Description of Advisory Firm Strategic Global Advisors, LLC (“SGA,” “we,” “our,” or “us”) is an independent, majority employee and women-owned and controlled Limited Liability Company headquartered in Newport Beach, California. In December 2005, Cynthia Tusan, CFA founded Strategic Global Advisors, LLC. In March 2006, SGA started operating as an investment adviser registered with the U.S. Securities and Exchange Commission (the “SEC”). Investment professionals with ownership include Cynthia Tusan, CFA and Gary Baierl, PhD. Advisory Services Offered Investment Management Services SGA currently manages client portfolios in International Large Cap, All Cap, Small Cap, Small-Mid Cap, Emerging Markets, Domestic, and Global equity strategies, primarily using foreign ordinaries or domestic common stocks. SGA also offers strategies that are comprised primarily of ADRs, such as the International Equity ADR strategy. While similar to the foreign ordinaries strategies, a strategy that primarily consists of ADRs can have significant differences in the number of securities and the exposure to alpha and risk factors, as well as currency, industry and country weights. SGA’s investment management team has developed investment strategies within a collaborative environment, primarily utilizing a bottom-up decision-making process. Our investment process integrates quantitative and fundamental methods. We construct portfolios with a focus on stock selection, rather than country and sector market timing, although the firm does, from time to time, employ country and sector tilts depending on market conditions. Certain strategies of the firm may allow a greater degree of sector and country timing than other strategies. Portfolio managers provide active oversight and exercise significant discretion when managing portfolios while employing the firm’s quantitative models. Therefore, portfolio construction decisions are not made solely by a model, but rather are overseen by a portfolio manager. Please refer below to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss associated with our investment strategies. Foreign exchange transactions for client accounts are generally limited to those necessary to settle trades in securities which are not denominated in the base currency of an account. Foreign exchange is generally not a discretionary part of SGA’s investment management process and foreign exchange transactions are typically undertaken to minimize operational risk and maximize efficiency and best execution. SGA does not typically hedge directly against currency fluctuations between the currencies of international markets and uses a base currency specified by the client, generally US dollar. Please refer below to Item 12 - Trading Spot Foreign Exchange for additional information regarding foreign exchange transactions. SGA provides continuous and regular investment management services on a discretionary and non- discretionary basis, limited by the client’s individual needs and specific client restrictions. We offer clients the ability to gain exposures to domestic, international, and global equity markets through our product offerings, diversified portfolios, and custom solutions. SGA’s services are provided through separate accounts and as further described below, wrap account advisory programs, model portfolio programs, 7 Strategic Global Advisors, LLC – Brochure Revised March 29, 2024 collective investment trusts, and other investment vehicles in certain foreign jurisdictions. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. We describe the fees charged for investment management services below under Item 5 - Fees and Compensation. Limitations on Investments In some circumstances, SGA’s advice can be limited to certain types of securities. To replace client restricted securities, we may hold individual mutual funds, ETFs or fixed-income securities, depending on the investment strategy of the account, transition requirements, and client restrictions and preferences. The holding period may be temporary or based on the individual needs of the client and objective of the strategy. SGA may also utilize mutual funds and ETFs when transitioning accounts and equitizing cash positions, or as proxies for exposures to certain equities that are illiquid or not otherwise easily available to SGA client accounts. Limitation by Client SGA may also limit advice based on certain client-imposed restrictions. Holdings and performance may vary based on a client’s restrictions. For more information about the restrictions clients can place on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. Limitation by Broker-Dealer/Custodian The investment options and markets available to clients may be further limited by the broker- dealer/custodian chosen by the client and/or SGA. Wrap Fee Programs SGA also provides investment recommendations to clients participating in wrap fee programs sponsored by broker-dealers. SGA contracts directly with the wrap fee program sponsor and not with the underlying clients of the wrap fee program. At this time, SGA does not act as a sponsor to a wrap fee program.

