Columbia Management Investment Advisers, LLC (“Columbia Management Investment Advisers”), through its predecessors, was organized in Minnesota in 1985 and is a subsidiary of Ameriprise Financial, Inc. (“Ameriprise Financial”), which owns 100% of the voting interests of the firm. This Brochure describes the investment advisory services offered by Columbia Management Investment Advisers and the words “we,” “our,” “us,” “the firm,” “our firm” and similar words mean Columbia Management Investment Advisers. We are providing this Brochure to persons who receive or who may receive investment advisory services from us in order to ensure compliance with the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Our General Services We offer professional advisory services on a discretionary or non-discretionary basis and related services including trading, cash management and reporting. In addition to traditional advisory services, the services we provide may include asset-liability management, investment accounting, credit-analysis, and asset allocation services. Nearly all of the advisory services we provide involve continuous investment advice based on the stated investment objectives and policies of each client. Our firm does not specialize in any one particular type of advisory service. In certain cases, we hire other investment advisers to provide discretionary advisory services to our clients in a subadvised capacity. The subadvisers we hire may be affiliated or non-affiliated. Moreover, while we do not offer financial planning services, we do prepare market updates that are made available to our clients and to our affiliate that provides financial planning services, Ameriprise Financial Services, LLC (“Ameriprise Financial Services”). We also provide information that is used by Ameriprise Financial Services in developing certain asset allocation and financial planning tools. The advisory services we offer are provided to non-affiliated clients and to our affiliates, including Ameriprise Financial and its subsidiaries. The discretionary advisory services we offer are available directly to clients who have an investment management agreement with us. The investment management agreement incorporates investment restrictions and guidelines developed in consultation with each client as well as any additional services required by the client. These restrictions and guidelines customarily impose limitations on the types of securities that may be purchased and the percentage of account assets that may be invested in certain types of securities. Clients may also choose to restrict investment in specific securities or groups of securities for social, environmental or other reasons. As of December 31, 2023, the amount of client assets managed (reported as Regulatory Assets Under Management) on a discretionary basis was $426.3 billion and the amount of client assets managed on a non-discretionary basis was $783.6 million. In addition, we provide investment advisory services to over $35.1 billion assets within various model delivery programs. Prospective clients or investors may also choose to obtain our services indirectly by purchasing a securities product that we or an affiliate advise or subadvise, such as a Private Fund (as defined under “Types of Clients” and which, depending upon its strategy, may be referred to as a hedge fund), a collective trust fund, an exchange traded fund (“ETF”), a collateralized loan obligation (“CLO”), a Non-U.S. Fund (as defined under “Types of Clients”) or open-end or closed-end investment company (each a “Fund”), rather than establishing a direct investment advisory relationship with us. This is common in the case of retail investors, who typically access our services indirectly by investing in certain of the Funds we manage, but may also be an attractive investment option for institutional clients. Clients or prospective clients who are eligible for multiple products or services should consider whether similar or comparable services are available at a lower overall cost through a different product or service type. Prospective clients may also wish to consider the different levels of liquidity and transparency of underlying holdings, as well as the different tax attributes that may be associated with certain products and services. Clients or investors should consider these product features and their own specific needs and circumstances in identifying the most suitable investment vehicle or investment services from the available alternatives. Services Provided to Non-U.S. Clients We may also act as an investment adviser or subadviser and may conduct marketing activity with respect to clients and prospective clients domiciled in foreign jurisdictions in some instances without maintaining regulatory licenses or registrations in those jurisdictions to the extent permitted by applicable law. Clients and prospective clients in these jurisdictions should consider whether the regulatory framework of their own jurisdiction as it applies to them imposes restrictions on hiring an investment adviser that does not hold local regulatory licenses or registrations. Clients and prospective clients should also consider whether the regulatory framework we are subject to provides sufficient protections given that we may not be subject to the regulatory framework they are familiar with in their own jurisdiction. Global Asset Management As we seek to enhance our investment capabilities and the support services provided to our clients, we may utilize services from, and provide services to, some of our U.S. affiliates (“U.S. Advisory Affiliates”) and non-U.S. affiliates (“Non-U.S. Advisory Affiliates”). For example, we engage certain of our U.S. Advisory Affiliates and Non-U.S. Advisory Affiliates that engage in investment advisory services (collectively, “Advisory Affiliates”) to provide (jointly or in coordination with