Issue link: https://read.uberflip.com/i/1494883
28 Soft Dollar Practices SIMC does not intend to cause an account to pay more in commissions in return for research products and/or services provided to SIMC. However, brokers with which SIMC trades may provide proprietary research materials or technology to SIMC. While SIMC does not necessarily consider receipt of such information, or access to such technology, to constitute soft dollar arrangements, it does present a conflict of interest for SIMC in connection with the selection of brokers for the execution of trades to the extent that SIMC considers such research or technology to be valuable. Sub-advisors to the SEI Funds may engage in soft dollar transactions pursuant to the sub-advisors' own policies and procedures. Client Referrals SIMC does not consider, in selecting or recommending broker-dealers, whether SIMC or a related person receives client referrals from a broker-dealer or third-party and the conflicts this creates. Directed Brokerage In limited circumstances, a client may direct SIMC to use a particular broker-dealer (subject to SIMC's right to decline and/or terminate the engagement) to execute some or all transactions for the client's account. In such event, the client will negotiate terms and arrangements for the account with that broker-dealer, and SIMC will not seek better execution services or prices from other broker-dealers or be able to "batch" the client's transactions for execution through other broker-dealers with orders for other accounts managed by SIMC. As a result, client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Trade Aggregation SIMC is permitted to aggregate or "batch" orders placed at the same time for the accounts of two or more clients if it is in the best interests of its clients. By batching trade orders, SIMC may obtain more favorable executions and net prices for the combined order, and ensure that no participating client is favored over any other client. Typically, SIMC will affect block orders for the purchase and sale for the same security for client accounts to facilitate best execution and to reduce transaction costs. When an aggregated order is filled in its entirety, each participating client account generally will receive the block price obtained on all such purchases or sales with respect to such order. The portfolio manager for each account must determine that the purchase or sale of the particular security involved is appropriate for the client and consistent with the client's investment objectives and with any investment guidelines or restrictions applicable to the client's account. The portfolio manager for each account must reasonably believe that the block trading will benefit, and will enable SIMC to seek best execution for each client participating in the block order. This requires a reasonable good faith judgment at the time the order is placed for execution. Item 13 – Review of Accounts Servicing of the Client accounts is conducted by the Institutional Group's Client Portfolio Managers. Each Client Portfolio Manager is assigned to accounts, conducts reviews of account status periodically and is available to Clients on an on-going basis. Each account is subject to an annual review of the Client's Investment Guidelines and their financial objectives and goals (or more frequently if or when appropriate) to ensure that the current asset allocation is designed to meet the Client's needs, considering financial situation, return expectation, risk tolerance, time horizon and asset class preferences. Client Service Directors additionally serve as the primary correspondent with the account administrators of the Client's custodian bank (generally, but not always SPTC). Item 14 – Client Referrals and Other Compensation