A. General Description of Advisory Firm. Richard Bernstein Advisors LLC (“RBA” or the “Firm”) is an investment adviser focusing on longer-term investment strategies that combine top-down, macroeconomic analysis and quantitatively-driven portfolio construction. RBA strives to be a leading provider of innovative investment solutions for investors, and we believe that our competitive edge is our research-driven macro style of investing. That research starts with Richard Bernstein, the Firm’s Chief Executive Officer (“CEO”) and Chief Investment Officer (“CIO”), who is widely recognized in the area of style investing and asset allocation. He has over 40 years' experience on Wall Street, including most recently as the Chief Investment Strategist at Merrill Lynch & Co. He is much-noted on equity, style and asset allocation; and was voted to Institutional Investor magazine's annual "All-America Research Team" 18 times, including ten as the top-ranked analyst in his category and only one of 57 analysts to be inducted into the Institutional Investor All-American Research Hall of Fame*. Mr. Bernstein has also authored two books on style investing, including “Style Investing – Unique Insight into Equity Management," which is widely viewed as the seminal book on style-oriented investment strategies. We believe that our top-down macro approach is a unique style of equity and asset allocation and differentiates the Firm from the more common and traditional bottom-up approach of many asset managers. Our extensive array of macro indicators allows us to construct portfolios for clients that are innovative, risk-controlled, and focused on overall portfolio construction rather than on individual stock selection.
RBA offers its advisory services to a variety of clients, across various different formats. We distribute our services mainly through partnerships with some of the world's leading financial institutions, where we provide clients sub-advisory services through separately managed accounts (“SMAs”) and wrap fee programs. RBA also provides tailored asset- allocation models for discretionary wrap programs and equity income-oriented portfolios for open-end and/or closed-end registered investment companies, unit investment trusts (“UITs”) as well as serve as a sub-adviser or index provider to exchange-traded funds * Institutional Investor rankings relate to Richard Bernstein personally, and not to Richard Bernstein Advisors LLC. Mr. Bernstein was named to Institutional Investor’s “All-America Research Team” from 1991 through 2008, including a top-ranking in Equity Derivatives, Portfolio Strategy and Quantitative Research in 1995 through 2004. Mr. Bernstein was inducted into Institutional Investor’s All-American Research Hall of Fame in 2001. Institutional Investor is a leading international business to business publisher, focused on the publication of premium journalism, newsletters and research. The published rankings are based on responses to multi- factor surveys from a large number of investment professionals across a broad range of asset management firms that meet certain minimum eligibility requirements, including a minimum amount of sell-side commissions annually. The formula Institutional Investor uses to develop its rankings is proprietary. The rankings are not indicative of future performance, and there is no guarantee of future success. For additional information, visit www.institutionalinvestor.com. (“ETFs”). We also offer advisory services directly for institutions and individuals through SMAs. RBA was founded in 2009 as a Delaware limited liability company and is headquartered in New York City. The Firm became a registered investment adviser with the SEC (SEC File Number: 801-71501) in 2010. The Firm is principally owned by Mr. Bernstein and iM Global Partner (“iMGP”). B. Description of Advisory Services. Separately Managed Accounts RBA provides discretionary investment advisory services to SMA clients, primarily through financial intermediaries, for example, broker-dealers and registered investment advisers, often through wrap fee programs (see below), including UITs. RBA also provides discretionary investment advisory services directly to individuals and institutions. SMA clients generally select an investment strategy after consultation with RBA or their primary advisor. Some relationships involve dual contract arrangements whereby both RBA and the client’s primary advisory have an advisory agreement with the client. As detailed below, clients are permitted to impose reasonable restrictions if such restrictions are not materially different from a strategy’s investment objectives. Clients who impose investment restrictions should be aware that the performance of their accounts may differ from that of the investment strategies not subject to investment restrictions. Wrap Fee Programs RBA provides investment strategies to accounts under wrap fee programs sponsored by other unaffiliated financial institutions or “wrap sponsors.” The wrap sponsors recommend and assist clients in selecting an appropriate RBA investment strategy, taking into account their financial situation and investment objectives. RBA’s role is to manage the client’s account according to the strategy selected. In a wrap fee program, the wrap sponsor may provide investment advisory, execution and custodial services to clients in return for an all- inclusive – or “wrap” – fee paid to the sponsor. RBA receives a portion of the wrap fee for providing these strategies. RBA manages its wrap fee program accounts

