Tidal Investments LLC (“Tidal”), f/k/a Toroso Investments, LLC, is a Delaware limited liability company founded in March of 2012. Tidal is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). Fund Administrator, Tidal ETF Services, is a wholly owned subsidiary of Tidal and both are joined under the brand name, Tidal Financial Group. Over 50% of Tidal’s voting rights are controlled by employee-members. Types of Advisory Services Registered Investment Companies Tidal currently serves as an investment adviser to investment companies (each a “fund” and collectively, the “funds”) registered under the Investment Company Act of 1940 (“1940 Act”). Tidal has the responsibility to oversee the activities of any appointed sub-advisers and it is Tidal’s responsibility to ensure that all transactions comply with applicable regulations and prospectus covenants. Tidal also can serve as investment sub-adviser to investment companies registered under the 1940 Act. In addition, where Tidal is the adviser or sub-adviser, there are certain funds for which Tidal will initiate placement, execution, and settlement of trades. Tidal’s trading desk will be responsible for initiating trades necessary to keep the funds in line with a model portfolio provided by the adviser, sub-adviser or, in the case of an exchange traded fund, the indexing agent or at the direction of the adviser or sub-adviser. Sub-Advisory Services Tidal will enter into sub-advisory agreements with other registered investment advisers to provide certain investment management services to those advisers. The sub-advisory services offered by Tidal may include but are not limited to: conducting trades as directed by the primary adviser; executing model portfolios for investment managers; and providing a platform to assist the primary adviser with implementing portfolios managed by the primary adviser. Other registered investment advisers who enter into a sub-advisory agreement with Tidal will delegate their discretionary authority to conduct trades on behalf of specified accounts. Tidal will use this discretionary authority to implement portfolio selections or direct trade instructions provided by the primary investment adviser. When Tidal acts as a sub-adviser, the primary adviser is responsible for ensuring that it complies with all applicable statutes, regulations, and rules. Furthermore, the primary adviser is responsible for assessing whether instructions provided to Tidal, regarding the selection of a portfolio, the purchase of a security, or the sale of a security meet the applicable suitability/best interest standards. Other Services Tidal also offers fee- only discretionary and non-discretionary investment management services to individuals; high net worth individuals, including family offices and institutions, which primarily include qualified pension plans, Taft-Hartley

plans, and 401(k) plans. Additionally, Tidal provides fee-only non- discretionary pension consulting services to corporate retirement plans and non-discretionary outsourced chief investment officer (OCIO) consulting services to financial advisors. Tidal also provides bespoke independent financial services to individual investors, retirement plan sponsors and corporations. Tidal provides an ETF-focused, diversified asset allocation approach that is outcome focused and strives for consistent performance while embracing each client’s specific risk tolerance and true time horizon. Tidal generally provides these services via its Tidal Advisors division, or Faro Advisory division (a sub-division of the Tidal Advisors division). Prospective clients can enter into a discretionary or non-discretionary investment management services agreement directly with Tidal. Direct separate account clients will participate in one or more interviews that will assist Tidal in obtaining information about the client’s financial situation so that Tidal can recommend one or more of its investment strategies and portfolio options to the client. In general, tailored investment advice will be provided to these clients as recommended investment strategies and portfolio options. Investment Manager to UCITS Tidal provides certain investment management services to non-affiliated UCITS funds registered with the Central Bank of Ireland (CBI). Separately Managed Accounts (SMAs) Toroso Advisors Division Toroso Advisors is a division of Tidal. Toroso Advisors offers fee-only discretionary and non- discretionary investment management services to individuals; high net worth individuals, including family offices; and institutions, which primarily include qualified pension plans, Taft-Hartley plans, and 401(k) plans. Additionally, Tidal provides fee-only non-discretionary pension consulting services are offered via Toroso Advisors primarily to corporate retirement plans. Such services typically include the provision of advice regarding investment strategies, investment policy, asset allocation, asset class specification and investment vehicle selection, as well as portfolio monitoring services. Conflict of Interest The existence of advisory, sub-advisory, or profit-sharing agreements may create a material conflict of interest because it provides Tidal with an incentive to increase assets under management in ETFs for which it provides advisory or sub-advisory services. To mitigate that potential conflict, Tidal does not charge its advisory fees on client assets invested in Tidal-advised, sub-advised or sponsored ETFs. Assets Under Management As of December 31, 2023, Tidal had the following client assets under management: o Discretionary Assets: $10,697,761,421 o Non-Discretionary Assets: $636,661,256 o Total Assets Under Management: $11,334,422,677