Russell Investments Capital, LLC (“RICAP”) is part of Russell Investments (defined below), a global investment solutions company. Headquartered in Seattle, Washington, Russell Investments operates globally with offices in various financial centers around the globe. RICAP and its affiliates are indirect wholly-owned subsidiaries of Russell Investments Group, Ltd., a Cayman domiciled company (“Russell Investments” or “RI”). The limited partners of certain private equity funds affiliated with TA Associates Management, L.P. indirectly hold a majority ownership interest, and the limited partners of certain private equity funds affiliated with Reverence Capital Partners, L.P. indirectly hold a minority ownership interest in Russell Investments. Hamilton Lane Advisors LLC, a private markets firm, along with current and former management of Russell Investments also hold minority positions in Russell Investments. References to “we”, “us”, and “our” refer to RICAP unless the context otherwise requires. We provide investment management and consulting services to institutional clients including employee benefit plans such as public pension funds, corporate pension funds, defined contribution and profit-sharing plans, and Taft-Hartley plans; and not-for-profit organizations including universities, healthcare organizations, charitable organizations, foundations, and endowments. We also provide investment advice to certain affiliated pooled investment vehicles not required to be registered under the Investment Company Act of 1940, as amended (“Investment Company Act”) that are used in providing investment solutions to certain clients (“Private Funds”). Our investment management services and strategies are designed to assist clients in meeting their objectives in a diversified, risk-controlled manner. We provide the following categories of investment management and advisory services to our clients:  Strategic asset allocation recommendations and decisions  Third-party money manager (“money manager”) selection, allocations, and monitoring  Portfolio design, construction, and management  Alternatives investment services  Investment and retirement plan consulting services  Outsourced Chief Investment Officer (“OCIO”) services  Other advisory services The section below provides a summary of each of these services. Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, for more information regarding our investment strategies. RICAP has been a registered investment adviser since June 8, 1999. RICAP is also registered as a commodity pool operator (“CPO”) with the Commodity Futures Trading Commission (“CFTC”) and is a member of the National Futures Association (“NFA”). As of December 31, 2023, RICAP had $23,026,995,111 in regulatory assets under management, all of which was discretionary. INVESTMENT MANAGEMENT SERVICES We offer a range of investment solutions focused on identifying and addressing clients’ needs with risk adjusted solutions. We take a holistic view of client portfolio assets (each a “portfolio”) Russell Investments Capital, LLC / Form ADV Part 2A / 6 and aim to gain a deep understanding of the factors that drive a portfolio’s risks and returns. We then strive to combine risk factors in such a way that maximize the portfolio’s chances of success. We blend our core capabilities including capital markets insights, manager research, asset allocation, portfolio implementation and factor exposures to design, construct and manage total portfolio solutions. Client portfolios are often invested using a “multi-style multi-manager” open-architecture approach. RICAP’s multi-manager approach is often implemented through the use of proprietary multi-manager investment vehicles, including the Private Funds, as well as through unaffiliated registered and unregistered pooled investment vehicles (“Third-Party Funds”). We provide investment management services based on investment guidelines and restrictions that are developed in consultation with the client, or in accordance with the mandate selected by the client. Each Private Fund managed or otherwise advised by us is managed in accordance with the investment guidelines and restrictions of the Private Fund. Depending on the investment strategy or strategies a client wishes to pursue, the client’s contractual relationship may be with RICAP and one or more of its affiliates. Asset Allocation Our asset allocation process incorporates information about the potential implications of changes in capital markets with client specific information that includes a client’s goals, return objectives, spending policy, ability to tolerate risk and liquidity needs. We help clients to:  Develop investment objectives and a statement of investment policy;  Define and control risk for their specific requirements;  Diversify their investment portfolio;  Meet cash flow needs; and  Conduct scenario analysis on their portfolio(s) as well as evaluate alternative portfolios. Once a strategic asset allocation is determined, an investable portfolio is constructed by identifying the specific investment strategies and money managers that will be used in the portfolio. Third-Party Money Manager Selection Multi-manager portfolio assets are managed by us and at least two other unaffiliated money managers pursuant to a multi-style (e.g., growth, value, market-oriented, defensive, and/or dynamic) and multi-manager approach. RICAP may change a money manager asset allocation at any time, including not allocating assets to one or more money manager strategies. Such changes may be made without notice to clients. Our money manager research services include evaluating and recommending third-party money managers according to designated investment objectives, outcomes, styles, and strategies. A money manager may have: Russell Investments Capital, LLC / Form ADV Part 2A / 7  A discretionary asset management assignment where it is allocated a portion of a portfolio’s assets to manage directly, selects the individual instruments for that portfolio, and also purchases and sells individual instruments for the portfolios assigned to them;  A non-discretionary assignment where it provides a model portfolio to us representing its investment recommendations, based upon which we apply our own investment advice, and through an affiliate, purchase and sell individual instruments for the portfolio; or  Both a discretionary and non-discretionary assignment. Portfolio Management and Construction In moving from a strategic asset allocation to an implementable portfolio, the portfolio is developed using our proprietary strategies (discussed below) and active strategies from selected third-party money managers. In addition to utilizing discretionary third-party money managers to manage client portfolios, we construct