Description of the Firm Northern Trust Investments, Inc. (“NTI”) is the primary U.S. investment adviser of Northern Trust Asset Management. Northern Trust Asset Management is the branding name of the asset management business of Northern Trust Corporation, a financial holding company and publicly traded company. NTI has been registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser pursuant to the Investment Advisers Act of 1940 since 1988. NTI is also an Illinois banking corporation subject to the rules and regulations of the Illinois Department of Financial and Professional Regulation. NTI is a wholly owned subsidiary of The Northern Trust Company (“TNTC”), an Illinois state banking corporation. NTI is registered with the U.S. Commodities and Futures Trading Commission as a Commodity Pool Operator (“CPO”) and Commodity Trading Advisor (“CTA”) and designated as a Swap Firm. NTI is also a member of the National Futures Association. Types of Advisory Services NTI is a multi-asset class provider of a wide range of discretionary and non-discretionary investment advisory and sub-advisory services. NTI’s asset class capabilities include equity, fixed income, liquidity and asset allocation strategies. Strategy implementation ranges from passive and factor-based quantitative, to fundamental active and multi-manager solutions. Investment solutions can incorporate sustainable investing principles and customized tax management. The following is a description of the investment vehicles and services NTI offers to clients: Investment Pools: NTI provides discretionary investment advisory and sub-advisory services to the following types of affiliated and unaffiliated registered and unregistered investment pools:
• Mutual Funds
• Bank Common and Collective Funds
• Exchange-Traded Funds
• Limited Partnerships
• Other U.S. Investment Funds Each investment pool has an investment objective and investment guidelines. Generally, NTI cannot tailor the investment guidelines or impose restrictions on an investment pool to meet individual client needs. Investment objectives and guidelines, and any restrictions or limitations thereto, may be customized for single investor investment pools. NTI also provides clients with access to select certain third-party investment strategies through limited partnership structures, some of which are offered on a private placement basis. Separately Managed Accounts: NTI provides discretionary and non-discretionary investment advisory services tailored to meet a client’s individual investment objectives and guidelines, as well as client investment restrictions or limitations. The investment performance of any client account may be affected by the imposition of investment restrictions or limitations. Clients who impose investment restrictions or limitations might affect the account’s performance and limit NTI’s ability to employ various investment strategies. This may result in investment performance that differs from that of a benchmark or other client accounts utilizing the same or similar investment strategy. NTI provides investment advisory strategies delivered through other financial intermediaries (such as banks, registered investment advisers and wrap-fee sponsors). Under such arrangements, NTI may be selected to provide investment strategies through model portfolio services (as noted below) or where NTI acts as portfolio manager only. In such arrangements, NTI manages the account in accordance with the agreed-upon investment objectives, guidelines, risk tolerances and restrictions established by the financial intermediary or their client. Under such arrangements the intermediary is acting

as fiduciary with regard to suitability of the investment advisory strategies for its clients. Model Portfolio Services Model Delivery: NTI provides non-discretionary investment advisory services to other financial intermediaries (including Wrap Programs) as noted above. Under such arrangements, NTI provides model portfolios of our proprietary investment strategies. The recipients of these models may use NTI’s model portfolios, as well as any on-going updates to the model portfolio, either alone or with other model portfolios to manage the accounts on behalf of their clients. Sponsors and other recipients of the models retain investment discretion under these arrangements, and NTI is only responsible for providing its model portfolio to the financial intermediary. The financial intermediary, Sponsor, or other recipient of the models is responsible for determining the suitability and appropriateness of any model portfolio for its clients. Model Implementation of Third-Party Strategies: Through the model portfolio services platform, NTI provides clients with access to select certain third-party investment strategies. Under such arrangements, the third-party manager is responsible for security selection and on-going model updates while NTI provides managed account implementation and trading services. Model portfolio implementation is designed to maximize operational efficiencies for separately managed account investments by centralizing the delivery and manufacturing of model portfolio strategies. Through a highly scalable process of construction, rebalancing, and daily monitoring of activity, accounts are managed to minimize dispersion from the selected model portfolio. NTI relies on a suite of proprietary and vended applications to assist in the ongoing management of these accounts. Multi-Manager: NTI provides asset allocation investment advisory services, including selection, oversight and termination of affiliated and unaffiliated investment advisers. Multi-manager strategies can range from a single asset class to multiple asset classes employing a number of investment advisers. NTI performs research, due diligence and program management across multiple asset classes. Outsourced Chief Investment Officer (“OCIO”) Services: NTI provides outsourced investment management services to individual and institutional clients. To meet the needs of its clients, NTI employs various investment vehicles (custom separate accounts and common, collective, registered and private funds). OCIO engages clients on a discretionary and advisory basis. For discretionary clients, OCIO has investment authority and is responsible for the implementation of investment decisions. For advisory services, OCIO provides recommendations, and clients retain investment authority over account activity. FORM ADV PART 2A Investment Research and Advisory Services: NTI provides investment research and advisory services to clients for their use in evaluating and implementing investment solutions. Overlay Services: NTI provides clients with overlay services that include currency hedging, cash equitization and beta management. These strategies may employ foreign exchange forwards, futures and exchange-traded funds. Index Services: NTI constructs indexes that certain of its advised exchange-traded funds or other clients use as benchmarks. NTI may also create indexes for unaffiliated clients. Transition Management Services: NTI provides transition management services to assist clients in restructuring or reallocating their assets. Assets Under Management As of December 31, 2023, NTI managed approximately $1,016,556,943,580 in regulatory assets under management on a discretionary basis.