Issue link: https://read.uberflip.com/i/1494883
22 Item 9 – Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SIMC or the integrity of SIMC's management. SIMC has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations SIMC, which is an indirect, wholly owned subsidiary of SEIC hires affiliates and third parties to perform services for SIMC and its clients. Some of these relationships could create conflicts of interest. These relationships are described below. Hiring of Managers and Sub-Advisors As a manager-of-managers, SIMC hires sub-advisors to provide day-to-day securities selection for its investment products. SIMC has hired an affiliated advisor, LSV Asset Management ("LSV"), to serve as sub- advisors to some of SIMC's investment products. Specifically, SIMC's parent company, SEIC, maintains a minority ownership interest (approximately 39% as of December 31, 2021 in LSV, which is a sub-advisor in the Funds and some separately managed accounts. To mitigate this conflict of interest, each sub-advisor, regardless of whether it provides or receives the affiliated services noted above, is subject to SIMC's standard manager due diligence and selection process for the applicable program and/or strategy offering. Additionally, to the extent LSV is managing SEI Fund assets, it is subject to the same Board of Trustees approval process as non-affiliated sub-advisors and the affiliation is disclosed in the SEI Fund prospectuses. SIMC also hires sub-advisors for its investment products who may also be investment advisors/sub-advisors to other investment products offered by SIMC's affiliates and partners. Therefore, SIMC has an incentive to recommend a firm for sub-advisory services for its investment products because they are also providing services to SIMC's affiliates and partners. To address this conflict, SIMC conducts the same due diligence on all sub-advisors regardless of whether they provide other services to SIMC's affiliates and partners. Additionally, some of the sub-advisors that SIMC selects for its Funds and Separately Managed Accounts may also be customers of SEIC for other services and products (e.g., technology solutions, middle and back office platform solutions, turn-key pooled product solutions) for which SIMC's affiliates may be compensated, which could influence SIMC's decisions when recommending or retaining sub-advisors. To mitigate these conflicts of interest, each sub-advisor, regardless of whether it provides or receives the affiliated services noted above, is subject to SIMC's standard manager due diligence and selection process for the applicable SEI program and/or strategy offering. Also, potential conflicts identified are raised to the Board of Trustees of the SEI Funds or to SIMC Compliance prior to the sub-advisor being hired by SIMC. Investment Products SIMC not only provides investment management and advisory services to individuals and institutions, it also serves as the investment advisor to its investment products, including the SEI Funds (including subsidiaries of such Funds), SEI Alternative Funds, and SEI CITs. Additionally, SIMC is the sponsor to, and the advisor of, managed accounts, including Managed Account Solutions ("MAS") and Distribution Focused Strategies (each of which is offered to clients through a separate market unit). SIMC may invest its Clients into these and other products. Therefore, the Client may pay SIMC investment advisory fees which are agreed to in the Client's investment advisory agreement, and pay SIMC investment advisory fees through the underlying investment products. However, SIMC generally, and to the extent required by the Employee Retirement Income Security Act of 1974 ("ERISA") and other applicable law, will offset or credit any advisory fees earned by SIMC with respect to a Client's investment in an underlying investment product against that Client's account level fee.