certain portfolios by combining non-discretionary money manager models in a centralized portfolio (“Enhanced Portfolio Implementation” or “EPI”). Under EPI, we hire money managers to provide lists of recommended investments and the weightings of such investments in accordance with designated investment guidelines. For example, a portfolio may utilize strategies from multiple non-discretionary money managers. We implement the portfolio by aggregating the model portfolios of each non-discretionary money manager and may adjust the combined aggregated model in order to vary certain exposures, to adhere to any portfolio level guidelines and other restrictions, and for transaction cost management. We generally allocate portfolio assets to two or more money manager strategies; however, RICAP or its affiliates also may directly manage all or some portion of a portfolio’s assets (“direct investment”) for a variety of purposes. In such a scenario, Russell Investments may retain more of its advisory fee as it pays less in fees to money managers. Our direct investment of portfolios can include the implementation of certain quantitative analysis and/or rules-based processes to assess a portfolio’s characteristics or fundamental strategies; investing in securities and instruments which provide desired exposures (such as volatility, momentum, value, growth, quality, capitalization size, industry, sector, region, currency, commodity, credit or mortgage exposure, country risk, yield curve positioning, or interest rates); modifying the portfolio’s overall investment strategy or risk/return characteristics relative to investments made by one or more money managers; and enhanced funding, cash management, currency overlay or other direct investment management techniques (collectively, “Proprietary Strategies”). We, or our affiliate, may also directly manage portions of a portfolio during transitions between money managers. Client portfolios may gain exposure to certain asset classes by investing in listed investment vehicles such as real estate investment trusts (“REITs”), Exchange Traded Funds (“ETFs”), and Exchange Traded Notes (“ETNs”), as well as in Third-Party Funds. Third-Party Funds may be leveraged or unleveraged and may be established in regulated or unregulated jurisdictions. RICAP and the Private Funds that invest in Third-Party Funds will not have an active role in the day-to-day management of the Third-Party Fund and will not have the opportunity to evaluate the specific investments made by a Third-Party Fund before they are made. In particular, RICAP will not carry out due diligence on the underlying investments selected for investment by the Third- Party Fund and will instead rely exclusively on the due diligence carried out on those underlying investments by the relevant Third-Party Fund investment manager. Russell Investments Capital, LLC / Form ADV Part 2A / 8 Before investing in a Third-Party Fund, we perform initial due diligence. However, there can be no assurance that such due diligence will detect misconduct, negligence, or fraud on the part of the Third-Party Fund and its managers and advisers or that the Third-Party Fund will be successful in meeting its investment objectives. Alternative Asset Advisory Services Our investment management services include advising and providing due diligence services on alternative asset classes that have a lower correlation

to public markets and managing portfolios of alternative assets for clients. Broadly speaking, alternatives are investments in assets other than traditional stocks, bonds, and cash. Investors increasingly use alternative strategies to help them achieve their diversification and return goals. Our alternative advisory services fall into three main categories: real assets including real estate, hedge funds, and private markets strategies. Real Assets Strategies Real assets strategies include infrastructure, commodities, and public and private real estate. Infrastructure assets are broadly defined to be real assets that provide essential or commercial services to the public. Examples of infrastructure assets include transportation systems, communication networks, sewage, water, and electric systems. Certain sectors such as energy and water utilities, transportation, social amenities (hospitals, schools) and some areas of telecommunications have the general characteristics of infrastructure assets. There are generally three types of commodity assets: agricultural (e.g., live cattle, wheat, corn, soybeans), metals (e.g., copper, aluminum, nickel), and energy (e.g., oil, gasoline and uranium). Commodity exposure may be obtained through the use of futures and options as well as ownership of the physical commodity itself. Our real estate investment management activities include evaluating client real estate investments, investment strategies and objectives; evaluating potential new investments, and making and implementing investment decisions. Advice is given on managers of publicly traded real estate securities, generally REITS; on commingled funds of private real estate, and on direct private real estate investments. Hedge Funds Strategies We evaluate, advise on and select hedge fund investments designed to produce certain outcomes or that invest in specialized sectors such as long/short, event driven, equity hedge, relative value and tactical trading strategies. These hedge fund investments may be managed by us or our affiliates or by third-party asset managers and can be single funds and funds of funds. In this capacity, we have full and exclusive discretionary authority and responsibility to manage the day- to-day operations of clients’ investments in such hedge funds and to invest and reinvest assets, including the authority to sell, exchange or otherwise transfer all or any portion of the assets of such hedge funds. Private Markets Strategies Russell Investments Capital, LLC / Form ADV Part 2A / 9 Private markets investment strategies typically include investments in the securities and instruments of individual entities that aim to unlock unrealized value in those entities, including, but not limited to, leveraged buyouts, mergers and acquisitions, and venture capital. We evaluate, advise on, and select funds that implement private markets strategies. These private markets funds may be managed by RICAP or its affiliates or third-party asset managers. Investment and Retirement Plan Consulting Services Our investment consulting services include providing ongoing strategic as well as project-based advice to clients that help them make overall governance and structuring decisions related to their investment program. Consulting services include:  Advice on governance and fiduciary framework and structure;  Assisting clients