WILLIAM BLAIR & COMPANY L.L.C.

March 31, 2025 FORM ADV PART 2A This Brochure (also known as Form ADV Part 2A) provides information about the business practices of William Blair & Company, L.L.C. If you have questions about the contents of this Brochure, please contact us at pwmcompliancegroup@williamblair.com or (312) 236-1600. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. William Blair & Company, L.L.C. 150 North Riverside Plaza Chicago, Illinois 60606 (312) 236-1600 www.williamblair.com Additional information about William Blair & Company, L.L.C. also is available on the SEC’s website at www.adviserinfo.sec.gov. William Blair & Company, L.L.C. is registered as an investment adviser with the SEC. Our registration as an investment adviser does not imply a certain level of skill or training.  ITEM 2 – MATERIAL CHANGES William Blair & Company, L.L.C. (“William Blair” or “firm” or “we”) has updated our Brochure (also known as Form ADV Part 2A) as of March 31, 2025. Our last update was an annual amendment as of March 29, 2024. We continue to conduct our business and provide investment advisory services in substantially the same manner as described in this last annual update to our Brochure. This Brochure contains routine updates, including, but not limited to, information regarding assets under management. The Brochure has also been updated to eliminate references to SYSTM Wealth Solutions LLC and to reflect changes to our Merchant Banking Program, including the removal of certain fees in connection therewith. As a reminder, we may at any time update our Brochure and will either send you a copy or offer to send you a copy (either electronically or in hard copy) as may be necessary or required. If you would like another copy of this Brochure, you may download it from the SEC’s website at www.adviserinfo.sec.gov, or you may contact our Compliance team at (312) 236-1600 or e-mail us at pwmcompliancegroup@williamblair.com. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 1  ITEM 3 – TABLE OF CONTENTS ITEM 2 – MATERIAL CHANGES ................................................................................................................................................. 1 ITEM 3 – TABLE OF CONTENTS ................................................................................................................................................. 2 ITEM 4 – ADVISORY BUSINESS ................................................................................................................................................. 3 ITEM 5 – FEES AND COMPENSATION ....................................................................................................................................... 5 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...............................................................................17 ITEM 7 – TYPES OF CLIENTS ....................................................................................................................................................19 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................................................................19 ITEM 9 – DISCIPLINARY INFORMATION ...................................................................................................................................25 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................................................25 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ....................30 ITEM 12 – BROKERAGE PRACTICES .........................................................................................................................................32 ITEM 13 – REVIEW OF ACCOUNTS ...........................................................................................................................................36 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................................................37 ITEM 15 – CUSTODY ...............................................................................................................................................................41 ITEM 16 – INVESTMENT DISCRETION ......................................................................................................................................42 ITEM 17 – VOTING CLIENT SECURITIES ....................................................................................................................................42 ITEM 18 – FINANCIAL INFORMATION .....................................................................................................................................44 William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 2  ITEM 4 – ADVISORY BUSINESS Firm Description William Blair is a global investment firm offering investment management and related services to clients. The firm was founded in 1935 and is registered with the SEC as both an investment adviser and a securities broker-dealer. William Blair (a privately held company) is a wholly owned subsidiary of WBC Holdings, L.P., which is wholly owned by current William Blair employees (we also refer to employee owners as ‘partners’ in this Brochure). William Blair also is an affiliate of William Blair Investment Management, LLC, an investment adviser registered with the SEC (“WBIM”). WBIM provides institutional investment management business, separate from the other business lines within William Blair. Investment Advisory Services William Blair’s private wealth management division (“PWM”) and its advisors (“PWM Advisors”) provide discretionary and non-discretionary investment management services to clients for a fee. Clients pay us investment advisory fees based on fee schedules as described in Item 5. William Blair also manages accounts for wrap fee program clients. As a discretionary investment manager, we provide investment management services in accordance with each client’s investment guidelines. We accept investment restrictions from clients if the restrictions do not hinder our ability to execute our investment strategies and if such restrictions can be appropriately implemented. According to a client’s investment objectives and subject to reasonable investment restrictions, a PWM Advisor may elect to allocate all or a portion of that discretionary advisory client’s assets to one or more William Blair proprietary models (“William Blair Proprietary Home Office Models”). In certain cases, we provide investment guidance to clients on a non-discretionary basis (on either a portion of the assets held in the account or the entire account) with the client making final investment decisions. William Blair provides non-discretionary advisory services to other registered investment advisers by delivering model portfolios (“Non-Discretionary Model Portfolio Program”). With respect to the Non-Discretionary Model Portfolio Program, William Blair has no investment discretion, no knowledge of the underlying investment advisers’ clients, no authority to effect and/or execute trades on behalf of these registered investment advisers’ clients and no knowledge as to whether a registered investment adviser followed any of our non-discretionary investment recommendations. We provide non-discretionary investment advisory services to these registered investment advisers based on strategy model portfolios (similar to how we manage other separate accounts). William Blair has an indirect, minority- ownership interest in certain investment advisers that participate in the Non-Discretionary Model Portfolio Program. Wrap Fee Program Clients William Blair serves as an investment manager to and sponsor of a comprehensive advisory fee program (also known as a wrap fee program), the “William Blair Wrap Program,” as described further in William Blair’s Form ADV 2A, Appendix 1, also known as our “William Blair Wrap Fee Program Brochure.” A wrap fee program is a program where a client is charged a specified “bundled” fee (generally, a percentage of assets under management) for discretionary investment management services and trade execution costs and sometimes other services such as custody, record keeping and reporting. In order to participate in a William Blair Wrap Program, an advisory client must maintain a brokerage account with William Blair, as introducing broker-dealer. As described more fully below, Fidelity Investments and/or its various affiliates including but not limited to National Financial Services and Fidelity Brokerage Services (collectively, “NFS”) acts as clearing broker and provides custodial, clearing, settlement and certain other services for William Blair Wrap Program advisory clients. Our compensation under our William Blair Wrap Fee Program may be lower than our standard fee schedule; however, the overall cost of a wrap arrangement may be higher than a client otherwise would pay if the client paid our standard fee schedule and negotiated transaction costs and any other services (e.g., custody, record keeping and reporting) through a broker-dealer. William Blair’s wrap program fees and standard advisory fees are negotiable. Platform Clients William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 3  William Blair has entered into agreements with asset management platform providers (the “Platform”). PWM Advisors, for certain discretionary advisory account clients, access and hire discretionary investment advisers (the “Sub-Managers”) through the Platform providers. Some Platform providers and their underlying Sub-Managers require information from clients, such as agreement to their standard terms & conditions, a client profile or application and other related documentation (including, in some instances, the opening of custodial and/or brokerage accounts). Your PWM Advisor will work with you to obtain any Platform required documentation. A client may impose reasonable restrictions on the management of account assets being managed on a Platform, such as, the designation of particular securities or types of securities that should not be purchased or that should be sold if held in the account. As the client will not be able to communicate directly with any Sub-Manager available through a Platform, the client should communicate these reasonable restrictions to their William Blair PWM Advisor. Sub Advisory Clients In some instances, certain entities hire William Blair to manage assets for their underlying clients. In these instances, William Blair acts in a sub-advisory capacity. In some instances, William Blair has discretion to buy, sell and hold securities in the underlying clients’ accounts. In other instances, William Blair acts in a non-discretionary capacity and the ultimate decision to buy, sell or hold securities is made by the registered investment adviser that hired William Blair. In some instances, the underlying client is able to communicate with William Blair while in other instances all communication is between William Blair and the entity. Sub-Management Agreement with WBIM William Blair has entered into a Sub-Management Agreement with its affiliate, WBIM. If authorized by the client, William Blair has the discretion to hire WBIM as a sub-adviser to manage those allocated assets, with discretion (“WBIM Sub-Advisory Accounts”). William Blair MB Investments Program William Blair established the “MB Investments Program” to provide select clients with access to certain investment opportunities generated through William Blair’s proprietary, global relationship network. William Blair MB Investments GP, LLC, a William Blair affiliate, (“MB General Partner”), serves as the general partner to William Blair MB Investments, L.P., a Delaware series limited partnership (“MB Partnership”). The MB Partnership’s investments are made in (a) other investment funds (such as private equity, debt, venture capital, and real estate) and (b) direct investments in private capital and business combination transactions including private company financings (ranging from early-stage to late stage rounds), leveraged and unleveraged buyout transactions, and management buyout transactions; and (c) co-investment opportunities (“Co-Investments”) (collectively, “MB Investments”). A new series will typically be formed to invest in each MB Investment (“Series”). An investor must independently and affirmatively elect to participate in the MB Investments Program and to invest in a Series and, if admitted as a limited partner, will receive interests in that Series (“Interests”). Interests in a Series are in Client’s name and ownership is recorded in the books and records of the MB Partnership. In certain cases (e.g., where the Co-Investment is made through the sponsor’s investment vehicle, such Co-Investment will be held in Client’s name and ownership will be recorded in the books and records of the Co-Investment issuer. The MB Partnership is excluded from regulation under the Investment Company Act of 1940 and its securities are exempt from registration under the Securities Act of 1933. Accordingly, investors are not afforded the protections of those Acts. As discussed in the MB Partnership offering documents and in the non-discretionary investment advisory agreement, the MB General Partner uses its good faith efforts to determine the fair market value of Interests. To the extent a client participates in the MB Investments Program through a non-discretionary investment advisory account, William Blair earns an investment advisory fee based on the fair market value of the Interests. Our affiliate, the MB General Partner, values the Interests. The higher the fair market value of the Interests or Co-Investment, the more William Blair earns in advisory fees, creating a conflict of interest. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 4  The MB General Partner can delegate to William Blair certain management and administrative responsibilities including the authority to select investment opportunities and make investment-related decisions on behalf of the MB Partnership. Investment advice is provided directly to the MB Partnership and not individually to the limited partners. William Blair and PWM Advisors will not provide investment advice or recommendations to clients with respect to participation in the MB Investments Program or investing in any Series.. A client independently decides to participate in the MB Investments Program and affirmatively elects to purchase Interests in each MB Partnership Series.,. A Series limited partner can contribute capital through a brokerage account, advisory account, bank account or otherwise. Once the client invests in any Series through a non-discretionary advisory account, William Blair will provide asset allocation, monitoring and performance reporting. Information regarding limited partner eligibility, fees, expenses, risks, conflicts of interest and terms and conditions are set forth in the MB Partnership offering documents as well as highlighted in this Brochure. Proxy Voting, Corporate Actions and Other Legal Matters Clients have the option of voting proxies directly or delegating proxy voting discretion to William Blair or a third party. In cases where William Blair has proxy voting discretion, Institutional Shareholder Services, Inc. (“ISS”) provides proxy voting, maintenance, reporting, analysis and recordkeeping services for William Blair with respect to proxies for companies whose securities are managed by William Blair on a discretionary basis. Assets under Management As of December 31, 2024, William Blair had approximately $58.3 billion in assets under management, of which, we managed approximately 90% on a discretionary basis and 10% on a non-discretionary basis. ITEM 5 – FEES AND COMPENSATION William Blair provides discretionary and non-discretionary investment management services to clients and charges annual fees, payable quarterly either in advance or in arrears (depending on the terms of each investment management agreement). We charge up to a 2.00% fee on all assets, subject to negotiation. When charged in advance, fees are calculated on the total market value of each account (including on assets invested in cash and cash equivalents and on accrued interest and dividends) on the last day of the prior quarter except as otherwise described in this section. When charged in arrears, fees are calculated on the total market value of each account (including on assets invested in cash and cash equivalents and on accrued interest and dividends) on the last day of the current quarter, except as otherwise described in this section. As more fully described below, assets in a client’s account invested in a William Blair Fund, Blair Private Fund, William Blair MB Managed Investment, WBIM Sub-Advisory Account, WBIM Separate Account and any assets agreed to by the client and William Blair to be held in the account as an accommodation and not subject to supervision will be excluded from the calculation of the advisory fee. Notwithstanding the foregoing, in certain instances the calculation of the advisory fee paid to William Blair will include the assets held in or through a WBIM Sub-Advisory Account, provided that WBIM does not charge a separate advisory fee to the client for its sub-advisory services. Please see Item 4 of our William Blair Wrap Fee Program Brochure and the investment advisory contract for a description of fees and compensation with respect to William Blair Wrap Fee Program services. Ongoing fees reduce the value of an investment portfolio over time. Because of the fees you pay, you have a smaller amount invested that is earning a return when the fee is debited from a portfolio’s assets. You are encouraged to discuss the impact of fees with your PWM Advisor. Note that William Blair is a private partnership; a primary factor in becoming a partner of the partnership, and the compensation paid to a partner, is the amount of revenue generated by a particular employee or partner, as the case may be. Employees and partners are therefore incented to increase revenue, which presents conflicts of interest between our employees and you. To mitigate these conflicts, we maintain our Code of Ethics (“Code”), which details our fiduciary duty to put our clients’ interests ahead of our own, and we conduct annual training on our Code. We William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 5  also have established supervisory controls and procedures to oversee the actions of our employees and partners and their compliance with applicable law. Client’s custodian shall be responsible for valuing all assets in a client’s account; valuation is not the responsibility of William Blair. Securities without a readily available market price shall be valued as determined in good faith by custodian, as appropriate, to reflect its fair value. William Blair, Platform providers and Sub-Managers will cooperate with custodian in custodian’s good faith efforts to determine fair market value. With respect to client account assets in alternative investments (such as private funds), alternative investment managers and underlying vehicles are responsible for providing custodian with valuation in accordance with applicable laws. Payment of Fees Many of our clients elect to have their quarterly fees directly debited from their accounts while others choose to receive an invoice. We prorate fees based on the length of time we managed your account in the event you opened or terminated your account during the quarter. We will refund any fees prepaid but not yet earned or will request prompt payment for any fees earned but not yet paid. Other Fees and Expenses In addition to, and separate from, the investment management fee, our clients pay other costs and charges in connection with their accounts or certain securities transactions payable to William Blair or its affiliates or payable to parties other than us. Depending on your arrangement with William Blair, these may include, among other fees and expenses, the following (also refer to Item 12 – Brokerage Practices): Commissions and other charges for executing trades through broker-dealers; Transaction fees for the purchase or sale of mutual funds in advisory accounts; Certain odd-lot differentials; Exchange fees; Taxes, duties and other governmental charges, such as transfer taxes; Costs associated with international exchange transactions; Electronic fund, wire transfer and other transfer fees; Fees imposed for certain types of custody or brokerage accounts; Fees imposed in connection with certain custodial, trustee or other account services; • • • Dealer mark-ups, markdowns and spreads; • Auction fees; • • • • • • • • Account maintenance or service fees; • Fees in connection with transferring your account to another investment advisor or broker-dealer (also known as ACAT exit fees); Securities lending fees; • Regulatory transaction fees; • • Multi margin fees; • Non-purpose loan fees; • Platform provider fee reflects costs to access a Platform and Sub-Manager fee reflects costs to pay each Sub- Manager on the Platform; • Access Fees for certain private funds; Performance-based fee, if applicable, on certain MB Partnership Series ; • • Mutual fund redemption fees if shares are sold before the designated time period set forth in a prospectus; William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 6  • Fees and expenses associated with mutual funds (including William Blair Funds), exchange traded funds and other commingled products (such as affiliated private funds including Blair Private Funds and William Blair Managed MB Investments) as well as unaffiliated private funds (including William Blair MB Investments); Fees associated with separate accounts established with affiliated and unaffiliated registered investment advisers; Pass-through or other fees associated with American Depositary Receipts; Fees and charges related to reporting, including performance reporting; Charges mandated by law or regulation; and • • • • Activity assessment fee; • • Fees in connection with the establishment, administration, maintenance, or termination of accounts (including retirement or profit-sharing plans or trust accounts). Further information regarding the fees and expenses are found in your investment advisory agreement with William Blair as well as in other documents such as brokerage account documentation, other third-party service provider documentation, third party advisory and/or Platform provider documentation and mutual fund and private fund offering documents. For more information regarding fees and expenses, please discuss with your PWM Advisor. Other Fees and Expenses Related to NFS, Platform Providers and Other Third-Party Providers William Blair has entered into agreements with NFS whereby NFS provides custodial, brokerage and certain other services for certain clients of William Blair. Clients who choose to use NFS’s services enter into the applicable custodial and/or brokerage agreements. Clients are not required to use NFS for these services, and clients are free to work with other custodians. Please note that not all custodians provide the same services or services at the same cost as NFS. Each client who considers NFS is provided with the appropriate agreements and applicable fee schedules at that time. Third party managers utilized by the client through an asset management platform provider must maintain a custodial account with NFS and direct most, if not all trades, to NFS or William Blair. Pursuant to an agreement with NFS, in addition to a one-time payment by NFS to William Blair upon contract renewal in 2023, William Blair receives certain fees and credits including, but not limited to, those set forth in this section. NFS pays William Blair a fee in connection with moving new client assets to the NFS platform (the “Transition Credit”). In certain cases, the amount of the Transition Credit exceeds the amount of the fee charged by the prior custodian in connection with the transfer. If William Blair terminates its agreements with NFS, William Blair repays NFS a portion of the Transition Fees. Also pursuant to an agreement with NFS, William Blair receives from NFS a portion of the fees it charges or credits it pays related to certain services, including securities lending, multi-margin accounts, non-purpose loans and certain fixed income trades executed through systems made available by NFS, among other services offered for certain types of client accounts as disclosed in applicable agreements for those services. If you choose to enter a multi-margin relationship, our advisory fees increase as the market value of your investment portfolio increases. Our offer to provide margin as a strategy creates a conflict of interest since we stand to receive increased advisory fees, and William Blair earns margin revenue from NFS based on your interest payments. If you choose to loan your securities, NFS pays you a fee based on the loan. NFS reduces the amount of the loan fee paid to you by the amount that NFS pays to William Blair. Our continued receipt of our advisory fee on the security as if it were not loaned as well as NFS paying us a portion of your loan fee creates a conflict of interest. In addition, because we receive this fee and have discretionary authority over purchases and sales of securities in your account, we are incented to purchase and hold securities that are available to be loaned (or generate a larger loan fee) instead of those that are ineligible to be loaned or garner a lower fee. PWM Advisors are compensated on multi-margin and securities lending. NFS offers non-purpose loans, for a fee, collateralized by assets in your advisory accounts. NFS shares with William Blair a portion of the interest earned on non-purpose loans. As with multi-margin, William Blair’s receipt of a portion of NFS’ interest fees on non-purpose loans create a conflict of interest and incentivizes William Blair to recommend NFS over other providers. In addition, William Blair charges its advisory clients certain operational fees such as: fees for account transfers (“ACAT Exit Fees”), wire transfers, foreign exchanges, bounced checks, IRA terminations, as well as other fees described in the client account documentation. The amount that William Blair charges its clients is higher than the William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 7  amount that William Blair pays to NFS in connection with those services. William Blair keeps the difference between the fee its clients pay, and the amount paid to NFS for coordination and oversight of these services provided through NFS as well as to generate revenue. This presents a conflict of interest since setting a higher fee increases the revenue William Blair receives even though it results in you paying higher fees. These markups are in addition to the investment advisory fees you pay us, and you should consider the additional revenue that William Blair receives when evaluating the appropriateness of our investment advisory fees. NFS has also agreed to pay William Blair business development and technology development credits. If William Blair terminates its agreements with NFS, William Blair repays NFS a portion of these credits. These fees, charges and credits cause conflicts of interest because: 1) they incentivize William Blair to recommend clients utilize NFS custodial and other services instead of another custodian; 2) they incentivize William Blair to recommend securities lending, non-purpose loans and margin activity; and 3) they incentivize William Blair to maintain its relationship with NFS to avoid repayment of Transition Fees, business, infrastructure, technology development and other credits. To help manage these conflicts, we rely on controls including the following: • payments and credits as well as a description of conflicts are disclosed in documents including, but not limited to, this Brochure, Wrap Brochure, advisory agreements, the Customer Relationship Summary (“Form CRS”), prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms; • PWM Advisors are not compensated based on Transition Fees, or business, infrastructure, technology credits (PWM Advisors are compensated on multi-margin and securities lending); • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own, and conduct annual training on our Code; and • PWM Advisors are obligated to employ a standard of care and comply with clients’ investment guidelines and restrictions when selecting investments for clients’ accounts. William Blair also pays for services from Platform providers (as defined under Item 4) or their affiliates. William Blair receives a discount on the cost of these services based on the level of our clients’ assets on the Platform. Therefore, William Blair has a conflict of interest in that there is an incentive to increase the amount of its clients’ assets on a Platform to reduce the cost to William Blair of other services it receives from the Platform provider or its affiliates. The Platform provider is used to generate orders for the Proprietary Home Office Models, which in almost all cases will route trades to William Bliar’s broker-dealer trade desk for execution through various trading venues. While an underlying client account is not charged an additional fee for using the Platform provider, William Blair retains a larger portion of the Advisory Fee to cover the administrative cost of the Platform provider, and the PWM Advisor retains less of the Advisory Fee. This creates an incentive for the PWM Advisor not to use the Proprietary Home Office Model. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; Clients can restrict the use of Proprietary Home Office Models through a Platform provider; • Clients can restrict the hiring of any Sub-Adviser through a Platform provider; and • • • Conflicts of interest are disclosed in this Brochure, Form CRS, SYSTM’s Form ADV, Part 2A, SYSTM’s Form CRS and in the investment advisory agreement. Other Fees and Expenses Related to Third Party Investment Managers or Sub-Managers William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 8  Some PWM Advisors access and hire Sub-Managers through the asset management Platform described in Item 4 – Advisory Services. In cases where a client’s account or a portion thereof is managed by a third party investment manager or Sub- Manager, clients will pay the third party management fee, as well as William Blair’s advisory fee and any platform access fee, if applicable. In addition, the third party investment manager or Sub-Manager, in its sole discretion, may place a client’s trade orders with a broker-dealer firm other than the custodian’s designated broker-dealer if the manager determines that it must do so to comply with its best execution obligations. This means that clients who invest with third party investment managers or Sub-Managers will most likely incur execution costs (whether in the form of commissions or markup/markdowns that are built into the net price of the security) in addition to, and which will not reduce, the advisory account fees. Clients should therefore consider these costs when selecting and/or determining whether to remain invested in accounts managed by third party investment managers or Sub-Managers. William Blair does not monitor the level of trading away from the designated broker-dealer by third party investment managers or Sub-Managers. Other Fees and Expenses Related to Private Funds Private fund investments are generally held in a discretionary or non-discretionary investment advisory account, directly (if the client meets the private fund’s minimum investment) or through a private fund platform. In certain cases, such investments may be held in a brokerage account. If you hold a private fund investment in a brokerage account, you will typically pay an upfront placement agent fee to William Blair plus the underlying costs of the private fund investments (which in some cases includes a platform access fee). If you hold such investments in an advisory account, (including a William Blair Wrap Program account), you will pay an investment advisory fee to William Blair plus the underlying costs of the private fund investment (which in some cases includes a platform access fee,;). Private funds are highly illiquid and cannot be sold or transferred and you will pay the ongoing, annual advisory fee for the life of the private fund investment. The fair market value of interests in an underlying unaffiliated private fund (including a MB Investment) shall be included for purposes of calculating William Blair’s advisory fee. William Blair relies on the issuer, custodian and/or other third parties to provide a good faith, fair market value. The timing and process for fair market valuation of private fund investments is not as reliable as valuations of publicly traded securities. Depending on the size of the advisory fee and the market value of the private fund investment over the life of the fund, William Blair could earn more revenue than if the same investment was held in a brokerage account or directly with the issuer. Therefore, to earn these ongoing advisory fees, William Blair and your PWM Advisor are incented to recommend that you purchase interests through your advisory account instead of in a brokerage account. If a client invests in private funds through a private fund platform, clients may pay an access fee. Clients may also pay a performance based fee, as described further in the fund documents. Certain employees, partners and clients of William Blair and its affiliates will be able to access the same MB Investments directly or through other investment vehicles at different fee structures that are more advantageous than accessing the MB Investment through the MB Partnership Series. The ability for certain employees, partners and clients to access the MB Investments without paying a performance-based fee (or a lower performance-based fee), directly or through a lower paying fee structure also creates a conflict of interest between William Blair’s employees, partners and clients and the MB Partnership’s limited partners. Affiliated private funds. When you invest in a private fund managed by William Blair’s affiliate, WBIM (“Blair Private Fund”) or where William Blair or an affiliate is the general partner, manager, adviser and/or control person of the underlying MB Investments (“William Blair Managed MB Investment”), you are subject to the Blair Private Fund’s and/or William Blair Managed MB Investment’s internal management fees and other expenses; however, we do not charge our investment management fee in addition to these internal management fees. Instead, we exclude the assets invested in the Blair Private Funds and/or William Blair Managed MB Investments when we calculate the investment management fees we charge you. However, up to 50% of the management fee earned on PWM’s clients’ assets invested in the Blair Private Funds and/or William Blair Managed MB Investments is shared with William Blair and PWM Advisors. In certain cases, where our affiliate does not charge a separate fee, assets managed by that affiliate will be included in our fee, and we will compensate our affiliate up to 50% of fee that is based on the amount of assets managed by that affiliate. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 9  Receipt of, or the prospect of receiving, this compensation influences William Blair and PWM Advisors with respect to Blair Private Funds and/or William Blair Managed MB Investments over non-affiliated private funds and creates a conflict of interest. If the payment William Blair receives from Blair Private Fund and/or William Blair Managed MB Investments is higher than the fee it receives from the client for managing the advisory account, then William Blair’s overall fee will increase as the allocation to Blair Private Funds and William Blair Managed MB Investments increases. For more information on conflicts of interest, please discuss with your PWM Advisor and see documents including, but not limited to, the Brochure, Form CRS, advisory agreements, Blair Private Funds’ offering documents, MB Partnership offering documents, separate client account opening documentation and/or separate disclosure documents. In addition to fees and expenses listed above, other expenses include: sales expenses, accounting, tax and audit expenses; legal expenses; and other expenses not listed. Private funds that invest with an underlying manager or in underlying funds bear associated fees and expenses. Feeder funds generally bear a pro rata portion of the expenses associated with the related master fund. Details regarding expenses can be found in the applicable offering memorandum and other governing documents. Investing in our Blair Private Funds and William Blair Managed MB Investments creates a conflict of interest. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; • A client does not need to invest in a Blair Private Fund or William Blair Managed MB Investments; • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, Blair Private Fund offering documents, William Blair MB Partnership offering documents and/or separate disclosure forms; • Blair Private Funds and William Blair Managed MB Investments are subject to an annual audit; and • We offset investment management fees on a client’s assets held in the Blair Private Funds and William Blair Managed MB Investments, where a separate management fee is charged. Clients will pay a performance based fee, if applicable, in connection with MB Investments, an advisory fee to William Blair that is based on, in part, the value of such investments, and, as a limited partner in such investments, the costs and expenses that are allocated to such partners, as more fully described in the applicable fund documents. While William Blair and PWM Advisors do not provide any recommendations or advice with respect to client’s independent decision to participate in the MB Partnership Program or subscribe for Interests in any MB Partnership Series, receipt of, or the prospect of receiving, performance-based fees, if applicable advisory fees on the fair market value of Interests,, investment banking fees and any internal management fee on a MB Investment creates conflicts of interest to favor MB Investments instead of investing in unaffiliated private funds, directly or through an unaffiliated private fund platform. To help manage conflicts: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; • A client does not need to invest in private funds, including any MB Investment; • If a client meets the minimum investment amount, the client may be able to invest directly instead of through any private fund platform,including the MB Investments Program,; • MB Partnership maintains written policies and procedures with respect to the fair market valuation of Interests and allocation of investment opportunities; ; • F • William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 10  • Private funds, including the William Blair MB Partnership, are subject to annual audits; and • • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, William Blair MB Partnership offering documents and/or separate disclosure forms. As discussed above, unaffiliated private funds, MB Investments, Blair Private Funds (affiliated private funds advised by WBIM) and William Blair Managed MB Investments also bear their own operating and other expenses such as those associated with the formation, operation, dissolution, winding-up or termination. Each MB Partnership Series will bear partnership expenses, including but not limited to carried interest/performance- based fees, if applicable, and additional expenses incurred in connection with the formation, management, operation, maintenance and liquidation of the MB Partnership and the MB General Partner. From time to time, the MB General Partner or William Blair will be required to decide whether certain fees, costs and expenses should be borne by a Series, allocated among multiple Series or paid entirely or in part by the MB General Partner or William Blair. Therefore, in these circumstances, the portion of an expense allocated to a Series will not reflect the relative benefit derived by such Series for the service received. In exercising its discretion to allocate fees and expenses, the MB General Partner or William Blair are faced with a variety of conflicts of interest due to the inherent biases in the process. William Blair or the MB General Partner will make any such expense allocation determinations in a fair and reasonable manner using its good faith judgment, despite its interest (if any) in the allocation. Mutual Fund and ETF Fees and Expenses For clients whose guidelines allow a portion of their assets to be invested in mutual funds (both open-end funds and closed-end funds) or exchange traded funds: • When invested in shares of unaffiliated funds (funds not advised by WBIM) in your account, you are subject to our investment management fees in addition to the mutual fund or exchange traded fund internal management fees and other expenses (as described below). In addition, exchange traded funds and closed end funds may trade at prices that vary from their net asset value, sometimes significantly. Performance of a fund pursuing a passive index-based strategy may diverge from the performance of the index. • When invested in shares of the William Blair Funds (affiliated mutual funds advised by WBIM) in your account, you are subject to the William Blair Funds’ internal management fees and other expenses (as described below); however, we do not charge our investment management fee in addition to the William Blair Funds’ internal management fee. Instead, we exclude the assets invested in the William Blair Funds when we calculate the investment management fees we charge you, unless no internal management fee is charged by William Blair Funds, in which case William Blair will compensate WBIM up to 0.35% of the investment management fee charged by William Blair. Our affiliate, WBIM, compensates William Blair (and, in turn, PWM Advisors) up to 0.35% on PWM’s clients’ assets invested in the William Blair Funds. Receipt of, or the prospect of receiving, this compensation influences William Blair and PWM Advisors to recommend or invest client assets in the William Blair Funds over unaffiliated funds and creates a conflict of interest. If the payment William Blair receives from WBIM is higher than the fee it receives from the client for managing the account, then William Blair’s overall fee will increase as the allocation to the William Blair Funds increases. For more information on conflicts of interest, please discuss with your PWM Advisor and see documents including, but not limited to, this Brochure, Form CRS, advisory agreements, the William Blair Funds’ prospectus and other offering documents, separate account opening documentation and/or separate disclosure documents. Share Class Selection As noted above, investment in a mutual fund is subject to certain internal fees and expenses, such as advisory, administrative, custody and other fees and expenses charged by the fund, which shareholders bear on a pro rata basis. Mutual funds offer a variety of share classes, which hold the same portfolio securities but differ in total cost due to the William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 11  imposition of various fees (such as 12b-1 fees, sub-transfer agency and shareholder services fees). A higher cost share class of a particular mutual fund will result in lower investment performance compared to a lower cost share class of the same fund. William Blair does not typically use share classes that charge 12b-1 fees if there is a non-12b-1 share class available. If a 12b-1 share class is used in the future, any such fees paid to William Blair will be rebated to clients. William Blair seeks to purchase or recommend the least costly share class that is available on the relevant custodial platform and for which a client is eligible. Note that there may be other less costly share classes offered by the fund that are not available on the relevant custodial platform. The lowest cost share class available on one custodial platform may not be available on other custodial platforms. William Blair monitors on a periodic basis for the launch and availability of lower cost share classes and will seek to exchange investors into such share classes on a periodic basis following the availability of such lower cost share class; note however that William Blair does not canvass the entire universe of lower cost share classes. William Blair will be able to more expediently identify lower cost share classes and exchange holdings for investors when their accounts are held on the NFS custodial platform as opposed to other custodial platforms. Certain mutual funds will waive eligibility criteria if requested by a financial intermediary, such as an investment adviser. As a general practice, William Blair does not request waivers of the share class criteria set by mutual fund companies even if the prospectus of the fund states that such a waiver is possible. This means that clients generally will not receive the benefit of being able to invest in a lower cost share class that might be obtainable if William Blair were to request a waiver of the criteria set by a fund company to purchase a particular share class. Some mutual funds also charge redemption fees if shares are sold before the designated holding period set forth in a prospectus. William Blair does not reimburse your account for redemption fees even if William Blair, using discretion, caused your shares to be sold before the designated time period set forth in a prospectus. These fees and expenses, including the total net operating expenses of each fund, including the William Blair Funds, are set forth in the applicable prospectus, and, with respect to the William Blair Funds, some of these fees and expenses are paid by the William Blair Funds to William Blair or its affiliates. Clients can obtain more information by reviewing a prospectus for the underlying mutual funds, including the William Blair Funds, or exchange traded funds. As with all investments, you should ask your PWM Advisor why the particular funds held in your advisory account are appropriate for you in consideration of your expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, the amount of the advisory fee charged and how these fees and expenses adversely affect long-term performance. Fees and expenses are exclusive of and in addition to any investment management fees we charge you. As described above, we do not charge our investment management fee in addition to a William Blair Fund’s internal investment management fee. William Blair and its affiliate, WBIM, have contractually agreed to bear some of the operational expenses for many of the William Blair Funds. The extent to which WBIM or William Blair bears these expenses varies by William Blair Fund. Therefore, when negotiating those expenses with third party service providers, WBIM and William Blair have an economic incentive to favor a fee structure that shifts expenses from William Blair Funds for which WBIM or William Blair has a lesser (or no) reimbursement obligation. Further, to the extent William Blair or its affiliates have discretion to allocate client assets among the William Blair Funds, they have an incentive to allocate to the William Blair Funds where WBIM and William Blair have a limited reimbursement obligation. As always, clients have the option to purchase recommended investment products through broker-dealers or agents not affiliated with William Blair and can restrict William Blair Funds in their account. Provision of services to the William Blair Funds by William Blair or its affiliates presents conflicts of interest because we are incented to recommend and invest in the William Blair Funds based on compensation to us or our affiliate. We have an additional conflict of interest because our affiliate, WBIM, compensates us and PWM Advisors to invest our clients’ assets in the William Blair Funds. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 12  • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; • A client can restrict the purchase of William Blair Funds; • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms; and • We offset investment management fees on a client’s assets held in the William Blair Funds (as described more fully above, a fee offset is not applicable if any third party Sub-Manager through a Platform invests your assets in the William Blair Funds). Other Fees and Expenses Related to William Blair Investment Management, LLC Sub-Advisory Accounts If authorized by the client, PWM Advisors may use their discretion to hire our affiliate, WBIM as a sub-adviser. PWM Advisors do not conduct initial or ongoing due diligence on our affiliate, WBIM. With respect to WBIM Sub-Advisory Accounts, we either do not charge our account level investment management fee in addition to what WBIM earns to manage assets in the WBIM Sub-Advisory Account or our account level fee is inclusive of the assets managed by WBIM, in which case WBIM will not separately charge an investment management fee on the assets for which it sub-advises. If we exclude the assets under a WBIM Sub-Advisory Account when we calculate the investment management fees we charge you, WBIM will earn a sub-advisory fee to manage client assets in a WBIM Sub-Advisory Account and will compensate William Blair (and, in turn, PWM Advisors) up to 50% of the sub- advisory fee it earns based on PWM’s clients’ assets managed in WBIM Sub-Advisory Accounts. Receipt of, or the prospect of receiving, this compensation influences William Blair and PWM Advisors to hire its affiliate as a sub- adviser over other third-party managers or Sub-Managers and creates a conflict of interest. If the payment William Blair receives from WBIM is higher than the fee it receives from the client for managing the account, then William Blair’s overall fee will increase as the allocation to a WBIM Sub-Advisory Account increases. For more information on conflicts of interest, please discuss with your PWM Advisor and see documents including, but not limited to, this Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, separate client account opening documentation and/or separate disclosure documents. Hiring our affiliate as a sub-adviser creates a conflict of interest based on compensation we receive from our affiliate, WBIM. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conducts annual training on our Code; • We monitor WBIM Sub-Advisory Accounts to ensure they are consistent with our understanding of the client’s objectives; • A client may refuse to authorize us to hire WBIM as a sub-adviser; • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, separate client account opening documentation and/or separate disclosure forms; and • Where WBIM charges a separate advisory fee for its sub-advisory services, we offset our investment management fees on a client’s assets held in a WBIM Sub-Advisory Account. Fees Related to Bank Deposit Sweep Program Please review the Bank Deposit Sweep Program (the “Program”) Disclosure Document for more information about how the Program works, including limitations, restrictions, interest rates, deposit insurance, how changes are implemented and additional discussion of William Blair’s conflicts of interest. For current interest rates (and fees) applicable to the Program or a copy of the Disclosure Document, please contact your PWM Advisor or click on the following link: https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep-Program.aspx. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 13  William Blair “sweeps” available uninvested cash balances for eligible account types that custody at NFS into deposit accounts at one or more banks participating in our Bank Deposit Sweep Program. The compensation that William Blair receives from the Program is in addition to the account’s advisory fee that you pay (as further described in this Item 5). This means that William Blair earns two layers of fees on the cash balances in your account. William Blair receives significant compensation from your account’s use of the Program. For more information regarding our compensation, see Frequently Asked Questions at https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep- Program.aspx. The Program is a multi-bank program under which uninvested account cash balances are automatically swept into deposit accounts at participating FDIC-insured banks (and in some cases, into shares of a money market mutual fund). Clients earn interest on such deposits (and dividends on investments in a money market mutual fund, where applicable). The Program is made available and administered by NFS, which also earns fees in connection with record keeping and other services provided for the Program. Absent the fees earned by NFS under the Program, NFS would likely charge us higher fees for providing their clearing services. Fees for the Program will typically exceed the interest paid on client deposits. Under the Program, NFS generally contracts with participating banks to make specific amounts of deposit capacities available at certain all-in funding rates, which are typically tied or related to the Federal Funds Rate (or a similar type of metric, composite, index, etc.). Client interest, as well as Program fees (i.e., the compensation received by William Blair and NFS), are paid from the bank’s all-in funding rates. All-in funding rates (generally a percentage applied to average daily program deposits at the bank), may be fixed, variable, subject to capacity and other requirements or a combination thereof. Capacity levels may be subject to minimums and maximums. Contract terms with each participating bank are unique and are expected to change over time. Accordingly, at any given time, participating banks will generally pay different all-in funding rates notwithstanding that interest earned by clients on their sweep deposits will not vary regardless of where their funds are actually swept. Moreover, changes in the Federal Funds Rate (or other applicable factor) will not immediately affect all-in funding rates paid or interest rates offered under the Program. The greater the amount of client deposits held in the Program and the longer such deposits are held, the greater the compensation William Blair and NFS receive. Different banks participating in the Program pay different all-in funding rates (and are subject to different contractual requirements), creating an incentive for NFS to direct Program deposits to banks (through how the Program bank priority list(s) are designed or changed from time to time) that result in William Blair and NFS receiving greater compensation. Both William Blair and NFS receive more compensation with respect to amounts in the Program than with respect to other sweep products. The fees William Blair receives in connection with the Program creates a conflict of interest and incentive to offer and designate the Program as the cash sweep option for client accounts. In addition, the fees William Blair receives in connection with the Program creates a conflict of interest and incentive to recommend you maintain and/or increase cash balances in your Account, as greater cash balances in your Account increase compensation to William Blair under the Program. Banks participating in the Program do not have a duty to provide William Blair clients with the highest interest rates available and will instead seek to pay a lower rate, and a rate that is lower than other options available in the market, including money market mutual funds and most certificates of deposit. Banks have the financial incentive to pay all-in funding rates as low as the market will permit. There is no necessary linkage between rates of interest paid by Program banks and the highest rates available in the market, including any money market mutual fund rates. By comparison, a money market mutual fund generally seeks to achieve the highest rate of return (less fees and expenses) consistent with the fund’s investment objective, which can be found in the fund’s prospectus. The Program operates differently depending on your account type. Program Accounts other than Advisory Individual Retirement Accounts With respect to all eligible account types other than advisory individual retirement accounts, William Blair is responsible for establishing its compensation levels under the Program. Each Program bank will pay William Blair a William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 14  fee equal to a percentage of the average daily deposit balance in each deposit account with the bank. Such fees differ among the participating Banks. The combined total fees that William Blair and NFS can earn will be a maximum of the Federal Funds Target Rate plus 0.25% as determined by the total deposit balances at all of the Program banks over a 12-month rolling period. The higher the compensation received by William Blair and NFS, the less available to pay client interest. William Blair will set its compensation levels for the Program based on prevailing economic and business conditions, which are subject to change at any time. It is expected that the vast majority of the all-in funding rates paid by the banks will be paid to William Blair and NFS as fees. Accordingly, the interest rate clients receive on Program deposits will be lower than the all-in funding rates paid by the banks and will likely be lower than the rate of return on (i) other investment vehicles that are not FDIC-insured, such as money market mutual funds and (ii) bank deposits offered outside of the Program. William Blair may change its compensation levels for the Program and any such reductions or increases may vary between clients. Program Accounts that are Advisory Individual Retirement Accounts With respect to advisory individual retirement accounts (“Advisory IRAs”) in the Program, the Program is made available and administered by NFS and a Program Administrator, which both earn fees in connection with record keeping and other services provided to the Advisory IRAs for the Program. For Advisory IRAs, William Blair receives a level monthly fee for each Advisory IRA participating in the Program (the “Advisory IRA Sweep Fee”). The monthly Advisory IRA Sweep Fee is determined based on the Federal Funds Target Rate expressed as a percentage. The Advisory IRA Sweep Fee schedule is included in the Bank Deposit Sweep Program Disclosure Document, available at https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep-Program.aspx. It is anticipated that William Blair’s Advisory IRA Sweep Fee will be paid from the total amounts paid by Program banks. For Advisory IRAs participating in the Program, William’s Blair’s fees, and those of NFS and the Program Administrator, reduce the interest rates that are credited to Advisory IRAs. As a result, William Blair has a significant incentive and conflict of interest in offering the Program to Advisory IRAs. Ineligible Accounts For accounts that are ineligible to sweep into the Program, William Blair will generally sweep such accounts’ uninvested cash balances into a money market mutual fund (typically offered by your custodian). When we sweep your available cash balance into unaffiliated funds, we charge our investment management fee on your total account assets. If your client account is held in custody at NFS, your available cash balance will be swept into a Fidelity money market mutual fund. FCASH Eligible accounts may also sweep uninvested available cash to FCASH. Offered by NFS, FCASH is a means for holding cash balances. FCASH is not a bank deposit or a money market mutual fund. NFS may, but is not required to, pay interest on the balances held in FCASH. Current interest rates on FCASH can be found at https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep-Program/Interest-Rate-Tiers. Note that like any cash held in or through a securities account, FCASH is protected by the Securities Investor Protection Corporation (“SIPC”), up to applicable limits. Free Credit Interest NFS benefits from deposits and credits in advisory client accounts before cash balances are invested or swept into a sweep vehicle (usually the next business day). This benefit, “free credit interest,” is in the form of income at the prevailing market rates on overnight investments averaging 0.01%. A portion of this free credit interest is retained by NFS and a portion is credited to our advisory client. Separate Accounts We charge investment management fees for separate accounts as described herein. Fees are negotiable. We, in our sole discretion, may waive or reduce the management fee schedules for clients who are members, employees or William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 15  affiliates of William Blair, relatives of such persons, certain large or strategic investors, and in certain other limited circumstances. William Blair may, but is not obligated to, aggregate assets under management across multiple accounts when determining the amount of advisory fee charged to these accounts. For clients’ accounts managed by PWM, we charge up to a 2.00% fee on all assets, subject to negotiation. These annual fees are generally payable quarterly in advance, based on the appraised total market value of the account(s) including accrued interest and dividends but excluding the then current balance invested in any William Blair Funds, Blair Private Funds, WBIM Sub-Advisory Accounts, WBIM Separate Accounts, William Blair Managed MB Investments, any assets agreed to by the client and William Blair to be held in the account as an accommodation and not subject to supervision will be excluded from the calculation of the advisory fee and as described in the investment advisory agreement. Notwithstanding the foregoing and as previously noted in this Brochure, in certain instances the calculation of the advisory fee paid to William Blair will include the assets held in or through a WBIM Sub-Advisory Account, provided that WBIM does not charge a separate advisory fee to the client for its sub-advisory services. Comprehensive Fee/William Blair Wrap Fee Program For clients with a Comprehensive Fee (“William Blair Wrap Fee Program”) investment advisory agreement, William Blair charges up to a 2.00% fee on all assets in a William Blair Wrap Fee Program account, subject to negotiation. William Blair generally acts as the introducing broker-dealer and executes trades for accounts in the William Blair Wrap Fee Program with NFS as described above, which includes most of our high-net-worth clients. In limited instances, we also may trade with third party broker-dealers. For more information regarding William Blair’s obligation to seek best execution, see Item 12. Under a Comprehensive Fee investment advisory agreement, you do not pay separately for commissions for each trade executed in your account. Instead, we incur the cost of executing securities transactions in your account. This creates a conflict of interest because William Blair is incented to initiate fewer trades in your account to minimize expenses for William Blair. To manage this conflict of interest, we monitor account activity to help identify inactivity and ensure that trading levels are consistent with a client’s investment objectives and risk tolerance. Where William Blair has discretion to select Sub-Managers, PWM clients’ statements will either reflect a separate Platform provider fee that reflects the costs to access the Platform and pay each Sub-Manager, or the Platform provider fee and Sub-Manager fee will be deducted from the account level advisory fee, depending on the investment advisory agreement with the client. With respect to transactions in a WBIM Sub-Advisory Account, trades are not executed with William Blair as the introducing broker and NFS as the clearing broker. Therefore, clients will incur brokerage costs. As such, Sub-Managers who trade away from William Blair and WBIM Sub-Advisory Accounts are not part of the William Blair Wrap Fee Program. For fee information associated with William Blair Wrap Fee Program client accounts, please see our Wrap Fee Brochure as well as your investment advisory agreement. Other Advisory Services For certain clients, William Blair provides non-discretionary investment advisory services to clients (including registered investment advisers under the Non-Discretionary Model Portfolio Program) for a fee. These non- discretionary advisory services include but are not limited to: recommending the purchase and sale of securities; monitoring the performance of third party managers; recommending unaffiliated investment advisers that are otherwise not available on the Platform Provider; and/or aggregated and consolidated reporting on client assets, including asset allocation advice, investment policy statement monitoring, and performance reporting. For the outlined non-discretionary advisory services, we charge a flat fee or an asset-based fee, subject to negotiation. With respect to the Non-Discretionary Model Portfolio Program, William Blair provides investment recommendations to other registered investment advisers, including some in whom William Blair and / or its partners may own a minority interest. These registered investment advisers pay us advisory fees based on their clients’ total assets following a model portfolio. William Blair’s interest in these investment advisers, particularly those in which William Blair and / or its partners own a minority interest, creates a conflict of interest that William Blair would provide them William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 16  with investment recommendations in advance of other clients. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conducts annual training on our Code; • We maintain an equity trade rotation process where transactions in William Blair’s discretionary account clients following a model portfolio are effected in the first tier; and only after all such transactions are executed and complete, investment recommendations will be disseminated to investment advisers in the Non-Discretionary Model Portfolio Program; and • We monitor transactions in our discretionary client accounts following a model portfolio as well as investment recommendations provided to investment advisers in the Non-Discretionary Model Portfolio Program for compliance with our equity trade rotation process. In some instances, PWM Advisors may recommend to certain clients that they establish a separate investment advisory account managed by our affiliate, WBIM. (“WBIM Separate Accounts”). William Blair and PWM Advisors do not conduct initial or ongoing due diligence on our affiliate, WBIM. In these instances, PWM’s clients are free to accept or reject our recommendation. If a PWM client accepts our recommendation, the client would enter into a separate investment advisory agreement with WBIM setting forth all fees (including an investment management fee) and expenses (including execution costs). When we recommend that our PWM client hires our affiliate, we do not charge our account level investment management fee in addition to what WBIM charges to manage assets in the WBIM Separate Account. Instead, we exclude the assets in a WBIM Separate Account when we calculate the investment management fees we charge you. However, our affiliate, WBIM compensates William Blair (and, in turn, PWM Advisors) up to 50% of the management fee it earns based on PWM’s clients’ assets invested in WBIM Separate Accounts. Receipt of, or the prospect of receiving, this compensation influences William Blair and PWM Advisors to recommend that you open a WBIM Separate Account instead of hiring an unaffiliated investment adviser and creates a conflict of interest. If the payment William Blair receives from WBIM is higher than the fee it receives from the client for managing the account, then William Blair’s overall fee will increase as the allocation to a WBIM Separate Account increases. In certain cases, where our affiliate does not charge a separate fee, assets managed by that affiliate will be included in our fee, and we will compensate our affiliate up to 50% of fee that is based on the amount of assets managed by that affiliate. For more information regarding conflicts of interest, please discuss with your PWM Advisor and see documents including, but not limited to, this Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, separate client account opening documentation and/or separate disclosure forms. Recommendations to open a WBIM Separate Account creates a conflict of interest based on compensation we receive from our affiliate, WBIM. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We monitor WBIM Separate Accounts to ensure they are consistent with our understanding of the client’s objectives; • A client may decline our recommendation to open a WBIM Separate Account; • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, separate client account opening documentation and/or separate disclosure forms; and • We offset our investment management fees on a client’s assets held in a WBIM Separate Account, where a separate management fee is charged by WBIM. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Performance-Based Fees William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 17  William Blair does not offer performance-based fee arrangements to clients. As discussed above, , William Blair’s affiliate, the MB General Partner, may earn a performance-based fee for MB Partnership Series, if applicable. As more fully described in any applicable offering documents, the MB General Partner will be entitled to a portion of the profits of the limited partnership as “carried interest.” The amount of the performance-based fee and how it is calculated is fully disclosed in the applicable MB Partnership offering document. The amount of the performance-based fee may vary by MB Partnership Series. Carried interest, where applicable, is indirectly borne by limited partners who are not affiliated with the MB General Partner and/or William Blair. Limited partners should understand that the receipt of performance-based fees creates a conflict of interest as the MB General Partner has the potential to receive higher compensation. Performance-based fees creates an incentive for the MB General Partner to pursue riskier or more speculative investments than might otherwise be the case in the absence of such arrangement. Additionally, the payment by some MB Partnership Series, but not all MB Partnership Series, or the payment of carried interest at varying rates creates an incentive for the MB General Partner to disproportionately allocate time, services, functions or investment opportunities to those MB Partnership Series paying carried interest or paying carried interest at a higher rate. The MB General Partner seeks to mitigate these conflicts through disclosures in this Brochure; additional disclosures in the applicable offering documents as well as policies and procedures, including allocation of investment opportunities. Side-by-Side Management of Multiple Portfolios William Blair typically makes investment decisions for multiple portfolios using various investment strategies depending upon clients’ guidelines and restrictions. Some of these same investment strategies serve as the basis for the Non-Discretionary Model Portfolio Program. In addition, according to a client’s investment objectives and subject to reasonable restrictions, a PWM Advisor may elect to allocate all or a portion of a discretionary advisory client’s assets to one or more William Blair’s Proprietary Home Office Models. In connection with the MB Investments Partnership, William Blair and the MB General Partner will encounter situations in which it must determine how to allocate investment opportunities. When an opportunity is identified, William Blair will make a good faith determination to present such investment opportunity to: (1) the MB Partnership, (2) other investment vehicles utilized by partners and employees of William Blair to make investments in privately held companies, or (3) participants in the MB Partnership as co-investors. Such good faith determination is based on several factors including, but not limited to, the source of origination. The MB Partnership will not be presented with every investment opportunity. In addition, the application of William Blair’s investment allocation methodology will often result in the MB Partnership receiving an allocation on a non-pro rata basis. These investment management responsibilities create conflicts of interest. We seek to conduct ourselves in a manner we consider to be the most fair and consistent with our fiduciary obligations to our clients and make investment decisions and recommendations based on an account’s available cash, investment objectives, restrictions, permitted investment techniques and other relevant considerations. With respect to privately held investment opportunities, William Blair has adopted written policies and procedures that will not favor or disfavor, consistently or consciously, other investment vehicles utilized by partners and employees over the MB Partnership or other clients. The conflicts of interest that arise in managing multiple accounts include, for example, conflicts among investment strategies, conflicts in allocation of trades, conflicts in the allocation of investment opportunities (including MB Investments), conflicts based on account type, or conflicts due to different fees. Some accounts have higher fees than others. Fees charged to clients differ depending upon a number of factors including, but not limited to, the particular strategy, the size of the portfolio being managed, the relationship with the client, the service requirements, or the account type (e.g., separately managed accounts and wrap accounts). Based on these factors, a client could pay higher fees than another client with the same PWM Advisor or in the same strategy. Also, clients with larger assets under management generate more revenue for William Blair than smaller accounts. These differences give rise to a conflict that a PWM Advisor may favor one account over the other or allocate more time to the management of one account over another. To help manage conflicts, we have implemented various controls, including the following: William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 18  • We review the performance of accounts to identify performance outliers; • For accounts managed according to strategy-based model portfolios, we confirm differences relative to account- specific guidelines; and • We have adopted trade order aggregation, trade allocation and MB Investment allocation policy and procedures that seek to manage, monitor and, to the extent possible, minimize the effects of these conflicts. ITEM 7 – TYPES OF CLIENTS William Blair provides investment advisory and management services to a number of clients including high net worth clients, individuals, small institutions, William Blair Wrap Program clients and registered investment advisers following our Non-Discretionary Model Portfolio Program. In addition, William Blair provides investment management services to the MB Partnership (subject to the direction and control of its affiliate, the MB General Partner) and not individually to any limited partner. Investment Minimums For discretionary accounts, William Blair generally requests minimums as described below: Account Type/Relationship Minimum $2 million $50,000 $100,000 WBIM Sub-Advisory/WBIM Separate Accounts PWM Non-Wrap Program Accounts William Blair Wrap Program Accounts Platform Separate Accounts* $100,000 *Certain third-party managers may be higher. We reserve the right to accept accounts below our stated minimums. We also accept lesser amounts for accounts in separately managed account programs sponsored by unaffiliated intermediaries (e.g., wrap programs). Private fund investment minimums vary by fund (including Blair Private Funds and MB Partnership Series), however the managing member or general partner may, in its sole discretion, permit investments below the minimum amount set forth in each respective offering document. Interests in the Blair Private Funds and the MB Partnership are offered to “qualified purchasers” as defined under the Investment Company Act of 1940 or as a “qualified client” under the Advisers Act. In addition to these investor qualification requirements, in order to participate in the William Blair MB Investments Program, a client typically maintains $25 million in assets with William Blair. Redemption Limitations for Investments in Private Funds Unless otherwise noted in any underlying private fund offering document, investors in private funds typically redeem all or a portion of their investments from the private fund with limited frequency and upon prior written notice as specified in the applicable offering document. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis William Blair is an active investment manager and utilizes a variety of methods and strategies to make investment decisions and recommendations. When evaluating investment opportunities, we employ fundamental and technical William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 19  research methods using various resources such as financial news sources and websites; corporate data; ratings services; third party research; SEC filings (e.g., annual reports, prospectuses); company press releases; and proprietary research. The following describes our principal investment strategies as of the date of this Brochure. Descriptions of strategies are qualified in their entirety by reference to the applicable investment advisory agreement and related investment guidelines as well as by the applicable prospectus and statement of additional information for mutual fund investments and offering documents for private fund investments. 1. Private Wealth Management Investment Strategies William Blair offers custom wealth management based on each client’s individual needs and objectives. In choosing investments for clients, we consider a broad array of securities and investment vehicles, including but not limited to: common stocks, corporate, government and municipal fixed income securities, affiliated and unaffiliated mutual funds, private funds and money market funds. In addition, for certain clients, we have discretion to hire Sub- Managers through Platforms or WBIM as sub-adviser. 2. William Blair Platform Strategies For certain clients that have given us discretion, PWM Advisors select Sub-Managers based on each client’s unique objectives, risk tolerance and financial profile and provide ongoing advice to clients. We emphasize asset allocation to help manage risk and return in portfolios. PWM Advisors access Sub-Managers through Platforms. In our investment process, we seek Sub-Managers who meet the Platforms’ initial and ongoing due diligence standards for manager selection evaluation, as well as management style and performance track record. In most instances, William Blair does not independently conduct due diligence on Sub-Managers available on the Platforms. In addition, certain clients authorize us to hire our affiliate, WBIM as a sub-adviser. In other instances, we recommend that a client establish a WBIM Separate Account. We hire our affiliate as a sub-adviser or recommend our affiliate as an adviser in instances where a WBIM strategy meets a client’s unique objectives, risk tolerance and financial profile. We do not conduct any initial or ongoing due diligence on WBIM. Clients are provided the applicable Platform providers’, Sub-Managers’ and/or WBIM’s Form ADV Part 2A. 3. Private Fund Investments Based on each client’s individual needs and objectives, William Blair may recommend that the client invest in affiliated or unaffiliated private funds. Our investment process before recommending an unaffiliated private fund typically includes investment and due diligence reviews, including assessment of relevant investment and operational factors. As part of our investment process, we either conduct initial and ongoing due diligence internally and/or by employing external consulting and research resources. For private fund investments that are offered through certain external alternative investment platforms, we rely upon research and due diligence processes and materials developed by the third-party platform providers. The third-party platform provider relies either on proprietary research resources of the third-party platform or consultants employed by the third-party platform. We do not conduct independent initial or ongoing due diligence on unaffiliated private funds accessed through the third-party platforms. We do not conduct any initial or ongoing due diligence on Blair Private Funds. With respect to the MB Investments Program, William Blair does not make any recommendations to clients regarding participation in the MB Investments Program or investing in a MB Partnership Series. However, the MB General Partner (or an affiliate, including William Blair) does conduct initial due diligence on the underlying investment opportunities. For example, the MB General Partner (or an affiliate, including William Blair) either conducts initial due diligence internally and/or employs external due diligence consulting and research resources when assessing relevant investment and operational factors related to potential MB investment opportunities. No initial or ongoing due diligence is conducted on William Blair Managed MB Investments. RISK OF LOSS All investments in securities involve a risk of loss of your principal (invested amount) and any profits that have not been realized (i.e., the securities have not been sold to "lock in" the profit). The value of securities in an account can go up or down, sometimes rapidly or unpredictably. Local, regional or global events such as war, acts of terrorism, the William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 20  spread of infectious illness or other public health issue, recessions or other events could have a significant impact on the valuation of securities. Securities may decline in value due to factors affecting securities markets in general or particular industries represented in the securities markets. The value of a security may decline due to general market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. The value of a security may also decline due to factors that affect a particular industry or industries, such as labor shortages or increased production costs and competitive conditions within an industry. During a general downturn in securities markets, including those unrelated to financial markets (such as a global pandemic), multiple asset classes may decline in value simultaneously. If an Account is not diversified, a loss in a single position or group of positions with a concentrated, aggregate exposure could have a materially adverse impact on an Account. In addition, if you enter into securities lending, margin and/or non-purpose loans arrangements, there are additional risks to your principal, as more fully described in separate account documentation. There is no guarantee that any investment strategy will achieve its stated investment objectives. William Blair cannot guarantee any level of performance or that you will not experience a loss of account assets. Common Risks Associated with Equity Investments Investments in equity securities can expose you to certain specific risks such as the following: • Equity securities. Equity securities (stocks) held in your portfolio may decrease in response to activities of companies or market and economic conditions. • Growth stocks. Growth stocks may be more sensitive to market movements because their prices tend to reflect future investor expectations rather than just current profits and may underperform value stocks during given periods. • Value stocks. Value stocks may perform differently from the market as a whole and may be undervalued by the market for a long period of time and may underperform growth stocks during given periods. • Small-capitalization companies. Small cap stocks may exhibit erratic earnings patterns, competitive conditions, limited earnings history, and a reliance on one or a limited number of products. • Initial public offerings. Initial public offerings (IPOs) are subject to high volatility and limited availability. • Private placements. Private placements may be classified as illiquid and difficult to value. • Options. Purchasing options involves the risk that the underlying instrument will not change price in the manner expected, so an investor loses their premium. Selling options involves potentially greater risk because the investor is exposed to the extent of the actual price movement in the underlying security, which could result in a potentially unlimited loss. • ESG Investing. Portfolios that select securities based on Environmental, Social and Governance (“ESG”) factors or similar criteria may forgo certain market opportunities available to portfolios or strategies that do not use these criteria.. In this regard, the strategy will be precluded from purchasing, or required to sell, certain investments that otherwise meet its objective and strategy and that might otherwise be advantageous to hold. The application of the ESG factors could result in performance that is better or worse than the performance of a similar strategy, depending on the performance of the excluded investments and the investments included in place of such excluded investments. Integrating ESG analysis into investment decisions requires qualitative determinations and is often subjective by nature, and there can be no assurance that the process utilized, or any judgment exercised by William Blair, will operate as expected when addressing positive environmental or social benefits. Common Risks Associated with Non-U.S. Investments Investments in non-U.S. securities can expose you to certain specific risks, including risks associated with equity investments previously described above, as well as the following: William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 21  • Current market conditions. In recent years, debt and equity markets, domestic and international, have experienced increased volatility and turmoil, which can adversely impact your portfolio. • Liquidity in financial markets. The financial markets in the U.S. and elsewhere have experienced a variety of difficulties and changed economic conditions, which could adversely impact the value of your portfolio’s assets. • Government intervention and market disruptions. The global financial markets have undergone fundamental disruptions that have led to extensive and unprecedented government intervention that could prove detrimental to the efficient functioning of the markets and adversely impacting your portfolio. • International markets. International markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. • International securities. International stocks are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. • Emerging markets. Securities traded in certain emerging markets may be subject to risks due to the inexperience of financial intermediaries, the lack of modern technology, the lack of a sufficient capital base to expand business operations, and the possibility of temporary or permanent termination of trading. Political and economic structures in many emerging markets may be undergoing significant evolution and rapid development, and emerging markets may lack the social, political and economic stability characteristics of more developed countries. • International currency markets. Investments in international securities expose a portfolio to fluctuations in currency exchange rates, which may adversely affect the value of investments in international securities held in your portfolio. • Currency risks. Investments denominated in an international currency are subject to the risk that the value of a particular currency will change in relation to one or more currencies. Common Risks Associated with Fixed Income Investments Investments in fixed income securities can expose you to certain specific risks such as the following: • Credit risk. Fixed income securities (bonds) are subject to the risk that the bond issuers may not be able to meet interest or principal payments when the bonds come due. • Below investment grade rated securities. Below investment grade bonds are subject to a higher probability that the issuers may not be able to meet payment of interest or principal on a timely basis or at all. These securities also may be less liquid than investment grade securities and experience higher price volatility. It may not be possible to sell these securities at the desired price and within a given time period. • High yield securities. High yield securities are rated in the lower rating categories by the various credit agencies and are subject to greater risk of loss of principal and interest than higher rated securities. High yield securities generally are considered predominantly speculative with respect to the issuer’s capacity to pay interest and repay principal. • Interest rates. Interest rates may adversely affect the value of an investment. An increase in interest rates typically causes the value of bonds and other fixed income securities to fall. Interest rates continue to be at historic lows. Investments with longer maturities, which typically provide higher yields than securities with shorter maturities, may subject a portfolio to increased price changes resulting from market yield fluctuations. Under extreme circumstances, a substantial decrease in interest rates may lead to a negative yield on investments. • Income risk. The income received by a portfolio may decrease as a result of a decline in interest rates. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 22  • Prepayment risk. There is a risk of prepayment in mortgage- and asset-backed securities. This risk arises when market interest rates are below the interest rates charged on the loans that comprise the securities. Elevated prepayment activity may result in losses in these securities. • Liquidity risk. Investments that trade less can be more difficult or more costly to buy, or to sell, than more liquid or active investments. It may not be possible to sell or otherwise dispose of illiquid securities both at the price and within a time period deemed desirable. Securities subject to liquidity risk include emerging market securities, below investment grade securities and other securities without an established market. Common Risks Associated with Alternative Investments Investments in alternatives investment strategies including structured notes can expose you to certain specific risks, including risks associated with equity and fixed income investments (in the U.S. and Non-U.S. investments) previously described above, as well as the following: • Derivative securities. Derivatives may be difficult to value, may be illiquid and may be subject to wide swings in valuation caused by changes in value of the underlying security. The use of derivatives can result in losses that substantially exceed the initial amount paid or received. • Short sales. A short sale involves the risk of a theoretically unlimited increase in the market price of a security sold short, which could result in an inability to cover the short position and a theoretical unlimited loss. • Commodity and futures contracts. Commodities futures markets (including financial futures) are highly volatile and are influenced by factors such as changing supply and demand, governmental programs and policies, national and international political and economic events and changes in interest rates. A high degree of leverage is typical in commodities futures trading, and as a result, a relatively small price movement may result in substantial losses. • Leverage. The use of borrowing (leverage) exposes an investor to additional levels of risk including greater losses from investments than would otherwise have been the case without borrowing; margin calls or changes in margin requirements may force premature liquidations of investments; and losses on investments where the investment fails to earn a return that equals or exceeds the cost of the leverage. • Lack of diversification. The portfolio may not generally be as diversified as other investment vehicles. Accordingly, investments may be subject to more rapid change in value than would be the case if the portfolio maintained a wide diversification among types of securities, geographical areas, issuers and industries. Accordingly, a loss in a single position could have a materially adverse impact on a portfolio. • Liquidity. A portfolio’s assets may, at any given time, include securities and other financial instruments or obligations that are thinly traded or for which no market exists and/or which are restricted as to their transferability under applicable securities laws. The sale of any such investments may be possible only at substantial discounts, and it may be extremely difficult to value accurately any such investments. • Event-driven trading. Event-driven trading involves the risk that the event identified may not occur as anticipated or may not have the anticipated effect, which may result in a negative impact upon the market price of securities held in the portfolio. Common Risks Associated with Sub-Managers Investments utilizing Sub-Managers, WBIM Sub-Advisory Accounts and WBIM Separate Accounts are subject to risks depending upon the strategy and types of securities employed by the third party and/or affiliated investment manager. William Blair selects Sub-Managers or hires or recommends its affiliate, WBIM, based on, among other things, the client’s investment objectives and the Sub-Managers’ and WBIM’s management style and performance track record. However, past performance is not a guarantee of future results. In addition, William Blair does not have any influence over the Sub-Manager’sor WBIM’s investment decisions or securities selections. In most instances, William Blair does not independently conduct due diligence on Sub-Managers.. There is a risk that the Platforms do not conduct adequate initial and ongoing due diligence on Sub-Managers and. William Blair and WBIM are affiliates and WBIM is not subject to the same level of due diligence as unaffiliated Sub-Managers. As disclosed throughout, William Blair has a conflict of interest when hiring WBIM as a sub-adviser, recommending a WBIM Separate Account William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 23  or any product managed by WBIM. Please refer to this Brochure for information as to how William Blair manages this conflict