may enter into a Master Sub-Advisory Agreement with Aperio, or may enter into a sub- advisory or similar agreement with another Intermediary that provides access to a turnkey asset management platform (“TAMP”) and has entered into a Master Sub- Advisory Agreement with Aperio, when Aperio has been selected to manage portfolios for such Intermediaries’ clients as a sub-advisor. In this case, the Intermediary’s client (usually an individual investor, a high-net-worth individual investor or foundation/endowment) delegates to the Intermediary the authority to select sub- advisor managers. Otherwise, non-sub-advisory clients, including those that are introduced to Aperio by an Intermediary, typically enter into an individual Investment Advisory Agreement. Both the Master Sub-Advisory Agreement and the individual Investment Advisory Agreement may be terminated by either party upon written notice to the other party. If Aperio terminates a Master Sub-Advisory Agreement, Aperio agrees to continue service for a specified period to facilitate transitioning of accounts. Both agreements generally provide for management fees paid in advance to be pro-rated to the date of termination and any unearned portion of the prepaid fees to be refunded to the client. For services billed in arrears, the client will be billed for services earned but not paid. Services of Affiliates BlackRock, Inc., operates its investment management business through the Advisers, as well as through multiple affiliates, one of which is a limited purpose national banking association chartered by the U.S. Department of Treasury’s Office of the Comptroller of the Currency, some of which are registered only with non-U.S. regulatory authorities and some of which are registered with multiple regulatory authorities. The Advisers use the services of their broker-dealer affiliates which are registered under the Securities Exchange Act of 1934, as amended (the “Exchange Act”) and members of the Financial Industry Regulatory Authority (“FINRA”), as needed.

For additional information, please refer to Item 10 (“Other Financial Industry Activities and Affiliations”) and Item 12 (“Brokerage Practices”) of this Brochure. The Advisers, including Aperio from time to time, use the services of one or more BlackRock, Inc., subsidiaries or appropriate personnel of one or more BlackRock, Inc., subsidiaries for investment advice, portfolio execution and trading, operational support, and client servicing in their local or regional markets or their areas of special expertise without specific consent by the client, if permitted and except to the extent explicitly restricted by the client in or pursuant to its agreement with Aperio, or inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including but not limited to dual employee, delegation, participating affiliate, sub-advisory, sub-agency, or other servicing agreements. This practice is designed to make BlackRock’s global capabilities available to an Adviser’s clients in as seamless a manner as practical within a varying global regulatory framework. In these circumstances, the Adviser with which the client has its agreement remains fully responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliates’ services except as set forth in the client’s agreement, governing documents and/or offering memorandum (“OM”). Wrap Program Services Aperio’s separate account strategies are also offered through certain wrap programs (each, a “Wrap Program”), which are sponsored by unaffiliated multi-service financial institutions (each, a “Wrap Sponsor”). A list of Wrap Programs may be found in Part 1 of our Form ADV. For further information on Wrap Programs, please also refer below to information in Item 5. Aperio requires a minimum account size for certain of its investment strategies, which varies among Wrap Programs. In most Wrap Programs, the Wrap Sponsor is responsible for establishing the financial circumstances, investment objectives, and investment restrictions applicable to each client, often through a client profile and discussions between the client and the Wrap Sponsor’s personnel. For single-contract Wrap Programs, Aperio contracts directly with the Wrap Sponsor or an affiliated advisor, or with an Intermediary that provides the Wrap Sponsor with access to a TAMP, and the written agreement governing Aperio’s services for the Wrap Program describes the services to be provided for each Wrap Program client (the “Wrap Client”), Aperio’s responsibilities, and the terms of engagement, including fees and termination. For single-contract Wrap Programs, Aperio does not execute a contract with each Wrap Client. Conversely, for dual-contract Wrap Programs, Aperio will execute an individual Investment Advisory Agreement with each Wrap Client. Wrap Sponsors of such dual- contract Wrap Programs may require service or other additional agreements with Aperio to cover items such as use of software provided, data downloads of account information, and electronic trading service terms and conditions. Generally, a Wrap Client, with the assistance and advice of the Wrap Sponsor, selects an investment advisor, such as Aperio, from a list of Wrap Sponsor approved advisers to provide investment management services for their assets allocated to their Wrap Program account(s). In addition, a Wrap Client may receive certain other services provided by the Wrap Sponsor and/or entities affiliated with the Wrap Sponsor (such as manager selection, trading execution, custodial services, periodic monitoring of investment managers, and performance reporting). Wrap Clients are typically charged by the Wrap Sponsor quarterly, in advance or in arrears, a comprehensive or wrap fee based upon a percentage of the value of the assets under management to cover such services (the “Wrap Fee”). The Wrap Fee often, but not always, includes the advisory fees charged by Aperio (or other participating managers) through the Wrap Program. Where the services provided by Aperio are included in the Wrap Fee, the Wrap Sponsor generally collects the Wrap Fee from the Wrap Client and remits the advisory fee to Aperio. For dual-contract Wrap Programs, Aperio’s fee is typically paid directly by the Wrap Client pursuant to the Investment Advisory Agreement with Aperio. Although the types of investment management services provided by Aperio to Wrap Clients are generally the same as the types of investment management services provided to our non-Wrap Program Clients, certain differences may exist. For example, as with other Master Sub-Advisory arrangements, the Wrap Sponsor often collects each client’s investment objectives and assists the client in determining the strategy best suited for the client, and client communications regarding the investment management of a Wrap Client’s assets are generally between the Wrap Sponsor or an affiliated advisor and the Wrap Client, with Aperio communicating only with the Wrap Sponsor or affiliated advisor, unless requested otherwise. Since the Wrap Fee paid by Wrap Clients to the Wrap Sponsor is all-inclusive, subject to enumerated exceptions for additional fees borne by Wrap Clients as determined by the Wrap Sponsor, Aperio believes it is important for each Wrap Client to evaluate whether such a program is suitable for their needs and cost effective, given factors such as the size of the account, frequency of transactions, and the Wrap Client’s investment objectives, as well as whether comparable or similar services are available at a lower cost if provided separately. Wrap Sponsors are responsible for providing Wrap Clients with this Brochure and applicable brochures for the Wrap Program (the “Wrap Program Brochure”). Wrap Clients should review the Wrap Program Brochure for further details about the relevant Wrap Program. Model-Based SMA Program Pursuant to participation in a “Model-Based SMA Program,” Aperio provides discretionary investment advisory services to an overlay portfolio manager (“OPM”) in connection with the OPM’s provision of investment advisory services to clients through a unified managed account Wrap Program. Specific to the terms of the Model-Based SMA Program agreement, Aperio acts as investment adviser to each Model-Based SMA Program client designated by the Wrap Sponsor and exercises discretion to select securities for the Model-Based SMA Program client’s account solely by delivering a model portfolio to the OPM, which the OPM will implement (subject only to account-specific restrictions imposed by such client) and arrange for execution of trades in such client’s account. Under the terms of the Model-Based SMA Program, the OPM can choose not to execute the trades recommended by Aperio. In the Model-Based SMA Program, the fees payable to Aperio for providing model portfolios are paid by the Wrap Sponsor based on the amount of their clients’ assets that are managed by the OPM pursuant to a model portfolio provided by Aperio. The Model-Based SMA Program to which Aperio currently provides model portfolios is identified in Aperio’s Form ADV Part 1. Amount of Client Assets Managed As of December 31, 2023, the following represents the total amount of client assets under management by Aperio: Type of Account Assets Under Management (“AUM”) Discretionary $80,212,688,341 Non-Discretionary $0 Total: $80,212,688,341