SEI INVESTMENTS MANAGEMENT CORP

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, ETFs, hedge funds, private equity funds, alternative 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 of December 31, 2025 were $216,428,500,660, $ 211,986,837,592 of which it manages on a discretionary basis and $4,441,663,068 on a non-discretionary basis. 

Institutional Group 

SIMC offers Outsourced Chief Investment Officer solutions including 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 strategic asset allocation, and our portfolios are designed to capture opportunities over both the shortterm and the long-term. SIMC recommends a strategic asset allocation for each Client based on such Client’s Investment Guidelines, objectives and risk constraints. 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 risks. 

When recommending or implementing a Client’s customized asset allocation portfolio, the Institutional Group generally invests Client assets in: (i) SIMC’s Pooled Investment Vehicles; (ii) individual equities or fixed income vehicles; (iii) derivatives; and/or (iv) other investments as otherwise may be agreed. Subject to Client-specific contractual terms, SIMC generally assumes full management responsibilities for the agreed-upon Client portfolio upon, or shortly after, executing an investment management 5 agreement with the Client. As part of the on-boarding process, SIMC will review the Client’s current investment portfolio and work with the Client to determine if any portfolio assets will be retained. 

In addition to acting as Clients’ investment manager for certain accounts, SIMC may also provide nonfiduciary/non-discretionary oversight services for other Client accounts, or a portion of that other account or security/strategy (“Oversight Services”) as specified in writing with the Client. 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 modeling, asset allocation studies, shadowing of activities, as well as periodic recommendations regarding the investment policy statement and benchmarks relating to assets held within such an account. 

Clients may choose to custody assets at SEI Private Trust Company (“SPTC”), an affiliate of SIMC. Please see Item 15 for additional information. 

Direct Alternative Private Fund Investments 

To the extent that certain of SIMC’s advisory Clients qualify, they will be eligible to invest directly into privately offered third party alternative funds. Investment in these funds involves a significant degree of risk and is an appropriate investment only for those investors who do not require a liquid investment. These funds may be managed by third-party investment advisors selected and overseen by SIMC or selected by the Client either before or after retaining SIMC’s services and overseen by SIMC. SIMC may work with Clients to tailor the direct alternative fund investment strategy to each Client. Since certain affiliates of SIMC provide funds’ accounting and other services to third-party hedge funds, it is possible that some funds in the direct alternative fund program may use a SIMC affiliate for such services, for which that affiliate will earn fees. SIMC seeks to mitigate the risk of such a conflict by conducting the same comprehensive due diligence and selection process with respect to all funds, without any consideration to whether or not the fund has any business relationship with a SIMC affiliate. 

Derivatives 

SIMC may recommend certain derivatives for certain Clients. These derivatives may be entered into by SIMC as agent and/or investment adviser to the Client. 

SEI Pooled Investment Vehicles 

The Institutional Group may also invest Client assets in the following SIMC Pooled Investment Vehicles to seek to achieve the Client’s investment goals. 

(a) SEI Funds 

SIMC serves as the investment advisor to the SEI Mutual Funds (“SEI Funds”), which is a family of SEC-registered mutual funds. Most of the SEI Funds are manager-of-managers funds, which means that SIMC: (i) hires one or more sub-advisors to manage all or a portion of the SEI Funds on a day-today basis; (ii) monitors the sub-advisors; (iii) allocates, on a continuous basis, assets of a SEI Fund among the sub- advisors (to the extent a fund has more than one sub-advisor) and, (iv) when necessary replaces sub- advisors. Each sub-advisor makes investment decisions for the assets it manages and continuously reviews, supervises and administers its investment program. SIMC is generally responsible for 6 establishing, monitoring, and administering the investment program of each SEI Fund. With respect to many of the SEI Funds, including, as applicable in combination with the manager-of-managers structure, SIMC directly manages all or a substantial portion of the SEI Funds’ assets directly. Please see Item 8 for additional information on the sub-advisor selection process. 

