Firm Description Zevenbergen Capital Investments LLC (“ZCI”) is the successor organization to Zevenbergen Capital, Inc. which was established in March 1987. ZCI is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser whose primary business is providing investment advisory services through individually managed, aggressive growth equity portfolios. ZCI also serves as an adviser to two open-end mutual funds: the Zevenbergen Growth Fund and the Zevenbergen Genea Fund (collectively, the “Zevenbergen Funds” or the “Funds”). The Zevenbergen Funds are Registered Investment Companies (RIC) organized as a series under a Multiple Series Trust provided and maintained/administered by U.S. Bancorp Fund Services, LLC and distributed by Quasar Distributors, LLC. Principal Owners ZCI is primarily owned via a holding company (ZCI Holdings LLC) through which the firm’s owners, including certain key employees, hold their interests in ZCI. The parties named below hold economic interests in the firm as follows:
• evenstar3 inc.* 65%
• Virtus Partners, Inc. 30%
• Employee owners 5% *evenstar3 inc. is wholly owned by Nancy Zevenbergen, ZCI's President, Chief Investment Officer and sole Board member. Types of Advisory Services ZCI provides discretionary investment advisory and portfolio management services, based on client objectives, to individuals, high net worth individuals, pension and profit sharing plans, state or municipal government entities, corporations, charitable organizations and investment companies. ZCI provides advisory services through individually managed portfolios using the following strategies: Growth Equity Strategies:
• Zevenbergen Growth Equity: invests in growth companies with varied capitalization ranges.
• Zevenbergen Genea Growth Equity: exhibits sector concentration, investing in growth companies with primary emphasis in the technology, internet and telecommunications industries.
• Zevenbergen Income Growth: invests primarily in more mature companies with historical and expected future dividend growth.
• NVM: solely targets long-term capital appreciation through investment in non- diversified, highly concentrated positions in growth companies. Fixed Income:
• ZCI also advises on fixed-income securities as part of a client’s overall investment objective, typically selecting investment grade securities with the intent to hold to maturity. ZCI typically uses individual securities to implement the strategies described above but may use ETFs, mutual funds or other pooled vehicles as part of a client’s portfolio in order to meet their objectives. Proprietary Mutual Funds ZCI may also recommend purchase of the Zevenbergen Funds in providing advisory services to clients. The decision to purchase the Zevenbergen Funds is based on certain client circumstances, including but not limited to: level of client assets, tax status, investment objectives, liquidity needs and the potential fees and expenses (other than advisory fees) related to managing the client’s account(s) (please see the Description of Fees section in Item 5). Based on these circumstances, ZCI will make every effort to provide the client the most cost-effective investment approach (i.e. exclusively separately managed account, exclusively Zevenbergen Funds, or a combination thereof). Tailored Relationships ZCI may elect to provide investment advisory services to fulfill specific client investment objectives that differ from the above-described strategies. ZCI accepts reasonable

limitations or restrictions to such authority from the client. All limitations and restrictions placed on accounts must be presented to ZCI in writing, typically within the investment advisory agreement or similar document. Investment Advisory Agreement ZCI enters into an investment advisory agreement (“Agreement”) with all clients. At a minimum, the Agreement provides the following:
• Prohibits assignment of the Agreement without client consent.
• Identifies the rate and frequency of investment advisory fees.
• Notes name(s) of the account and/or beneficial party.
• Describes the services to be rendered, the extent of the firm’s discretionary authority over the account(s) and its ability to direct the custodian to that end.
• Discloses that ZCI will not serve as custodian of client assets.
• Identifies the type and frequency of reports and disclosures made to the client and their delivery method.
• Identifies whether client or ZCI is responsible for voting proxies.
• Allows for the client to authorize ZCI to directly debit advisory fees from the account or choose to pay fees themselves.
• Makes necessary representations applicable to ERISA accounts. Retirement Rollovers A client or prospective client leaving an employer typically has four options with regards to their 401(k) or other retirement plans (“Plan”): 1) if permitted, leave the money in former employer’s Plan 2) if available and permitted, rollover the assets into new employer’s Plan 3) transfer or “rollover” the assets into an individual retirement account (IRA) 4) liquidate and withdraw the assets, which is dependent upon the client’s age and could result in tax consequences and penalties When considering their options, ZCI provides general guidance and education to clients, enabling them to make informed decisions on retirement account transfers. In limited circumstances, ZCI may recommend a client rollover their assets into an IRA that ZCI manages, which results in a potential conflict due to the financial incentive. ZCI earns income based on the amount of assets a client has with the firm, and therefore the rollover into a ZCI managed IRA leads to more compensation for ZCI. To mitigate this conflict, ZCI takes into consideration various factors, as they are available to ZCI, such as the investment options available to the client or prospective client, fees and expenses of the Plan compared to the IRA, the services available, ability to take out loans, required minimum distributions, age considerations, and tax consequences. A client or prospective client is never under any obligation to rollover over their Plan assets into an IRA that may be managed by ZCI. Privacy Notice Delivery of ZCI’s Privacy Notice to new clients is made at the beginning of the advisory relationship. Clients will also receive an updated Privacy Notice should ZCI make a change to its privacy policy or as required should there be a change in its information sharing practices. If a client or prospective client would like to receive ZCI’s current Privacy Notice, they may email cco@zci.com or call our main office at (206) 682-8469. Assets Under Management ZCI manages client assets on a discretionary basis. As of December 31, 2023, ZCI managed total assets of $4,411,874,000 on a discretionary basis. In addition, ZCI provided investment advisory services to approximately $214,183,000 in assets under advisement. These assets are not included in the managed assets noted above.