A. General Description of Advisory Firm Exchange Traded Concepts, LLC (“ETC” or the “Adviser”) is organized as a limited liability company under the laws of the State of Oklahoma and is principally owned by Cottonwood ETF Holdings, LLC. ETC became a registered investment adviser with the Securities Exchange Commission (“SEC”) on August 18, 2009, under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and became a registered commodity pool operator (a “CPO”) with the National Futures Association (the “NFA”) on April 15, 2016. ETC serves its clients through its offices located in Oklahoma City, Oklahoma and New York City, New York. In January 2023, Exchange Traded Concepts, LLC (“ETC”) organized a wholly-owned subsidiary, ETC Platform Services, LLC (“Platform Services”), into which it has transitioned the non-investment advisory, operational, fund marketing and administrative services of ETC. Platform Services also provides administrative support to employees of ETC, such as payroll and benefits administration, and serves as a payment agent to ETC and to ETC’s fund sponsor relationships. The creation of Platform Services is the reason behind the reduction in total employees and employees providing advisory services, previously identified in Item 5 of Part 1A (“Item 5”) of the Firm’s Form ADV. The employees no longer identified in Item 5 of Part 1A of the Form ADV have been transitioned as employees of Platform Services, providing the same non-advisory services to fund clients that were previously provided by ETC directly. B. Types of Advisory Services Exchange Traded Concepts specializes in “private label” exchange traded funds (“ETFs”). Through its ETF-In-A-Box™ service, ETC provides a complete turnkey solution to help fund sponsors, index providers and other registered investment advisers (collectively, “Fund Sponsors”) to launch and operate custom ETFs in the U.S. ETC offers both passive (i.e., indexing) and active discretionary investment advisory services for the (i) U.S.-registered exchange traded funds (“ETFs”) and (ii) pooled investment vehicles that are not U.S.- registered mutual funds (e.g., a private investment vehicle and offshore funds). Together, we refer to ETFs, the private investment vehicle and offshore funds collectively as “Funds”. For ETFs that ETC manages as the investment adviser, ETC has overall responsibility for the general management and provides or causes to be furnished all supervisory, administrative and other services necessary for the operation of the ETFs, subject to the supervision of each ETF’s Board. ETC does not provide custodial services to any ETF and will not at any time accept or maintain custody with respect to an ETF’s assets. In accordance with the applicable Investment Advisory Agreement, ETC provides an investment program for each Fund and manages the investment of each Fund’s assets in conformity with the stated investment policies of such Fund, in the following general categories. For additional information regarding the Funds’ fees, investment objectives, investment strategies and associated risks, please refer to the Funds’ Prospectuses

and Statements of Additional Information. This ADV brochure does not constitute an offer to sell, or a solicitation of an offer to buy, shares of any ETF: Indexing Indexing is an investment strategy for tracking the performance of a specified market benchmark, or “index.” To the extent that ETC is managing a passive, or “index” Fund, either as an investment adviser or subadviser, ETC will manage the Fund’s portfolio to align the holdings of the Fund to the appropriate Index. An index is a group of securities whose overall performance is used as a standard to measure the investment performance of a particular market. The index provider determines which securities will be included in the index and the weighting of each security in the index. Under normal circumstances, the index provider will rebalance an index on a regular schedule. An index provider may carry out additional ad hoc index rebalances or delay or cancel a scheduled rebalance. Generally, the index provider does not provide any warranty, or accept any liability, with respect to the quality, accuracy, or completeness of either the target index or its related data, and ETC does not provide any warranty or guarantee against such errors. Active Management ETC also serves as investment adviser or subadviser to certain Funds that are actively managed. Actively managed funds do not seek to track the performance of a benchmark index; rather, the portfolio managers try to outperform that index and peer funds through investment selection. In pursuing an active Fund’s investment objective, ETC may license trading strategies, signals and indicators, artificial intelligence investment systems, and other forms of intellectual property developed by third parties. Either ETC or a Sub-adviser is responsible for placing purchase and sale orders and providing continuous supervision of the investment portfolio of each of the actively managed ETFs. Portfolio Trading Services ETC also serves as a trading subadviser for certain Funds. For these Funds, ETC executes trades to implement the investment program developed by the primary investment manager for the Fund. Specific Investments ETC invests in a wide range of investments in implementing the above strategies. These investments include, but are not limited to equity securities, fixed income securities, cash and cash equivalents, money market funds and derivatives, including listed options, futures, and swaps. C. Customized Services for Individual Clients The Adviser will tailor its advisory services for each Fund as set forth in a written advisory agreement and, if applicable, the registration statement or other governing document for such Fund. Any restrictions on the Adviser’s investment discretion are set forth in the written advisory agreement. D. Wrap Fee Programs The Advisor does not sponsor or maintain any wrap fee programs. E. Assets Under Management As of January 31, 2023, ETC had approximately $5,687,,000 of regulatory assets under management on a discretionary basis. As of January 31, 2023, ETC did not have any regulatory assets under management on a non- discretionary basis.