SIMC develops various SEI Funds, each of which seeks to achieve particular investment goals. These SEI Funds are not tailored to accommodate the needs or objectives of specific individuals, but rather the program is designed to enable SIMC to match its Clients with SEI Funds that are consistent with the Client’s Investment Guidelines. Additionally, Clients invested in the SEI Funds may not impose restrictions on investing in certain securities or types of securities within each SEI Fund. 

(b) SEI Alternative Funds 

SIMC also serves as investment advisor for several privately offered investment funds referred to as the “SEI Alternative Funds”. To the extent that certain of SIMC’s Clients qualify, they will be eligible to participate as investors in the SEI Alternative Funds. Investment in the SEI Alternative Funds involves a significant degree of risk and is an appropriate investment only for those investors who do not require a liquid investment. 

The SEI Alternative Funds may currently be structured in one of three ways; (a) fund-of-funds, meaning that the fund invests in underlying third-party funds; (b) direct, meaning that the fund invests in direct holdings as selected by SIMC or by SIMC appointed third-party sub-advisors; and/or (a) customizable, meaning that a segregated portfolio within a fund, or a dedicated fund, could invest as set forth in (a) and (b) above along with a customizable component wherein the Client participates in tailoring the investments to accommodate its individualized needs or objectives. 

SIMC has the ultimate responsibility for the investment performance of the SEI Alternative Funds due to its responsibility to select investments and monitor investment portfolios and oversee underlying funds and their managers. Since certain affiliates of SIMC provide accounting and other services to third-party hedge funds, it is possible that some underlying funds in which the SEI Alternative Funds invest may use a SIMC affiliate for such services, for which that affiliate will earn fees. SIMC seeks to mitigate the risk of such a conflict by conducting the same comprehensive due diligence and selection process with respect to all underlying funds, without any consideration to whether or not the underlying funds and their managers have any business relationship with a SIMC affiliate. 

SIMC offers various SEI Alternative Funds, each of which seeks to achieve particular investment goals. The SEI Alternative Funds are not tailored to accommodate the needs or objectives of specific individuals, but rather are designed to enable Clients to be matched with an SEI Alternative Fund that is consistent with the Client’s Investment Guidelines. Additionally, Clients invested in the SEI Alternative Funds may not impose restrictions on investing in certain securities or types of securities within each SEI Alternative Fund, except as described above. 

SIMC receives compensation either directly as the investment advisor to the SEI Alternative Fund or is paid an advisory fee directly from Clients investing into the SEI Alternative Fund, with the application of proper fee offsetting/crediting in accordance with applicable law. 

(c) SEI Collective Investment Trusts 

SIMC may make available certain SEI CITs to its eligible Clients. The SEI CITs are bank-maintained pooled investment vehicles for the collective investment of tax qualified retirement plans and governmental plans and are each intended to be exempt from SEC registration as a security under Section 3(a) (2) of the Securities Act of 1933 and an investment company under Section 3(c) (11) of the Investment Company Act of 1940.

SEI Trust Company, an affiliate of SIMC, is a state-chartered trust company regulated by the Pennsylvania Department of Banking and Securities, which serves as trustee of the SEI CITs, and for which it receives compensation. As the trustee of each SEI CIT, it has retained SIMC to provide investment advice with respect to each SEI CIT. Each SEI CIT invests primarily in one or more underlying SEI Funds, or in an individual SEI Alternative Fund. For certain SEI CITs, SIMC may also perform investment advisory services with respect to managing the asset allocation of the SEI CIT’s underlying investment portfolios. Please see Item 10 for additional information. 

SIMC receives compensation either directly as the investment advisor to the SEI CIT or is paid an advisory fee directly from Clients investing into the SEI CIT, with the application of proper fee offsetting/crediting in accordance with applicable law. 

