MESIROW FINANCIAL INVESTMENT MANAGEMENT, INC.

January 5, 2026 Mesirow Financial Investment Management, Inc. Currency Management 353 North Clark Street, Chicago, Illinois 60654 Telephone: 312.595.6000 | Email: inquiries@mesirow.com mesirow.com ITEM 1 | Cover Part 2A of Form ADV Firm Brochure This brochure provides information about the qualifications and business practices of Currency Management (“MFIM Currency”), a division of Mesirow Financial Investment Management, Inc. If you have any questions about the contents of this brochure, please contact 312.595.6000 or inquiries@mesirow.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Mesirow Financial Investment Management, Inc. (“MFIM”) also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. MFIM’s CRD number is 111135. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved.  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 2 | Material Changes Mesirow Financial Investment Management, Inc. (“MFIM”) Form ADV Part 2A, currently dated January 5, 2026, as amended from time to time, is MFIM’s client disclosure document prepared based on the Securities and Exchange Commission’s regulatory requirements. MFIM is required to update this document at least annually, or when an event occurs that can be deemed to have a material impact on MFIM’s Currency Management and related investment management business and/or on its clients. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 2  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 3 | Table of Contents ITEM 1 | Cover ...................................................................................................................................... 1 ITEM 2 | Material Changes ................................................................................................................... 2 ITEM 3 | Table of Contents ................................................................................................................... 3 ITEM 4 | Advisory Business .................................................................................................................. 4 ITEM 5 | Fees and Compensation ........................................................................................................ 5 ITEM 6 | Performance-Based Fees and Side-By-Side Management .................................................... 7 ITEM 7 | Types of Clients ...................................................................................................................... 7 ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 8 ITEM 9 | Disciplinary Information ........................................................................................................ 10 ITEM 10 | Other Financial Industry Activities and Affiliations .............................................................. 10 ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....... 11 ITEM 12 | Brokerage Practices ........................................................................................................... 13 ITEM 13 | Review of Accounts ............................................................................................................ 13 ITEM 14 | Client Referrals and Other Compensation .......................................................................... 13 ITEM 15 | Custody .............................................................................................................................. 14 ITEM 16 | Investment Discretion ......................................................................................................... 14 ITEM 17 | Voting Client Securities ...................................................................................................... 14 ITEM 18 | Financial Information .......................................................................................................... 15 Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 3  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 4 | Advisory Business MFIM, an Illinois corporation formed in 1986, is an investment advisor registered with the SEC with its principal place of business located in Illinois. MFIM does not provide tax or legal advice. Clients should consult with an expert on matters pertaining to tax or legal matters. MFIM's principal shareholder is Mesirow Financial Services, Inc., which is a wholly-owned subsidiary of Mesirow Financial Holdings, Inc. (“MFHI” or “Firm”). MFIM Currency offers Currency Advisory and other exposure management services solely for eligible contract participants ("ECP"), as defined by the Commodities Exchange Act, through separately managed accounts and funds. MFIM Currency also provides Collateral Management Support Services to existing Currency Advisory Services clients. CURRENCY ADVISORY SERVICE MFIM Currency provides three types of risk management overlay services for ECPs with portfolios that are exposed to currency exchange rate exposures. These services are called active, passive, and passive-plus. These services isolate the currency component from the underlying asset base and manages the associated risks independently. The goal of currency overlay is to reduce volatility and risk within the portfolio, while enhancing the overall return. In addition to the risk management overlay services, MFIM Currency offers currency return strategies. These strategies are called Intelligent Currency Factor Strategy, Emerging Markets Currency Alpha, Asian Markets Currency Alpha, Extended Markets Alpha and Systematic Macro. The Intelligent Currency Factor Strategy aims to capture