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4 Item 4 – Advisory Business SIMC is an investment advisor registered under the Investment Advisers Act of 1940 ("Advisers Act") with the SEC. It is an indirect wholly-owned subsidiary of SEI Investments Company ("SEIC"), a publicly traded diversified financial services firm (NASDAQ: SEIC) headquartered in Oaks, Pennsylvania, a suburb of Philadelphia. SIMC and its predecessor entities were originally incorporated in 1969. SIMC is investment advisor to various types of investors, including but not limited to, corporate and union sponsored pension plans, public plans, defined contribution plans (including 401(k) plans), endowments, charitable foundations, hospital organizations, banks, trust departments, registered investment advisors, trusts, corporations, high net worth individuals and retail investors. SIMC also serves as the investment advisor to a number of pooled investment vehicles, including mutual funds, hedge funds, private equity funds, collective investment trusts and offshore investment funds (together, the "Pooled Investment Vehicles"). Additionally, SIMC serves as the sponsor of and advisor to, managed accounts. SIMC's total assets under management as December 31, 2020 2021 were $222,762,411,742, $214,085,475,016 of which it manages on a discretionary basis and $8,676,936,726 on a non-discretionary basis. Institutional Group SIMC offers investment management and investment advisory services directly to institutional clients through SEIC's business segment called Institutional Investors (the "Institutional Group"). SIMC's Institutional Group delivers integrated healthcare, retirement and non-profit investment solutions to institutional clients including, but not limited to, corporate and union sponsored pension plans, public plans, defined contribution plans (including 401(k) plans), endowments, charitable foundations, and hospital organizations (each a, "Client" and together the "Clients"). Although we may use "SIMC" and "Institutional Group" interchangeably in this Brochure, when we refer to advisory services, SIMC provides those services. The solutions offered by the Institutional Group are designed to enable Clients to meet financial objectives, reduce business risks and fulfill their due diligence requirements through implemented fiduciary management strategies for defined benefit plans, defined contribution plans, endowments, foundations and other balance sheet assets. The Institutional Group provides customized asset allocation advice to Clients based on the financial objectives, investment objectives, risk tolerance and investment restrictions of the individual Client ("Investment Guidelines"). SIMC uses a proprietary asset allocation methodology to make its initial and ongoing recommendations. SIMC's methodology uses estimates of the long-term rates of return, volatility and correlations of various asset classes. SIMC also provides comparisons of its performance to relevant benchmarks. SIMC maintains an open architecture investment management platform. The foundation of our approach is active management, and our portfolios are designed to capture opportunities over both the short-term and the long-term. SIMC recommends a strategic asset allocation for each Client based on such Client's Investment Guidelines. While this allocation should be the primary focus for a Client to achieve its investment objectives, there may be periods of time in which it is possible to capture shorter-term market opportunities. We seek to implement our advice in the most efficient manner. Further, asset allocation changes are recommended to attempt to improve portfolio returns as well as to reduce avoidable risks. In addition to acting as Client's investment manager for certain accounts, SIMC may also provide non- fiduciary/non-discretionary oversight services for that other Client accounts, or a portion of that other account or security/strategy ("Oversight Services"). These services may include reviews of the investment performance and risk metrics of third-party investment products or managers utilized by such Clients, consolidated reporting, financial model, asset allocation studies, shadowing of activities, as well as periodic