Advisory Business ProManage and Principal Ownership ProManage has been providing managed account or asset allocation services to retirement plans since 1999, first as Strategic Financial Concepts and then after a merger with ProManage Inc. in 2004, as ProManage, LLC, a Delaware limited liability company. On May 31, 2023 ProManage, LLC became a subsidiary of Smart USA Co. Smart USA Co. is a subsidiary of Smart Pension Limited. Types of Advisory Services Offered ProManage PROgram™ ProManage provides investment advisory services to defined contribution (such as 401(k), 403(b) and 457) plans and their sponsors. With the ProManage PROgram, our asset allocation service, plan sponsors can provide their participants with an investment strategy based on each person’s particular circumstances and the investments offered by the plan. Through an analysis of specific plan and demographic data provided by the plan sponsor, the plan’s recordkeeper, and other plan service providers, goals and objectives are set. Using a participant’s particular circumstances (age, plan account balance, length of investment time horizon, and where available salary, projected Social Security benefits, and, if applicable, projected defined benefits and the choice of a user of ProManage’s online guidance tool, Vision, to implement changes), ProManage develops an investment strategy for the participant. Projections of Social Security benefits assume continued government funding and payment streams without interruption or cuts in benefits. ProManage then creates and manages a portfolio based on that strategy. ProManage will choose which investment funds to use among those provided by the plan and in what proportions, based on a person’s changing circumstances. ProManage will rebalance their accounts periodically. This service is customized at the participant level only to the extent that it analyzes the above referenced data. ProManage creates a portfolio which may consist of mutual funds, institutionally managed commingled funds and/or separate accounts, collective investment trusts (CIT) also known as collective investment funds (CIF), and other investments which may be offered in a defined contribution plan. ProManage assesses these investment products’ manager’s capabilities, the investment objective of the product, and the products’ fit within the client’s investment portfolio. This analysis includes both qualitative and quantitative evaluation techniques. Qualitative factors that may be examined include, but are not limited to, investment philosophy and process, investment style consistency, investment team, firm, and portfolio holding characteristics. On a quantitative basis, factors ProManage evaluates include but are not limited to fees/expenses, assets under management, performance, risk, downside protection, risk-return tradeoffs, and correlations relative to benchmarks and other asset classes. The evaluation process will include meetings with investment professionals when available and appropriate. ProManage, LLC ADV2A for All Services, version 03/06/2024 5 Plan Insight Reporting ProManage offers Insight reporting which allows a plan sponsor to understand their programs, potential design changes and see the progress their participants are making towards meeting their financial needs in retirement. The report illustrates the diversification, risk, and performance of assets in participant portfolios, their combined savings rates and other statistics to give each sponsor a better picture of its plan. A periodic report such as a Plan Health Check for the plan sponsor analyzes the overall health of their program and the impact of the managed account service. Unlike reports that benchmark participant statistics against a plan universe, Insight assesses the percentages of participants that are on track for retirement and includes a demographic analysis. Insight reporting can encompass customized reports designed to mine data from their plan. Vision metrics are available. Retirement Readiness Statements can provide additional insight at the participant level. Vision ProManage also offers, through plan sponsor clients and plan providers, Vision its online guidance tool offering simulations and statistical analysis for use by their participants. Each plan sponsor client selects the parameters/assumptions and sets the defaults. Vision focuses on saving and investing for and through retirement, while balancing the four retirement levers – Retirement Age, Retirement Income, Savings Rate and Investment Risk. With this online guidance tool, participants can fine-tune their retirement strategies online by adjusting their assumptions (e.g., life expectancy, wage increase rate, projected Social Security benefit), objectives and preferences and by inputting data such as certain other retirement assets and benefits. Changes to the algorithm or underlying assumptions can materially affect participants’ portfolios. Projected Social Security benefits assume continued government funding and payment streams without interruption or cuts in benefits. If the ProManage PROgram is offered by the plan sponsor, then the suggestions can be a combination of a savings rate change and use of the PROgram. Consequently, with Vision a person can choose to enable implementation of the suggestions generated, manually implement the suggestions in whole or in part, or ignore the suggestions. The Vision service utilizes stochastic financial modeling techniques, taking into account the four retirement levers. The stochastic model is a complex Monte Carlo simulation that evaluates numerous combinations of