In addition, SGA has entered into agreements with wrap sponsors where the client maintains an agreement with the wrap sponsor and the wrap sponsor has a separate master agreement with SGA. Furthermore, SGA may enter into an agreement directly with client where SGA has duties and responsibilities within that agreement. For wrap program accounts, SGA may effect transactions through other broker-dealers, but it is expected that most of the transactions will be executed through the wrap sponsor because part of the wrap sponsor’s negotiated fee with the client may include brokerage commissions and trading costs. In the rare event SGA trades away from the wrap sponsor, clients may pay an additional per trade fee. The schedule of wrap fees is set forth in each wrap program sponsor’s client brochure related to the program. SGA manages the wrap program accounts on a discretionary basis. SGA attempts to manage these accounts in the same manner as our non-wrap accounts. Model Portfolio Services SGA enters into arrangements to provide model portfolio recommendations to unaffiliated third parties. 8 Strategic Global Advisors, LLC – Brochure Revised March 29, 2024 The third parties use the model portfolio recommendations/weights to provide investment management services to their clients. SGA has no discretion over the implementation of such model portfolio recommendations and does not have any knowledge of the clients’ identities or financial situations. As such, the service is not tailored to a specific client’s needs. When we provide such model portfolio recommendations, we use reasonable efforts to confirm that the third-party providing or publishing the information has a policy to limit the distribution of changes to the model around the time of those changes to those clients and their advisors who have selected the applicable model portfolio. Once confirmed, SGA will include the model platform in its trade rotation process with other accounts managed and executed exclusively by SGA. If we find distribution is not limited, we may delay the release of applicable research reports or model portfolios to the third-party. Services to Collective Investment Trusts SGA provides investment advisory services to collective investment trusts (“CIT”) sponsored by an unaffiliated institutional trustee. SGA has entered into a written agreement with the trustee which outlines the services we perform for each CIT. For those interested and eligible to invest, SGA may help facilitate their participation in the CIT. Services to Undertakings for Collective Investment in Transferable Securities SGA provides sub-advisory services to Undertakings for Collective Investment in Transferable Securities (“UCITS”) sponsored by an unaffiliated third party. UCITS are investment funds regulated by the European Union. SGA will enter into a written agreement with the third party which outlines the services we will perform for the UCITS product. The UCITS fund manager is responsible for interaction with clients/prospects and distribution of this product in relevant jurisdictions. Tailored Services and Client Imposed Restrictions SGA manages client accounts based on the investment strategy the client chooses, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. SGA applies the strategy for each client and will take into account the client’s and client advisors’/consultants’ direction or restrictions when tailoring investment decisions for clients based on this information. Our recommendations may be limited if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep SGA informed of any changes to their investment objectives or restrictions. Currently SGA does not have clients for whom we provide general financial planning or asset allocation advice. Clients may provide SGA with general investment guidelines, across a variety of parameters including, but not limited to, country, industry, and sector limitations. Clients may also request other restrictions on the account, such as when a client wants to keep a minimum level of cash in the account or does not want SGA to buy or sell certain specific securities or security types in the account. SGA relies on the accuracy of the restrictions and investment guidelines that the client provides to SGA or receives from a third-party vendor. SGA is generally not expected to perform additional reviews of the list of restricted securities provided by the client or third-party vendor to confirm accuracy or completeness. SGA will apply these restrictions prior to trading, adjusting portfolios to reflect client restrictions, which may result in portfolio 9 Strategic Global Advisors, LLC – Brochure Revised March 29, 2024 parameters that are significantly different from SGA’s default parameters and may cause performance dispersion. SGA reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Assets Under Management SGA manages client assets in discretionary accounts on a continuous and regular basis. As of 12/31/2023, SGA was actively managing $2,768,301,384 of client assets on a discretionary basis. Additionally, through unified managed accounts (UMAs) we provided advice on $337,721,323 of client assets on a non- discretionary basis (e.g., assets under advisement).