currency returns via three distinct risk premia existing in the currency markets (i.e. carry, value, and momentum). Emerging Markets Currency Alpha, Asian Markets Currency Alpha, and Extended Markets Alpha are primarily systematic investment processes with a discretionary risk overlay. The Systematic Macro is a purely systematic investment process with no discretionary risk overlay. MFIM Currency does not provide currency services to any affiliated business unit. MFIM’s other business units also serve as general partner to a number of private investment vehicles structured as limited partnerships. As of March 31, 2025, MFIM Currency manages approximately $177.1 billion1 in client assets on a discretionary basis and no client assets on a non-discretionary basis. FIDUCIARY EXECUTION In addition to the currency overlay services described above, MFIM Currency offers a non-discretionary investment management service focused on high quality execution called Fiduciary Execution. Fiduciary Execution is a full-service execution service where MFIM Currency executes trades on clients’ behalf as an agent. In connection with the execution service MFIM Currency can also evaluate and make recommendations to clients, on a non-discretionary basis, with respect to the type, structure, time horizon and size of instruments to be traded in order to provide efficient hedging and risk mitigation strategies. 1 Currency assets under management includes AUM associated with (i) active and passive currency risk management products $174.7 billion, (ii) non-fx overlay strategies such as equitization and beta overlays $873.6 million, and (iii) alpha strategies $1.5 billion. In all such cases, AUM is calculated based on notional value of currency investments. Additionally, AUM for alpha strategies is adjusted because clients can select a volatility target (generally between 2% and 12% annualized), which is normalized to 2% in order to create a consistent depiction of alpha strategy AUM. This results in a “scaled” AUM, which is higher than the actual aggregate notional value of all alpha strategy portfolios if clients have selected a volatility target higher than 2%. As of 03.31.25, the “unscaled” AUM for alpha strategies was $448 million. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 4  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management COLLATERAL MANAGEMENT SUPPORT SERVICE MFIM Currency provides a Collateral Management Support Service for certain clients of its Currency Advisory Service. The Collateral Management Support Service manages and effectuates the calculation and exchange of collateral between clients and counterparty banks. The Collateral Management Support Service is typically performed in connection with satisfying regulatory margin requirements; however, clients can utilize the service for purposes other than satisfying regulatory requirements. EXPOSURE MANAGEMENT MFIM offers a rules-based overlay investment advisory service using foreign exchange and other instruments solely for ECPs through separately managed accounts and non-sponsored funds. These services include cash overlays, policy implementation, and other custom hedges. ITEM 5 | Fees and Compensation All advisory fee schedules are negotiable and vary by investment strategy, product type, account size, customization requirements and required service levels. The standard annual fee ranges are as follows: • MFIM’s annual fee for passive overlay currency can range up to 10 basis points per annum for the average market value of the client’s portfolio. • MFIM’s annual fee for active overlay currency can range up to 40 basis points per annum for the average market value of the client’s portfolio • MFIM’s annual fee for passive-plus overlay currency can range up to 25 basis points per annum for the average market value of the client’s portfolio • MFIM’s annual fee for the currency for return strategies can range up to 200 basis points per annum for the average market value of the client’s portfolio plus a performance fee. • MFIM’s annual fee for exposure management can range up to 20 basis points per annum for the average market value of the client’s portfolio The upper range of these fees are based on small accounts that are offered a minimum flat fee. In certain instances, the index used as a client’s performance benchmark carries additional fees for individual client use. These fees are passed on to individual clients. These fees are charged on a percentage of client portfolio AUM or a flat fee depending on the index or indexes chosen. Additional fees can also be charged for other bespoke services. The management fee is typically payable in arrears on the 30th business day after the end of each quarter. Because the management fee is paid in arrears, refunds for fees paid are not given. In the event an account terminates, fees will be prorated for the number of days the account was under management. Fees are typically billed to the client or client's custodian. MFIM Currency charges a volume-based fee for its Fiduciary Execution service. These fees can range up to 10 basis points on the volume executed for a client. The fee for this service can be either embedded in the price of each trade or invoiced at the client’s discretion. If the fees are invoiced, the client will typically be invoiced on a quarterly basis. For fees Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 5  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management that are embedded in the price, the bank counterparty or liquidity provider will collect the fees and remit