of interest. As with all investments, investment strategies employed by Sub-Managers (including our affiliate, WBIM) may fail to produce the intended results. Common Risks Associated with Private Funds Investors in private funds must be prepared to bear the risk of a complete loss of their investments. In addition to the material risks affecting financial markets generally (as described above), investments in affiliated and unaffiliated private funds include but are not limited to the following specific risks: • Long-Term Investment; Illiquidity of Investments. Unlike liquid investments, private fund investments do not provide daily liquidity or pricing. In fact, investment in certain private funds (including the MB Partnership) requires a long-term commitment, with limited or no liquidity opportunities and no certainty of return. The return of capital and the realization of gains and other income, if any, from an investment may not occur until several years after such investment is made, if at all. Given that certain private funds are expected to operate over several years, substantial changes to the business, economic, political, and regulatory and technology environment may have a more profound effect on private fund investments. • Limited Transferability of Interests. Certain private funds (including the MB Partnership and Blair Private Funds) and applicable securities laws impose substantial restrictions upon the transferability of private fund interests. There is no public market or other market for most private fund interests. • Valuation. The underlying investments in certain private funds consists of significant amounts of securities and other financial instruments that are very thinly traded, or for which no market exists, or which are restricted as to their transferability. As discussed above, William Blair relies on the issuers, custodians and other third parties to provide a good faith, fair market value with respect to interests in private funds. With respect to the MB Partnership, there is no actively traded market for the securities issued by each MB Partnership Series. The MB General Partner will apply a fair value methodology based on their best judgment and that is appropriate considering the nature, facts and circumstances of each MB Investment. The process of valuing securities for which reliable market quotations are not readily available is based on inherent uncertainties and likely results in values that would differ had an active market existed for such securities. The good faith fair market value determinations for Interests in a MB Partnership Series will most likely differ from the value of such securities when ultimately sold. To the extent that the MB General Partner or William Blair’s interests are not fully aligned with those of the MB Partnership’s limited partners, conflicts of interest with respect to valuations of interests in MB Partnership Series will arise. As discussed above, William Blair charges an advisory fee based on the fair market value of unaffiliated private fund interests held in advisory accounts. In addition, as William Blair earns an asset based advisory fee on MB Partnership Interests and the fair market value of these Interests are determined, in good faith, by the MB General Partner, a conflict of interest exists to increase the fair market value of these Interests. In addition to disclosing this conflict of interest, the MB Partnership has in place written, valuation policies and procedures. • Limited Operating History. Certain private funds have limited operating histories and there can be no assurance that the private funds’ investments will achieve results similar to those achieved by previous investments (including performance of predecessor private funds). • Competition. The activity of opportunistically identifying, completing and realizing attractive investments is highly competitive and involves a high degree of uncertainty. Private funds will be competing with other established funds and investment organizations with substantial resources and experience. • Limited Number of Investments/Lack of Diversity. Except as set forth in each private fund’s offering documents, private funds are under no obligation to diversify its investments, whether by reference to amount invested or industries or geographical areas in which the investments are made. Accordingly, private funds participate in a limited number of investments and, as a consequence, the aggregate return of any private fund may be substantially adversely affected by the unfavorable performance of even a single investment. • Investing in a Single Issuer. Unlike a typical private equity fund or fund-of-funds, which are intended to invest in a variety of portfolio companies and/or portfolio funds, a MB Partnership Series is expected to invest exclusively William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 24  in a single MB Investment. This approach carries a number of risks and special considerations not associated with typical private equity funds or funds-of-funds, including: no benefits of portfolio diversification; performance will be determined exclusively by the performance of the MB Investment; performance will be burdened by the costs and procedures associated with the formation, management, operation, dissolution and liquidation of the MB Partnership Series; and susceptibility to idiosyncratic risks associated with the MB Investment such as death or incapacity of a key officer or manager or possibility of fraud and other misconduct by its employees and service providers. The common risks of loss described in this section are intended as a high-level overview. Please see other disclosure documents for a complete discussion of the risks attributable to an individual investment including, but not limited to, prospectuses, private placement memorandum and structured note, margin and option documentation. ITEM 9 – DISCIPLINARY INFORMATION William Blair & Company L.L.C. and WBIM (collectively for purposes of this paragraph, William Blair) have entered into a settlement with the SEC in connection with the agency’s industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement requires William Blair to pay a civil monetary penalty of $10,000,000 and retain a compliance consultant for a period of one year, following the format for all other recent electronic communications settlements. William Blair cooperated with the government’s inquiry and has already taken significant steps to further strengthen the firm’s compliance environment as it relates to electronic communications. In May 2017, the SEC found that from 2010 until 2014, as a result of erroneous payments, William Blair negligently used mutual fund assets to pay for (i) distribution and marketing of fund shares outside of a written, board-approved rule 12b-1 plan and (ii) sub-transfer agent ("Sub-TA") services in excess of board-approved limits. These payments totaled approximately $1.25 million and rendered certain of William Blair Funds' disclosures concerning payments for distribution and Sub-TA services inaccurate. As a result of this conduct, the SEC found that William Blair violated Section 206(2) of the Investment Advisers Act and Section 34(b) of the Investment Company Act, and caused the William Blair Funds to violate Section 12(b) of the Investment Company Act and Rule 12b-1 thereunder. The SEC alleged that William Blair also failed to fully disclose to the William Blair Funds' Board of Trustees that William Blair (and not a third-party service provider) would retain a fee for providing shareholder administration services to the William Blair Funds under a shareholder administration services agreement between certain of the Funds and William Blair. As a result of this conduct, William Blair violated Section 206(2) of the Investment Advisers Act. Without admitting or denying the findings, except as to the SEC's jurisdiction over it and the subject matter of these proceedings, which are admitted, William Blair consented to the entry of an order instituting cease-and-desist proceedings, pursuant to Section 203(k) of the Investment Advisers Act and Section 9(f) of the Investment Company Act, making findings, and imposing a cease-and-desist order. William Blair also was assessed by the SEC a civil money penalty in the amount of $4,500,000. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS William Blair Funds Our affiliate, WBIM, is an investment adviser and manager, and William Blair is distributor for the William Blair Funds. William Blair and WBIM are paid by the William Blair Funds for the services they each provide. As investment adviser and manager, WBIM manages the William Blair Funds’ investments, administers their business affairs, furnishes office facilities and equipment, provides clerical, bookkeeping and administrative services, and provides shareholder and information services. Partners and employees of William Blair and WBIM can serve (without compensation) as trustees or officers of the William Blair Funds if elected to such positions. As of December 31, 2024, investment management fees paid by the William Blair Funds ranged from 0.60% to 1.10% for all share classes. In addition to an investment management fee, each William Blair Fund pays the expenses of its operations, including a portion of the William Blair Funds’ general administrative expenses, allocated based on each Fund’s net assets. As of December 31, 2024, WBIM advised approximately $12.5 billion in assets for the William Blair Funds. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 25  PWM Advisors have discretion to buy and sell mutual funds, including the William Blair Funds, in their clients’ accounts and receive asset-based investment management fees. Clients can exclude the purchase of William Blair Funds in their accounts. As the William Blair Funds’ principal distributor, we also receive fees from the sale of William Blair Fund shares. As discussed above, our affiliate, William Blair Investment Management LLC, compensates us up to 0.35% of our clients’ assets invested in William Blair Funds. These circumstances create a conflict of interest because we are incented to purchase or recommend the purchase of affiliated mutual funds over other types of investments or funds. To help manage any conflict, we have implemented controls, including the following: • We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code; • We monitor client portfolios to ensure they are consistent with each client’s objectives and investment strategy; • At account opening, we typically solicit client consent to invest in affiliated mutual funds; • WBIM Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, William Blair Funds’ prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms; and • We offset investment management fees on a client’s assets held in affiliated mutual funds. Please also refer to the William Blair Funds’ prospectuses and statements of additional information, which are available at www.williamblairfunds.com or by calling 1-800-742-7272. Investment Adviser/Sub-Adviser for Other Pooled Funds Our affiliate, WBIM, serves as investment adviser or sub-adviser to other pooled funds including other U.S. mutual funds, Canadian trusts/funds, Australian trusts/funds, collective investment trusts, and UCITS 1 and receives investment management fees as described in WBIM’s Form ADV Part 2A. With respect to these types of pooled funds where our affiliate serves as investment adviser or sub-adviser, WBIM compensates us up to 0.35% of our clients’ assets invested in the pooled fund. Similar to the William Blair Funds, a conflict of interest exists as we are incented to purchase or recommend these pooled funds for purchase by our investment management clients over unaffiliated pooled funds. To help manage conflicts, we have implemented controls, including the following: • We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code; • We monitor client portfolios to ensure they are consistent with each client’s objectives and investment strategy; • We typically solicit client consent to invest in affiliated pooled vehicles; • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms; and • We offset investment management fees on a client’s assets held in affiliated pooled vehicles. Blair Private Funds Our affiliate, WBIM, is the investment manager to a number of limited partnerships and limited liability companies, which are Blair Private Funds that are structured as hedge funds, funds-of-hedge funds, multi-advisor commodity pools or other pooled investment vehicles. These Blair Private Funds are offered only to accredited investors, qualified purchasers or qualified eligible persons. When we recommend the purchase of Blair Private Funds, we have a conflict of interest because we receive compensation from our affiliate, WBIM, based on the amount of assets invested in the Blair Private Funds. This creates conflicts of interest because we are incented to recommend these securities for clients over other suitable investment options. 1 William Blair has been appointed global distributor of the William Blair SICAV. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 26  To help manage conflicts of interest, we make these investments available solely to certain William Blair partners and employees as well as select eligible investors. Because our affiliate, WBIM can receive performance fees for certain Blair Private Funds, our affiliate is incented to favor these accounts over other clients’ accounts; however, this incentive is mitigated by the illiquid nature of these investments. We have implemented controls, including the following: • We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code; • We offset investment management fees on a client’s assets held in Blair Private Funds; Conflicts of interest are disclosed in Blair Private Funds’ offering documents; • • A client may decline our recommendation with respect to Blair Private Funds; • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, private fund offering documents, separate client account opening documentation and/or separate disclosure forms; and • We monitor client portfolios to ensure they are consistent with each client’s objectives and investment strategy. WBIM Separate Accounts and WBIM Sub-Advisory Accounts Our affiliate, WBIM, manages a number of domestic and international fixed income, equity and alternative investment strategies. With respect to any recommendation that our PWM clients open a WBIM Separate Account or in instances where a client has authorized us to hire WBIM as a sub-adviser, we have a conflict of interest because we receive compensation from our affiliate, WBIM, based on the amount of assets invested in these WBIM Separate Accounts and, for certain sub-advisory arrangements, WBIM Sub-Advisory Accounts. This creates conflicts of interest because we are incented to recommend these WBIM Separate Accounts or hire WBIM as a sub-Adviser over other third-party managers. To help manage conflicts of interest, we have implemented controls, including the following: • We maintain a written Code, which details our fiduciary duty to clients and conduct annual training on our Code; • We offset investment management fees on a client’s assets held in WBIM Separate Accounts and WBIM Sub- Advisory Accounts, where our affiliate charges a separate management fee; Conflicts of interest are disclosed in this Brochure, Form CRS, and in other documents; • • A client may decline our recommendation with respect to WBIM Separate Accounts; • A client may restrict us from hiring WBIM as a sub-adviser; • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, separate client account opening documentation and/or separate disclosure forms; and • We monitor WBIM Separate Accounts and WBIM Sub-Advisory Accounts to ensure they are consistent with our understanding of the client’s objectives in hiring a third-party manager or sub-advising a portion of their account. Corporate and Executive Services William Blair provides strategic advice and solutions for companies, corporate executives and other registered investment advisers. Examples of these services include the following: Corporate cash management • Cashless stock option exercise Investment banking services Corporate share repurchases • Retirement plans • • • • Directed share programs William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 27  • Restricted stock • Officer and affiliate trading • Other services as deemed coordination and sales programs appropriate Equity risk management • A PWM Advisor will be restricted from trading in a public company’s securities if an executive officer, director or any insider of that company is also a client of the PWM Advisor. This means that clients of that PWM Advisor may experience less favorable performance than others who are clients of other PWM Advisors or financial professionals of other advisory firms who are not similarly restricted. Financial Planning, Consulting and Advisory Services William Blair provides financial planning, consulting and advisory services to high-net-worth individuals and families and works with you to help you determine the services that may be appropriate given your goals and circumstances. We also provide services to foundations, endowments, retirement plans and other registered investment advisers (including SYSTM and those investment advisers where William Blair owns an indirect, minority ownership interest). We may charge a fee for these services that is separate from any investment advisory fees and transaction charges. In other cases, the client is not charged a separate fee for these services. Examples of these services include the following: • Enhanced reporting services, including performance Estate planning • Investment Consulting • Research & Due Diligence • Alternative Investments • Retirement Plans Philanthropic strategies • Asset allocation • Retirement planning • • • Advisory services for foundations and endowments Securities Business In addition to our registration with the SEC as an investment adviser under the Investment Advisers Act of 1940, William Blair also is registered with the SEC as a securities broker-dealer under the Securities Exchange Act of 1934 and is a member of the Financial Industry Regulatory Authority (FINRA). In its broker-dealer capacity, the firm executes securities transactions for clients, underwrites securities, distributes the William Blair Funds, and distributes shares of the William Blair SICAV. These activities present conflicts of interest, as described below and throughout this Brochure. Investment Banking Activities William Blair's Investment Banking Department provides investment banking and financial advisory services to corporate clients. This creates conflicts of interest with our private wealth management clients. In the provision of investment banking services, our employees may come into possession of material, non-public information or other confidential information about a particular company, which if disclosed might affect a person’s decision to buy, sell or hold a company’s securities. The firm maintains policies and procedures as well as physical, technical and logistical controls to mitigate unauthorized access to and/or use of non-public information. Because of these procedures (and related legal requirements), investment decisions related to these securities may be temporarily restricted in your account. In addition, certain MB Investments are generated through William Blair’s proprietary, global relationship network (including our Investment Banking Department). William Blair (including one or more of its affiliated or related entities) and/or the MB General Partner have interests that conflict with the interests of the MB Partnership, one or more MB Partnership limited partners that are also PWM clients, and/or one or more MB Investments. In addition, William Blair’s Investment Banking Department may make referral payments to certain minority-owned investment advisers upon the completion of a successful investment banking transaction. Please see Item 11 below for discussion of material conflicts of interest related to MB Partnership and William Blair’s indirect, minority ownership interest in investment advisers. William Blair is expected to serve as a pipeline for prospective investment opportunities for the MB Partnership, including as a result of William Blair’s proprietary investment banking and other relationships. William Blair earns investment banking and other fees in connection with certain MB Investments, such as substantial investment banking fees related to mergers, acquisitions, add-on acquisitions, refinancings, private placements, public offerings, sales, divestments or other dispositions and similar transactions. In addition, William Blair and its affiliates or one or more William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 28  of its clients, prospective clients, outside members, directors and/or other person or entities with which William Blair and/or its affiliates have a relationship may be control persons or otherwise have a financial interest in MB Investments. Receipt of investment banking and other fees from a MB Investment creates conflicts of interest for William Blair, the MB General Partner and their respective members, affiliates, and employees. If William Blair receives fees (including investment banking fees) in connection with a transaction, the MB General Partner is incentivized to cause the MB Partnership to participate in such transaction. In addition, certain MB Investments may be managed by or related to William Blair as well as to other William Blair clients or referral sources. Management fees, incentive compensation, and any other fee or investment amount that the MB Partnership Series pays to such a MB Investment confers a benefit on William Blair, an affiliate, client or referral source. The payment and receipt of these fees to and from the MB Investments creates a conflict of interest between William Blair and its affiliates and the MB Partnership and its limited partners because the amounts of these other fees are often substantial. Certain Affiliated Investment Strategies and Products In some cases, we believe it is in a client’s best interest to: invest a portion of the client’s portfolio in certain William Blair Funds; hire William Blair Investment Management for a Sub-Advisory Account; recommend a WBIM Separate Account; or recommend or invest in Blair Private Funds. In some instances, a client independently elects to participate in the MB Partnership Program and to invest in a William Blair Managed MB Investment. For example, we may invest in mutual fund shares for smaller accounts in order to achieve greater portfolio diversification that can otherwise be more difficult with fewer assets. We choose to invest in the William Blair Funds, our affiliated mutual funds, primarily because portfolio managers for our affiliate, WBIM, use the same investment strategies they use for institutional separate accounts to manage them. Similarly, we either hire or recommend WBIM for a WBIM Sub-Advisory Account or WBIM Separate Account, respectively, because our affiliate utilizes the same strategies for institutional separate accounts. As discussed above, when we invest in shares of affiliated mutual funds in your account, recommend that you invest in Blair Private Funds or you independently elect to invest in a William Blair Managed MB Investment, you are subject to the William Blair Funds’, Blair Private Funds’ or William Blair Managed MB Investment’s internal management fees and other expenses (as described above); however, we do not charge our investment management fee in addition to the William Blair Fund, Blair Private Fund or William Blair MB Managed Investment internal management fee. Similarly, we do not charge our investment management fee on any client assets in a WBIM Separate Account or, subject to below, a WBIM Sub-Advisory Account. Instead, we exclude the assets invested in the William Blair Funds, Blair Private Funds, William Blair MB Managed Investment, WBIM Sub-Advisory Account or WBIM Separate Account when we calculate the investment management fees we charge you. However, as discussed more fully above, William Blair does receive compensation based on PWM’s clients’ assets in William Blair Funds, Blair Private Funds, William Blair Managed MB Investments, a WBIM Sub-Advisory Account or WBIM Separate Account, creating a conflict of interest. Notwithstanding the foregoing, in certain instances the calculation of the investment management fee paid to William Blair will include the assets held in or through a WBIM Sub-Advisory Account, provided that WBIM does not charge a separate investment management fee to the client for its sub-advisory services. Sell Side Equity Research William Blair’s Equity Research Department provides investment analysis and recommendations of companies across various sectors. This creates conflicts of interest with our private wealth management clients because our employees may come into possession of material, non-public information or other confidential information about a particular company, which if disclosed might affect a person’s decision to buy, sell or hold a company’s securities. The firm maintains policies and procedures as well as physical, technical and logistical controls to mitigate unauthorized access to and/or use of non-public information. Because of these procedures (and related legal requirements), investment decisions related to these securities may be temporarily restricted in your account. In addition, if a PWM Advisor’s William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 29  client purchases William Blair equity research, in some instances, revenue is recognized by the Private Wealth Management Department and the PWM Advisor. The receipt of this compensation creates an incentive to recommend that an advisory client purchase equity research. For more information, see the William Blair Wrap Fee Program Brochure Institutional Sales and Trading William Blair’s Institutional Sales and Trading Department provides trade execution, underwriting and sales to investors and issuers. This can create conflicts of interest with our PWM clients because our employees may come into possession of material, non-public information or other confidential information about a particular company, which if disclosed might affect a person’s decision to buy, sell or hold a company’s securities. The firm maintains policies and procedures as well as physical, technical and logistical controls to mitigate unauthorized access to and/or use of non- public information. Because of these procedures (and related legal requirements), investment decisions related to these securities may be temporarily restricted in your account. In addition, if a PWM Advisor’s client utilizes services provided by William Blair’s Institutional Sales and Trading Department, in some instances, revenue is recognized by the Private Wealth Management Department and the PWM Advisor. The receipt of this compensation creates an incentive to recommend that an advisory client utilize these services. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING William Blair has adopted a Code of Ethics, pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, that governs a number of conflicts of interest we have when providing our advisory services to clients. We have designed our Code to help ensure we meet our fiduciary obligation to our clients as well as to emphasize a culture of compliance within our firm. • We distribute our Code to each employee at the time of hire and annually thereafter. We provide annual training and monitor employee activity on an on-going basis. According to our Code, employees must: • Report their transactions in reportable securities quarterly and disclose reportable securities holdings annually; • Disclose all securities accounts in which they have a beneficial interest (i.e., they are the account owner or have a present economic interest in the account); Protect material non-public information; • • Not purchase securities in an initial public offering (IPO) and obtain prior approval for participation in private placements; • Receive approval prior to engaging in outside business activities including serving on any Board of Directors of a public company; • Report gifts and business entertainment; and Certify on an annual basis as to compliance with our Code. • If you would like a copy of PWM’s Code of Ethics, please contact our Compliance team at pwmcompliancegroup@williamblair.com or (312) 236-1600 or write to us at the following address: William Blair & Company, L.L.C. Attn: PWM Compliance 150 North Riverside Plaza Chicago, IL 60606 Securities in which William Blair has a Financial Interest Because of our diverse financial services activities, William Blair or its affiliates have financial interests in various securities including, but not limited to, the William Blair Funds, William Blair SICAV, William Blair Private Funds, and a William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 30  partnership that holds minority interests in other registered investment advisers (some are clients in the Non- Discretionary Model Portfolio Program, purchase Equity & Consulting Research and/or pay us referral fees for insurance products) as well as securities of corporations to which we provide investment banking and other corporate and executive services. William Blair, its affiliates, partners and certain employees may have a pre-existing interest in, or may subsequently acquire an interest in, a MB Investment, or in investment opportunities that are offered to and/or evaluated by but rejected by the MB Partnership. These interests may substantially differ in liquidation preference, voting rights or other investment terms and may result in investment interests that directly conflict with the interests of the MB Partnership. We or our affiliates also have financial interests in securities for which WBIM serves as sub-adviser (such as other mutual funds or collective investment trusts). We sometimes recommend to our clients that they purchase or sell securities in which we have a financial interest, or in cases where we have investment discretion, we may purchase or sell those securities on behalf of our clients. In addition, our participating affiliates, William Blair International, Ltd, William Blair B.V. and William Blair International (Singapore) Pte. Ltd., may recommend to or invest in the same securities for its own clients as securities in which William Blair or its clients have an interest. As discussed above, we receive compensation from our affiliate, WBIM, based on our clients’ assets invested in William Blair Funds, WBIM Separate Accounts, WBIM Sub-Advisory Accounts (except for WBIM Sub-Advisory Accounts where WBIM does not charge a separate advisory fee, and instead such assets are included in William Blair’s advisory fee, a portion of which is shared with WBIM) and Blair Private Funds. Certain PWM clients are offered the opportunity and independently elect to participate in the William Blair MB Investments Program and invest in a MB Partnership Series.This creates a conflict because we are incented to promote or purchase these securities over others.. A conflict of interest also arises in situations where we may restrict or refrain from making investment recommendations on particular securities because we are actively engaged in investment banking activities, issuing sell side equity research and institutional sales and trading for issuers of those corporate securities. To help manage these conflicts, we rely on various compliance controls including the following: • We maintain a Code, which reinforces our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We have written policies and procedures that clearly prescribe processes for employees when recommending or managing investments for our clients; • We utilize technological trading and compliance tools to monitor portfolio activities; • We review portfolios to ensure investments are consistent with clients’ objectives, guidelines and restrictions; • We typically solicit client consent to invest in the William Blair Funds for their investment advisory accounts; • A client may decline to invest in William Blair Funds, Blair Private Fund or to open a WBIM Separate Account; • A client may restrict us from hiring WBIM as a sub-adviser; • With respect to the William Blair MB Investments Program, William Blair does not make any recommendation to clients with respect to participation in the William Blair MB Investments Program or investing in any MB Partnership Series.. A client makes an independent decision as to whether to participate in the William Blair MB Investments Program and affirmatively elects to invest in Interests in any MB Partnership Series ; • If a client meets the minimum investment amount, the client may be able to invest directly in the MB Investment instead of through the William Blair MB Investment Program; • MB Partnership has written policies and procedures with respect to the fair market value of Interests; • MB Partnership has written policies and procedures with respect to allocation of investment opportunities; • We offset investment management fees on a client’s assets invested in any William Blair Managed MB Investment, unless such investment does not otherwise charge a management fee; William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 31  • For the portion of our clients’ assets in a WBIM Separate Account, WBIM Sub-Advisory Account, William Blair Funds, Blair Private Funds and/or William Blair Managed MB Investments, we do not charge additional investment advisory fees, unless management fees are not otherwise being charged; • We have information barriers in place to prevent dissemination of material, non-public information (including with respect to MB Investments) between our various business groups; • We have allocation policies in place that seek to ensure fair and equitable access to investment opportunities for accounts over time; • We have trade rotation policies in place that seek to effect securities transactions of our clients and to disseminate Non-Discretionary Model Portfolios to our investment adviser clients in a fair and equitable manner; and • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, William Blair Wrap Brochure, Form CRS, WBIM’s Form ADV, Part 2A, advisory agreements, William Blair Funds’ prospectuses and other offering documents, Blair Private Funds’ and MB Partnership’s offering documents, , separate client account opening documentation and/or separate disclosure forms. Personal Securities Trading Because William Blair permits employees to engage in personal securities transactions, our employees may buy or sell securities for their own personal accounts in a manner that is inconsistent with those purchased or sold in our clients’ accounts. As an example, an employee may buy a particular security that we recently have sold for clients. In addition, an employee or an employee of our affiliate, WBIM, may make a personal investment in the securities of our clients’ companies. These situations create conflicts of interest because employees could be motivated to favor their own investment interests or the interests of certain clients over other clients. To help manage these conflicts, we rely on various compliance controls including the following: • We maintain a Code, which reinforces our fiduciary duty to clients and conduct annual training on our Code; • In cases where we are purchasing or selling securities for clients’ accounts, we prohibit a client’s PWM Advisor from trading ahead in the same securities in his or her own accounts; and • We monitor employees’ personal securities transactions in an effort to identify patterns or improper activities. Political Contributions We do not allow our employees to make or solicit political contributions to support political candidates or elected officials for the purpose of obtaining or retaining business with governmental entities. We permit employees to make personal contributions to support candidates for whom they are eligible to vote subject to William Blair’s political contributions policy. ITEM 12 – BROKERAGE PRACTICES Best Execution in Private Wealth Management Accounts In most instances, William Blair’s clients will maintain a brokerage account with William Blair, as the introducing/executing broker (cleared through and custody held by NFS). In effecting transactions for clients whose accounts are introduced or maintained by William Blair, as described above, all trades are directed to William Blair’s sell-side broker-dealer trade desk. In effecting transactions for clients whose accounts are introduced by William Blair, William Blair takes all reasonable steps to seek best execution of orders. William Blair’s sell-side broker dealer has policies and procedures that are designed to obtain the best possible execution result, subject to the nature of the order, any restrictions placed upon us in filling the order and the market in question. William Blair’s sell-side broker dealer takes into consideration a range of different factors which includes price but may also include such other factors as timely execution, the liquidity of the market, the cost of the transaction and the nature of the financial transaction. In some markets, price volatility may mean that the timeliness William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 32  of the execution is a priority, where other markets that have low liquidity may mean the execution itself may constitute the best execution. In limited circumstances, a client will maintain their custodial account at another qualified custodian and give William Blair the ability to effect transactions through any broker-dealer. In effecting trades for these clients’ accounts, in most instances, trades will be directed to William Blair’s sell-side broker-dealer trade desk, as described above. In other circumstances, a client will maintain their custodial account at another qualified custodian and direct us to place their order or a portion of their brokerage orders through specific broker-dealers, other than William Blair “Directed Brokerage.” Please refer to the Client Directed Brokerage discussion later in this section. Important Information about Best Execution and Trading Away for Certain Client Accounts Some PWM Advisors access and hire Sub-Managers through the asset management Platform described in Item 4 – Advisory Services. In cases where a client’s account or a portion thereof are managed by third party investment managers (including WBIM for a WBIM Separate Account or WBIM Sub-Advisory Account) or Sub-Managers, the third party investment manager or Sub-Manager, in its sole discretion, may place a client’s trade orders with a broker-dealer firm other than the custodian’s designated broker-dealer if the manager determines that it must do so to comply with its best execution obligations. WBIM does not typically execute trades through William Blair’s sell-side broker-dealer. This means that clients, even those in our Comprehensive Fee Program, who invest with third party investment managers or Sub-Managers will most likely incur execution costs (whether in the form of commissions or markup/markdowns that are built into the net price of the security) in addition to, and which will not reduce the advisory account fees. Clients should therefore take these costs into consideration when selecting and/or determining whether to remain invested in accounts managed by third party investment managers (including WBIM) or Sub-Managers. Research and Other Soft Dollar Benefits Under the limited circumstances where WBIM selects broker-dealers for WBIM Sub-Advisory Accounts or WBIM Separate Accounts, our affiliate may use broker-dealers that provide it research to execute client transactions, and WBIM may pay higher commissions to receive such research. Our affiliate receives research products and services from broker-dealers and third parties that are used to carry out its investment management responsibilities with respect to client accounts over which it exercises investment discretion (including WBIM Sub-Advisory and WBIM Separate Accounts). WBIM pays for these research products and services using a combination of direct payment (“hard dollars”), and client commission dollars (“soft dollars”), paying for independent third-party research with hard dollars while paying for broker-dealers’ proprietary research and services using both soft and hard dollars. WBIM uses both agency only brokers and broker-dealers, some of which provide us with research products and services to execute client transactions. WBIM pays all brokers execution only commission rates but also will participate in client commission arrangements and commission sharing arrangements with certain broker-dealers. Only broker-dealers who generate their own proprietary research are eligible to be compensated with soft dollars. Similarly, a Sub- Manager may execute Platform account transactions through broker-dealers that charge higher commissions in order to receive such research. Section 28(e) of the Securities Exchange Act of 1934 permits a registered investment adviser such as WBIM and Sub- Managers to pay higher commissions if it can demonstrate the commissions are reasonable in relation to the research or brokerage services it receives. Registered investment advisers using soft dollars are incented to use client commission dollars to purchase research instead of having to pay for the research out of its profits. To the extent WBIM and Sub-Managers use commission dollars to purchase research, it must use the commission dollars generated from accounts that have granted discretion for brokerage placement. Accordingly, commission dollars generated from accounts that grant brokerage placement discretion are likely to be used to purchase research that also benefits accounts that do not grant such discretion. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 33  To the extent that soft dollars are utilized, WBIM and Sub-Managers are not required to use all products and services for the sole benefit of the clients whose commission dollars paid for the products and services. Research obtained from commissions paid by one account are most likely used to benefit all accounts. This creates conflicts because some clients get the benefit of research or services received due to another client’s commission dollars. For more information on our affiliate’s and Sub-Managers’ soft dollar practices, see WBIM’s and Sub-Managers’ Form ADV. Client Directed Brokerage In most instances, clients direct us to place their order through William Blair, as the introducing/executing broker (transactions cleared through NFS). In more limited instances, clients direct us to place their order or a portion of their brokerage orders through specific broker-dealers, other than William Blair (“Directed Brokerage”). This Directed Brokerage arrangement may include “expense reimbursement” and “commission recapture” arrangements, where certain broker-dealers will rebate a portion of a client’s brokerage commissions (or spreads on fixed income or principal trades) directly to their account, or apply the amount to an account’s expenses. In some instances, clients may direct us to place their order or a portion of their brokerage orders through “discount brokers.” We may deny client requests to direct brokerage, and we must accept direction before it will be effective. In selecting the directed broker, the client is solely responsible for negotiating commission rates and other transaction costs with the directed broker. Clients with directed broker arrangements may not receive best execution since the directed brokerage may result in higher commissions than might be the case if we were empowered to negotiate commission rates or select broker-dealers based on best execution. We are not required to execute any transaction through the directed broker if we reasonably believe that doing so could result in a breach of our fiduciary duty. By instructing us to execute transactions through the directed broker (including expense reimbursement and commission recapture arrangements), the client may not necessarily obtain commission rates and execution as favorable as those that would be obtained if we were able to place transactions with William Blair for execution through trading venues. The client also may forego benefits that we may be able to obtain for our other clients through, for example, negotiating volume discounts or block trades. In addition, directed brokerage can distract us from our normal trading process and represents a conflict of interest in our efforts to obtain best execution for all clients and to obtain adequate research. Also, if the directed broker played a role in introducing or referring the client to our firm, we face a conflict of interest that could be seen as reducing our incentive to obtain a lower commission. If the brokerage firm to which William Blair is directed by the client to execute trades is not on our approved list of brokers, the client may be subject to additional credit and settlement risks. Trade Order Aggregation for Private Wealth Management Clients In effecting transactions for our clients, we process orders as received by the various PWM Advisors. William Blair may enter and combine transactions in the same security for different client accounts for which discretionary authority is exercised, and record the price for each client account as the average of the prices at which such transactions are executed (a “bunched trade” or “bunching”). We are not obligated to aggregate/bunch orders. Equity Trade Rotation Process We utilize a multi-tiered trade rotation process that seeks to effect equity securities transactions of our discretionary clients (including the Proprietary Home Office Model Program) and disseminate model portfolios to our Non- Discretionary Model Portfolio Program in a fair and equitable manner. The trade rotation process presents issues that include detrimental market impact (i.e., earlier trades can move the market causing subsequent trades to receive inferior prices), “signaling” concerns (i.e., broker-dealers anticipate additional trades in the same security and use this information to the detriment of the adviser’s client), and timing differences that result in clients obtaining different execution prices and performance dispersion among accounts. Such concerns are mitigated where the securities involved have significant trading volume and high liquidity. William Blair’s trade rotation tiers for client’s accounts not in the Proprietary Home Office Model Program, are as William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 34  follows: 1. First Tier Discretionary advisory clients are traded in the first tier. 2. Second Tier We typically wait to trade second tier accounts until the “bunched” first tier trade is completed. We then execute trades for second tier accounts. Clients included in the second tier are 1) clients that direct us to utilize specified broker-dealers; and 2) clients invested in certain securities markets or security types that make bunching impractical or would lead to unfair results. A client’s decision to utilize a broker as the custodian of its account can, even in the absence of an express direction to use that broker for executing securities transactions, have the same practical effect as a direction depending on the broker’s capabilities and charges. 3. Third Tier Third tier accounts typically wait until the first tier and second tier trades are completed. Non-Discretionary Model Portfolio Programs are included in the third tier. William Blair’s trade rotation tiers for client’s accounts in the Proprietary Home Office Model Program, are as follows: 1. First Tier Proprietary Home Office Model Program advisory clients are traded in the first tier. 2. Second Tier We typically wait to trade second tier accounts until the first tier trades are completed. We then execute discretionary advisory clients’ accounts whose PWM Advisor customizes the investment recommendations underlying a Proprietary Home Office Model Program strategy. 3. Third Tier We typically wait to trade third tier accounts until all trades in the first and second tiers are completed. We then execute trades for third tier accounts. Clients included in the third tier are 1) clients that direct us to utilize specified broker-dealers; and 2) clients invested in certain securities markets or security types that make bunching impractical or would lead to unfair results. A client’s decision to utilize a broker as the custodian of its account can, even in the absence of an express direction to use that broker for executing securities transactions, have the same practical effect as a direction depending on the broker’s capabilities and charges. Trade Allocation and Investment Allocation When the full amount of a bunched equity order is not executed, partially executed orders will typically be allocated among the participating client accounts on a pro rata basis in a fair and equitable manner in accordance with applicable policies and procedures. With respect to the William Blair MB Partnership Program, William Blair has adopted written investment allocation policies and procedures. Please see Item 6-Performance Based Fees and Side-By-Side Management for more information. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 35  Trade Errors William Blair as an investment adviser employs a standard of care in the placement of trades for clients’ accounts. William Blair as the introducing broker-dealer on certain client accounts employs a standard of care in the execution of trades for clients’ accounts. Generally, William Blair considers any deviation from these standards a trade error. When we cause a trade error, we take prompt action to resolve the error with the objective to return the client’s account to the position that it would have been in had there been no error. We pay to correct an error and reimburse a client for any loss resulting from the error. To ensure trade errors do not adversely affect a client’s portfolio, the Compliance Department or delegate reviews each trade error and routinely reviews our trade error log. Cross Trades and Principal Trades We can effect securities transactions between two advisory clients (which are commonly referred to as “cross trades”). William Blair receives no compensation for effecting the transactions and will do so in an objective manner and only if it does ensure it has a reasonable basis for believing the price is fair to both buyers and sellers. William Blair does not effect cross trades in ERISA accounts. We can effect securities transactions for an advisory client with non-advisory clients of William Blair (which are commonly referred to as “agency cross trades”) in accordance with Section 206(3) of the Investment Advisers Act of 1940 and Rule 206(3)-2 thereunder. William Blair receives compensation from the non-advisory client to execute the transaction. William Blair has duties and obligations to both their advisory and non-advisory clients and a conflicting division of loyalty exists on the part of William Blair in such transactions. Note that you can restrict us from trading on a cross-agency basis at any time. We generally do not sell securities to, nor purchase securities from, our advisory clients’ accounts as principal (which are commonly referred to as “principal trades.”). With authorization by our clients, in very limited circumstances and in accordance with applicable laws and the rules and regulations promulgated by the SEC, we will engage in a principal trade. ITEM 13 – REVIEW OF ACCOUNTS Account Reviews William Blair reviews clients’ accounts for appropriateness and relative value of investments. We meet periodically to discuss current developments and relative merits of investments. We appraise account holdings and review accounts for accuracy from an administrative, accounting and investment viewpoint. A member of PWM’s senior management reviews the appropriateness of investment holdings on an ongoing basis. We determine the frequency, depth and nature of reviews based on the terms of each client’s advisory agreement, mandate and particular needs as they may be communicated to us by the client. We may review accounts during other periods based upon certain trigger factors including significant market events, changes in a client’s investment objectives or guidelines or expected or unexpected material cash flow in an account. PWM Advisors conduct the reviews. The Compliance Department also routinely assesses client accounts via electronic compliance monitoring systems. We use technological tools (as noted above) to assist with our reviews on both an account-by-account basis and on a securities holdings’ basis, as well as performance exceptions and other bases. We conduct reviews to determine if an account’s holdings are consistent with the investment objectives and restrictions imposed by the client. For our PWM clients, financial advisors typically construct custom portfolios based on a client’s unique objectives and restrictions and manage and review portfolios based on individualized parameters. Client should communicate any changes in investment objectives and restrictions as well as changes in financial condition to their William Blair PWM Advisor. As the client will not be able to communicate directly with any Sub- William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 36  Manager available through a Platform or with WBIM for a WBIM Sub-Advisory Account, client should communicate these reasonable restrictions to their William Blair PWM Advisor. Account Reports William Blair provides written reports to clients periodically. These reports may include portfolio performance and portfolio positioning as of the end of the period. Portfolio performance reports are provided to clients on at least an annual basis. We will include additional detail related to transactions or other information as may be requested by clients. We also will provide reports on a monthly or other interim basis upon client request. For clients in wrap fee programs or other programs where the client has requested that a report not be sent because a report is being sent by the consultant, wrap program sponsor, or broker, we do not send a statement. Investors in private funds (including Blair Private Funds and MB Partnership) typically receive a copy of audited financial statements of the relevant private fund within 120 days after the fiscal year end of each such fund. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Referral Payments On occasion, we can enter into an agreement with unaffiliated third-party promoters in order to pay cash compensation to the promoter for referring advisory clients to our firm. To the extent we enter into such an arrangement, we will comply with the applicable requirements under Rule 206(4)-1 of the Investment Advisers Act pertaining to compensated “endorsements.” Clients that are referred to us through such arrangements are provided a disclosure document describing the terms and conditions of the arrangement, including the compensation paid to the promoter. The advisory fees paid by referred clients to us generally are based upon the revenue generated by the referred clients’ accounts, and the clients’ advisory fees are not higher than they would otherwise be because of the referral fees paid. Participation in Fidelity Wealth Advisor Solutions® William Blair participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which William Blair receives referrals from Strategic Advisers LLC (“Strategic Advisors”), a registered investment adviser and Fidelity Investments company. William Blair is independent and not affiliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise or control William Blair, and Strategic Advisors has no responsibility or oversight for William Blair’s provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a solicitor for William Blair, and William Blair pays referral fees to Strategic Advisers for each referral received based on William Blair’s assets under management attributable to each client referred by Strategic Advisers or members of each client’s household. The WAS Program is designed to help investors find an independent investment adviser, and any referral from Strategic Advisers to William Blair does not constitute a recommendation or endorsement by Strategic Advisers of William Blair’s particular investment management services or strategies. More specifically, William Blair pays the following amounts to Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” and “cash” assets by Strategic Advisers and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, William Blair has agreed to pay Strategic Advisers a minimum annual fee of $50,000 to participate in the WAS Program. These referral fees are paid by William Blair and not the client. To receive referrals from the WAS Program, William Blair must meet certain minimum participation criteria, however, William Blair was selected for participation in the WAS Program as a result of its other business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). Clients should refer to Item 5- Advisory Business for important information regarding William Blair’s arrangements with NFS, an affiliated entity of Strategic Advisers and FBS. As a result of its participation in the WAS Program, William Blair has a conflict of interest with respect to its decision to use certain affiliates of Strategic Advisers, including FBS, for execution, custody and clearing for certain client accounts, and William Blair has an incentive to suggest the use of FBS and its affiliates to its advisory clients, whether William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 37  or not those clients were referred to William Blair as part of the WAS Program. Under an agreement with Strategic Advisers, William Blair has agreed that it will not charge clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Pursuant to these arrangements, William Blair has agreed not to solicit clients to transfer their brokerage accounts from affiliates of Strategic Advisers or establish brokerage accounts at other custodians for referred clients other than when William Blair’s fiduciary duties would so require, and William Blair has agreed to pay Strategic Advisers a one- time fee equal to 0.75% of the assets in a referred client account that is transferred from Strategic Advisers’ affiliates to another custodian; therefore, William Blair has an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of Strategic Advisers. However, participation in the WAS Program does not limit William Blair’s duty to seek best execution. Other Payments and Contributions Some of our clients and prospective clients retain investment consultants or financial advisors to advise them on the selection and review of investment managers. As a firm, we also may have other business relationships with these third parties. To the extent allowed under applicable law and our policies, we contribute toward expenses related to educational seminars, training programs, conferences or meals and entertainment incurred by third parties, financial advisors, and firms that use William Blair or affiliates as a sub-advisor or include us on a list of recommended investment advisers (including consultants). We also pay travel and lodging expenses relating to financial advisors' attendance at our due diligence meetings. We make charitable contributions or underwrite or sponsor charitable events at the request of others, including those who are affiliated with clients or program sponsors or consultants that may have referred clients to the firm. From time to time, we also buy from third parties certain services or products used in our investment advisory business (such as research services) or pay registration or other fees toward or assist in sponsoring such parties’ industry forums, seminars or conferences. We pay these contributions and payments out of our own resources. The amount of payments and the value of items and benefits may or may not be substantial. These payments, items and benefits give the recipients incentives to favor our private wealth management services and other William Blair- affiliated investment products and services over those of investment management firms that do not provide the same payments, items and benefits. Conversely, from time to time, third parties, including NFS and Platform Providers, defray costs of William Blair sponsored training events and conferences. These payments create a conflict of interest in that William Blair is incented to favor products and services offered by these third parties over those third parties that do not. However, these payments are subject to our internal policies that address and, in some cases, limit payments with the overall aim to avoid compromising advice or recommendations given to clients by special incentives or compensation arrangements. Asset-Based Compensation William Blair receives compensation from clients whose assets are held in advisory accounts. The William Blair advisory fee charged may vary based on the underlying holdings in the client’s accounts (for example, a client may have an account with only fixed income securities that may be charged a lower advisory fee than that same client’s account with only equity securities). Based on this advisory fee differential, William Blair and its PWM Advisors have a conflict of interest when purchasing securities. William Blair and its PWM Advisors have a conflict of interest when they recommend that a prospective client or a current brokerage client open an advisory account that will generate ongoing fees instead of no fees (for a prospective client) or transaction-based fees for a brokerage client. Employees, including when the employees are acting in their role as registered representatives, receive compensation for their clients’ investment in securities or other investment products, including asset-based compensation. As discussed above, our affiliate, WBIM compensates us and our PWM Advisors with respect to PWM’s clients’ assets invested in WBIM Separate Accounts, William Blair Funds, Blair Private Funds, and WBIM Sub-Advisory Accounts (except when William Blair includes the assets held in or through a WBIM Sub-Advisory Account in William Blair’s calculation of the advisory fee, provided that WBIM does not charge a separate advisory fee to the client for its sub-advisory services). This practice constitutes a conflict of interest in that we and our PWM Advisors are incented to purchase William Blair Funds, recommend a WBIM Separate Account, hire WBIM as a sub-adviser and recommend an investment in Blair Private Funds. While William Blair and PWM Advisors do not make recommendations with respect to a client’s election to participate in the William Blair MB Investments Program or invest in any MB Partnership Series (including a