us) services relating to client relations, investment monitoring, account administration, investment research, trading and discretionary investment management (including portfolio management and risk management) to certain of our clients and accounts we manage, including certain Funds and separately managed accounts. In some circumstances, an Advisory Affiliate may delegate responsibility for providing those services to another Advisory Affiliate. In addition, we provide certain similar services to our Advisory Affiliates for accounts they manage. Under personnel-sharing and other arrangements, our personnel may act on behalf of one of our U.S. Advisory Affiliates for purposes of providing some of those services for that U.S. Advisory Affiliate to its clients, such as funds and/or separately managed accounts, and some of our U.S. Advisory Affiliates’ personnel may act on behalf of our clients, including Funds and separately managed accounts. Certain of our employees and officers are also officers of certain U.S. Advisory Affiliates, and employees and officers of our U.S. Advisory Affiliates are also officers of ours. We believe that harnessing the collective expertise of our firm and our Advisory Affiliates benefits our clients. In this regard, we have certain portfolio management, trading, research, distribution and client servicing teams at both our firm and certain of our Advisory Affiliates (through subadvisory, delegation or other intercompany arrangements) operating jointly to provide a better client experience. These joint teams use expanded and shared capabilities, including the sharing of research and other information by investment personnel (e.g., portfolio managers, analysts and traders) relating to economic perspectives, market analysis and equity and fixed income securities analysis. The joint teams also have expanded capabilities to provide services in various local or regional markets. To facilitate the collaborative approach noted above, we have entered into subadvisory agreements, delegation agreements, intercompany agreements and “participating affiliate” arrangements with certain of our Non-U.S. Advisory Affiliates, including Threadneedle International Ltd. (“TINTL”), Threadneedle Asset Management Ltd. (“TAML”), Threadneedle Management Luxembourg S.A. (“TMLSA”), Threadneedle Investments Singapore (Pte.) Limited (“TIS”), Threadneedle Investments Services Limited (“TISL”), Columbia Threadneedle Management Limited (“CTML”), Columbia Threadneedle Fund Management Limited (“CTFML”), Columbia Threadneedle Investment Business Limited (“CTIBL”), Columbia Threadneedle Netherlands B.V. (“CTNL”), Pyrford International Ltd (“Pyrford”), Thames River Capital LLP (“Thames”) and Ameriprise India, LLP (“Ameriprise India”), each of which, like us, is a direct or indirect wholly-owned investment advisory subsidiary of Ameriprise Financial. Each of TINTL, TAML, TMLSA, TIS, CTML, CTIL, CTFML, CTIBL, CTNL, Thames and Pyrford is registered with the appropriate respective regulators in their home jurisdictions and Ameriprise India is exempt from such registration. In addition, each of TINTL CTML, and Pyrford is also registered with the SEC as an investment adviser and TINTL is also registered with the United States Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor. As part of any “participating affiliate” arrangements, certain employees of our Non-U.S. Advisory Affiliates serve as “associated persons” of ours when providing certain of these services to our clients, including placing orders for trade execution, and in this capacity are subject to our oversight and supervision. To the extent that we so engage one or more of our Non-U.S. Advisory Affiliates in this manner, we remain responsible for and oversee the services provided by employees of such Non-U.S. Advisory Affiliates(s) to our clients. In addition to relationships with our Non-U.S. Advisory Affiliates, we have entered into subadvisory agreements, personnel-sharing agreements, delegation agreements and/or other intercompany arrangements for portfolio management and certain investment-related services, which may include placing orders for trade execution and/or research sharing with certain of our U.S. Advisory Affiliates, including Columbia Wanger Asset Management, LLC (“Columbia Wanger”), Lionstone Partners, LLC (“Lionstone”), and Columbia Cent CLO Advisers, LLC (“CCCA”), each of which is an SEC- registered investment adviser. In addition, we may provide certain investment-related support services to Advisory Affiliates and their clients. These Advisory Affiliates may also provide certain similar services to us and our clients. Such support services include, but are not limited to, traditional “middle office” and utility functions, such as trade processing, valuation, proxy voting administration and client and regulatory reporting. Retail Managed Account Program Services We also provide discretionary and non-discretionary investment advisory services in connection with wrap fee programs, including dual contract programs (“Retail Managed Account Programs”). The Retail Managed Account Programs we participate in may be sponsored by affiliated or non-affiliated entities and may involve strategies of other outside managers in addition to our own. In these arrangements, the Retail Managed Account Program sponsor typically has primary responsibility for client communications and service. In wrap fee programs, sponsors provide bundled services to clients for a specified fee not based directly upon transactions in a client’s account. The client enters into an advisory agreement with the program sponsor, and the program sponsor enters into an agreement with us. We do not have an agreement directly with the wrap fee program client. We provide discretionary and non-discretionary advisory services through wrap fee programs. In dual contract programs, sponsors