them to MFIM Currency periodically. Limited Negotiability of Advisory Fees Although MFIM Currency has established the aforementioned fee schedule(s), it retains the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These facts, circumstances and needs include, among other factors, the complexity of the client; assets to be placed under management; anticipated future additional assets; related accounts; portfolio style; account composition; and reporting requirements. The specific annual fee schedule will be identified in the contract between the advisor and each client. Termination of the Advisory Relationship Clients that invest in separately managed accounts are typically able to terminate their investment management agreement upon providing 30 days prior written notice. Certain fees could be paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees are generally refunded. In calculating a client's reimbursement of fees, MFIM Currency can prorate the reimbursement according to the number of days remaining in the billing period. In certain situations, other terms are made available to clients. No penalty will be charged for any termination. Fees due for the final period of the agreement will be adjusted proportionally to the number of days in the period and will be due and payable no later than 30 days after the date of termination. Additional Fees and Expenses In addition to MFIM Currency's advisory fees, clients are also responsible for the fees and expenses charged by custodians, including, but not limited to, any transaction charges imposed such as commissions, electronic platform fees and prime brokerage fees. Custodian fees are not reflected or segregated on MFIM Currency’s invoices. There can be instances where MFIM Currency refers its clients to affiliated entities, which may perform other services. In those instances, MFIM Currency and/or its employees receive referral compensation in exchange for such referral. Similarly, MFIM and/or their employees can refer clients to MFIM Currency for which MFIM Currency pays referral compensation to such affiliates and/or their employees. MFHI, a Delaware corporation, is the owner of Mesirow Financial Services, Inc. ("MFS"), the parent of MFIM. MFIM is affiliated with numerous MFS and MFHI subsidiaries, which constitute or are registered as one or more of the following: an investment advisor, a broker/dealer, an insurance agency, and/or entities creating or packaging private investment vehicles. MFIM does not currently have any material arrangements with any of these entities other than as described in Item 10. Grandfathering of Minimum Account Requirements Pre-existing advisory clients are subject to MFIM Currency's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, minimum account requirements can differ among clients. ERISA Accounts In certain circumstances MFIM is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act of 1974 ("ERISA"). As such, Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 6  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management MFIM is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. Commissions or Markups With the exception of the Fiduciary Execution service, in the event that MFIM receives commissions or markups, advisory fees will be reduced to offset the commissions or markups. Advisory Fees in General Clients should note that similar advisory services could be available from other registered (or unregistered) investment advisors for similar or lower fees. Limited Prepayment of Fees Under no circumstances does MFIM require or solicit payment of fees in excess of $1,200 six months or more in advance of services rendered. Educational Events MFIM employees benefit from educational events sponsored by service providers to MFIM, such as law firms, audit firms and other professional service firms. ITEM 6 | Performance-Based Fees and Side-By-Side Management MFIM Currency can accept a performance-based fee from the client. Such a performance-based fee is calculated based on gains of the portfolio of the client. Pursuant to the Investment Advisers Act of 1940 Rule 205-3, to qualify for a performance-based fee arrangement, a client (or Fund investor, as applicable) must either demonstrate a net worth of more than $2,200,000 or must have at least $1,100,000 under management with MFIM at the time of entering into a management agreement with MFIM Currency. Clients should be aware that a performance-based fee arrangement creates an incentive to recommend investments that could be riskier or more speculative than those that might be recommended under a different fee arrangement. Furthermore, MFIM Currency has clients who do not pay performance-based fees, MFIM Currency has an incentive to favor accounts that do pay such fees because compensation received from these clients is more directly tied to the performance of their accounts. ITEM 7 | Types of Clients MFIM Currency provides advisory and collateral management services to ECPs, which may include: • Investment companies and private funds • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 7  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management METHODS OF ANALYSIS Passive Currency Overlay For each client portfolio, MFIM Currency tailors passive management programs to meet specific currency exposures and other objectives and applies global best practices in passive management to ensure fair value execution, provide optimal program efficiency and offer comprehensive risk management controls and policies. Active Currency Overlay MFIM Currency’s investment