We are a research-based investment management company with a specialist focus in applying statistical and mathematical inference to financial markets in an attempt to identify profitable investment opportunities for our clients. We are wholly owned by Winton Group Limited (together with its subsidiaries, “Winton”). David Harding founded Winton in 1997 and he is the principal owner of Winton. Our investment processes include statistical analysis of historical data to identify relationships and patterns that can be used to make inferences. We develop predominantly quantitative investment strategies that seek to achieve the Client’s investment objective, within the defined risk framework. These investment strategies are applied systematically. We use various combinations of our strategies to provide investment advisory services to: (i) Winton-titled funds (“Funds”); and (ii) third-party funds or accounts (“Managed Accounts” and, together with the Funds, “Clients”). Our Clients may invest long and short, using leverage, in a range of instruments as described further below. Our investment profiles include the following: Multi-Strategy A diversified combination of quantitative and systematic investment strategies applied to some or all of the following: equity securities (which includes some or all of the following: common stock of companies of any market capitalization; depositary receipts; exchange traded funds; and securities or other interests issued by collective investment funds managed or advised by us), fixed income securities, and a range of derivative instruments (including some or all of the following: swaps on a range of underlying instruments; forwards (which include currency forwards); futures on equity indices, bonds, interest rates, currencies, cryptoassets traded on regulated futures exchanges and commodities; and options).
Diversified Macro Strategy A diversified managed futures strategy that combines a core allocation to systematic trend following, with complementary quantitative investment strategies. The strategy is applied predominantly to a range of derivative instruments (including some or all of the following: swaps on a range of underlying instruments; forwards (which include currency forwards); futures on equity indices, bonds, interest rates, currencies and commodities; and options) and equity securities (which includes some or all of the following: common stocks of companies of any market capitalization; depositary receipts; exchange traded funds; and securities or other interests issued by collective investment funds managed or advised by us). Trend Following Strategy This trend following strategy is applied to a range of derivative instruments (including some or all of the following: swaps on a range of underlying instruments; forwards (which include currency forwards); and futures on equity indices, bonds, interest

rates, currencies, cryptoassets traded on regulated futures exchanges and commodities); and equity securities (including some or all of the following: common stocks of companies of any market capitalization; depositary receipts; exchange traded funds; and securities or other interests issued by collective investment funds managed or advised by us). Clients may invest in other instrument types. Our investment process is described in more detail under Item 8 below. We also manage accounts for an employee in relation to their personal securities portfolio. The accounts are managed on a discretionary basis and do not follow the quantitative strategies described above. We provide investment advisory services to the Funds pursuant to the terms of each Fund’s investment management agreement, offering memorandum and governing documents. We provide investment advisory services to Managed Accounts pursuant to the terms of investment advisory agreements, which generally contain bespoke investment constraints. The investment management and investment advisory agreements of the Clients and the offering memoranda and governing documents of the Funds are collectively referred to in this document as “Governing Documents”. We systematically restrict our investment strategies from investing in companies that manufacture, supply and/or distribute cluster munitions, anti-personnel landmines and other banned weapons prohibited under relevant conventions to which the United States and/or United Kingdom are signatories. In certain circumstances, we apply a country block where a particular country or currency is considered high-risk from a financial crime perspective. This will limit our flexibility to buy or sell securities of certain issuers. Further information is included in our Responsible Investment Policy available on request. All discussions of the Clients in this document, including but not limited to their investments, objectives, investment strategies, fees and other costs, conflicts of interest and relevant material risks are qualified in their entirety by reference to the relevant Governing Documents for each such Client. This brochure does not constitute an offer to sell or the solicitation of an offer to purchase any securities issued by any entities described herein. As of December 31, 2023, we had regulatory assets under management of approximately $7,846,552,535, representing Client assets managed on a discretionary basis. For the purpose of calculating this figure, we have used the prescribed methodology for calculating regulatory assets under management (“RAUM”). RAUM does not reflect assets under management relating to separately managed accounts that follow the Trend-Following Strategy and Diversified Macro Strategy where these accounts do not meet criteria to be included RAUM.