New Age Alpha Advisors, LLC (“NAAA”) is an investment adviser that seeks to manage assets for private funds, institutional investors, and high net worth individuals so as to achieve expected returns using a proprietary investment methodology. NAAA is a Delaware limited liability company that was formed on August 9, 2018 and is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser. Registration with the SEC does not imply a certain level of skill or training. New Age Alpha LLC is the sole owner of NAAA. New Age Alpha LLC is owned by Six A, LLC, JALT Investment, LLC, and Versorgungswerk der Zahnärztekammer Berlin K.d.ö.R. (through its wholly-owned subsidiary, VZB-ABB LLC). Armen Arus is the majority owner of Six A, LLC and Julian Koski is the majority owner of JALT Investment, LLC. NAAA provides investment advisory services, primarily focused on implementing equity, fixed income, and environmental, social and governance (“ESG”) asset management strategies using a proprietary investment methodology. NAAA provides discretionary advisory services to certain unregistered funds (each a “Fund” and collectively the “Funds”) and provides discretionary sub- advisory services whereby other investment advisers may hire NAAA to manage a portion of their individual client’s portfolios or funds using NAAA’s proprietary investment methodology. NAAA also offers services to institutional investors and high net worth individuals through separately managed accounts (“SMAs”). NAAA typically provides advisory services to clients in an agency capacity pursuant to an investment management agreement (“IMA”) between the client and NAAA by which each client generally grants to NAAA full discretion to manage their investment assets. NAAA manages the New Age Alpha Master Fund SPC, Ltd., a hedge fund organized as an exempted company incorporated with limited liability and registered as a Segregated Portfolio Company under the laws of the Cayman Islands. New Age Alpha Master Fund SPC, Ltd. is the master fund in a master-feeder arrangement. It has two (2) feeder funds: (1) New Age Alpha Fund, LP, an onshore feeder fund organized under the laws of the state of Delaware, and (2) New Age Alpha Fund SPC, Ltd., an offshore feeder fund organized under the laws of the Cayman Islands (collectively, the “Master-Feeder Hedge Funds”). NAAA provides discretionary investment advisory services to the Master-Feeder Hedge Funds consistent with the investment objectives, strategies, and any applicable investment restrictions described in each Fund’s Private Placement Memorandum or other applicable offering documents. New Age Alpha Fund SPC, Ltd. has two segregated portfolios. NAAA provides sub-advisory services to Funds that are domiciled in South Africa and Luxembourg. NAAA has discretion to manage these Funds consistent with the investment objectives, strategies, and any applicable investment restrictions described in each Fund’s applicable offering documents. NAAA provides sub-advisory services via its direct and custom indexing investment products (“direct indexing”) through a proprietary technology system called Systematic Personal Asset Customization Engine (“SPACE”). SPACE is only available to other investment professionals, such as registered investment advisers, to utilize on their client’s or on their own behalf. In some cases, NAAA provides sub-advisory services to accounts on SPACE and in those circumstances, it is responsible for the management of the investment objectives and policies of each account, which includes investment discretion and responsibility for executing the trades. The principal advisers maintain both the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client suitability for NAAA’s designated investment strategies and/or programs. In performing its services, NAAA shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. For clients setting up a SMA, NAAA employs a disciplined investment process that begins with an assessment of each client’s objectives, return expectations, risk tolerance, and investment constraints based upon information provided by each client (the “Investment Objectives”). NAAA works together with each SMA client to establish the client’s initial Investment Objectives and to make sure they are tailored to the client’s specific needs. During this process, and afterward by providing written notice to NAAA, the SMA client may modify the Investment Objectives or impose restrictions on investing in certain securities or certain types of securities. For example, SMA clients may place restrictions on NAAA’s ability to use leverage or to invest in specific securities or types of securities. The SMA client’s Investment Objectives will be memorialized by NAAA and documented in writing prior to implementation of an investment strategy. NAAA will utilize the Investment Objectives to determine the appropriate