in substantially the same manner as its SMA clients employing the same investment strategy. RBA will allow reasonable investment restrictions if they do not differ materially from a strategy’s investment objectives. Clients who impose investment restrictions should be aware that the performance of their accounts may differ from that of the investment strategies not subject to investment restrictions. Model Portfolio Provider (also known as Unified Managed Account Programs) RBA provides investment strategies via model portfolios to other investment advisers, including several ETF asset allocation driven models. As the model portfolio provider, RBA designs, monitors and updates the portfolio. The investment advisers may then implement the model portfolio for their clients and adjust the model portfolio as recommended by RBA. While RBA typically does not have discretion over client assets as a model portfolio provider, investment advisers may grant shared trading authority to RBA or “dual-discretion” over the clients’ assets whereby RBA has discretion to execute trades on behalf of the clients. Pooled Investment Vehicles RBA offers its advisory (or sub-advisory) services to a variety of different pooled investment vehicles, including open-ended registered investment companies (“mutual funds”), UCITS funds, UITs, ETFs, collective investment trusts, and investment vehicles exempt from registration under the Investment Company Act of 1940, as amended (such vehicles, “private funds”). RBA currently serves as the sub-adviser to mutual funds sponsored by Eaton Vance Management. In addition, RBA currently provides advisory services to Undertakings for the Collective Investment in Transferable Securities (UCITS) funds. A UCITS fund is a collective investment vehicle operating under the UCITS regulatory framework, which allows for the sale of across Europe. Also, RBA currently serves as the adviser or sub-adviser to UITs. A UIT is a pooled investment vehicle in which investors own a fractional undivided interest (i.e., units) in a portfolio of securities. RBA acts as sub-adviser to an ETF. RBA may act as sub-adviser to additional ETFs, on either a discretionary or non-discretionary basis whereby RBA provides model portfolios to the ETFs. We tailor our advisory services for a fund to such fund’s overall investment program, and not to the needs of any underlying investor therein. RBA has entered into an investment advisor agreement with Global Trust Company (“GTC”) to serve as investment adviser with respect to the assets of collective investment funds under the Richard Bernstein Advisors Collective Investment Trust (the “Trust”) established by GTC. GTC serves as Trustee of the Trust. The Trust was established to provide for the collective investment and reinvestment of assets of tax-exempt employee benefit plans. RBA has entered an investment management agreement with certain private funds to serve as investment adviser. RBA or its affiliate may serve as the general partner or manager for such funds. Interests in the private funds are offered to a limited number of selected institutional and other sophisticated investors. Investments in the private funds are subject to a number of restrictions with regard to investments, transfers and withdrawals. This document should not be considered an offering document for any mutual fund, UCITS, UIT, ETF, collective investment trust, private fund or other pooled investment vehicle. Please see the respective fund’s offering materials such as the prospectus, statement of additional information, and other reports to investors for complete disclosures relating to such fund. Index Provider Services RBA has created, maintains and licenses multiple indexes covering a range of asset classes. RBA licenses the right to use indexes to unaffiliated third parties but has no discretion over the assets that are to be managed by the third party manager pursuant to the index. In certain instances, RBA may also receive an index support fee to provide marketing, due diligence support or other assistance to licensees of the index. Published Research and Investment Commentary RBA may also provide published research and investment commentary to clients. RBA may also provide targeted advice based on the individual needs of its clients. Customized advice is provided on a case-by-case basis and is developed to suit the needs of the client. C. Managing the Individual Needs of Clients. RBA offers custom solutions through SMAs for both high net worth individual and institutional investors. RBA offers specific equity investment strategies and generally does not modify its investment strategy based on an individual client’s financial situation, investment experience, risk tolerance, or investment objective if it differs from the investment objective of RBA’s strategy. Notwithstanding the foregoing, RBA may allow reasonable investment restrictions that do not materially affect its investment strategy. D. Assets Under Management. As of December 31, 2022, RBA had approximately $14,475,225,397 in assets under management/advisement of which approximately $5,238,538,748 were managed on a discretionary basis and approximately $9,236,686,649 were managed on a non- discretionary basis. Assets under advisement or “non-discretionary” assets include client assets over which RBA does not have discretion such as for its model portfolio provider services. In addition, as of December 31, 2022, unaffiliated third parties maintained approximately $274,395,504 in assets for products which utilize RBA’s Index Provider Services.