Separately Managed Accounts

The Institutional Group may also invest Client assets in separately managed accounts, which may either be managed directly by SIMC or by third party investment advisors selected and overseen by SIMC. When a SIMC-appointed investment advisor directly manages Client assets, the investment advisor will retain discretion to select broker-dealers to execute orders. SIMC, and sub-advisors retaining discretion to manage Client assets, may execute trades directly through third party broker-dealers or through SEI Investments Distribution Co. (“SIDCO”), SIMC’s affiliated broker-dealer, consistent with their duty to seek best execution. In certain cases, when managing equity-based separately managed accounts strategies, SIMC is provided with the third party investment manager’s investment strategy model (each, a “Model Strategy”) and SIMC will generally execute all equity trades through SIDCO. In most cases, Clients will not be charged commission by SIDCO when SIMC is trading a Model Strategy through SIDCO. In all cases, the Client’s agreement with SIMC will reflect fees for the Model Strategy, including commission charged or waived. See Items 10 and 12 below for more information on SIMC’s brokerage practices. SIMC has a conflict of interest when selecting SIDCO to execute these orders as SIDCO will earn a commission on these orders and SIMC may be motivated to pay a higher commission for trades involving SIDCO compared to a third party broker. SIMC mitigates this conflict through its duty to seek to obtain best execution. In certain cases when executing Model Strategy trades through SIDCO, SIMC has arranged for SIDCO to waive the commission SIDCO would otherwise charge and, instead, a portion of the advisory fee SIMC charges the Client covers these trading costs. 

Client assets will be invested in accordance with such Client’s investment guidelines. Clients may, at any time, impose reasonable restrictions on the management of the Client’s assets invested in individual securities. Costs paid by a Client may be more or less than other advisors and/or if such Client paid separately for investment advice, brokerage and other services. To the extent Client wishes to retain a third-party investment advisor selected by the Client, SIMC will also perform a review of the investment advisor. 

SIMC in its sole discretion may provide due diligence on third party funds or managers selected by a Client (“third party strategies”), including third party strategies that the Client established prior to its relationship with SEI. SIMC does not provide recommendations with respect to such third party strategies, and does not perform due diligence on such third party strategies to the same extent as SIMC selected strategies, unless the Client hires SIMC to have discretion with respect to such third party strategy as specifically requested. SIMC will perform a lower level of due diligence with respect to third party strategies as disclosed to the Client that (i) are below certain asset thresholds within the client portfolio; or (ii) that are anticipated to be removed from the Client portfolio following an initial transition period to SIMC. 

Additional restrictions may include one or more “screens” offered by SIMC that restrict or permanently remove securities from the Client’s selected strategy on the basis of ESG or other criteria. SEI has selected and engaged Institutional Shareholder Services Inc. and MSCI ESG Research LLC, as “vendors” to provide the selected screens. Each vendor can vary materially from other ESG vendors and advisers with respect to its methodology for constructing screens, including with respect to the factors and data that it collects and applies as part of its process. As a result, Clients can expect that the vendors’ screens 8 will differ from or contradict the conclusions reached by other ESG vendors or advisers with respect to the same issuers. A client restriction, including the selection of a screen, will likely contribute to performance deviations from the strategy, including underperformance. 

For temporary defensive or liquidity purposes during unusual economic or market conditions, SIMC and/or sub-advisors may (i) invest all or a portion of investor portfolios in cash, money market instruments, repurchase agreements and other short-term obligations that would not ordinarily be consistent with a portfolio’s strategy; and/or (ii) delay or suspend purchases and sales of securities. SIMC or a sub-advisor will only do so only if it believes that the risk of loss outweighs the opportunity for capital gains or higher income. During such time, a portfolio may not achieve its investment goal. 

LDI Fixed Income Strategy 

SIMC may implement a custom liability driven investment strategy for certain Clients. The LDI strategy may include a combination of relevant fixed income SEI Funds (e.g., Long Duration Credit Bond Fund, Intermediate Duration Credit Bond Fund, etc.) and also invest directly in the following types of investments: fixed income securities, mutual funds, exchange traded funds, U.S. Government securities, including U.S. Treasury obligations consisting of separately traded interest and principal component parts of such obligations known as Separately Traded Registered Interest and Principal Securities (“STRIPS”), and interest rate swaps or other interest-rate derivatives entered into by SIMC on behalf of the Client. 

Use of Affiliates

For each of the programs and products described in this Brochure, SIMC hires one or more of its affiliates to perform various services, including transition management services when transitioning Client assets to SIMC from its previous service providers, sub-advisory services, administrative services, custodial services, brokerage and/or other services and such affiliates receive compensation for providing such services. Please refer to Item 10 for additional information.