with developing and documenting investment objectives, risk tolerance, and cash flow needs relative to market opportunities;  Establishing and advising on asset allocation and portfolio structures;  Advice on defined contribution plan tier structure and qualified default investment alternative options;  Consulting on the effect of asset mix on projected asset values and cash flows;  Providing our economic forecast, based upon our capital markets assumptions concerning the expected returns and risks of a variety of asset classes;  Providing research and guidance on third-party money managers;  Recommending the client select certain investment strategies, retain or terminate certain money managers, or reallocate assets among various managers or strategies;  Advising on environmental, social, and governance considerations of an investment strategy, manager, or portfolio;  Performance evaluation; and  Creation of materials for staff analysis, as well as committee consideration and education. The consulting client is responsible for weighing our advice in these areas and making the final strategic decisions related to its plans, including governance structure, strategic asset allocation, glide path, risk and liquidity needs, and investment policy statement. Typically, when serving as a consultant, we do not act as a conventional “investment manager”, do not have investment discretion over client funds, and do not make specific investments of client assets or make recommendations with respect to specific securities. Outsourced Chief Investment Officer (“OCIO”) Services OCIO leverages our experience in both consulting and asset management by offering an investment solution where a client retains fiduciary oversight over its investment program, while delegating the day-to-day investment decisions and operations to us as a co-fiduciary manager. OCIO combines strategic advice, implementation, asset management and administration. Institutional clients may choose to outsource their investment program for a variety of reasons including a desire for a strategic partner, a lack of internal resources, better risk management through portfolio construction techniques and risk factor exposure management, a desire to increase return potential and focused fiduciary oversight through a co-fiduciary arrangement. Russell Investments Capital, LLC / Form ADV Part 2A / 10 For these client relationships, we provide the consulting services described above, select, hire and terminate investment managers, select investment funds and other holdings, trade portfolio assets, manage portfolio risk, and rebalance portfolio assets. When RICAP acts as a discretionary investment manager, we execute and deliver all agreements necessary for client account and portfolio management; direct the client-appointed custodian to acquire, hold, sell, transfer, exchange and dispose of investments as applicable; and perform other tasks associated with “end-to-end” management of the client’s portfolio. OCIO includes other administrative support including customized performance reporting and analytics, audit support, and optional donor services support. Other Advisory Services Investment Adviser Oversight and Due Diligence Services We provide non-investment management due diligence reviews which cover a third-party investment adviser’s business structure and activities, operations, and compliance, and assess an investment adviser’s non-investment risks. TYPES OF INVESTMENTS Our advisory services encompass all types of investments and asset classes, including equity, fixed income, multi-asset, alternatives, and derivatives. Types of investments in which we offer investment advice include, but are not limited to: exchange listed securities, privately placed securities, Private Funds, Fund of Funds, REITS, ETFs, ETNs, master limited partnerships (“MLPs”), securities traded over-the-counter, foreign issues, depository receipts, warrants; corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual fund shares, U.S. and non-U.S. sovereign government securities, commodities, listed futures and options contracts. Other types of investments may include foreign currency (“FX”) instruments, including forwards, spots and swaps, centrally cleared swaps and other bilateral OTC instruments. We may also recommend that clients invest in the Private Funds, certain other pooled investment vehicles, open- or closed-end mutual funds, separate account programs, individual securities or other assets. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, for more detail on the types of instruments used in implementing our strategies. SERVICES OF AFFILIATES We utilize our affiliates to offer certain services to clients; some of these affiliates also are investment advisers or broker-dealers registered with the SEC, the Financial Industry Regulatory Authority (“FINRA”), and some are registered or are exempt from registration with other federal, state, or non-U.S. regulatory authorities. We may use the services or personnel of one or more of our affiliates for investment advice, portfolio execution and trading, and client servicing in their local or regional markets or their areas of special expertise, except to the extent restricted by the client pursuant to its investment management agreement or other type of advisory agreement (“IMA”), or inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including dual employee, delegation, participating affiliate, sub-advisory, sub-agency or other formal or informal servicing arrangements. Certain of those affiliates’ employees are deemed “associated persons” within the Russell Investments Capital, LLC / Form ADV Part 2A / 11 meaning of Section 202(a)(17) of the Advisers Act, as Russell Investments’ affiliates may, through such employees, contribute to our investment advisory and investment research process. These arrangements comply with applicable law and regulation including, but not limited to, ERISA and its prohibited transaction exemptions, U.S. federal securities laws and regulations, and the regulations of applicable self-regulatory organizations such as the FINRA, the NFA and the Municipal Securities Rulemaking Board (“MSRB”). This practice of utilizing affiliates is designed to make Russell Investment’s global capabilities available to our clients in as seamless a manner as practical within a varying global regulatory framework. In these circumstances, we remain fully responsible for the portfolio from a legal and contractual perspective. If provided in the client’s IMA, a fund’s governing documents and/or private placement memorandum or offering memorandum (both and similar documents referred to as the “OM”), we will charge additional fees for such services as permitted by applicable law and regulation.