William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 38  William Blair Managed MB Investment), advisory compensation based on the fair market value of the MB Partnership Interests (as determined by our affiliate, MB General Partner) as well as compensation to or from our affiliate, the MB General Partner, creates conflicts of interest with respect to PWM’s clients’ assets invested in that MB Partnership Series. Please see Item 4-Advisory Business, Item 5-Fees and Compensation, Item 6-Performance Based Fees and Side-By-Side Management, Item 10-Other Financial Industry Activities and Affiliations and Item 11– Code of Ethics, Participation or Interest in Client Transactions and Personal Trading for a description of these conflicts of interest and how William Blair manages them. As described in Item 10, William Blair acts as distributor for the William Blair Funds and receives for its services a shareholder/distribution services fee from certain share classes of each Fund as described in the William Blair Funds’ prospectuses and statements of additional information. This constitutes a conflict of interest for William Blair in that its employees are incented to recommend investment in share classes subject to the above-described fees. William Blair’s registered representatives are responsible for understanding the availability of sales charge discounts to provide the client the opportunity to purchase a Fund under the most favorable terms available. Clients also have the option to invest in securities other than the William Blair Funds. Clients should review the prospectuses and statements of additional information for the William Blair Funds. The William Blair Funds’ prospectuses are available on the William Blair Funds’ website at www.williamblairfunds.com or by calling 1-800-742-7272. Other Financial Incentives from William Blair to PWM Advisors William Blair pays investment professionals with financial incentives when they join William Blair and on an ongoing basis. PWM Advisors are eligible to receive incentives, including loans, back-end bonuses and/or other compensation (including expense accounts to cover certain expenses related to PWM Advisors’ business) if the reach certain asset levels within a specified period of time. These asset levels can be met by a combination of bringing client assets with them from their prior firm and/or garnering assets from clients new to them and William Blair. The amount paid to PWM Advisors under these arrangements is largely based on the size of the business serviced at their prior firm and the PWM Advisor achieving the target asset levels within a specific time period after joining William Blair, as well as certain qualitative factors. These payments are substantial and take various forms, including salary guarantees, loans, transition bonus payments and various form of compensation to encourage financial professionals to join William Blair. Therefore, even if the fees you pay at William Blair remain the same or are less, the transfer of your assets to William Blair contributes to your PWM Advisor’s ability to meet targets. Your PWM Advisor’s continued employment is based on meeting these targets. These practices create an incentive and conflict of interest for your PWM Advisor to recommend the transfer of your account assets to William Blair since a significant part of their compensation is contingent on the PWM Advisor achieving a pre-determined level of assets at William Blair. Compensation from Retirement Accounts William Blair receives compensation from clients whose assets are invested in an Individual Retirement Account (“IRA”). William Blair and its PWM Advisors have a conflict of interest when they recommend that a participant roll money out of an employer retirement plan, such as a 401(k) plan, and into an IRA that will generate ongoing fees for the firm and the PWM Advisor. Even though William Blair and its employees are NOT compensated for making the recommendation, we will receive compensation for services under an investment advisory agreement should the retirement investor follow our recommendation to rollover their money into an IRA with William Blair. Investing assets in a William Blair IRA most likely will result in higher fees than investing through an employer’s retirement plan. To help manage this conflict of interest, we have implemented the following: • acknowledging that when we provide investment advice to a retirement investor (including a recommendation to rollover retirement assets into a William Blair IRA), William Blair and the PWM Advisor are fiduciaries within the meaning of ERISA and the Code; • William Blair and the PWM Advisor will act in the retirement investors’ best interest and not put our interest ahead of the retirement investors; William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 39  • Conflicts of interest are disclosed in the Brochure, Form CRS, the “Retirement Investor Acknowledgement & Fiduciary Acknowledgement” form; • Retirement investor clients and prospects are provided with “Information Regarding Transfers, Distributions, and IRA Rollovers;” and • William Blair has policies, procedures and controls (including an annual, retrospective review) in place with respect to advisory accounts for retirement investors. Similarly, NFS’ affiliate acts as a record keeper for certain retirement plans whose participants are pre-existing investment advisory clients of William Blair. Certain retirement plans allow their participants to grant discretion to investment advisers to manage assets within their retirement accounts. In these instances, William Blair and the PWM Advisor have a conflict of interest in that they will receive compensation for services under an investment advisory agreement should we be hired to manage the participant’s assets within their retirement account held at NFS’ affiliate. Compensation from Service Providers William Blair utilizes various service providers. Certain partners or employees of William Blair own an interest in some of these service providers. William Blair has a conflict of interest in that there is an incentive to maintain and increase our business relationship with such service providers rather than with comparable service providers. As described in Item 5 – Advisory Business, William Blair has entered into agreements with NFS, whereby NFS acts as a clearing broker and provides custodial, brokerage and certain other services for certain clients of William Blair. As described in Item 5-Fees and Compensation-Other Fees and Expenses Related to NFS, NFS reimburses William Blair for Transition Fees. In certain cases, the Transition Fees may exceed the costs incurred by the client in moving assets from their prior custodian to NFS. If William Blair terminates its agreements with NFS, William Blair repays NFS a portion of the Transition Fees. As described more fully above in Item 5, William Blair receives from NFS a portion of the fees it charges or credits it pays related to certain services, including securities lending, multi-margin accounts, non-purpose loans and certain fixed income trades, among other services offered. In addition, William Blair charges its advisory clients certain operational fees such as ACAT Exit Fees, fees for wire transfers, bounced checks, IRA terminations, and other fees. NFS has also agreed to pay William Blair business development and technology credits that help defray William Blair’s costs associated with advisory clients’ accounts that are maintained at NFS. If William Blair terminates its agreements with NFS and client assets are removed from NFS, William Blair repays NFS a portion of these credits. These fees and credits cause conflicts of interest because: 1) they incentivize William Blair to recommend clients utilize NFS custodial and other services instead of another custodian; 2) they incentivize William Blair to recommend securities lending and margin activity; and 3) they incentivize William Blair to maintain its relationship with NFS to avoid repayment of Transition Fees, business development and technology credits and other credits. To help manage these conflicts, we rely on controls including the following: • Payments and credits as well as a description of conflicts are disclosed in documents, including but not limited to, this Brochure, Form CRS, advisory agreements, prospectuses and other offering materials, separate client account opening documentation and/or separate disclosure forms; • PWM Advisors are not compensated based on Transition Fees, business, infrastructure or technology (PWM Advisors are compensated based on multi-margin and securities lending); • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own, and conduct annual training on our Code; and • PWM Advisors are obligated to employ a standard of care and comply with clients’ investment guidelines and restrictions when selecting investments for clients’ accounts. William Blair also pays for and receives services from Platform providers or their affiliates. William Blair receives a discount on the cost of these services based on the level of our clients’ assets on the Platform. Therefore, William Blair William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 40  has a conflict of interest in that there is an incentive to increase the amount of its clients’ assets on a Platform to reduce the cost of other services received from the Platform provider or its affiliates. Compensation for Internal Referrals William Blair and its affiliates have established an internal referral program to support growth across the organization. If a referral is made for a William Blair advisory relationship, there is no impact on the advisory fee charged to that client. William Blair employees can be paid direct compensation for generating qualified leads within one of the other departments across William Blair and affiliates. Therefore, employees are incented to refer a client to other business lines of William Blair or its affiliates. Compensation for Insurance Referrals From time to time, William Blair refers its clients to insurance providers and receives referral fees from the provider when the client purchases an insurance product, including annuities. This referral fee creates a conflict of interest because William Blair and PWM Advisors are incented to refer clients to insurance providers paying a referral fee instead of to those that do not pay a referral fee. William Blair has an indirect, minority ownership interest in one such insurance provider which creates an additional incentive to refer clients to this insurance provider rather than to an insurance provider where we have no ownership interest or those that do not pay a referral fee. William Blair employees who are properly licensed as insurance agents are eligible to receive referral fees. Conflicts of interest are disclosed in this Brochure, Form CRS, and in separate disclosure documents. Compensation for Bank Referrals From time to time, William Blair refers its clients to national banks and receives referral fees based on a percentage of the monthly average outstanding balance on the referred client’s line of credit. This referral fee creates a conflict of interest because William Blair and PWM Advisors are incented to refer clients to providers that pay a referral fee instead of to a provider that does not pay a referral fee. Conflicts of interest are disclosed in this Brochure, Form CRS, and in separate disclosure documents. ITEM 15 – CUSTODY Clients choose which custodians will custody their assets. It is our understanding that certain such custodial agreements or other agreements or documents may contain provisions that could result in William Blair having inadvertent custody of client account assets as a result of language permitting us, as investment adviser, to withdraw client assets upon instruction to the custodian. Our agreements with our clients, however, are not intended to give us broad authority to withdraw client assets, and we disclaim such authority to the extent applicable. With respect to these concerns, our authority as it relates to custody should be considered to be limited in the ordinary course to customary trading and settlement of securities and investment transactions in the client’s account, typically on a “delivery vs payment” basis for securities transactions, as well as fee deductions in certain cases, as applicable. Clients are not required to use NFS for these services and clients are free to work with other custodians. As discussed above, William Blair receives certain fees and credits from NFS. Most clients choose to custody their assets at NFS since William Blair has a clearing relationship with NFS as described in Item 5 – Fees and Compensation and Item 14 – Client Referrals and Other Compensation. William Blair has custody of client accounts since some clients authorize their custodian, including NFS, to deduct William Blair’s advisory fees from their client account. In addition, pursuant to a standing letter of authorization (“SLOA”) some clients grant William Blair limited discretion to disburse funds to one or more third parties, as specifically designated by the client. After granting William Blair with this limited authorization, the client then instructs the qualified custodian for the client's account to accept William Blair’s direction on the client's behalf to move money to the third party designated by the client on the SLOA. The qualified custodian takes that instruction in writing directly from the account holder (the client), and William Blair’s authority is limited by the terms of that William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 41  instruction. We are authorized to act merely as an agent for the client. The client retains full power to change or revoke the arrangement. William Blair does NOT have discretion as to the amount, payee or timing of transfers under the SLOA. If client’s interests in private funds cannot be held at a qualified custodian, the interests will be held in the client’s name and ownership is recorded in the books and records of the issuer. For the avoidance of doubt, client’s Interests in any MB Partnership Series are held in the client’s name and recorded in the books and records of the MB Partnership Series while Co-Investments are held in the client’s name and recorded in the books and records of the Co-Investment issuer. The MB Partnership is required to undergo an annual audit of its financial statements to comply with certain exemptions set forth in Rule 206(4)-2 of the Advisers Act. Investors in private funds, including Blair Private Funds and MB Partnership Series, will receive audited financial statements. To the extent a private fund does not get its financial statements audited on annual basis and instead is subject to a surprise examination of its assets, the assets of such private funds are held by one or more custodial banks or broker-dealers, and such custodial banks or broker-dealers send account statements to investors in such private fund. You should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains your investment assets. Our investment account statements will vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. For tax and other purposes, your custodial statement is the official record of your account(s) and assets. We urge you to carefully review your custodian statements and compare them to the account statements that we provide to you as your investment manager. If you have any questions with respect to your custodial statement and account statements, please contact your PWM Advisor. ITEM 16 – INVESTMENT DISCRETION Investment Discretion William Blair maintains discretionary authority for the majority of assets we manage. In addition, William Blair will accept client accounts on a non-discretionary basis. As discussed above, William Blair provides a Non-Discretionary Model Portfolio Program where the underlying clients are other registered investment advisers. We typically receive an executed investment advisory agreement from the client providing the authority to manage their account assets. Subject to acceptance by William Blair, a client may request certain limitations on the management of their account as set forth in the agreement’s investment guidelines or otherwise in writing. These investment guidelines may restrict our discretion, for example, with respect to the securities of a particular country or industry. We typically request clients provide changes to their investment guidelines to us in writing and will confirm in writing any verbal changes provided by the client. We also request certain documentation in addition to an executed investment management agreement as may be needed (for example, to verify a client’s authority over the assets). Aggregate Ownership of Securities We monitor the aggregate ownership of equity securities across accounts and have adopted limits placed on aggregate ownership levels based on firm and regulatory considerations. The limits we place on aggregate ownership of securities across accounts can cause performance dispersion among accounts with similar investment guidelines if a security’s aggregate ownership has reached prescribed limits. This tends to be more common with accounts invested primarily in small and mid-capitalization stocks. In cases where a security has reached its ownership limit, PWM Advisors may seek to either substitute a similar security or omit the security and reallocate the portfolio. ITEM 17 – VOTING CLIENT SECURITIES Proxy Voting Practices William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 42  In cases where William Blair has proxy voting authority, we will vote the proxies solely in the interest of our clients. We act with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. We are not responsible for voting proxies we do not receive in a timely manner. For clients participating in a securities lending program via their custodian, we will not be eligible to vote proxies for the portion of shares on loan. For clients where we vote proxies, unless a client otherwise notifies William Blair, in writing, contact information will not be distributed to third-party solicitors. Generally, when William Blair votes proxies, we rely upon a Proxy Administrator, Institutional Shareholder Services (“ISS”) to facilitate our proxy voting activities. ISS reviews all proxies received, subject to the requirement that all votes shall be cast solely in the best interest of the clients in their capacity as shareholders of a company. ISS votes the proxies according to the firm’s selected voting guidelines (domestic or international), which are designed to address matters typically arising in proxy votes.2 Accordingly, if the voting guidelines indicate a vote “for”, ISS will vote in favor of the matter; if the voting guidelines indicate a vote “against,” ISS will not vote in favor of the matter. We do not intend for such voting guidelines to be exhaustive; hundreds of issues appear on proxy ballots and it is neither practical nor productive to fashion a guideline for each. Rather, such voting guidelines are intended to cover the most significant and frequent proxy issues that arise. In the rare instance where the voting guidelines have no recommendation or indicate a vote on a “case-by-case” basis, ISS will vote in the manner directed by William Blair, based on what we believe is in the best interest of our client. ISS is an independent third-party research provider that analyzes each vote from the shareholder vantage point. ISS provides proxy voting, maintenance, reporting, analysis and recordkeeping services. For information regarding proxy voting for private funds, including Blair Private Funds and MB Partnership, please see each fund’s offering materials. Share-Blocking Policy for International Markets In international markets where share blocking applies, we typically will not, but reserve the right to, vote proxies due to liquidity constraints. Share blocking is the “freezing” of shares for trading purposes at the custodian/sub-custodian bank level in order to vote proxies. Share blocking typically takes place between 1 and 20 days before an upcoming shareholder meeting, depending on the market. While shares are frozen, they may not be traded. Therefore, the potential exists for a pending trade to fail if trade settlement falls on a date during the blocking period. We do not subordinate the interests of participants and beneficiaries to unrelated objectives. Oversight of Proxy Administrator William Blair and its affiliate, WBIM utilize ISS as their proxy administrator. William Blair relies on WBIM for oversight of ISS. For more information related to ISS oversight, please see WBIM’s Form ADV. We periodically review a random sample of votes for consistency with the voting guidelines. How to Obtain Proxy Records and Voting Policy We will make available to our clients a report on proxy votes cast on their behalf upon their request. Clients can contact us at 312-236-1600 or pwmcompliancegroup@williamblair.com for this information. Clients and prospects also can obtain a copy of our proxy voting policies and procedures upon request by contacting us at (312) 236-1600 or pwmcompliancegroup@williamblair.com. For information regarding how proxies were voted for the William Blair Funds, please refer to the William Blair Funds’ website at www.williamblairfunds.com and select Proxy Voting Information. The William Blair Funds’ proxy voting records also are available on the SEC’s EDGAR website at www.sec.gov/edgar. 2 The voting guidelines are available on ISS’s website at https://www.issgovernance.com/policy-gateway/voting-policies. William Blair typically follows the Benchmark Proxy Voting Guidelines. Clients also can instruct William Blair to follow other ISS proxy voting guidelines. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 43  ITEM 18 – FINANCIAL INFORMATION As described in Item 15, William Blair is considered to have custody of clients’ assets because we have the ability to debit some of our clients’ accounts for investment management fees. William Blair has no known financial condition that we believe is likely to impair our ability to meet our commitments to our investment advisory clients. Additionally, we have not been the subject of any bankruptcy petition during the past ten years. You can obtain a copy of our most recent financial statement on our website at www.williamblair.com under Statement of Financial Condition. William Blair & Co., L.L.C. – Form ADV Part 2A – March 31, 2025 44 

March 31, 2025 William Blair Equity Research Services Form ADV Part 2A This Brochure (also known as Form ADV Part 2A) provides information about the qualifications and business practices of William Blair & Company, L.L.C and the equity research services of its Equity Research department. If you have questions about the contents of this Brochure, please contact us at ecmcomply@williamblair.com or (312) 236-1600. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. William Blair & Company, L.L.C. 150 North Riverside Plaza Chicago, Illinois 60606 (312) 236-1600 www.williamblair.com Additional information about William Blair & Company, L.L.C. also is available on the SEC’s website at www.adviserinfo.sec.gov. William Blair & Company, L.L.C. is registered as an investment adviser with the SEC. Our registration as an investment adviser does not imply a certain level of skill or training. William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 0  ITEM 2 – MATERIAL CHANGES William Blair & Company, L.L.C. (“William Blair,” “firm,” “we,” or “our”) has updated our Brochure (also known as Form ADV Part 2A) as of March 31, 2025. Our last update was as of March 29, 2024. We continue to conduct our business and provide investment advisory services in substantially the same manner as described in this last annual update to our Brochure. As a reminder, we may at any time update our Brochure and will either send you a copy or offer to send you a copy (either electronically or in hard copy) as may be necessary or required. If you would like another copy of this Brochure, you may download it from the SEC’s website at www.adviserinfo.sec.gov, or you may contact our Compliance team at (312) 236-1600 or e-mail us at ecmcomply@williamblair.com. William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 1  ITEM 3 – TABLE OF CONTENTS ITEM 2 – MATERIAL CHANGES ................................................................................................................................................. 1 ITEM 3 – TABLE OF CONTENTS ................................................................................................................................................. 2 ITEM 4 – ADVISORY BUSINESS ................................................................................................................................................. 3 ITEM 5 – FEES AND COMPENSATION ....................................................................................................................................... 5 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................................ 5 ITEM 7 – TYPES OF CLIENTS ..................................................................................................................................................... 6 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..................................................................... 6 ITEM 9 – DISCIPLINARY INFORMATION .................................................................................................................................... 7 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................................................... 8 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..................... 9 ITEM 12 – BROKERAGE PRACTICES .........................................................................................................................................10 ITEM 13 – REVIEW OF ACCOUNTS ...........................................................................................................................................10 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................................................10 ITEM 15 – CUSTODY ...............................................................................................................................................................10 ITEM 16 – INVESTMENT DISCRETION ......................................................................................................................................10 ITEM 17 – VOTING CLIENT SECURITIES ....................................................................................................................................10 ITEM 18 – FINANCIAL INFORMATION .....................................................................................................................................10 William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 2  ITEM 4 – ADVISORY BUSINESS This Brochure describes the equity research services that the Equity Research department of William Blair & Company, L.L.C. (“William Blair”) offers to its institutional clients. William Blair is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and as a securities broker-dealer under the Securities Exchange Act of 1934, as amended. Firm Description William Blair is a global investment firm offering investment management and related services to clients. The firm (a privately held company) was founded in 1935 and is a wholly owned subsidiary of WBC Holdings, L.P., which is wholly owned by current William Blair personnel (also referred to as ‘partners’ in this Brochure). William Blair also is an affiliate of William Blair Investment Management, LLC, an investment adviser registered with the SEC. William Blair Investment Management, LLC provides institutional investment management services. Equity Research Services William Blair offers the equity research services described in this Brochure (the “Research Services”) to institutional clients through its Equity Research department. The Research Services made available to clients include (but are not limited to) the following: • • • equities-based research reports containing discussion and analysis of companies, industries, sectors, markets and macro-economic developments, in each case produced by research analysts in William Blair’s Equity Research department; other research-related communications and materials from research analysts relating to published research reports and companies covered by research analysts and the securities of such companies, including financial models and other analysis; and access to research analysts in connection with industry conferences, and calls and meetings with institutional clients. William Blair research analysts within the Equity Research department provide Research Services relating to several hundred companies, across seven growth-oriented sectors: consumer; energy and sustainability; financial services and technology; global industrial infrastructure; global services; healthcare; biotechnology; and technology, media and communications. Any investment advisory relationship is strictly limited to the provision of Research Services for which William Blair receives a Research Fee and is limited in duration to the period of each Research Service for which William Blair receives a Research Fee. Please note that Research Services do not include any services or communications provided by William Blair’s Institutional Sales & Trading department. While the Research Services provided to a particular client vary, William Blair does not tailor or personalize such services to the individual needs of specific clients. Research Services are not customized to meet, and do not consider, the specific investment objectives, goals, strategies, financial needs, or risk profile of any client who receives the Research Services (nor any customers of such clients). Research Services are solely impersonal investment advice and are for general use only and do not include tailored or personalized investment advice or recommendations. Clients must make their own independent evaluation of the suitability of the Research Services and the recommendations contained therein to their specific objectives (and to those of any of their underlying customers), and of the risks and merits of any investment decisions by the client (for itself or its underlying customers) that are based on Research Services. The Research Services are not meant to be the primary or sole basis for any investment decision made by client (for itself or for its underlying customers). William Blair does not undertake to monitor your accounts or investments in connection with the Research Services. William Blair will give advice, make recommendations, and take action in the performance of its duties to other clients or for its own accounts that will differ from advice or recommendations given, or in the timing and nature of action taken, with respect to the Research Services provided to you. William Blair is not obligated to recommend for purchase or sale any security or other investment that William Blair may purchase or sell, or recommend for purchase or sale, to or for the account of any other client or for its or their accounts. William Blair may provide Research Services to some clients that are inconsistent with, and reach different conclusions from, information in Research Services provided to other clients. When William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 