target asset allocation and the discretionary management of the SMA client’s assets on an ongoing basis. The Investment Objectives will be reviewed and approved by the client at the inception of the relationship and will be reviewed and discussed periodically over time, but no less frequently than annually. Clients must notify NAAA should there be any changes to their financial circumstances, needs, objectives and/or tolerance for risk or other circumstances relevant to management of their account(s). For Fund clients, NAAA maintains compliance procedures designed to ensure that Fund assets are invested in compliance with the investment objectives, strategies, and any applicable investment restrictions described in each Fund’s applicable offering documents, as amended or supplemented, and with any policies, guidelines, instructions and procedures approved by the Fund’s management, Board of Trustees, Board of Directors, or other governing body and provided to NAAA. NAAA may license its proprietary investment methodology, including the use of its Indices, to other third parties which may include investment advisers. The licensing agreements with the investment advisers will allow the investment adviser to use and implement the methodology as part of its advisory services. NAAA may also license access to SPACE to other investment professionals, such as registered investment advisers. In these situations, NAAA would not be providing advisory services to the clients of the investment adviser who is utilizing the methodology or SPACE. NAAA may also prepare written commentary on general market conditions that is not specifically tailored to any particular client’s needs. The commentary is prepared to educate and inform current and prospective clients, consultants, and other business contacts about market conditions or trends that NAAA may consider of interest. NAAA does not charge a fee for providing this written commentary. NAAA does not participate in any wrap fee program. NAAA intends to primarily manage client accounts on a discretionary basis. Managing accounts on a discretionary basis means that NAAA is authorized to buy and sell securities in these accounts without transaction-by-transaction authorization from the client. NAAA may also agree to manage accounts in a non-discretionary manner on a case-by-case basis. With a non-discretionary account, NAAA will advise clients on purchasing, selling, holding, valuing, or exercising rights with respect to particular investments, but will not have discretion to execute purchases or sales on behalf of the client without the specific instruction of the client. In non-discretionary accounts, the client will make the final determination as to whether to act on such recommendations. As noted in this brochure, NAAA can provide services to SMA accounts and through direct indexing accounts in SPACE. However, as of the date of this brochure, NAAA does not have any SMA or direct indexing clients or assets. As of December 31, 2022, NAAA was managing $131,431,240 of Regulatory Assets Under Management on a discretionary basis and $0 of assets on a non-discretionary basis. Assets Under Advisement In addition to its Regulatory Assets Under Management, NAAA also provides certain additional services to clients which are non-discretionary in nature (the “Advisement Services”). The assets that NAAA advises pursuant to its Advisement Services (the “Assets Under Advisement”) are not considered Regulatory Assets Under Management by the SEC. Assets Under Advisement refer to assets on which NAAA provides advice or consultation but for which it does not have discretionary authority or does not ultimately arrange or effectuate securities transactions.  Assets advised under the following situations are included in NAAA’s Assets Under Advisement:
• NAAA has entered into an arrangement pursuant to which it creates model indexes for an asset manager platform. Those advisers that subscribe to that asset manager platform are permitted to access NAAA’s model indexes and invest their client’s assets following NAAA’s model indexes. NAAA is responsible for establishing the model indexes and for periodically updating the model indexes.
• NAAA will be entering into separate index licensing arrangements pursuant to which NAAA will create and curate indexes for individual institutional clients for managing their portfolios. NAAA is responsible for establishing the model indexes and for periodically updating the model indexes.
• NAAA has also entered into a separate arrangement pursuant to which it provides its model indexes, Expectation Risk FactorTM (f/k/a Human Factor) algorithm methodology, RiskSelect® Methodology, asset allocation services, and training and support on this use of its services to another advisory firm. Fees charged for the Advisement Services are negotiable and may differ from the fees charged by NAAA for investment advisory services. As of December 31, 2022, NAAA’s total Assets Under Advisement was $1,563,193,251.