generally provide bundled services (aside from investments management) and impose fee structures in a manner similar to other wrap fee programs. The client enters into an investment management agreement directly with us and a separate agreement with the program sponsor. We provide discretionary investment advisory services through dual contract programs. When we provide non-discretionary investment advisory services in a Retail Managed Account Program, we deliver investment strategies in the form of investment models (“Model-Delivered Strategies”) to the program sponsor and/or another investment adviser retained by the program sponsor, commonly referred to as an “overlay manager”. The program sponsor or the overlay manager exercises discretion over client accounts in the Retail Managed Account Program. In these programs, we provide periodically updated Model-Delivered Strategies to the overlay manager and/or Retail Managed Account Program sponsor who then exercises discretion and decides whether and how to implement the Model- Delivered Strategy in a client account which may be made up of other separately managed account strategies and/or securities products. Therefore, the sponsor or overlay manager may or may not utilize the specific holdings or changes imbedded in our Model-Delivered Strategies as and when received from us in connection with their management of their client accounts. In these arrangements, we do not typically have discretion to implement the changes imbedded within our Model-Delivered Strategies; however, some overlay managers and program sponsors, pursuant to our contract with them, may be required to implement our services exactly as provided, while maintaining discretion with respect to brokerage. We do not have an adviser-client relationship with clients participating in these Retail Managed Account Programs when providing non-discretionary advisory services, nor do we have access to the identity of clients or the composition of a client’s account. For any Retail Managed Account Program through which we provide Model-Delivered Strategies, we cannot and do not provide any investment services that are intended to be individualized or suitable or fiduciary in nature for any specific account within the program. Any changes in a separately managed account strategy provided to the sponsor or overlay manager through a Model- Delivered Strategy may also reflect investment recommendations we have made to our other clients for whose accounts we do have investment discretion and we may be trading at the same time, or before or after the sponsor or overlay manager acts on changes to a separately managed account strategy we have provided. As a result, our clients or the overlay manager’s clients may be advantaged or disadvantaged in the marketplace due to execution timing, price movements, large orders or thinly traded securities. We may also participate in “hybrid” arrangements that have one or more aspects of these types of Retail Managed Account Programs. Clients in Retail Managed Account Programs and other client accounts following a strategy with the same name managed by the same portfolio management team may be managed differently. For example, a strategy designed for Retail Managed Account Programs may be structured to hold fewer securities positions than would be held in another client account following a strategy with the same name managed by the same portfolio management team. Also, the Program sponsor may impose investment restrictions or administrative requirements upon us in managing accounts that could cause those accounts to be managed differently from other client accounts in the same strategy managed by the same portfolio management team that were not subject to those restrictions or requirements. For example, if a Program sponsor or client imposes investment restrictions on an account for which we provide discretionary advisory services which prohibits investment in a security that is held in the selected strategy, the security will not be replaced with a comparable security and the client’s account will hold a larger cash position than other clients in that strategy. Finally, as described in the section entitled “Trade Aggregation, Allocation and Partial Fills on a Trading Desk”, there are differences in the trading procedures for accounts in a Retail Managed Account Program compared to other accounts. Where we provide investment management services in Retail Managed Account Programs that include mutual funds or other products that are also advised by us, we will provide such services to the extent permitted by applicable law, including the Employee Retirement Act of 1974 (“ERISA”). As a result of applicable laws, including ERISA, we may be limited in the scope and timing of our advice, including potentially restricting our ability to provide advice that we would otherwise seek to implement. Furthermore, when we deliver our investment models on a non-discretionary basis to financial intermediaries for their consideration, we do not intend to act, and are not acting, as a fiduciary to those intermediaries or any clients of such intermediaries unless we have specifically agreed otherwise. We generally do not have sufficient information to be a fiduciary in such situations. Retail Managed Account Program clients, with assistance from the Program sponsor or their financial adviser, may select us to provide investment advisory services for their account (or a portion thereof) for a particular strategy. When we have investment discretion, we normally rely on information provided by the Program sponsor or financial adviser about a client’s individual needs and financial situation when accepting clients into a strategy. The Program sponsor pays us a portion of the fee it receives from its clients for our services. More information about Retail Managed Account Program fees we receive can be found