A. Firm Description Instinet, LLC (“ILLC” or the “firm”) provides agency-focused electronic trading and ancillary services to institutional clients and broker-dealers. ILLC registered with the U.S. Securities and Exchange Commission (“SEC”) as a broker-dealer in 1979, and as an investment adviser in 2016. It is indirectly owned by Instinet Holdings Incorporated (“IHI”), which is itself owned indirectly by Nomura Holdings, Inc. (“NHI”). NHI is a publicly traded company listed on the Tokyo and New York stock exchanges. NHI, together with its subsidiaries, is referenced herein as “Nomura” or the “Nomura Group” unless noted otherwise. B. Description of Advisory Services In addition to broker-dealer services, the firm provides technical analysis, commentary and trading ideas regarding various financial and investment products including equities, indices, fixed-income securities, exchange-traded funds, crypto-currencies, foreign currencies and commodities for a fee to institutional clients. These services (collectively, the “Advisory Services”) may include any or all of the following: 1) daily and intra-day reports of unfolding market patterns and price movements, 2) periodic analysis of significant trends over a given week, month or quarter, 3) access to technical analysts for explanation and commentary on the daily reports and periodic analysis, and 4) trading ideas which may highlight a specific near-term catalyst or event impacting a company or a market that is anticipated to have a short-term price impact on the securities or financial instruments described therein. The daily and intra-day reports and periodic analysis are provided to clients via email and typically include bullet commentary along with illustrative charts, data tables, and statistics drawn from publicly available resources. Occasionally, such analysis may focus on a single security and, when appropriate, provide directional scenarios using chart patterns, underlying trends and various technical indicators to derive price objectives (profit taking levels) and risk levels (stop losses). Access to technical analysts is provided via email, telephone and certain online platforms like Instant Bloomberg. The access allows clients to submit specific questions (e.g., on an underlying ratio, spread or complex trading structure) and get appropriate answers from ILLC’s personnel based upon technical analysis. Trading ideas are licensed to market professionals and/or provided to clients and can be delivered via email or an online platform, or integrated as an XML feed into the client’s website. ILLC’s Advisory Services are designed to support professional investors, by complimenting their own investment expertise and their primary analysis and due diligence. None of the Advisory Services are research reports. Clients retain sole investment discretion and trading authority and are solely responsible for determining whether and how to utilize the outputs from the Advisory Services and are free to deviate from any such outputs.

Advisory Services, including reports, analysts’ explanations and trading ideas, are, in all cases, general recommendations and delivered on an “as is” basis with no undertaking to update. ILLC’s Advisory Services are not rendered in relation to the securities holdings or other investments of any particular client and do not purport to meet the specific investment or trading objectives of any person receiving such services. Clients receiving Advisory Services are referred to herein as “Advisory Clients” and other ILLC clients are referred to as “Non-Advisory Clients”. As pertinent, Advisory Clients and Non-Advisory Clients are collectively referred to as “clients”. ILLC’s advisory relationships with Advisory Clients are strictly limited to the provision of Advisory Services. Any trades, transactions or orders that may be executed, routed or otherwise processed on behalf of Advisory Clients will be handled by ILLC solely in its capacity as a broker-dealer. ILLC does not maintain investment advisory accounts for clients or provide discretionary investment advisory services. ILLC also does not maintain custody of Advisory Clients’ assets or securities. C. Availability of Customized Services to Individual Clients ILLC provides only impersonal advisory services, meaning that the Advisory Services are not tailored to the individual needs or investment objectives of clients. Consistent with this limitation, ILLC offers clients the ability to customize certain Advisory Services to their preferences. For example, ILLC provides customized trading ideas to institutional investors, including model portfolios, based on client-specified parameters. ILLC also provides customized commentary or analysis on a particular financial instrument, sector, index or market at the request of an Advisory Client. In addition, ILLC will take under consideration a request to provide a customized version of the above services or a different type of advisory services that would utilize our technical analysis and expertise. In these circumstances, a client may impose constraints or restrictions on such things as security types or asset classes. Importantly, all customized Advisory Services are provided on an impersonal basis, without regard to whether a securities transaction or investment strategy is suitable for the Advisory Client or any particular person. For additional information, please see Item 8.B “Risk of Loss” in this brochure. Because advisory fees are negotiated separately with each client, ILLC can tailor the components of the package of services to meet the preferences of a given Advisory Client. Features, content (including data, assumptions, and research), length of term, permitted number of authorized recipients, usage limits, fees, legal terms and conditions, levels of analyst access, and other services and functionality will differ between packages. D. Wrap Fee Programs ILLC does not provide portfolio management services in connection with any wrap fee programs. E. Assets Under Management ILLC does not manage client assets.