philosophy maintains that currency movements are driven by the impact of numerous factors (i.e. market news, capital flows, trade deficits and central bank reserve policies) and these drivers can impact currency valuations over specific time horizons. In addition, the factors that drive the markets change over time and the duration and direction of the impact also varies. MFIM Currency believes that it is much more important to understand the impact of the market drivers on currency prices, regardless of what they are, rather than forecasting the drivers themselves. MFIM Currency’s quantitative investment process attempts to measure the statistical impact of market drivers over various timeframes, and across directional and mean reverting market environments. Despite a changing array of factors, the process is adaptive in nature in that it works to identify the impact of these factors on currency prices to capitalize on both mean reverting and directional environments, across various time periods. Due to each client’s unique set of underlying exposures and objectives, MFIM Currency applies a custom solution for each client portfolio utilizing MFIM Currency’s core investment philosophy. Specific models, investment decisions, trade execution and positions may vary across client portfolios to reflect these differences in exposures, custom benchmarks and portfolio objectives. In select regions where MFIM Currency partners with local experts (such as Perreard Partners Investment SA in Switzerland) MFIM Currency will also utilize the local expertise and market analysis of its partnerships to make investment decisions. If MFIM Currency determines that it is in the best interests of clients, MFIM Currency will use its fundamental decision-making authority to override its quantitative approach. In some cases, MFIM Currency will operate purely on a discretionary basis. Passive Plus Currency Overlay Passive plus management is a hybrid of MFIM Currency’s passive and active strategies. MFIM Currency primarily incorporates valuation metrics in assessing significant movements for a client’s passive plus framework. Valuation metrics are supplemented with signals from MFIM Currency’s long-term trend and momentum views to identify longer-term movements and seek to provide downside protection by increasing hedges in this environment. The objective of the passive plus application is to efficiently hedge significant, long-term currency movements and to insulate the portfolio from a portion of this risk. MFIM Currency partners with clients and their consultants to evaluate the respective international portfolios and design a custom passive plus application to best fit their objectives by applying the program’s core philosophies. Exposure Management Exposure Management is set of overlay strategies designed to achieve investment objectives through adherence to the investment management guidelines. The program objectives typically include increasing expected portfolio returns, improving fund liquidity, limiting the performance cost caused by holding cash in a portfolio and reducing performance risk relative to policy benchmarks. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 8  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management Leverage is not employed unless desired by the client. Clients can use Exposure Management for cash securitization, rebalancing, and other exposure management as needed based on client objectives. Policy implementation utilizes exchange-traded instruments, including futures, over-the-counter (OTC) instruments, and other financial products to achieve its objective. Some exposure strategies which are intended to mitigate cash drag and/or increase or decrease the beta of a portfolio use financial instruments designed to track specific benchmarks. Since the strategies use futures, rather than cash instruments, the strategy will not be correlated to the reference benchmark in certain market situations. In addition to OTC instruments, Exchange-Traded Funds (“ETFs”) may be utilized. ETFs are publicly traded investment vehicles such as unit investment trusts, open-end funds, or depository receipts that seek to track the performance and dividend yield of specific indexes, sectors, or groups of companies. These indexes may be broad-based, sector-specific, or international in nature. Investing in ETFs generally exposes shareholders to risks similar to those of the underlying securities the ETF is designed to replicate. However, ETFs also involve additional risks, including but not limited to: (1) The risk that the market price of an ETF may not perfectly correlate with the net asset value or price movements of the underlying securities it tracks, potentially resulting in tracking error. (2) The risk that trading in an ETF may be halted or suspended due to market conditions, regulatory actions, or other factors, which could impair the ability to buy or sell shares promptly or at favorable prices. (3) Liquidity risk, particularly for ETFs that invest in less liquid markets or securities, which may affect the ETF’s pricing and ability to execute transactions efficiently. (4) Potential tax implications unique to ETFs, depending on their structure and underlying holdings. Clients should understand that although ETFs offer certain diversification and trading flexibility benefits, they remain subject to the risks of the markets and assets in which they invest, and market conditions can adversely affect ETF performance. Currency for Return • Mesirow Intelligent Factor Strategy: This strategy aims to capture currency returns via three distinct risk premia existing in the currency markets (i.e. carry, value, and momentum). • Emerging Markets Currency Alpha, Asian Markets Currency Alpha, and Extended Markets Currency Alpha: These strategies aim to profit from short and medium term moves in currency pairs. The programs are primarily systematic with a discretionary risk overlay. • Systematic Macro: This is a purely systematic managed account structure that invests in the systematic components of the three Alpha Programs: Extended, Asia, and Emerging. Fiduciary Execution Fiduciary Execution is a full-service execution service where MFIM Currency executes trades on clients’ behalf as an agent. This service is designed to help clients manage and minimize their transaction costs. MFIM Currency always acts as an agent within a market that has historically been traded on a principal basis. In connection with the execution service, MFIM Currency may also evaluate and make recommendations to clients, on a non-discretionary basis, with respect to the type, structure, time horizon and size of instruments to be traded in order to provide efficient hedging and risk mitigation strategies. Risks For All Forms of Analysis MFIM Currency's analysis depends on publicly-available sources of data relating to foreign exchange and transactions, providing accurate and unbiased data. While MFIM Currency is alert to indications that data may be incorrect, there is always a risk that MFIM Currency's analysis can be compromised by limited, inaccurate or misleading information. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 9  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management Strategies with a discretionary component bear additional risk that individuals exercising discretion will not analyze data in an accurate manner. RISK OF LOSS Investments are not guaranteed and clients may lose all invested funds. Clients may implement loss limits to mitigate losses. ITEM 9 | Disciplinary Information On July 22, 2022, MFIM entered into a settlement with the SEC, the details of which are available here: https://www.sec.gov/litigation/admin.htm. As described in more detail in the Order, the settlement was related primarily to insufficient disclosure related to purchases of non-affiliated mutual fund shares (No Transaction Fee or NTF funds). Specifically, prior to June 2019, the disclosure outlined in MFIM’s Form ADV allegedly did not adequately disclose the receipt of NTF revenue sharing by Mesirow Financial, Inc. (MFI), MFIM’s affiliated broker-dealer, or the conflicts this created for MFIM. Without admitting or denying the underlying findings, MFIM agreed to pay affected investors disgorgement of $487,862 prejudgment interest of $94,972; and pay a civil penalty of $170,000. MFIM subsequently notified affected investors of the settlement terms. ITEM 10 | Other Financial Industry Activities and Affiliations Certain employees of MFIM are separately licensed as registered representatives of Mesirow Financial, Inc. (“MFI”). These individuals, in their separate capacity, can effect securities transactions for which they will receive separate, yet customary compensation. While MFIM and these individuals endeavor at all times to fulfill their fiduciary responsibilities to clients, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and can affect the judgment of these individuals when making recommendations. As part of its services, MFIM Currency may utilize various instruments depending on the service provided and client’s underlying portfolio. Such instruments may include spot, forward or futures contracts, swaps, equities and options. In addition, non-deliverable forwards can be used only at the explicit request of the client. Mesirow Financial International UK, Ltd. (“MFIUK”) is a participating affiliate of MFIM that provides trading, portfolio management, research and other resources to MFIM. Participating affiliate arrangements allow registered advisers to utilize certain advisory services and personnel of unregistered advisory affiliates. Services provided by MFIUK to MFIM are provided via a participating affiliate agreement between MFIM and MFIUK. MFIUK employees who provide services to clients of MFIM act as “associated persons” in providing such services, and in that capacity are subject to MFIM supervision and oversight. Under the participating affiliate arrangement, these individuals may provide discretionary advisory and trading services across all MFIM Currency strategies. MFIM has implemented policies and procedures to ensure that MFIUK complies with the Investment Advisers Act of 1940, as amended, including adherence to MFIM’s code of ethics, trading policies and compliance oversight. MFIM’s clients contract with MFIM and MFIM remains fully responsible for the client relationship. MFIM and its affiliates are not restricted from forming additional investment funds, entering into other investment advisory relationships or engaging in other business activities, even though such activities can be in competition with the funds. Potentially, such activities could be viewed as creating a conflict of interest in that the time and effort of MFIM Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 10  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management management personnel and employees will not be devoted exclusively to the business of the funds, but could be allocated between the business of the funds and other business activities. As noted in Item 4 and 5, MFIM’s other business units can act as a general partner or sponsor of various private investment vehicles that MFIM may recommend or sell to its advisory clients. Prior to the sale of any such investments, MFIM will have disclosed any potential conflicts of interest and will recommend the investment only if it appears suitable for the client. Clients should be aware that the receipt of additional compensation by MFIM and its management persons or employees creates a conflict of interest that can impair the objectivity of MFIM and these individuals when making advisory recommendations. MFIM endeavors at all times to put the interests of its clients first as part of its fiduciary duty as a registered investment advisor. MFIM typically takes the following steps to address any potential conflicts: • MFIM discloses to clients the existence of all material conflicts of interest; • MFIM collects, maintains and documents accurate, complete and relevant client background information, including the client's investment mandates, financial goals, objectives and risk tolerance; • MFIM's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable for the client's needs and circumstances; • MFIM requires that its employees seek prior approval of any outside employment activity to ensure that any conflicts of interests in such activities are properly addressed; • MFIM periodically monitors outside employment activities of its employees to verify that any conflicts of interest continue to be properly addressed; and • MFIM educates its employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the investment advice provided to clients. ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MFIM has adopted a Code of Ethics, which sets forth the ethical standards of business conduct that MFIM requires of its employees, including compliance with applicable federal securities laws. MFIM and its personnel owe a duty of loyalty, fairness and good faith towards clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics. MFIM's Code of Ethics includes policies and procedures for the review of securities transactions as well as initial and annual securities holdings reports that must be submitted by MFIM's access persons. MFIM also has additional policies and procedures relating to the preclearance of all employee trades (other than securities deemed exempt from this obligation). MFIM's Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. MFIM's Code of Ethics further includes policies and procedures governing gifts and entertainment, outside business activities, confidentiality of information and information barriers, and charitable and political contributions. The Code of Ethics also prohibits the misuse of material non-public information and emphasizes the avoidance of conflicts of interest with investors. Each employee must acknowledge the terms of the Code of Ethics on an annual basis. Any employee who violates the Code of Ethics may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. A copy of MFIM's Code of Ethics is available to its advisory clients and prospective clients. You may request a copy by email sent to maryjo.hayes@mesirow.com, or by calling us at 312.595.6512. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 11  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management MFIM is part of a group of affiliated financial services companies that perform a number of different services for a client. MFIM is mindful of the conflicts or potential conflicts that such relationships create. Consequently, MFIM has adopted a Code of Conduct, which prescribes standards of conduct required of all employees, regardless of their position or affiliation in the group. The Code prohibits self-dealing and other improper activities, the misuse of material non-public information, and it emphasizes the avoidance of conflicts of interest with clients. Some specific areas of potential conflict are discussed below. MFIM and/or individuals associated with it may buy or sell for their personal account’s securities identical to or different from those recommended to its clients. In addition, any related person(s) can have an interest or position in certain securities, which can also be recommended to a client. Employees of other divisions of MFIM can sell interests in investment companies which the MFIM Currency division subadvises. Those employees can be compensated separately. MFIM, through MFI, can direct the purchase or sale in securities on a principal basis in accordance with Section 206 (3) under the Investment Advisers Act of 1940, as amended. As these situations represent actual or potential conflicts of interest to clients, MFIM has established the following policies and procedures for implementing its Code of Ethics, to ensure the firm complies with its regulatory obligations and provides clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of MFIM can put his or her own interest above the interest of an advisory client. 2. No principal or employee of MFIM can buy or sell securities, foreign exchange forward or a related derivative, for their personal portfolio(s) where their decision is because of information received as a result of his or her employment unless the information is also available to the investing public. 3. MFIM requires prior approval for any IPO or private placement investments. 4. MFIM maintains a list of all reportable securities holdings for the firm and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by the appropriate designated supervisor. 5. MFIM has established procedures for the maintenance of all required books and records. 6. All of MFIM's principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 7. MFIM requires delivery and acknowledgement of the Code of Ethics by each access person. 8. MFIM has established policies requiring the reporting of Code of Ethics violations to senior management. Any individual who violates any of the above restrictions may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. Other Participation or Interest in Client Transactions Due to the fact that MFIM is compensated based on AUM, MFIM employees are incentivized to have clients open accounts and to add to assets to new and existing accounts. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 12  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 12 | Brokerage Practices MFIM Currency will endeavor to select those banks and counterparties that will provide the best services at the best rates possible. MFIM Currency's decision as to which bank or counterparty to trade with is based on various factors including, but not limited to the counterparties' stability, reputation, creditworthiness, ability to provide professional services, and access to relevant markets. ITEM 13 | Review of Accounts INVESTMENT SUPERVISORY SERVICES PORTFOLIO MANAGEMENT While the underlying holdings within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed at least quarterly. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews can be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by Portfolio Management or another designated person. Reports in addition to the monthly statements and confirmations of transactions that clients receive from their custodians and/or broker/dealer, MFIM Currency regularly provides reports summarizing account performance, balances and holdings. MFIM Currency urges clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current. ITEM 14 | Client Referrals and Other Compensation CLIENT REFERRALS MFIM does not receive an economic benefit from anyone other than its clients. MFIM and its affiliates may enter into Referral Agreements with a promoter such as a broker-dealer or an investment adviser. MFIM or its affiliates generally pay the promoter a percentage of the management fee and/or performance-based fee collected from the client. Regardless of how it is calculated, any such referral fee will be paid solely from MFIM’s investment management fee and will not result in any additional charge to the client. See Item 5 for additional information on advisory fees. MFIM has entered into arrangements with unaffiliated third parties for their assistance in referring business to MFIM or providing advice to MFIM with respect to the expansion of the firm’s distribution of products or services in various U.S. and non-U.S. markets and distribution channels. MFIM may pay cash compensation under these arrangements based on a monthly flat fee as well as, in the sole discretion of the firm, a bonus at the conclusion of the arrangements. The fees paid to the unaffiliated third party are not passed on to any introduced clients, but the presence of these arrangements may affect MFIM’s willingness to negotiate below its standard investment advisory fees and, therefore, may affect the overall fees paid by referred clients. MFIM Currency acts as a sub-advisor or provide other services to other investment advisors or mutual funds and as such will be paid a fee based on a percentage of the assets of the fund. MFIM, or an affiliate, may also sell the fund to its clients and will receive compensation from the investment advisor or fund family. It is MFIM's policy not to accept or allow its related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services it provides to clients. MFIM compensates affiliate personnel that work in other business units for referrals. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 13  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 15 | Custody As part of the billing process, the client is invoiced for the amount of the fee. Clients typically hold funds at banks or other custodians and fund accounts on an as needed basis. Generally, MFIM does not custody client assets. In limited instances, MFIM is deemed to have custody of client assets under the SEC’s Custody Rule, 206(4)-2, due to the fact that a related person, as defined by the rule, serves as the general partner for certain private funds. In addition to the periodic performance statements that clients receive directly from their banks or custodians, MFIM Currency also sends account statements directly to its clients on a monthly basis. As noted above, MFIM Currency urges clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current. ITEM 16 | Investment Discretion Clients can engage MFIM to provide discretionary and non-discretionary asset management services. Clients can in certain circumstances limit such authority by giving MFIM written instructions. Clients give MFIM discretionary authority when they sign an investment management agreement with MFIM or complete the subscription documents for a fund. ITEM 17 | Voting Client Securities PROXY VOTING POLICIES AND PROCEDURES: MFIM does not vote proxies for clients. MFIM will exercise discretion as it relates to corporate actions in any legal proceedings, including bankruptcies or class actions, involving securities included in or previously included in the Account. ITEM 18 | Financial Information MFIM has no additional financial circumstances to report. MFIM has not been the subject of a bankruptcy petition at any time during the past ten years. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2026. All rights reserved. 14