participant objectives and action steps to determine which combinations provide a reasonable probability of achievement. Participants can specify acceptable ranges for Retirement Age, Retirement Income Replacement, Savings Rate, and Investment Risk (low, medium, or high) for the accumulation phase of their retirement planning. They can also indicate how important each of these factors is to them. In the decumulation module, Retirement Income Planner (“RIP”), which ProManage recently developed, Vision can also inform those PROgram participants approaching retirement (e.g. beginning at age 50 or 55) or already retired about investing and estimated potential distributions during retirement while balancing applicable retirement levers. Participants can add a retirement partner and that person’s retirement assets, as well as other investment assets that are to be used for living expenses during retirement. Participants can also enter other preferences affecting their withdrawals. Participants should estimate their expenses in ProManage, LLC ADV2A for All Services, version 03/06/2024 6 retirement before comparing with Vision’s estimated potential distributions. Plan sponsors can choose to include this module, and select the age threshold, as part of Vision. The information generated by the algorithms used within Vision also can be incorporated into a benefit statement that is delivered either in print form or online to plan participants. Investment Consulting ProManage accepts consulting assignments to help plan sponsors select and monitor investment funds that will be made available to participants for the investment of their retirement assets. ProManage also will consider accepting responsibility for selecting and monitoring investment funds on behalf of the plan sponsor. Employee Benefit Consulting ProManage can help plan service providers or plan sponsors design, implement, and monitor a wide variety of employee benefit plans, including but not limited to services such as employee benefit statements. The benefit statement may be offered electronically or in print. Retirement Readiness Statements (“RRS”) ProManage offers Retirement Readiness Statements for defined contribution plan sponsors and service providers who wish to help their participants prepare for retirement. ProManage’s benefit statements serve as a “reality check” on participants’ progress in the plan and can suggest actions to improve retirement readiness. A statement can show a participant:
• Where they are expected to be based on their current retirement savings and investment choices;
• Where they could be; and
• How they may get there by saving and investing in the plan during the accumulation phase. ProManage’s RRS methodology incorporates stochastic financial modeling techniques

using numerous Monte Carlo financial simulations to determine with statistical significance which potential outcomes provide a reasonable probability of achievement. RRS’ methodology can be somewhat similar to our Vision online guidance tool, which stochastically models for a future retirement event. Vision focuses on saving and investing for the specific purpose of retiring with a retirement income stream, while balancing the four retirement levers – Retirement Age, Retirement Income Replacement, Savings Rate, and Investment Risk (low, medium or high). RRS, while focusing on the specific purpose of retiring, may vary two of those retirement levers, Savings Rate and Investment Risk, to generate a given level of estimated Retirement Income Replacement beginning at a given Retirement Age. ProManage works with our clients to tailor the RRS’ approach to meet their needs. ProManage, LLC ADV2A for All Services, version 03/06/2024 7 Other Services ProManage also provides several advisory services separately or in combination. While the primary clients for these selection and monitoring services will be defined contribution and defined benefit plans, ProManage may also offer these services, where appropriate, to institutional investors such as foundations and endowments. Selection and monitoring services are comprised of five (5) distinct services: Investment Policy Statement Preparation, Money Manager Selection and Monitoring, Investment Performance Monitoring, Employee Communications and Recordkeeper Search and Evaluation. A client may choose to use any or all of the five services described below: Investment Policy Statement Preparation (“IPS”) ProManage will meet with the plan sponsor or institutional investor (in person or over the telephone) to determine the client’s investment needs and goals. ProManage may then prepare a written IPS outlining the objectives of the plan and the roles and responsibilities of various parties to achieve the stated objectives. The IPS will also outline the criteria for monitoring and evaluating the investment performance of the plan and its managers. Investment Manager Due Diligence, Selection and Monitoring ProManage will perform investment manager searches to assist the plan sponsor client in their selection of qualified independent investment advisers. Based on a client’s individual circumstances and needs, ProManage will determine which independent adviser’s portfolio management is appropriate for that client. The investments ProManage recommends will be based on an assessment of the investment manager’s capabilities, the investment objective of the product, and the product’s fit within the client’s investment program. This analysis will include both qualitative and quantitative evaluations techniques. The evaluation process will include meetings with investment