3  this occurs, the differences in ideas contained in the Research Services generally reflect the different time frames, assumptions, views, and analytical methods of the persons involved or that result from a client’s request. William Blair may favor some clients over others in various ways, including favoring clients that have greater relationships with or are responsible for greater revenues to William Blair. For example, William Blair Equity Research personnel may communicate to some clients with respect to their newly published research, market developments or other Research Services before communicating with other clients, and may provide certain clients with preferred or more extensive access to research analysts. William Blair and its clients may act on Research Services more quickly than another client, which may adversely impact that client’s investments or investment opportunities. Trades placed by you or your underlying customers may receive prices that are less favorable than prices obtained by William Blair and its other clients. Research Services include perspectives, opinions, analyses, insights, commentaries and outlooks of William Blair and its analysts within the Equity Research department, all of which are inherently uncertain and may or may not prove to be correct. To the greatest extent permitted by applicable law, William Blair and its employees and partners (including but not limited to analysts in the Equity Research department) shall not be liable for any losses, costs, liabilities or expenses suffered by a client (or its underlying customers) which may arise directly or indirectly from a client’s use of the Research Services, or any information or data provided therein or otherwise obtained or derived therefrom. This limitation is not meant to constitute a waiver or limitation of any rights accorded to a client under the applicable securities laws to the extent William Blair is deemed an investment adviser when providing the Research Services. You are neither required to act on any of the information provided through Research Services nor are you required to transact business with us if you choose to utilize any Research Services or implement any strategies, recommendations or other ideas contained within the Research Services. William Blair is not responsible for the re- distribution of information contained within the Research Services and a person’s receipt of such information shall not, by itself, be deemed to create an investment adviser-client relationship between William Blair and any such person. William Blair and its affiliates do offer a variety of other investment advisory services, including discretionary and non- discretionary investment advice with respect to a client’s investment portfolio and management of assets (“William Blair Investment Management Services”). For more information regarding William Blair’s Investment Management Services provided by the Private Wealth Management department of William Blair, including its comprehensive fee program (a/k/a Wrap Program), please see William Blair’s Form ADV Part 2A and Form ADV Part 2A, Appendix 1 (Wrap Brochure), respectively. For William Blair Investment Management Services provided by our affiliate, please see William Blair Investment Management LLC’s Form ADV. Brochures for William Blair and its affiliates can be found at https://www.williamblair.com. William Blair’s investment advisory relationship with a client of Research Services is strictly limited to Research Services to the extent provided to the client in exchange for a fee. William Blair’s investment advisory relationship does not extend to non-securities research, economic research, analytics not constituting investment advice, market or other data, corporate access (even if William Blair receives a fee in exchange for arranging such corporate access), any other communications or content that does not constitute investment advice, including through William Blair’s Institutional Sales & Trading personnel. Any relationship William Blair has with a client as an investment adviser by virtue of the delivery of the Research Services for a Research Fee is limited to the client and does not extend to any of the client’s officers, directors, employees, or underlying customers. William Blair will not be or become a fiduciary to a client or a client’s underlying customers for purposes of the Employee Retirement Income Security Act of 1974, as amended, or Section 4975 of the Internal Revenue Code of 1986, as amended, except to the extent William Blair expressly agrees to do so in a separate written agreement. In addition, the delivery of Research Services does not include trade execution, trading or brokerage services provided to clients. Any trades, transactions or orders that may be executed, routed, or otherwise processed through William Blair on behalf of clients (or customers of such clients) will be handled solely in our capacity as a broker-dealer. If you engage in securities transactions with us, we will not be acting as an investment adviser with respect to such securities transactions absent a separate, written agreement for William Blair Investment Management Services. To the extent a client receives research or other advice incidental to brokerage services (market color, analysis, perspectives, opinions, commentaries, or ideas by the Equity Research department or the Institutional Sales & Trading department) William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 4  that is in consideration of commissions or other trading (related compensation), such research or advice is NOT an investment advisory service. Please note that brokerage services are regulated under different standards than those that apply to investment advisory services and differ in terms of the types of investment assistance provided, fees charged, and the rights and obligations of the parties involved. Assets under Management The Research Services described in this Brochure do not encompass the management of clients’ assets and therefore is not included in William Blair’s assets under management. As of December 31, 2024, in other advisory programs, William Blair had approximately $58.3 billion in assets under management, of which, we managed approximately 90% on a discretionary basis and 10% on a non-discretionary basis. ITEM 5 – FEES AND COMPENSATION Fees for Research Services Fees for Research Services are negotiable and vary from client to client based upon the nature of the Research Services provided and other factors (“Research Fees”). The specific Research Fee and terms of payment are agreed upon between the parties and are typically paid in arrears. Invoices are available upon request but may also be provided when deemed necessary. William Blair generally does not solicit or accept pre-paid Research Fees for provision of Research Services. Other Fees and Expenses The Research Fees paid to William Blair by the client cover only the Research Services provided by William Blair. Research Services are limited in duration to the period of each Equity Research Service for which William Blair receives a Research Fee, commencing on delivery of such services and terminated upon receipt thereof. Clients may, but are not required to, utilize William Blair’s brokerage services or William Blair Investment Management Services. If a client hires William Blair or an affiliate under a separate, written agreement for William Blair Investment Management Services described above, the client will pay an investment advisory fee, exclusive of and in addition to the Research Fees, typically deducted from its assets under management. Should a client decide to execute trades based on Research Services, such client will incur transaction costs such as commissions and William Blair will be acting solely as a broker-dealer in connection with such trades. Such transaction costs are exclusive of and in addition to the Research Fees. William Blair may also receive compensation, exclusive of and in addition to the Research Fees, for providing access to a company's management. The receipt of additional compensation beyond the Research Fees creates a potential conflict of interest that gives William Blair and its representatives an incentive to recommend William Blair Investment Management Services and William Blair’s brokerage services based on the compensation received (whether by the individual making the recommendation, by the firm (or affiliate), or both), rather than on a client’s needs. We address this conflict through disclosure in the Brochure. In addition, personnel of William Blair’s Equity Research department are not directly compensated based on the sale of securities that are generated by Research Services or on any revenue generated by William Blair Investment Management Services; however, the broader compensation pool for William Blair’s Equity Research department is funded in part by William Blair’s overall revenue. Finally, clients receiving Research Services have the option to obtain brokerage services and other investment advisory services through broker-dealers and investment advisers not affiliated with William Blair. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT William Blair does not charge or maintain other arrangements involving the payment of performance-based fees in connection with the provision of Research Services. The recommendations made in connection with the Research Services do not raise the conflicts associated with the side-by-side management of accounts. However, other William Blair affiliates do advise or manage client accounts that are subject to performance-based fee arrangements. William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 5  ITEM 7 – TYPES OF CLIENTS William Blair provides Research Services to institutional clients who represent that it has the sophistication, expertise and investment knowledge needed to evaluate the Research Services and investment risks independently of William Blair, including but not limited to mutual funds, investment advisory firms, banks, pension funds, insurance companies and money managers across North America, Europe and Asia. As discussed above, in order to receive Research Services, clients are not required to open or maintain a brokerage account with William Blair or a William Blair Investment Management account with William Blair or any affiliate. ITEM 8 – METHODS OF ANALYSIS AND RISK OF LOSS William Blair’s Research Services consist of impersonal investment advice that covers a broad range of companies and is not tailored specifically for particular clients. We seek to cover only companies that have above-average growth prospects and above-average quality. We use multiple factors to identify high-quality companies with attractive growth prospects, including the company’s product line, level of service, and management experience. Our research universe ranges in market capitalization with an emphasis on small-and mid-cap stocks. Research Services are typically industry and/or company specific and do not generally include strategic investment advice related to asset allocation at a macro level or overall portfolio composition. Research analysts in our Equity Research department perform analysis based on publicly available market, industry, and company data. Research analysts may also meet or speak with management and third parties (such as expert networks and customers/clients/suppliers of companies) to gather information and data for the provision of Research Services. Clients must make their own independent evaluation of the suitability of the Research Services and the recommendations contained therein to their (and their customers’) specific investment objectives, and of the merits of any investment decisions that are based on the Research Services. Information provided in connection with Research Services is for general use only. Neither the information nor any opinion expressed constitutes an offer, or an invitation to make an offer, to buy or sell any securities or other investment or any options, futures, or other derivatives related to securities or investments. As discussed throughout this Brochure, William Blair’s Research Services does not provide personalized investment advice and the information provided by Research Services does not consider the specific investment objectives, financial situation, or the particular needs of any specific person. William Blair may change our views and opinions expressed in Research Services and such views and opinions are subject to change without notice. We have exclusive authority to determine Research Service’s coverage of companies, markets and other subjects and topics and we can terminate, limit, or suspend coverage of any such company, market, subject or topic for any or no reason. We may also limit, suspend, or terminate Research Services in connection with regulatory restrictions or our own policies and procedures. William Blair expressly disclaims any responsibility for the completeness, accuracy or timeliness of the Research Services provided and William Blair is under no duty to update or revise the Research Services, the contents thereof or analysis, recommendations or opinions expressed therein. Nothing contained in this paragraph or elsewhere in this Brochure shall constitute a waiver by clients of any of their legal rights under applicable U.S. federal securities laws or any other laws whose applicability is not permitted to be waived. Methods of Analysis In the provision of Research Services, William Blair may rely on third-party sources for information to create a mosaic for a given company and industry that it believes to be reliable, but it does not guarantee the quality, accuracy, or completeness of third-party information, or any other information or data. William Blair makes no express or implied warranties with respect to the Research Services or any other information or data. When analyzing a specific company, William Blair uses a three-point system to rate stocks. Individual ratings reflect the expected performance of the stock relative to the broader market (generally the S&P 500, unless otherwise indicated), over the next 12 months. The assessment of expected performance is a function of near-, intermediate-, and long-term company fundamentals, industry outlook, confidence in earnings estimates, valuation (and our valuation methodology), and other factors. William Blair & Company, L.L.C. – Equity Research Services Form ADV Part 2A – March 31, 2025 6  • An Outperform Rating (O) means that the stock is expected to outperform the broader market over the next 12 months. • A Market Perform Rating (M) means that the stock is expected to perform approximately in line with the broader market over the next 12 months. • An Underperform Rating (U) means that the stock is expected to underperform the broader market over the next 12 months. • Not Rated (NR) means that the stock is not currently rated. William Blair’s valuation methodologies include (but are not limited to) price-to-earnings multiple (P/E), P/E-to- growth-rate (PEG) ratio, market capitalization or enterprise value/revenue multiple, enterprise value/EBITDA ratio, discounted cash flow, and others. These valuation metrics are compared to absolute, relative, and historical benchmarks that the individual analyst deems relevant. The stock ratings and valuations methodologies reflect the opinion of the individual analyst and are subject to change at any time. Stock ratings and valuation methodologies should not be used or relied upon as investment advice. Past performance is not necessarily a guide to future performance. Risk Of Loss Information contained in the Research Services depends on inputs from various sources, including third-party information that we believe to be reliable. If the inputs are not accurate, the resulting content of the Research Services may also be inaccurate. As discussed above, William Blair does not guarantee the quality, accuracy and/or completeness of any such third-party information or information from other sources. All investments in securities involve a risk of loss of all or a portion the investment. Local, regional, or global events such as war, acts of terrorism, the spread of infectious illness or other public health issue, recessions or other events could have a significant impact on the valuation of securities. Securities may decline in value due to factors affecting securities markets in general or industries represented in the securities markets. The value of a security may decline due to general market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. The value of a security may also decline due to factors that affect a particular industry or industries, such as labor shortages or increased production costs and competitive conditions within an industry. During a general downturn in securities markets, including those unrelated to financial markets (such as a global pandemic), multiple asset classes may decline in value simultaneously. Small- to Mid-sized market capitalization companies can present higher risks than do securities of larger capitalization companies, including more erratic earning patterns, more limited earnings history, reliance on one or a limited number of products and less liquidity. Investments in non-U.S. securities involve not only the risks associated with equity investments but additional risks including, government intervention and market disruption; market volatility due to adverse political, regulatory, market or economic developments internationally; exposure to interest rate, fluctuations in currency exchange rates, economic and political risks (all of which are magnified in emerging markets). ITEM 9 – DISCIPLINARY INFORMATION On September 29,2023, William Blair & Company, L.L.C. and William Blair Investment Management, LLC (collectively for purposes of this paragraph, William Blair) entered into a settlement with the SEC in connection with the agency’s industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement requires William Blair to pay a civil monetary penalty of $10,000,000 and retain a compliance consultant for a period of one year, following the format for all other recent electronic communications settlements. William Blair cooperated with the government’s inquiry and has already taken significant steps to further strengthen the firm’s compliance environment as it relates to electronic communications. William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 7  In May 2017, the SEC found that from 2010 until 2014, as a result of erroneous payments, William Blair negligently used mutual fund assets to pay for (i) distribution and marketing of fund shares outside of a written, board-approved rule 12b-1 plan and (ii) sub-transfer agent (“Sub-TA”) services in excess of board-approved limits. These payments totaled approximately $1.25 million and rendered certain of William Blair Funds’ disclosures concerning payments for distribution and Sub-TA services inaccurate. As a result of this conduct, the SEC found that William Blair violated Section 206(2) of the Investment Advisers Act and Section 34(b) of the Investment Company Act, and caused the William Blair Funds to violate Section 12(b) of the Investment Company Act and Rule 12b-1 thereunder. The SEC alleged that William Blair also failed to fully disclose to the William Blair Funds’ Board of Trustees that William Blair (and not a third-party service provider) would retain a fee for providing shareholder administration services to the William Blair Funds under a shareholder administration services agreement between certain of the Funds and William Blair. As a result of this conduct, William Blair violated Section 206(2) of the Investment Advisers Act. Without admitting or denying the findings, except as to the SEC’s jurisdiction over it and the subject matter of these proceedings, which are admitted, William Blair consented to the entry of an order instituting cease-and-desist proceedings, pursuant to Section 203(k) of the Investment Advisers Act and Section 9(f) of the Investment Company Act, making findings, and imposing a cease-and-desist order. William Blair also was assessed by the SEC a civil money penalty in the amount of $4,500,000. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS______________________________________ William Blair & Company, L.L.C. As described above, William Blair is a global investment firm offering investment management, brokerage, and investment banking services to clients. William Blair is registered with the SEC as a broker-dealer under the Exchange Act and as an investment adviser under the Advisers Act. In its capacity as an investment adviser, in addition to providing the Research Services described herein, William Blair’s Private Wealth Management department and its advisors provide discretionary and non-discretionary investment management services to clients for a fee. William Blair also manages accounts for wrap fee program clients. In its broker-dealer capacity, the firm executes securities transactions for clients, underwrites securities, distributes the William Blair Funds, and distributes shares of the William Blair SICAV, an undertaking for collective investments in transferrable securities (“UCITS”). William Blair’s Investment Banking department provides investment banking and financial advisory services to corporate and other institutional clients. In addition, William Blair provides strategic advice and solutions for companies, corporate executives, and other registered investment advisers. William Blair also provides financial planning, consulting and advisory services to high-net-worth individuals and families, foundations, endowments, retirement plans and other registered investment advisers. For more information, please see our Brokerage Relationship Guide, Brochure or Wrap Brochure, available at https://www.williamblair.com. William Blair Investment Management, LLC Our affiliate, William Blair Investment Management, LLC (“WBIM”), is an investment adviser registered with the SEC and manages accounts for institutional clients and pooled funds such as registered investment companies (including the William Blair Funds), UCITS (including the William Blair SICAV), private funds (including private funds where an affiliate of WBIM serves as the general partner or manager (the William Blair Private Funds)), and collective investment funds, among others. WBIM manages accounts for wrap fee programs and high net worth clients. WBIM also provides model portfolios to certain unified managed account program sponsors. For more information regarding WBIM and its services and products, please see WBIM’s Brochure, available at https://www.williamblair.com, and any relevant offering materials, such as prospectuses, statements of additional information and offering memoranda. By reason of the above-described advisory, brokerage, investment banking, and/or other activities that William Blair and/or its affiliates conduct, we and our affiliates may acquire confidential or material non-public information or be restricted from providing Research Services regarding certain securities. William Blair will not be free to divulge, or to act upon, any such confidential or material non-public information and, due to these restrictions, we may not be able to publish a research report, other information or otherwise provide Research Services with respect to such securities. William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 8  ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics and Personal Trading William Blair has adopted a Code of Ethics for Equity Research Services, pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, that governs a number of conflicts of interest we have when providing our advisory services (including Research Services) to clients. We have designed our Code to help ensure we meet our fiduciary obligation to our clients as well as to emphasize a culture of compliance within our firm. Subject to the restrictions described below, William Blair and its employees (including those in the Equity Research department) and its affiliates and their employees, are permitted to engage in personal securities transactions, including in the same or related securities that are the subject of the Research Services. These transactions may differ from, or may be inconsistent with, the advice given to William Blair Research Services’ clients, and the transactions may occur at or about the same time that such securities are the subject of the Research Services. This creates a conflict of interest between the interests of our Research Services’ clients and the interests of William Blair and its affiliates and their employees. To address this conflict of interest, William Blair adopted the Code of Ethics. • We distribute our Code to each employee, including those providing Research Services, at the time of hire and annually thereafter. We provide annual training and monitor employee activity on an on-going basis. According to our Code, all employees must: • Report their transactions in reportable securities quarterly and disclose reportable securities holdings annually; • Disclose all securities accounts in which they have a beneficial interest (i.e., they are the account owner or have a present economic interest in the account); Protect material non-public information; • • Refrain from trading, either personally or on behalf of another, on material non-public information or communicate material non-public information to another person in violation of the law; • Not purchase securities in an initial public offering (IPO) and obtain prior approval for participation in private placements; • Receive approval prior to engaging in outside business activities including serving on any Board of Directors of a public company; • Report gifts and business entertainment; and Certify on an annual basis as to compliance with our Code. • If you would like a copy of the Code of Ethics, please contact our Compliance team at ecmcomply@williamblair.com or (312) 236-1600 or write to us at the following address: William Blair & Company, L.L.C. Attn: Capital Markets Compliance 150 North Riverside Plaza Chicago, IL 60606 In addition to the Code of Ethics, William Blair maintains a Research Department Trading Policy that governs personal trading for all Equity Research department employees and their related accounts. William Blair’s compliance department monitors the personal trading activities of the Equity Research department. Participation or Interest in Client Transactions William Blair or an affiliate does, and seeks to do, business with companies covered by the Equity Research department analysts. Employees of William Blair or its affiliates may serve as officers or directors of companies William Blair & Company, L.L.C. – Equity Research Services Form ADV Part 2A – March 31, 2025 9  covered by such research analysts. William Blair or its affiliates may hold securities of covered companies in the ordinary course of their business. For instance, William Blair may have long or short positions in, act as a principal in, and buy or sell the securities referred to in Research Services. As a result, William Blair has a conflict of interest that could affect the objectivity of Research Services’ content. William Blair addresses this conflict of interest through disclosures in this Brochure, disclosure on any written content provided under Research Services (such as a research report) and by ensuring that no part of a research analyst’s compensation is, or will be related, directly or indirectly, to the specific recommendations or views expressed by the research analyst contained within Research Services’ content. Political Contributions We do not allow our employees to make or solicit political contributions to support political candidates or elected officials for the purpose of obtaining or retaining business with governmental entities. We permit employees to make personal contributions to support candidates for whom they are eligible to vote subject to William Blair’s political contributions policy. ITEM 12 – BROKERAGE PRACTICES William Blair does not engage in securities transactions in connection with the provision of Research Services and, as a result, does not select broker-dealers. ITEM 13 – REVIEW OF ACCOUNTS Provision of Research Services does not require a client to establish an account with William Blair. William Blair does not manage client accounts and does not provide personalized investment advice tailored to a client’s investment objectives or existing portfolios in connection with Research Services. Therefore, there an no applicable client account reviews. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION William Blair does not compensate any person for client referrals in connection with Research Services. As discussed above, the broader compensation pool for William Blair’s Equity Research department is funded in part by William Blair’s overall revenue, including brokerage commission and William Blair Investment Management revenue, some of which may be generated by Research Services. Finally, clients receiving Research Services have the option to obtain brokerage services and other investment advisory services through broker-dealers and investment advisers not affiliated with William Blair. ITEM 15 – CUSTODY William Blair does not have custody of client funds or securities in connection with the provision of Research Services. ITEM 16 – INVESTMENT DISCRETION William Blair does not have or accept discretionary authority to buy or sell securities for client accounts or otherwise act for client accounts in connection with the provision of Research Services. ITEM 17 – VOTING CLIENT SECURITIES William Blair does not have authority to vote proxies in connection with the provision of Research Services. ITEM 18 – FINANCIAL INFORMATION William Blair has no known financial condition that we believe is likely to impair our ability to meet our commitments to our Research Services’ investment advisory clients. Additionally, we have not been the subject of any bankruptcy petition during the past ten years. You can obtain a copy of our most recent financial statement on our website at https://www.williamblair.com under Statement of Financial Condition. William Blair & Company, L.L.C. –Equity Research Services Form ADV Part 2A – March 31, 2025 10 