in the “Fees and Compensation” section that follows and a list of the Retail Managed Account Programs and Program sponsors we have arrangements with can be found in Part 1A of our Form ADV. For more information about potential conflicts of interest in providing advisory services through retail Managed Account Programs that include Columbia funds please see “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Products Sold or Managed by Us in Which We Have an Interest”. Global Investment Solutions Services Our Global Investment Solutions offering uses a consultative approach to deliver multi-asset solutions tailored to specific client needs and objectives. Each account is designed as a bespoke solution managed by a dedicated team of portfolio construction specialists, manager research experts and asset allocation professionals. Our investment process aligns the source of return with different types of risk and time horizons, and utilizes three investment components – Strategic Asset Allocation, Tactical Asset Allocation and Manager Selection - in the construction and design of our multi asset solutions. Global Investment Solutions has a research-driven philosophy that applies research intensity across the range of opportunities, combined with an open architecture approach and sophisticated portfolio construction. We cover all global asset classes, with both internally and externally managed strategies. Our capabilities include active, passive, traditional, alternative, and real asset investments in both public and private formats. Information regarding the fees for this service can be found in the “Fees and Compensation” section. A specific application of Global Investment Solutions is Fiduciary Management/OCIO where an asset owner delegates overall investment authority to our Global Investment Solutions team. Client portfolios are customized to specific investment policy statements and portfolios are managed toward specific return and volatility objectives. Offering Brands In marketing our services to prospective clients, we use Columbia Threadneedle Investments, the global brand of the Columbia and Threadneedle group of companies. We may also use various other offering brands. Columbia Threadneedle Investments North America is the operating division within our firm that we market to institutional clients. Columbia Threadneedle Investments North America and Columbia Management Capital Advisers claim compliance with the Global Investment Performance Standards (GIPS®). Columbia Management Capital Advisers is the operating division within our firm that we market to Retail Managed Account Programs. In accordance with GIPS®, all fee-paying discretionary (as defined by GIPS®) accounts within Columbia Threadneedle Investments North America and Columbia Management Capital Advisers are included in one or more composites that consist of accounts with similar objectives, strategies and risk tolerances. GIPS® also sets forth requirements for calculating and presenting investment manager performance in a fair and consistent manner. We also market certain strategies and products under the Seligman brand, and from time to time we may market Seligman Investments as an offering brand within Columbia Threadneedle Investments North America. Potential Conflicts of Interest Except in circumstances where an Advisory Affiliate is performing investment management, trading services, back or middle office services or legal or compliance support for our accounts or we are providing similar services or support for an Advisory Affiliate’s accounts, we do not otherwise share trade information with our Advisory Affiliates. Similarly, we do not coordinate or allocate trading activities with the accounts of an Advisory Affiliate unless such affiliate is providing trading services for our accounts or we are providing trading services for the Advisory Affiliate’s accounts. As a result, it is possible that we and our Advisory Affiliates may trade in the same instruments at the same time, in the same or opposite direction or in different sequence. Additionally, in circumstances where trading services are being provided on a coordinated basis for our accounts and the accounts of one or more Advisory Affiliates in accordance with applicable law, it is possible that the allocation opportunities available to our accounts may be decreased, especially for less actively traded securities, or orders may take longer to execute. As further detailed below under “Methods of Analysis, Investment Strategies and Risk of Loss”, we maintain an internal centralized research function for both equity and fixed-income strategies. Investment research we generate is shared with certain of our Advisory Affiliates at the same time that research is distributed internally. In connection with the sharing of relevant investment research among our Advisory Affiliates and, in providing services described above under “Global Asset Management,” investment personnel may have access to nonpublic holdings information of our clients and certain of our Advisory Affiliates’ clients. Portfolio managers of those Advisory Affiliates may decide to act on such research before our own portfolio managers do. The sharing of this information may also lead us and certain of our Advisory Affiliates to place orders in the same securities at the same or different times, if we and those Advisory Affiliates do not have a collaborative arrangement in place for the relevant client accounts. We have adopted policies and compliance controls that seek to ensure that our clients are treated fairly and equitably with respect to trading and sharing of information among Advisory Affiliates. More information about how we identify, mitigate and manage conflicts of interest can be found throughout this Brochure, and in particular, under “Our Approach to Conflicts of Interest” and “Other Conflicts of Interest”.