professionals when available and appropriate, and typically an assessment of various criteria, some of which may include: investment style consistency, investment philosophy and process, performance, risk, risk-return tradeoffs, correlation to benchmarks and other asset classes, diversification, fees, assets under management, professional investment resources and expertise, retention of investment professionals and adequacy of back office and trading resources. The number/types of investment products recommended will be guided by the client’s needs and objectives and industry norms. Investment Performance Monitoring Client investments will be monitored continuously based on the procedures and timing intervals delineated in their Investment Policy Statement. Although ProManage will not be involved in any way in the purchase or sale of these investments, ProManage may make recommendations to the client as market factors and the client’s needs dictate. Employee Communications For defined contribution plans where participants exercise control over assets/investment decisions in their own accounts (“self-directed plans”), ProManage will assist in targeting educational support and consult with educational providers to communicate such needs. ProManage, LLC ADV2A for All Services, version 03/06/2024 8 Recordkeeper Search and Evaluation ProManage offers clients assistance in their search for a suitable recordkeeper. ProManage can assist plan sponsors in their search and evaluation of these providers to meet their varied needs, including ProManage’s PROgram and other services. ProManage works closely with clients to identify the client’s criteria, factors and weights, and the pool of candidates the client wants considered. After research and review of the candidates, ProManage typically provides a list of recordkeepers to choose from based on the client’s objectives. The client can choose from those or pursue other options. ProManage’s aim is to provide information to help the client with its process, not to recommend any one of the recordkeepers. We will disclose potential conflicts of interest in advance of the client agreeing to use our services for the search. Certain recordkeepers have integrated the ProManage PROgram in their platforms; for more information, see Items 10 and 14. Tailoring of Services ProManage crafts solutions to meet the needs of plan sponsors and plan service providers and their concern for their participants. ProManage’s advisory agreement is with the plan, the plan sponsor or the plan service provider, not the individual participant. Clients can impose restrictions on our investing in certain securities or types of securities. For example, we have worked with clients who restrict investment in foreign securities. Others have limited our universe of investments based on social investing objectives. In general, ProManage will use the investment funds available as part of the core offerings within a plan, as chosen by the plan sponsor in consultation and negotiation with their administrator, to create diversified portfolios for each of our clients’ participants. Within the Vision service we offer significant choices to plan service providers, plan sponsors and individual participants that allow us to tailor our services to their needs. ProManage’s customization for clients extends beyond selecting predefined parameters, such as with the Retirement Readiness Statements. In designing the Retirement Readiness Statements, we also offer choices to clients. These include retirement readiness targets, objective retirement goals, system set-up assumptions, and the universe of participants, plans and investments used. As a result, the definition of Retirement Readiness varies by client. Benefit statements, of which RRS is only one type, can be as simple as a compilation of multiple plans’ data highlighting savings opportunities. They can be as sophisticated as a stochastically modelled retirement preparedness report that makes both savings and investment suggestions. In general, ProManage will use the investment funds or asset classes available as part of the core offerings for the plan(s), as chosen by the plan sponsor or plan service provider, to assure diversified portfolios for our client’s participants. Clients may impose restrictions on the magnitude or universe of investments used. The RRS parameters may encompass the retirement levers of retirement income replacement target, retirement age range, suggested savings rate and level of investment risk as well as assumptions addressing salary growth, inflation, capital market, life expectancy. Clients may define the universe of plans and participants. Data used may include participant account balance, employer-match or non-match, defined benefit plan, estimated social security ProManage, LLC ADV2A for All Services, version 03/06/2024 9 benefits, among others. For example, a client could define a successful Retirement Readiness scenario as having at least a 75% probability of being able to retire between ages 62 and 67, with at least 80% of final pay for initial retirement income (increased annually by an inflation factor (COLA)), for a stream of payments that lasts through the participant’s expected life. BeFine Financial Wellness Application -- Additional customization requested by a client and implemented by ProManage is subject to additional fees as negotiated. Wrap Fee Programs ProManage does not participate in any wrap fee programs. Assets Under Management Total of clients’ assets under management as of December 31, 2023: Discretionary: $5,350,515,424 Non-Discretionary: