MORNINGSTAR INVESTMENT SERVICES LLC

Morningstar Investment Services LLC Form ADV Part 2A: Firm Brochure Morningstar® Managed Plan SolutionsSM 22 West Washington Street Chicago, IL 60602 Phone: 800.886.1749 mp@morningstar.com July 8, 2025 This brochure provides information about the qualifications and business practices of Morningstar Investment Services LLC. If you have any questions about the contents of this brochure, please contact us at 312-696-6000 or send an email to compliancemail@morningstar.com. The information in our brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Morningstar Investment Services LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Morningstar Investment Services LLC is registered with the SEC as a registered investment adviser. Registration with the SEC does not imply a certain level of skill or training. Please retain this brochure for future reference. Item 3. Table of Contents Advisory Business ..................................................................................................................................... 1 Fees and Compensation ......................................................................................................................... 2 Performance-Based Fees and Side-by-Side Management ........................................................ 3 Types of Clients ......................................................................................................................................... 3 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 3 Disciplinary Information ........................................................................................................................ 5 Other Financial Industry Activities and Affiliations ..................................................................... 5 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 7 Brokerage Practices ................................................................................................................................. 8 Review of Accounts .................................................................................................................................. 8 Client Referrals and Other Compensation ...................................................................................... 8 Custody ......................................................................................................................................................... 8 Investment Discretion ............................................................................................................................. 8 Voting Client Securities .......................................................................................................................... 8 Financial Information .............................................................................................................................. 8 Item 2. Material Changes This Firm Brochure dated July 8, 2025 contains the following material changes since our last annual update dated March 27, 2025. Item 4. Advisory Business This brochure focuses on services we offer to retirement plans (individually a “Plan”, collectively “Plans”) and their participants, known as Morningstar® Managed Plan SolutionsSM. Morningstar Investment Services shut down the Morningstar Wealth Platform in May 2025. In addition, it transitioned its Model Provider clients to its parent company, Morningstar Investment Management LLC. This Firm Brochure is being updated to remove activities related to the Morningstar Wealth Platform and as a model provider. In March 2025, the following non-material changes were made to our Firm Brochure. Item 4. Advisory Business was updated to reflect our assets under management and advisement as of December 31, 2024. Morningstar Investment Services LLC and its Ownership Structure Morningstar Investment Services LLC is a Delaware limited liability company that was incorporated in 2000. (Where applicable, the terms “we”, “us”, and “our” also includes “Our Representatives”, as defined below, in this Firm Brochure.) Morningstar Investment Services is a wholly owned subsidiary of Morningstar Investment Management LLC. Morningstar Investment Management is a Delaware limited liability company that was incorporated in 1999, an investment adviser registered with the SEC, and a wholly owned subsidiary of Morningstar, Inc. (“Morningstar”). Morningstar is a publicly traded company (Nasdaq Ticker: MORN) with Mr. Joseph Mansueto, Executive Chairman of Morningstar, holding more than 35% of Morningstar’s outstanding shares. Because of that ownership, Mr. Mansueto is an indirect owner of Morningstar Investment Services. Item 10. Other Financial Industry Activities and Affiliations was updated to remove the Morningstar Wealth Elite Advisors Program. It was also updated to remove that Morningstar Investment Management receives compensation for its research and analysis activities (e.g., research papers) from a variety of financial institutions. Morningstar Investment Services is registered with the SEC under Section 203(c) of the Investment Advisers Act of 1940, as amended (“Advisers Act”). Morningstar Investment Services has filed the appropriate notices to conduct business in all 50 states, the District of Columbia, the Commonwealth of Puerto Rico, and the Virgin Islands. Item 14. Client Referrals and Other Compensation was updated to reflect instances where we may, direct or indirectly, receive cash payments from unaffiliated third- parties for referring their services to other advisory firms or investors. Morningstar Wealth, through Morningstar and its subsidiaries, make available products such as: (i) investment product delivery; (ii) Morningstar Funds Trust, (iii) Morningstar Office℠, Morningstar’s RIA portfolio software service; (iv) Morningstar® ByAllAccounts®, Morningstar’s investment data aggregation service; and (v) Morningstar.com®, Morningstar’s individual investor site offering. The Brochure Supplement accompanying this Firm Brochure was updated since the last annual update to note updated investment team responsibilities and supervisors. It was also updated to replace Marta Norton as the Chief Investment Officer with Philip Straehl. Certain Morningstar subsidiaries are authorized in the jurisdictions in which they operate to provide investment management and advisory services. In the United States, these subsidiaries are Morningstar Investment Management LLC and Morningstar Investment Services LLC. We made other edits where necessary to correct grammar or punctuation, to provide clarification or further information, for consistency in terminology or content, or to improve the readability of the brochure. ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 2 of 8 Advisory Services We Offer - Overview Morningstar Investment Services offers various investment advisory services that focus on our core capacities in asset allocation, investment selection, and portfolio construction to retail investors and to institutions including, but not limited to, asset management firms, advisory platform providers, banks, broker/dealers, endowments, foundations, insurance companies, investment advisers, investment fiduciaries, plan sponsors of retirement plans, providers of retirement plan services, trusts, and other business entities (collectively “Institutional Clients”). Plan’s Investment Lineup Additionally, we assist Plan Sponsors in determining the mutual funds and/or ETFs available under a Plan (each a “Fund”, collectively the “Funds”). We do this as a 3(38) “investment manager” (as defined under the Employee Retirement Income Security Act of 1974, as amended) through a platform provider. These services include the selection of securities which are then used to create the Portfolios. We rebalance the security weightings in the Portfolios and remove and replace securities as we deem necessary. We determine appropriate Funds primarily through the use of a proprietary fund rating system that is based on key factors. Such key factors are defined in the Methods of Analysis, Investment Strategies and Risk of Loss section of this brochure. Customized Services We provide advice based on the strategy chosen by you and/or your Financial Adviser and take into account any reasonable restrictions you request. Morningstar® Managed Plan SolutionsSM The Morningstar® Managed Plan SolutionsSM services (“Services”) are designed to help employers who are responsible for establishing and maintaining their company’s defined contribution or other retirement plan (the “Plan Sponsor”) and the participants enrolled in the Plan (“Participants”). Features within Services are as follows: Assets Under Management As of May 31, 2025, the regulatory assets under management for Morningstar Investment Services (rounded to the nearest $100,000) were: Discretionary Assets: $0 independent research, and progressive Item 5. Fees and Compensation Fees and Compensation Morningstar® Managed Plan SolutionsSM The Plan Sponsor, Plan, or Participant will pay us an annual basis point fee (“Fee”). Depending on what services (as described above) the Plan Sponsor or Plan choose, the Fee typically ranges from 20–30 basis points (0.20% to 0.30%) and is based on the Plan’s assets and the complexity involved in providing the services. The Fee is typically remitted quarterly to us by the Plan’s recordkeeper. Model Asset Allocation Portfolios We offer model asset allocation portfolios covering various risk levels (e.g., conservative, aggressive, etc.) (each a “Portfolio,” collectively, “Portfolios”). The Portfolios’ initial construction and ongoing monitoring and maintenance are provided by investment professional representatives of our direct parent company, Morningstar Investment Management. In accordance with an agreement between Morningstar Investment Management and us, those investment professionals are acting on our behalf in connection with the Services and Portfolios (“Our Representatives”). The Asset Allocation series is designed to provide broad risk diversification, distinctive, management in core portfolios that span the risk spectrum. This strategy invests primarily in diversified investments in domestic and international equity mutual funds and/or exchange-traded funds (ETFs) available through the Plan or the Plan’s recordkeeping provider. The goal of the Portfolios is to provide the Participant with the ability to invest their Plan account assets in a diversified manner. Risk Tolerance Questionnaire We make available to Participants a risk tolerance questionnaire. The questionnaire’s sole purpose is to provide Participants with general assistance in terms of identifying their risk tolerance and investment objectives and, based on this, which model asset allocation portfolio is most aligned with that risk tolerance/investment objective. Investment Policy Statement We provide Plan Sponsors with tools to help them develop an Investment Policy Statement (“IPS”). The purpose of the IPS is to provide guidelines for the investment and management of assets held for the benefit of Participants and beneficiaries of the Plan. The primary intent of the IPS is to: • Establish a framework for structuring a retirement savings program for Plan Participants by making available diversified investment options that support a range of long-term needs, goals and risk tolerances. Other Costs in Connection with Our Advisory Services Our Fee is separate from the fees and expenses a Participant incurs by the Funds in which Plan account assets are invested. This may include redemption fees that a Fund can impose as a result of a transaction-related request. Also, fees related to recordkeeping and certain other administrative services for the Plan may be charged to a Participant’s Plan account. Lastly, the Plan Sponsor or Participant may also secure the services of a financial adviser who may receive distribution, marketing and/or shareholder servicing fees from fund companies within the Plan. In addition, we are limited to choosing funds and fund shares classes from those made available to us through each Custodian’s platform, which can result in us choosing funds that charge other fees outside of our control. There may be cheaper share classes available for a fund on other Custodian platforms. While we typically seek to use the cheapest share class available to us, you should not assume we have access to the share class with the lowest possible expense ratio for a specific fund through your Custodian. More expensive share classes reduce the performance of an account. We periodically review the universe of funds the Custodian makes available to us and update your share class as more attractive options become available. All of the fees and expenses described in this paragraph are separate from the above-mentioned Fee and we have no control, influence or involvement in them. Termination of services and refunds of fees, if any, are governed by the contractual agreement between the parties, which is negotiated on a case-by-case basis. • Provide participants with investment options which, when prudently used, will diversify portfolio risks and better accommodate the range of risk/return preferences they may have. • Establish careful procedures for monitoring and evaluating the performance of the investment options within the Plan. • Describe the investment process used to select the Plan’s investment options and the asset allocation portfolios available in the Plan. • Describe the roles and responsibilities of the various parties that may be involved in the oversight of Plan investment activities. The fees and expenses charged by your Plan account’s underlying holdings are described in the security’s prospectus or an equivalent document. These fees will generally include a management fee, transfer agent fee, shareholder servicing fee, other investment expenses, and possibly a distribution fee (e.g., 12b-1). In some cases, a security may also charge an initial or deferred sales charge. Neither Morningstar Investment Services nor anyone affiliated with Morningstar Investment Services receive transaction-based compensation for the investment recommendations we make. Advisory and other fund-related expenses in mutual funds in which your account assets are invested not included in our Fee includes redemption fees that an open-end mutual ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 3 of 8 The investment principles are: fund underlying your account or qualified custodian may impose as a result of a transaction-related request you initiated (i.e., partial or complete liquidation of your account). In addition, in certain situations, decisions to rebalance and/or reallocate your account may result in you incurring a redemption fee imposed by one or more of the funds underlying your account. In both such cases, any such redemption fee charged to your account by the underlying fund or qualified custodian will be reflected on your quarterly account statement. - We put investors first - We’re independent-minded - We invest for the long term - We’re valuation-driven investors - We take a fundamental approach - We strive to minimize costs - We build portfolios holistically Exchange-traded funds have their own internal fees and expenses such as investment advisory, administration, and other fund-level expenses; by investing in them you incur a proportionate share of those fees and expenses. Those fees and expenses are in addition to the above-mentioned Fee. Compensation from Sales of Securities We do not expect, accept or receive compensation for the sales of securities, including asset-based sales charges or service fees from the sale of open-end mutual funds. Building upon our investment principles, the investment philosophy is built on the belief that portfolios should maintain a risk profile commensurate with the desired long-term asset allocation guidelines we provide to the client. We focus extensively on the portfolio structure to maintain a careful balance between being allocated similarly to the portfolio benchmarks and one that reflects our assessment of the value available in the current market environment. We select managers that we believe manage fund assets with a consistent and disciplined process that provides for sustainable long-term results. We prefer managers with a prudent, logical, and repeatable process and remain keenly focused on the consistency of the implementation of their investment disciplines. Investment Process Our investment process for our Services starts with scouring the globe for opportunities. Instead of hewing closely to an index-defined universe, we look broadly, investigating asset classes, sub-asset classes, sectors, and securities in markets around the world. Our capital markets research extends to more than 200 equity and 150 fixed-income asset classes. We also track more than 30 world currencies. You may have the option to purchase investment products in our model portfolios or similar services through other investment advisers or financial professionals not affiliated with us. Because our services are not exclusive to your Plan or Plan Sponsor, the Fee for the services described in this brochure could be higher than fees charged by other financial advisers who provide services similar to ours or if you paid separately for investment advice and other services. In addition, because the underlying holdings of our model portfolios are not exclusive to the services described herein, you may buy securities (e.g., mutual funds, exchange-traded funds, equity securities, etc.) outside of this service without our Fee. We apply deep valuation analysis supported by in-depth fundamental research to find opportunities around the globe. Alongside this analysis, which looks at both absolute and relative valuation, we also consider investor sentiment and positioning, which adds contrarian elements to our process and tells us how the market consensus views an investment class we’re considering. We prefer to invest in ideas that go against the market consensus because one of the only ways to outperform is to be different from what the market has already included in the stock price. Marketing, Distribution, and Educational Support Arrangements We enter into agreements with certain advisory firms whereby we provide compensation to the advisory firm in exchange for financial adviser access to educate them about our Services and Portfolios, having our Services and Portfolios listed or highlighted in the advisory firm’s materials, attendance or booth space at advisory firm’s conferences, and/or similar marketing, distribution, and educational activities. We also provide compensation to advisory firms to sponsor financial adviser, Plan Sponsor or Participant meetings and events. Revenue Sharing Arrangements We do not have any revenue sharing arrangements with any mutual funds. We also look closely at each asset class’ risk, which can be complex, multifaceted, and vary over time. We believe that one of the best ways to control for risk is to buy fundamentally strong assets that seem underpriced. Our in-depth valuation analysis and contrarian indicators, when brought together, are the key ways we generate investment ideas. These ideas might be names to include in an equity portfolio or our best thinking on reward for risk at the asset class-level. Item 6. Performance-Based Fees and Side-by-Side Management We do not have performance-based fee arrangements with any qualified client pursuant to Rule 205-3 under the Advisers Act. Item 7. Types of Clients The Services are intended for Plan Sponsors and/or Participants. Investment Selection Finding investment opportunities isn’t just about great ideas; it’s also about selecting great investments for our clients. Investments may be individual stocks, or active managers and/or passive exchange-traded products in a multi-asset portfolio. Our research-driven approach to selecting investments is designed to help investors reach their goals and objectives. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Portfolio construction and ongoing monitoring and maintenance of the Portfolios are provided on our behalf by Our Representatives, who are investment professionals of Morningstar Investment Management. When building multi-asset portfolios, we need to evaluate the active investment managers and/or passive funds we use to implement our investment strategies. Our investment selection process begins with analysis from Morningstar and its affiliates, which covers hundreds of thousands of investment offerings globally, including mutual funds, closed-end funds, separate accounts, exchange-traded products, individual stocks, and hedge funds. We then build upon that analysis with reviews by our internal investment team, which includes not only quantitative screens and assessments, but also one-on-one conversations with portfolio managers as part of our fundamental due diligence. Investment Philosophy Our investment philosophy is driven by the investment principles that are promoted throughout our organization. The principles are intended to guide our thinking, behavior and decision making. These principles have been inspired by a number of people we believe are the most experienced and successful investors in the last century. These principles also reflect and align with the history and foundation of Morningstar. ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 4 of 8 opportunities might be included in our portfolios, and watching markets closely for any signs that would call for adjustments within the portfolio. In our due diligence, we assess whether their investment team is qualified, experienced, and talented; that they follow a consistent and disciplined investment process; that their organization is strong and stable; and that they operate professionally and ethically. Portfolio management is not a stop/start process. We constantly review our positions, seeking to maximize reward for risk. Each strategy has a set of investment guidelines that outline the investment objectives, risk levels, and investment constraints. These are monitored to stay within the defined ranges. We study managers’ holdings using our proprietary tools and analytics to assess how well their strategy may work in combination with those of other managers. And we consider managers’ ability to outperform in different market environments. Rather than following simple style analytics or style neutrality blends, we seek process diversification and try to avoid the pitfalls of over- diversification often found in fund-of-fund investment strategies. As valuation-driven investors, we primarily focus on price changes relative to fair value through time. Given that markets are dynamic, we reassess the portfolio given the changes in investment ideas, aggregate risks, and portfolio exposures. This iterative process reconsiders the opportunity set, with a constant eye on fundamental diversification and portfolio allocations. Once we have selected active managers, we tend to keep them in place for the long haul. High turnover and crowded portfolios destroy investor value by creating an overpriced index fund. We believe hiring independent managers to run high- conviction strategies is a far better approach to multimanager portfolios. Turnover and trading reduce returns for investors and therefore any changes should be expected to add value by a comfortable margin. Investment decisions happen in the real world rather than on paper—transaction costs and taxes are real. This means being biased toward inaction and long-term holdings, keeping turnover and transaction costs as low as possible. As for passive vehicles, our selection process begins with the thousands of exchange-traded products in the Morningstar database and includes the work of Morningstar and its affiliates’ ETF analyst team. Our own analysts perform qualitative work that can’t be found in an automated service. Our global investment team works around the clock to understand markets and opportunities, monitor risk in existing portfolios, and vet ideas to make investment changes. This ongoing investment process powers every portfolio we manage. ETFs are often less expensive than their open-end mutual fund counterparts but assessing them has to go beyond this fact. We closely examine the risk characteristics that define ETFs—including tracking to the index, trading volume, bid/ask spread, and premium/discount—to help ensure the goals are realistic and the liquidity is what we expect. As with other funds, we assess ETFs within a portfolio context to achieve access to a particular market segment or sub-asset class. Individual stock selection relies heavily on our asset class research to identify attractive segments of the market (sectors, countries, or factors like quality) and a review of the valuations and fundamentals of the underlying stocks. We rely heavily upon Morningstar’s Equity Research group in addition to our own proprietary insights. Global Investment Committee Morningstar Wealth’s Global Investment Committee and its regional governance bodies, in addition to the Americas Investment Product Committee, are responsible for oversight of the investment methodologies across all products and services. Members of the Global Investment Committee may include officers, chief investment officers, managing directors, or managers of Morningstar Investment Management or its affiliates. The regional governance bodies meet quarterly to review guideline changes and performance across portfolios. Formal and informal global best practice working groups also exist with the goal of sharing methodologies and research across regions. These groups focus on specific investment areas such as valuation models driven by our capital markets research and methodologies used for asset allocation, investment selection, portfolio construction for different investment strategies and advice. In addition to governance bodies, the investment team has regional research and portfolio construction workflows that surface best thinking across investment opportunities and guide portfolio construction. An investment team provides the investment advice used in the products and services referenced in this brochure. Information on key members of this investment team is included in the attached Form ADV Part 2B brochure supplement. Building Portfolios Armed with investment ideas, our global team works together to holistically build portfolios suited to each strategy we offer. Portfolio construction is about ranking and risk management. We seek to gain the largest exposure to our best ideas that are the most underpriced (that is, have the largest difference between price and fair value), while building robust portfolios designed to stand up to challenging investment environments or investment errors. This judgment-driven approach also allows us to evaluate the complexity and multifaceted nature of investment risk. We view risk as the permanent loss of capital. Our valuation-based approach (that is, seeking underpriced assets and avoiding overpriced assets), fundamental diversification, and forward-looking approach to viewing asset class co-movements (that is, those that buffer gains and losses), all help mitigate risk in our portfolios. Information Sources Our global resources used in the formulation of our advisory services go down to our roots—the data and analysis from Morningstar, Inc. that form the base of our investment process. This expansive, in-house network of global data and investment analysis spans asset classes and regions to help drive timely new ideas. Morningstar or its affiliates have more than 800 analysts and make data available on more than 600,000 investment options and 5.2 million privately held companies. The extensive data, analysis, and methodologies from these resources, and external research reports, data, and interviews with investment managers are combined with financial publications, annual reports, prospectuses, press releases, and SEC filings to serve as the basis of our primary sources of information. To prepare investors for the future, we seek to construct robust portfolios designed to perform well in different environments rather than being considered “optimal” based on expected results or a specific environment. We avoid forecasts and building strategies based on our ability to predict specific environments. Instead, we aim to prepare for different environments through constructing portfolios that will hold up under many possible environments—even ones that we haven’t seen before. In effect, this involves trade-offs of aggregate reward for risk and a calibration of the probability and impact of negative outcomes. Managing Portfolios Once we’ve holistically built portfolios, we manage them. This part of the process is simply continuing to find opportunities, thinking through ways those Material Risks Investments in securities are subject to market risk, risk of loss, and other risks and will not always be profitable. There is no assurance or guarantee that the intended investment objectives of our recommendations will be received. We do not represent or guarantee that our investment recommendations can or will predict future results, will successfully identify market highs or lows, or will result in a profit or protect clients from ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 5 of 8 exist. We encourage you to consult with a tax professional about these and other tax consequences. Item 9. Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would influence adviser potential client to engage us. We do not have any material legal or disciplinary events to disclose. loss. Past performance of a security may or may not be sustained in the future and is no indication of future performance. A security’s investment return and an investor’s principal value will fluctuate so that, when redeemed, an investor’s shares may be worth more or less than their original cost. We are unable to predict or forecast market fluctuations or other uncertainties that may affect the value of any investment. We cannot guarantee that the results of our advice, recommendations, or the objectives of your portfolio will be achieved. We do not guarantee that negative returns can or will be avoided in any of its portfolios. Item 10. Other Financial Industry Activities and Affiliations Morningstar Investment Services is a wholly owned subsidiary of Morningstar Investment Management. Asset allocation and diversification are investment strategies which spread assets across various investment types for long-term investing. However, as with all investment strategies, these strategies do not ensure a profit and do not guarantee against losses. Our Representatives who are responsible for the day-to-day management of our Portfolios are paid a base salary plus a discretionary bonus, and in some cases, annual stock grants. The bonus is fully or partially determined by a combination of the employee’s business unit’s overall revenue and profitability, Morningstar’s overall annual revenue and profitability, and the individual’s contribution to the business unit. For most portfolio managers and their team members, part of their bonus is also based on select portfolio investment performance and risk metrics versus both a corresponding benchmark over specified three-, five-, and/or seven-year periods and appropriate peer groups. Benchmarks are used as a measure of investment performance and are chosen by senior personnel and approved by the Regional Investment Committee, which is chaired by the CIO. To mitigate the conflict of interest that arises from partially basing an employee’s bonus on performance of a select portfolio or portfolios, all investment decisions made within a portfolio by an individual portfolio manager must be peer reviewed by the broader regional team of portfolio managers. In addition, the Regional Investment Committee reviews strategy performance on a quarterly basis. Security Type Risks Exchange-Traded Funds Portfolios may be invested in exchange-traded funds whose investment objective is to track that sector. ETFs are traded on national exchanges and therefore are subject to similar investment risks as common stocks. ETFs, like all investments, carry certain risks that may adversely affect their net asset value, market price, and/or performance. An ETF’s net asset value (NAV) will fluctuate in response to market activity. Because ETFs are traded throughout the day and the price is determined by market forces, the market price you pay for an ETF may be more or less than the net asset value. Because ETFs are not actively managed, their value may be affected by a general decline in the U.S. market segments relating to their underlying indexes. Similarly, an imperfect match between an ETF’s holdings and those of its underlying index may cause its performance to not match the performance of its underlying index. Like other concentrated investments, an ETF with concentrated holdings may be more vulnerable to specific economic, political, or regulatory events than an ETF that mirrors the general U.S. market. Mutual Funds Investments in mutual funds involve risk, including loss of principal as a result of changing market and economic conditions and will not always be profitable. From time to time, advisory firms request that we pay to sponsor a marketing event or provide marketing support as it relates to our Services. These requests are reviewed on a case-by-case basis. For marketing events, such monetary support will typically be provided if one or more individuals will be attending on our behalf, including being a speaker, and/or is provided booth space. Periodically, we will host regional meetings for financial advisers with the main purpose of providing education. There are situations in which we will ask a person representing a fund company in which one or more of their funds are included in our portfolios to speak on various topics unrelated to specific securities. Money Market Funds A money market fund may impose a fee upon the sale of shares or may temporarily suspend your ability to sell shares if the fund’s liquidity falls below required minimum because of market conditions or other factors. An investment in a money-market vehicle is not insured or guaranteed by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. For most money market funds, their sponsor has no legal obligation to provide financial support to the fund, and you should not expect that the sponsor will provide financial support to the fund at any time. Although some money market funds seek to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. It is possible to lose money by investing in money market funds. For some of our advisory services, the universe of investment options from which we make our investment selections is defined by our client. In some cases, this universe of investment options includes proprietary investment options of our client. To mitigate any actual or potential conflict of interests presented by this situation, we subject all investment options to the same quantitative and qualitative investment selection methodology, based on several factors, including performance, risk, and expense so that the proprietary nature of an investment option does not influence our selection. When we, along with Morningstar and/or our other affiliates offer services to the same client, we have the option to enter into a bundled agreement with the client that encompasses all or part of those services. Additional fee(s) for such product(s) or service(s), if required, will be set forth in our agreement with the client. In these situations, clients pay a fee directly to us and each such affiliate for its products or services, or as part of a joint fee schedule which encompasses all services. Additional Risks and Disclosure As with any investment decision, you should consider the impact it may have on your tax situation. Please note, unless your investment is in a tax-deferred account, there are possible tax consequences when a mutual fund makes a distribution or you sell fund shares as a result of withdrawing or liquidating your investment. We encourage you to consult with your tax professional about these and other tax consequences related to your investments. If you are redeeming, surrendering or otherwise selling an existing security position to fund your account’s initial investment, you should fully understand the ramifications of such a redemption, surrender or sale including, but not limited to, potential tax liabilities and fees/charges that you may incur such as redemption fees, contingent deferred sales charge(s), and/or brokerage commissions. Our recommendations are made without taking into consideration potential tax consequences and we do not provide tax advice. Potential tax consequences may Affiliations – Registered Entities Morningstar has various subsidiaries across the globe that are each registered with and governed by the applicable regulatory body or bodies in that country to provide investment management or other advisory services. As described earlier in this brochure, we share resources with these various subsidiaries. One subsidiary, Morningstar Investment Management LLC, is our parent company and is also an investment adviser registered under the Advisers Act. In some instances, Morningstar Investment Management compensates our affiliates for services rendered and expenses ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 6 of 8 intercompany participating affiliate agreement. incurred via an intercompany charge. The services and compensation will be governed by an This compensation will likely be lower than compensation negotiated with non- affiliated financial institutions/institutional investors for same or similar services. Morningstar Research Services provides information to the public about various securities, including managed investments like open-end mutual funds and ETFs, which include written analyses of these investment products in some instances. Although we use certain products, services, or databases that contain this information, we do not participate in or have any input in the written analyses that Morningstar Research Services produces. While we consider the analyses of Morningstar Research Services, our investment recommendations are based on our decisions in regard to the investment product. In some cases, our senior management members have management responsibilities to these other affiliated entities. We do not believe that these management responsibilities create any material conflicts of interests for our clients. Morningstar investment Investment Management provides consulting or management services to clients that offer registered or pooled investment products, such as mutual funds, variable annuities, collective investment trusts, or model portfolios. To mitigate the conflict of interest presented by our role in these investment products, we exclude such investment products from the universe of investment options from which we make our recommendations to clients. Morningstar Research Services may issue investment research reports on securities we hold in our portfolios or recommend to our clients, but they do not share any yet-to-be published views and analysis and/or changes in estimates (i.e., their confidential information) with us on these securities. In making investment decisions or recommendations, we use Morningstar Research Services’ publicly available analysis as part of our review process and do not have access to their analysis prior to its public dissemination. We mitigate any actual or potential conflicts of interest that could arise from the access of their analysis prior to publication through measures such as informational barriers (both physical and technological), maintaining separate or dual organizational reporting lines, and monitoring by the compliance department. Our Representatives provide portfolio construction and ongoing monitoring and maintenance for the portfolios offered by Morningstar Investment Management. Morningstar Research Services prepares qualitative analysis on separately managed accounts and model portfolios. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis nor recommend any Morningstar separately managed account or model portfolio we create and manage. Morningstar Investment Management is registered as a Commodity Pool Operator with the Commodity Futures Trading Commission. Some of Morningstar Investment Management’s employees are registered with the National Futures Association as principals or associated persons. intercompany agreement. Some of Morningstar Research Services’ clients are sponsors of funds or associated with other securities that we may recommend to our clients. We mitigate any actual or potential conflicts of interests resulting from this fact through such measures as informational barriers (both physical and technological), maintaining separate organizational reporting lines, and monitoring by the compliance department. In addition, we do not factor in the relationship between Morningstar Research Services when analyzing investments or making recommendations. Morningstar Wealth has set up a shared services team, composed of employees of our affiliate and located at our affiliate’s office in Mumbai, India. Our affiliate is compensated for services rendered via an intercompany charge. The services and compensation will be governed by an This compensation will likely be lower than compensation negotiated with non- affiliated firms for the same or similar services. To mitigate any conflict of interest, we have established dual reporting lines for employees on the shared services team so that such employees report up to employees of Morningstar Investment Management. Information security boundaries and technology separation have been established to protect non-public information and Morningstar’s compliance department monitors the personal trading activity of these employees. Morningstar Investment Management serves as an investment adviser to investment companies registered under the Investment Company Act of 1940, as amended, and to other pooled investment products. To mitigate conflicts of interest, Morningstar Research Services does not prepare qualitative analysis on nor recommend as part of their investment consulting services any investment company Morningstar Investment Management is an investment adviser or sub-adviser to. Morningstar Research Services LLC is a wholly owned subsidiary of Morningstar and an investment adviser registered under the Advisers Act. Morningstar Research Services’ offerings center around the production of investment research reports and investment consulting services to financial institutions/institutional investors who themselves are registered with and governed by a regulatory body. Conflicts of interests between us and Morningstar Research Services are mitigated by such things as the maintenance of separate legal entities and dual reporting/organization lines, and the utilization of physical (i.e., separate office “neighborhoods”) and technological separation. Morningstar Research Services also maintains a committee structure so as to limit any unilateral decisions. Morningstar’s compliance department monitors the personal trading activities of Morningstar Research Services’ employees. Affiliations – Morningstar, Inc. Our ultimate parent company, Morningstar, Inc., is publicly traded (Ticker Symbol: MORN). We may recommend an investment product that holds a position in publicly traded shares of Morningstar’s stock. Such an investment in Morningstar’s stock is solely the decision of the investment product’s portfolio manager. We have no input into a portfolio manager’s investment decision nor do we require that the investment products we recommend own shares of Morningstar. An investment product’s position in Morningstar has no direct bearing on our investment selection process. We mitigate any actual or potential conflicts of interest by not factoring Morningstar’s publicly traded stock into our qualitative or quantitative analysis nor in our recommendations. Morningstar offers various products and services to the public. Some of Morningstar’s clients are service providers (e.g., portfolio managers, advisers, or distributors affiliated with a mutual fund or other investment option). We may have a contractual relationship to provide consulting or advisory services to these same service providers or we may recommend the products of these service providers to our advisory clients. To mitigate any actual or potential conflicts of interest, we do not consider the relationship between Morningstar and these service providers when making recommendations. We are not paid to recommend one investment option over another, including products of service providers with which Morningstar has a relationship. Morningstar provides information to the public about various investment products, including managed investments like open-end mutual funds and ETFs. In some cases, In some situations, we engage Morningstar Research Services to perform investment manager due diligence and/or selection services on our behalf as a sub-adviser or consultant. The notification to and authorization by our clients to our engaging Morningstar Research Services as a sub-adviser is addressed in our agreement with the client. On such occasions, we compensate Morningstar Research Services for services rendered via an intercompany charge This compensation will likely be lower than compensation negotiated with non- affiliated financial institutions/institutional investors for the same or similar services. Morningstar Research Services’ employees who are engaged to provide manager due diligence and/or selection services are prohibited from using non- public/confidential information obtained because of their engagement in its investment research reports and/or investment consulting services to clients, including us. ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 7 of 8 this information includes written analyses of these investment products. Although we use certain products, services, or databases of Morningstar, we do not have any decision-making input in the written analyses that Morningstar provides its licensees. While we consider the analyses of Morningstar, our investment recommendations are oriented to the mandates of the investment products in question. Morningstar hosts educational events and conferences and, in some instances, provides us with the opportunity to suggest invitees or offer (proactively or upon request) discounted or waived registration fees. We mitigate any actual or potential conflicts of interest this introduces by using pre-defined criteria to select the participants for these opportunities. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code Of Ethics We have in place a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act (“Code of Ethics”). Our Code of Ethics strives to uphold the highest standards of moral and ethical conduct, including placing our clients’ interest ahead of our own. Our Code of Ethics covers all our officers and employees as well as other persons who have access to our non-public information (collectively “Access Persons”). Our Code of Ethics addresses such topics as professional and ethical responsibilities, compliance with securities laws, our fiduciary duty, and personal trading practices. Our Code of Ethics also addresses receipt and/or permissible use of material non-public information and other confidential information our Access Persons may be exposed and/or have access to given their position. The Code of Ethics is provided upon hire and at least annually thereafter and at each time, the Access Person must certify in writing that she or he has received, read, and understands the Code of Ethics and that they agree to or have complied with its contents. As a wholly owned subsidiary, we use the resources, infrastructure, and employees of Morningstar and its affiliates to provide certain support services in such areas as technology, procurement, human resources, account, legal, compliance, information security, and marketing. We do not believe this arrangement presents a conflict of interests to us in terms of our advisory services. A copy of our Code of Ethics is available to existing and prospective clients by sending written request to compliancemail@morningstar.com. We have the option to make our clients aware of various products and services offered by Morningstar or its affiliates. We do not receive compensation for that introduction. Morningstar and its affiliates also have the option to make their clients aware of various products and services offered by us. Morningstar and its affiliates do not receive any compensation from us for that introduction, unless it falls under a solicitation arrangement, as described in Item 14 below. Interest In Client Transactions Our Access Persons have the option to maintain personal investment accounts and purchase or sell investments in those accounts that are the same as or different from the investments we recommend to clients. Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities should not conflict with our advisory activities or the timing of our recommendations and will not interfere with our clients’ interests, while allowing our Access Persons to invest in their own accounts. Our Portfolio recommendations are communicated to your Plan’s recordkeeper, who then relays them to your account custodian. We do not engage in principal transactions (transactions where we, acting in our own account or in an affiliated account, buy a security from or sell a security to a client’s account) nor do we engage in agency cross transactions (transactions where we or our affiliate executes a transaction while acting as a broker for both our client and the other party in the transaction) as part of the Services. Morningstar Wealth, through Morningstar and its subsidiaries, make available products such as: (i) investment product delivery; (ii) Morningstar Funds Trust, (iii) Morningstar Office℠, Morningstar’s RIA portfolio software service; (iv) Morningstar® ByAllAccounts®, Morningstar’s investment data aggregation service; and (v) Morningstar.com®, Morningstar’s individual investor site offering. Daniel Needham, our president, has management responsibilities for Morningstar Wealth. We do not believe that these management responsibilities create any material conflicts of interests for our clients, but we mitigate any actual or potential conflicts of interests resulting from that by imposing informational barriers where appropriate and undertaking compliance monitoring. Interest in Securities That We May Recommend Morningstar Investment Services does not have a proprietary trading account and thus, as a firm, does not invest in any security that we may recommend under Morningstar Managed Plan Solutions. through our parent company, Morningstar Affiliations – Morningstar, Inc.’s Subsidiaries Equity and manager research analysts based outside the United States are employed by various wholly owned subsidiaries of Morningstar. These analysts follow the same investment methodologies and process as Morningstar Research Services, as well as being held to the same conduct standards. As a result, we do not believe this structure causes actual or a potential for a conflict of interest. Morningstar Wealth, Investment Management, provides model portfolios to third-party financial institutions on a non- discretionary basis. Any model portfolio recommendations are communicated after the close of the trading day and Morningstar-affiliated accounts in Morningstar Wealth will be traded the next day so that no one person has an advantage over another. Affiliations – Credit Rating Agency We are affiliated with the Morningstar DBRS group of companies, which include DBRS, Inc., DBRS Limited, DBRS Ratings GmbH, and DBRS Ratings Limited. DBRS, Inc. is registered with the Securities and Exchange Commission as a Nationally Recognized Statistical Rating Organization (NRSRO). Morningstar DBRS companies are also registered with and governed by applicable regulatory body or bodies in other countries around the globe. In our analysis of certain securities, we use the publicly available credit rating and analysis issued by Morningstar DBRS. Because of our use of Morningstar DBRS ratings and analysis is limited to that which is publicly available, we do not believe there is an actual or potential conflict of interest that arises from such use. Personal Trading By Access Persons Our Code of Ethics is designed to ensure that Access Persons’ personal trading activities do not interfere with our clients’ interests. While our Access Persons have the option to maintain personal investment accounts, they are subject to certain restrictions. Our Code of Ethics includes policies designed to prevent Access Persons from trading based on material non-public information. Access Persons in possession of material non- public information are prohibited from trading in securities which are the subject of such information and tipping such information to others. In certain instances, we employ information blocking devices such as restricted lists to prevent illegal insider trading. Morningstar’s compliance department monitors the activities in the personal accounts of our Access Persons (and any accounts in which they have beneficial ownership) upon hire and thereafter. Access Persons are required to pre-clear IPO, initial digital coin offerings, and private placement transactions with Morningstar’s compliance department. ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.  Page 8 of 8 Item 12. Brokerage Practices Our trade recommendations are communicated to the appropriate institution as designated by the Plan Sponsor or your recordkeeper. We do not participate in any soft dollar practices. Item 18. Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We do not have any financial commitment that impairs our ability to meet our contractual and fiduciary commitments to clients, nor have we been the subject of any bankruptcy proceeding. Item 13. Review of Accounts Our services for Plans do not include the periodic review or ongoing monitoring of Participant accounts. We may, however, provide ongoing monitoring of specific investments in a Plan’s lineup and make periodic reports to the Plan Sponsor or your recordkeeper, and/or provide recommendations to the Plan Sponsor or recordkeeper for changes in the Plan’s investment lineup. Item 14. Client Referrals and Other Compensation Situations arise in which others introduce accounts to us or solicit clients for us. In those cases, we will enter into a written agreement with the solicitor that complies with Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended. The agreement will identify the specific percentage of the annual fee to be shared with the solicitor commensurate with the degree of effort and assistance provided. Our fee charged to clients will not be affected if they were introduced or referred by a solicitor. Third-Party Compensation We receive direct or indirect cash payments from unaffiliated third-parties for referring their services to other advisory firms or investors. This creates a conflict of interest as we have an incentive to recommend these third-parties in order to receive the cash payment. Item 15. Custody We do not serve as a custodian of Participant assets. Your Plan Sponsor or recordkeeper is responsible for selecting the custodian for Plan assets. The selection of custodians may be limited by the plan provider or recordkeeper. Participants should receive statements from the qualified custodian that holds the Plan assets at least quarterly. Participants should carefully review such statements. If you note any discrepancies on your account statements, you should promptly contact your plan administrator or recordkeeper. Item 16. Investment Discretion When we provide plan sponsor advice, typically the Plan Sponsor retains the investment discretion and control of Plan assets. We provide Plan Sponsors with information designed to help them make investment choices regarding their retirement plans, but the Plan Sponsors are responsible for managing the investments in their plans. However, in some cases, Plan Sponsors may delegate investment management discretion to us. When we provide advice to Participants, typically the Participant retains the investment discretion and control of their assets. We provide Participants with information designed to help them make investment choices regarding their assets and the recordkeeper notifies them of any changes recommended within their Portfolio. Participants are responsible for responding to the recordkeeper if they do not approve of those recommendations. Item 17. Voting Client Securities Participants are responsible for receiving and voting proxies for all investments held in their account. We do not have the authority to and will not vote proxies. Please note, we will not act on or advise you in regard to legal proceedings, including bankruptcies or class actions, involving securities held in an account. You are responsible for determining whether you want to participate in any class action suits filed against companies in which you are invested. ©2025 Morningstar Investment Services LLC. All Rights Reserved. The Morningstar name and logo are registered marks of Morningstar, Inc.