Meeder Investment Management, Inc. (“MIM”) offers a complete range of equity, fixed income and cash management investment solutions through its wholly owned SEC registered investment advisers: Meeder Asset Management, Inc. (“MAM”), Meeder Advisory Services, Inc. (“MAS”), and Meeder Public Funds, Inc. (“MPF”). MIM’s principal owners are Robert Meeder, Jr. and Robert Meeder, Sr. All affiliates of MIM are located at 6125 Memorial Drive, Dublin, Ohio 43017 and share employees. Meeder Asset Management, Inc. designs investment solutions that manage risk and improve investor outcomes. The firm is a defensive investing pioneer, whose tactical asset allocation expertise dates back to the firm’s inception in 1974. MAM offers its clients a model- driven, multi-discipline, multi-factor approach to investing. Our investment solutions include mutual funds, investment portfolios, separately managed accounts, retirement plan services, cash management solutions, and individualized financial planning services. As of December 31, 2023, MAM had assets under management of $2,420,073,659, all of which were managed on a discretionary basis. Individual Portfolio Management MAM provides a wide variety of investment management services to individuals, families and businesses. Before recommending an appropriate program and investment strategy, MAM will obtain information regarding your financial circumstances, investment goals and objectives. MAM may use questionnaires or other methods to determine your risk tolerance. MAM will collect other pertinent information regarding your current investments, income, earnings, assets, liabilities, retirement plans, tax circumstances and insurance policies. This information is used to make recommendations regarding each client’s investment strategy and clients should notify us promptly of any changes in their financial situation, goals or objectives. A financial adviser will assist clients in selecting an investment program and strategy that meets their investment needs and risk tolerance. WRAP FEE PROGRAMS Many investment management services offered by MAM are provided through wrap fee programs in which clients pay an asset-based fee that covers investment management, execution and custody services. These programs include Meeder Investment Portfolios, Meeder Select Portfolios, Meeder Premier Portfolios, Separately Managed Accounts, Private Wealth Management and Adviser Directed Accounts. Information about Meeder’s wrap fee program services may be found in the firm’s Form ADV, Part 2A, Appendix 1 brochure, which may be obtained upon request. Programs offered outside of the wrap fee program are described in this brochure. MEEDER INVESTMENT PORTFOLIOS Meeder Investment Portfolios are offered to Meeder clients as direct investments in Meeder Funds through our affiliated transfer agency, Mutual Funds Service Co. The portfolios offer clients the opportunity to purchase a managed portfolio of Meeder Funds designed to meet a variety of investment objectives. Clients utilize a questionnaire to determine their investment objectives and risk tolerance. The program recommends a suitable portfolio based on the responses given and clients select the portfolio that meets their needs. The portfolios consist principally or exclusively of Meeder Funds selected by the portfolio manager to meet specific investment objectives and risk tolerance levels. Meeder Funds are often the only investment options utilized for a Meeder Investment Portfolio. In other cases, MAM exercises a preference for its affiliated proprietary mutual funds but may supplement the portfolio with limited third-party mutual funds to meet specific objectives. The minimum account size for Meeder Investment Portfolios is $5,000. MEEDER SELECT PORTFOLIOS Meeder Select Portfolios are offered to individual clients on various custodial platforms, including those offering 403(b) tax-deferred retirement plans. Meeder also offers its Select Portfolios investment management service for certain fee- based variable annuity programs. In these MEEDER ASSET MANAGEMENT, INC. | MARCH 28, 2024 PAGE 5 programs, Meeder assumes discretionary authority to allocate subaccounts in accordance with the client’s investment objectives. The portfolios offer clients the benefits of Meeder tactical management in a portfolio comprised of non-proprietary mutual or exchange-traded funds. Clients utilize a questionnaire to determine their investment objectives and risk tolerance. The program recommends a suitable portfolio based on the responses given and clients select the portfolio that meets their needs. Account minimums for these programs are set by the program sponsor. SHORT-TERM FIXED INCOME PORTFOLIOS MAM’s Short-Term Fixed Income Portfolios are individually

designed for clients seeking income from highly liquid instruments. Participation in the program generally requires a minimum $1,000,000 investment. Short Term Fixed Income Portfolios are constructed from individual securities selected by the portfolio manager, including commercial paper, taxable and tax- exempt bonds, and certificates of deposit. Money market funds may also be utilized. The portfolio manager selects commercial paper, taxable and tax-exempt bonds from issuers approved by the firm’s credit committee, which utilizes fundamental credit and relative value analysis combined with ongoing oversight to select issuers eligible for purchase in this program. Institutional Portfolio Management MAM also provides investment advisory services to registered investment companies, institutional investors and qualified retirement plans who manage investments for their shareholders and participants. MAM serves as the manager and investment adviser to the Meeder Funds. For additional information about the Meeder Funds, please see the funds’ prospectus and statement of additional information. RETIREMENT PLAN SERVICES MAM provides retirement plan sponsors with fiduciary investment management services, including development of an investment policy statement, selection of designated investment options, and ongoing monitoring of the plan. In accordance with the terms of the retirement plan agreement and investment policy statement, MAM may exercise discretion to select, review and replace investment alternatives made available to participants in the plan and to direct the plan recordkeeper to implement those changes. All such services are offered subject to the specific terms of the retirement plan agreement. Retirement plan sponsors also engage MAM to offer managed portfolio solutions to their participants. In this program, MAM enters into an agreement with the plan to offer managed portfolios to plan participants as a designated investment option under the plan. Pursuant to the agreement and investment policy statement, MAM exercises discretion in creating and maintaining the portfolios and directs the plan’s recordkeeper to implement any changes to the portfolios. Participants select a portfolio that meets their needs from those made available by the plan. Available portfolios include risk-based portfolios designed to achieve a certain investment objective and risk tolerance, age-based portfolios that match an investment objective and risk tolerance with the participant’s current age, and target date portfolios that follow an incremental glidepath in which the asset allocation becomes more conservative over time. Meeder retirement portfolios may be constructed from proprietary Meeder Funds, non-affiliated mutual funds, or ETFs. For portfolios constructed from Meeder Funds, the portfolio manager exercises a strong preference for Meeder Funds, but on some platforms may supplement the portfolio with limited third-party mutual funds to meet specific objectives. Financial Planning & Consulting Services MAM offers financial planning and investment consulting services individually tailored to the needs of the client. Services are individually negotiated for each client and may be provided on an ad-hoc or ongoing basis. When offering these services, MAM does not undertake discretionary management of client assets, and clients are under no obligation to implement the recommendations provided. Clients may MEEDER ASSET MANAGEMENT, INC. | MARCH 28, 2024 PAGE 6 implement the advice themselves or through any other financial organization of their choice. When undertaking financial planning services, MAM will typically review the client’s overall financial situation, including income, assets, liabilities, taxation, insurance needs, retirement and estate planning objectives. Clients may include assets held at a variety of custodians, including different forms of retirement savings or pension plans. Financial planning clients typically receive a written financial plan, addressing savings goals, asset allocation, security selection, insurance, retirement income and other goals. Investment consulting services are typically offered to corporations, charitable organizations, investment advisers, and state and municipal government entities. Services may include development or review of an investment policy statement, evaluation of investment alternatives, monitoring and due diligence review of investment managers, portfolio analysis and monitoring reports, non- discretionary investment advice, and certain non- advisory investment services. Consulting services are highly customized for each client’s needs and are provided in accordance with individually negotiated agreements.