March 31, 2025 FORM ADV PART 2A – Appendix 1 (Wrap Fee Program Brochure) William Blair & Company, L.L.C. 150 North Riverside Plaza Chicago, Illinois 60606 (312) 236-1600 www.williamblair.com This wrap fee program brochure provides information about the business practices of William Blair & Company, L.L.C. If you have questions about the contents of this wrap fee program brochure, please contact us at pwmcompliancegroup@williamblair.com or (312) 236-1600. The information in this wrap fee program 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 William Blair & Company, L.L.C. also is available on the SEC’s website at www.adviserinfo.sec.gov. William Blair & Company, L.L.C. is registered as an investment adviser with the SEC. Our registration as an investment adviser does not imply a certain level of skill or training.  ITEM 2 – MATERIAL CHANGES William Blair & Company, L.L.C. (“William Blair” or “firm” or “we”) has updated our Wrap Brochure (also known as Form ADV Part 2A-Appendix 1) as of March 31, 2025. Our last update was an annual amendment as of March 29, 2024. This Brochure contains routine updates, including, but not limited to, information regarding assets under management. The Brochure as also been updated to eliminate references to SYSTM Wealth Solutions LLC and to reflect changes to our Merchant Banking Program, including the removal of certain fees in connection therewith. As a reminder, we may at any time update our Wrap Brochure and will either send you a copy or offer to send you a copy (either electronically or in hard copy) as may be necessary or required. If you would like another copy of this Wrap Brochure, you may download it from the SEC’s website at www.adviserinfo.sec.gov, or you may contact our Compliance team at (312) 236-1600 or pwmcompliancegroup@williamblair.com. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 1  ITEM 3 – TABLE OF CONTENTS ITEM 2 – MATERIAL CHANGES ....................................................................................................................................... 1 ITEM 3 – TABLE OF CONTENTS ...................................................................................................................................... 2 ITEM 4 – SERVICES, FEES AND COMPENSATION ............................................................................................................ 3 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ..................................................................................... 15 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION ................................................................................. 16 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .................................................................... 22 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS .......................................................................................... 23 ITEM 9 – ADDITIONAL INFORMATION ......................................................................................................................... 23 William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 2  ITEM 4 – SERVICES, FEES AND COMPENSATION Wrap Fee Program Services William Blair serves as sponsor and investment manager for the William Blair Comprehensive Fee Program (also known as the Wrap Fee Program) 1. William Blair offers this Wrap Fee Program to our Private Wealth Management (“PWM”) clients. We collectively refer to our advisors in PWM as “PWM Advisors.” PWM Advisors typically manage the accounts in our Wrap Fee Program according to each client’s investment objectives, financial circumstances, and risk considerations. According to a client’s investment objectives and subject to reasonable investment restrictions, a PWM Advisor may elect to allocate all or a portion of that discretionary advisory client’s assets to one or more William Blair proprietary models (“William Blair Proprietary Home Office Models”). Under this Wrap Fee Program, clients pay a single fee for discretionary investment management services and trade execution costs and, in certain instances, other services such as custody, recordkeeping and reporting. You do not pay separately for commissions for each trade we execute in this type of account. Instead, we incur the cost of executing securities transactions. This creates a conflict of interest because William Blair is incented to initiate fewer trades in your Wrap Program Fee Account to minimize expenses for William Blair. To manage this conflict of interest, we monitor account activity to help identify inactivity. For the avoidance of doubt, William Blair Wrap Fee Program client accounts will incur certain fees and expenses (including but not limited to SEC transaction fees) which are disclosed in confirmations and/or account statements. William Blair receives compensation from clients whose assets are held in Wrap Fee Program Accounts. William Blair and its PWM Advisors have a conflict of interest when they recommend that a prospective client or a current brokerage client open a Wrap Fee Advisory Account that will generate ongoing fees instead of no fees (for a prospective client) or transaction-based fees for a brokerage client. To participate in the Wrap Program, an advisory client must maintain a brokerage account with William Blair, as introducing broker-dealer. As described more fully below, Fidelity Investments and/or its various affiliates including but not limited to National Financial Services and Fidelity Brokerage Services (collectively, “NFS”) acts as clearing broker and provides custodial, brokerage and certain other services for William Blair Wrap Program advisory clients. Clients are not required to use William Blair, as introducing broker-dealer, and NFS for clearing and custodial services. However, if a client chooses not to hire William Blair and NFS in these capacities, they will not participate in this Wrap Program and should see the William Blair Form ADV Part 2A (“William Blair Brochure”) or contact their PWM Advisor for more information. In effecting transactions for Wrap Fee Program clients, all trades are directed to William Blair’s sell-side broker-dealer trade desk for execution through various trading venues. In effecting these transactions, William Blair takes all reasonable steps to seek best execution of orders. William Blair’s sell-side broker dealer has policies and procedures that are designed to obtain the best possible execution result, subject to the nature of the order, any restrictions placed upon us in filling the order and the market in question. William Blair’s sell-side broker dealer takes into consideration a range of different factors which includes price but may also include such other factors as timely execution, the liquidity of the market, the cost of the transaction and the nature of the financial transaction. In some markets, price volatility may mean that the timeliness of the execution is a priority, where other markets that have low liquidity may mean the execution itself may constitute the best execution. 1 As of January 1, 2021, for clients with a William Blair client Fee & Discount Commission advisory agreement, William Blair no longer charges a commission and these agreements as well as Comprehensive Fee agreements are considered under the Wrap Fee Program. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 3  For the William Blair Proprietary Home Office Models, William Blair uses a third-party provider to generate orders, which in almost all instances will route trades to William Blair’s broker-dealer trade desk for execution as described more fully above. After all trades are completed for accounts in the Proprietary Home Office Models, the underlying investment recommendations and allocations are disseminated to PWM Advisors who have the discretion to accept, reject or modify these recommendations for custom managed accounts. While a Wrap Fee Program client is not charged an additional fee for the third-party service provider in connection with Proprietary Home Office Models, William Blair retains a larger portion of the advisory fee to cover the administrative cost of this third-party provider and the PWM Advisor retains less of the advisory fee. This creates an incentive for the PWM Advisor NOT to utilize the Proprietary Home Office Models. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; • Clients can restrict the use of Proprietary Home Office Models through providers of an asset management platform (“Platform”),; and • • Conflicts of interest are disclosed in this Wrap Brochure, Form CRS, Part 2A, and in the investment advisory agreement. As described in Item 6, for our Wrap Fee Program portfolios, we consider a broad array of securities and investment vehicles including equity securities, debt securities, mutual funds or other investments that we consider suitable for a client based on their particular circumstances. Some PWM Advisors utilize programs established through Platforms that provide access to investment advisors, including our affiliate William Blair Investment Management, LLC, (“Sub-Managers”); such Platform programs are NOT included in the Wrap Fee Program. In some instances, PWM Advisors may recommend to certain clients that they establish a separate investment advisory account managed by our affiliate, William Blair Investment Management, LLC. (“WBIM Separate Accounts”). In these instances, PWM’s clients are free to accept or reject our recommendation. If a PWM client accepts our recommendation, the client would enter into a separate investment advisory agreement with William Blair Investment Management, LLC (“WBIM”) setting forth all fees (including an investment management fee) and expenses (including execution costs). Additionally, William Blair has entered into a Sub-Management Agreement with its affiliate, WBIM. If authorized by the client, William Blair has the discretion to hire its affiliate, WBIM, as a sub-manager to manage those allocated assets (“Allocated Assets”), with discretion (“WBIM Sub-Advisory Accounts”). WBIM does not execute transactions through William Blair as introducing broker. Instead, WBIM effects trades through third party broker-dealers. Therefore, transactions entered through WBIM Sub-Advisory Accounts will be charged separately for commissions and other costs and are in addition to the management fee for the Wrap Fee Program. William Blair has established the “MB Investments Program,” as described below,to provide select clients with access to certain investment opportunities generated through William Blair’s proprietary, global relationship network. Costs and expenses related to the MB Investments Program are in addition to any management fee you pay in connection with the Wrap Fee Program.. Information regarding limited partner eligibility, fees, expenses, risks, conflicts of interest and terms and conditions are set forth in the MB Investments Program offering documents. The “MB Investments Program” provides select clients with access to certain investment opportunities generated through William Blair’s proprietary, global relationship network. William Blair MB Investments GP, LLC, a William Blair affiliate, (“MB General Partner”), serves as the general partner to William Blair MB Investments, L.P., a Delaware series limited William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 4  partnership (“MB Partnership”). The MB Partnership’s investments are made in (a) other investment funds (such as private equity, debt, venture capital, and real estate) and (b) direct investments in private capital and business combination transactions including private company financings (ranging from early-stage to late stage rounds), leveraged and unleveraged buyout transactions, and management buyout transactions; and (c) co-investment opportunities (“Co-Investments”) (collectively, “MB Investments”). A new series will typically be formed to invest in each MB Investment (“Series”). An investor must independently and affirmatively elect to participate in the MB Investments Program and to invest in a Series and, if admitted as a limited partner, will receive interests in that Series (“Interests”). Interests in a Series are in Client’s name and ownership is recorded in the books and records of the MB Partnership. In certain cases (e.g., where the Co-Investment is made through the sponsor’s investment vehicle, such Co-Investment will be held in Client’s name and ownership will be recorded in the books and records of the Co-Investment issuer. The MB Partnership is excluded from regulation under the Investment Company Act of 1940 and its securities are exempt from registration under the Securities Act of 1933. Accordingly, investors are not afforded the protections of those Acts. As discussed in the MB Partnership offering documents and in the non-discretionary investment advisory agreement, the MB General Partner uses its good faith efforts to determine the fair market value of Interests. To the extent a client participates in the MB Investments Program through a non-discretionary investment advisory account, William Blair earns an investment advisory fee based on the fair market value of the Interests. Our affiliate, the MB General Partner, values the Interests. The higher the fair market value of the Interests or Co-Investment, the more William Blair earns in advisory fees, creating a conflict of interest. The MB General Partner can delegate to William Blair certain management and administrative responsibilities including the authority to select investment opportunities and make investment-related decisions on behalf of the MB Partnership. Investment advice is provided directly to the MB Partnership and not individually to the limited partners. William Blair and PWM Advisors will not provide investment advice or recommendations to clients with respect to participation in the MB Investments Program or investing in any Series.. A client independently decides to participate in the MB Investments Program and affirmatively elects to purchase Interests in each MB Partnership Series.,. A Series limited partner can contribute capital through a brokerage account, advisory account, bank account or otherwise. Once the client invests in any Series through a non-discretionary advisory account, William Blair will provide asset allocation, monitoring and performance reporting. Information regarding limited partner eligibility, fees, expenses, risks, conflicts of interest and terms and conditions are set forth in the MB Partnership offering documents. Account Fees William Blair charges a single comprehensive fee for the provision of services to Wrap Fee Program Clients. The comprehensive fee includes investment advisory services and trade execution costs (including costs involved in purchasing and selling no-load mutual funds) for an account. Under certain limited circumstances, William Blair, as a broker or dealer, may accept unsolicited orders from clients and may charge a commission on any unsolicited order initiated by the client. We can charge up to a 2.00% annual fee on all assets, subject to negotiation. Fees are negotiable. William Blair may, but is not obligated to, aggregate assets under management for multiple accounts owned across certain related accounts when determining the amount of advisory fee charged to Wrap Fee Program Clients. Our compensation under our Wrap Fee Program may be lower than our standard fee schedule; however, the overall cost of a wrap arrangement may be higher than a client otherwise would pay if the client paid our standard fee schedule and negotiated transaction costs and any other services (e.g., custody, recordkeeping and reporting) through William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 5  a broker-dealer. William Blair’s wrap program fees and standard advisory fees are negotiable. The wrap program advisory fee charged may vary based on the underlying holdings in the client’s accounts (for example, a client may have an account with only fixed income securities that may be charged a lower advisory fee than that same client’s account with only equity securities). Based on this wrap fee program advisory fee differential, William Blair and its PWM Advisors have a conflict of interest when purchasing securities. We customarily bill fees quarterly, in advance, based on the market value of portfolio assets (including dividends and interest) as of the last day of the prior quarter. When charged in advance, fees are calculated on the total market value of each account (including on assets invested in cash and cash equivalents and on accrued interest and dividends) on the last day of the prior quarter. When charged in arrears, fees are calculated on the total market value of each account (including on assets invested in cash and cash equivalents and on accrued interest and dividends) on the last day of the current quarter. NFS, as client’s custodian, shall be responsible for valuing all assets in a client’s account; valuation is not the responsibility of William Blair. Securities without a readily available market price shall be valued as determined in good faith by NFS, as appropriate, to reflect its fair value. William Blair will cooperate with NFS in its good faith efforts to determine fair market value. With respect to client’s account assets in a private fund (including a William Blair Private Fund, as described more fully below), the alternative investment managers and underlying vehicles are responsible for providing NFS with valuation in accordance with applicable laws. . Sub-Managers, Platforms and Platform service providers may or may not be billed separately to the client depending on the type of Investment Advisory Agreement. We do not charge clients in the Wrap Fee Program account level advisory fees on the William Blair Funds, William Blair Private Funds (as defined more fully below), to the extent that such funds charge a separate management fee, or any assets agreed to by the client and William Blair to be held in the account as an accommodation and not subject to supervision held in Wrap Fee Program accounts. Ongoing fees reduce the value of an investment portfolio over time. Because of the fees you pay, you have a smaller amount invested that is earning a return whether the fee is paid separately or debited from a portfolio’s assets. You are encouraged to discuss the impact of fees with your PWM Advisor. Other Fees and Expenses In addition to, and separate from, the investment management fee, our clients pay other costs and charges in connection with their accounts or certain securities transactions payable to William Blair or its affiliates or payable to parties other than us, including but not limited to the following: Taxes, duties and other governmental charges, such as transfer taxes; Costs associated with international exchange transactions; Electronic fund, wire transfer and other transfer fees; Fees imposed in connection with certain custodial, trustee or other account services; • Auction fees; • • • • • Account maintenance or service fees; • Fees in connection with transferring your account to another investment adviser or broker-dealer (also known as ACAT exit fees); • Regulatory transaction fees; • Securities lending fees; • Multi-margin fees; • Non-purpose loan fees; • Access fees for certain private funds; • Mutual fund redemption fees if shares are sold before the designated time period as set forth in the • prospectus; Fees and expenses associated with mutual funds (funds (including William Blair Funds), exchange traded funds and other commingled products (such as William Blair Private Funds) as well as unaffiliated private funds; William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 6  Pass-through or other fees associated with American Depositary Receipts; Charges mandated by law or regulation; and • • Activity assessment fee; • • Fees in connection with the establishment, administration, maintenance, or termination of accounts (including retirement or profit-sharing plans or trust accounts). Further information regarding the fees and expenses are found in your investment advisory agreement with William Blair as well as in other documents such as William Blair’s Customer Relationship Summary (“Form CRS”) and mutual fund and private fund offering documents. For more information regarding fees and expenses, please discuss with your PWM Advisor. Fees and Expenses Related to Private Funds Private fund investments may be held in a brokerage account, investment advisory account, directly (if the client meets the private fund’s minimum investment) or through a private fund platform. If you hold a private fund investment in a brokerage account, you will typically pay an upfront placement agent fee plus the underlying costs of the private fund investments (which in some cases includes a platform access fee). If a client chooses to hold a private fund in an advisory account (including a William Blair Wrap Program account), you will pay an investment advisory fee to William Blair plus the underlying costs of the private fund investment (which in some cases includes a platform access fee). Private funds are highly illiquid and cannot be sold or transferred and you will pay the ongoing, annual advisory fee for the life of the private fund investment. The fair market value of interests in an underlying unaffiliated private fund shall be included for purposes of calculating William Blair’s advisory fee. William Blair relies on the issuer and custodian to provide a good faith, fair market value. The timing and process for fair market valuation of private fund investments is not as reliable as valuations of publicly traded securities. Depending on the size of the advisory fee and the market value of the private fund investment over the life of the fund, William Blair could earn more revenue than if the same investment was held in a brokerage account or directly with the issuer. Therefore, to earn these ongoing advisory fees, William Blair and your PWM Advisor are incented to recommend that you purchase interests through your William Blair Wrap Program advisory account instead of in a brokerage account. If a client invests in private funds through a private fund platform, clients may pay an access fee. Neither William Blair nor the PWM Advisor earns an access fee. William Blair Private Funds (affiliated private funds advised by WBIM) also bear their own operating and other expenses. When you invest in a William Blair Private Fund in your account, you are subject to the William Blair Private Fund’s internal management fees and other expenses; however, we do not charge our investment management fee in addition to the William Blair Private Fund’s internal management fee. Instead, we exclude the assets invested in the William Blair Private Funds when we calculate the investment management fees we charge you. However, our affiliate WBIM, compensates William Blair (and, in turn, PWM Advisors) up to 50% of the management fee it earns on PWM’s clients’ assets invested in the William Blair Private Funds. In certain cases, where our affiliate does not charge a separate fee, assets managed by that affiliate will be included in the investment management fees we charge you, and we will compensate our affiliate up to 50% of the fee that is based on the amount of assets managed by that affiliate. Receipt of, or the prospect of receiving, this compensation influences William Blair and PWM Advisors to recommend or invest in William Blair Private Funds over non-affiliated private funds and creates a conflict of interest. If the payment William Blair receives from WBIM is higher than the fee it receives from the client for managing the account, then William Blair’s overall fee will increase as the allocation to William Blair Private Funds increases. For more information on conflicts of interest, please discuss with your PWM Advisor and see documents, including but not limited to, this Wrap Brochure, William Blair Brochure, Form CRS, advisory agreements, William Blair Private Funds’ offering documents, separate client account opening documentation and/or separate disclosure documents. In addition to fees and expenses listed above, other expenses include: sales expenses; accounting, tax and audit expenses; legal expenses; operating and other expenses such as those associated with the formation, operation, dissolution, winding-up or termination; and other expenses not listed. William Blair Private Funds that invest with an William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 7  underlying manager or in underlying funds bear associated fees and expenses. Feeder funds generally bear a pro rata portion of the expenses associated with the related master fund. Details regarding expenses can be found in the applicable offering memorandum and other governing documents. Investing in our William Blair Private Funds creates a conflict of interest based on compensation we receive from our affiliate, WBIM. To help manage conflicts, we have implemented various controls including the following: • We maintain our Code of Ethics (“Code”), which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; • A client does not need to invest in a William Blair Private Fund; • Conflicts of interest are disclosed documents including but not limited to, this Wrap Brochure, William Blair Brochure, Form CRS, advisory agreements, Private Fund offering documents and/or separate disclosure forms; and • We offset investment management fees on a client’s assets held in the William Blair Private Funds if such funds charge a separate management fee. MB Investment Fees Clients will pay a performance-based fee, if applicable, in connection with MB Investments, an advisory fee to William Blair that is based on, in part, the value of such investments, and, as a limited partner in such investments, the costs and expenses that are allocated to such partners, as more fully described in the applicable fund documents. While William Blair and PWM Advisors do not provide any recommendations or advice with respect to client’s independent decision to participate in the MB Partnership Program or subscribe for interests in any MB Partnership Series, receipt of, or the prospect of receiving, performance-based fees, if applicable, advisory fees on the fair market value of interests, investment banking fees and any internal management fee on a William Blair Managed MB Investment creates conflicts of interest to favor MB Investments instead of investing in unaffiliated private funds, directly or through an unaffiliated private fund platform. To help manage conflicts: • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own and conduct annual training on our Code; • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; • A client does not need to invest in private funds, including any MB Investment; • If a client meets the minimum investment amount, the client may be able to invest directly instead of through any private fund platform, including the MB Investments Program; and • MB Partnership maintains written policies and procedures with respect to the fair market valuation of Interests and allocation of investment opportunities. Private funds, including the William Blair MB Partnership, are subject to annual audits; and • • Conflicts of interest are disclosed in documents including, but not limited to, this Brochure, Form CRS, advisory agreements, William Blair MB Partnership offering documents and/or separate disclosure forms. Mutual Fund and ETF Fees and Expenses For clients whose guidelines allow a portion of their assets to be invested in mutual funds (both open-end funds and closed-end funds) or exchange traded funds: • When invested in shares of unaffiliated funds (funds not advised by WBIM) in your account, you are subject to our investment management fees in addition to the mutual fund or exchange traded fund internal management fees and other expenses (as described below). In addition, exchange traded funds and closed end funds may trade at William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 8  prices that vary from their net asset value, sometimes significantly. Performance of a fund pursuing a passive index-based strategy may diverge from the performance of the index. When invested in shares of the William Blair Funds (affiliated mutual funds advised by WBIM in your account, you are subject to the William Blair Funds’ internal management fees and other expenses (as described below); however, we do not charge our investment management fee in addition to the William Blair Funds’ internal management fee. Instead, we exclude the assets invested in the William Blair Funds when we calculate the investment management fees we charge you. In certain cases, where our affiliate does not charge a separate fee, assets managed by that affiliate will be included in the investment management fees we charge you, and we will compensate our affiliate up to 50% of the fee that is based on the amount of assets managed by that affiliate. • When our affiliate, WBIM, charges a management fee, WBIM compensates William Blair (and, in turn, PWM Advisors) up to 0.35% on PWM’s clients’ assets invested in the William Blair Funds. Receipt of, or the prospect of receiving, this compensation influences William Blair and PWM Advisors to invest client assets in the William Blair Funds over unaffiliated mutual funds and creates a conflict of interest. If the payment William Blair receives from WBIM is higher than the fee it receives from the client for managing the account, William Blair’s overall fee will increase as the allocation to the William Blair Funds increases. For more information on conflicts of interest please discuss with your PWM Advisor and see documents including but not limited to this Wrap Brochure, William Blair Brochure, Form CRS, advisory agreements, the William Blair Funds’ prospectus and other offering documents, separate account opening documentation and/or separate disclosure documents. Share Class Selection As noted above, investment in a mutual fund is subject to certain internal fees and expenses, such as advisory, administrative, custody and other fees and expenses charged by the fund, which shareholders bear on a pro rata basis. Mutual funds offer a variety of share classes, which hold the same portfolio securities but differ in total cost due to the imposition of various fees (such as 12b-1 fees, sub-transfer agency and shareholder services fees). A higher cost share class of a particular mutual fund will result in lower investment performance compared to a lower cost share class of the same fund. William Blair does not typically use share classes that charge 12b-1 fees if there is a non-12b-1 share class available. If a 12b-1 share class is used in the future, any such fees paid to William Blair will be rebated to clients. William Blair seeks to purchase or recommend the least costly share class that is available on the relevant custodial platform and for which a client is eligible. Note that there may be other less costly share classes offered by the fund that are not available on the relevant custodial platform. The lowest cost share class available on one custodial platform may not be available on other custodial platforms. William Blair monitors on a periodic basis for the launch and availability of lower cost share classes and will seek to exchange investors into such share classes on a periodic basis following the availability of such lower cost share class. William Blair will be able to more expediently identify lower cost share classes and exchange holdings for investors when their accounts are held on the NFS custodial platform as opposed to other custodial platforms. Certain mutual funds will waive eligibility criteria if requested by a financial intermediary, such as an investment adviser. As a general practice, William Blair does not request waivers of the share class criteria set by mutual fund companies even if the prospectus of the fund states that such a waiver is possible. This means that clients generally will not receive the benefit of being able to invest in a lower cost share class that might be obtainable if William Blair were to request a waiver of the criteria set by a fund company to purchase a particular share class. Some mutual funds also charge redemption fees if shares are sold before the designated holding period set forth in a prospectus. William Blair does not reimburse your account for redemption fees even if William Blair, using discretion, caused your shares to be sold before the designated time period set forth in a prospectus. These fees and expenses, including the total net operating expenses of each fund, including the William Blair Funds, are set forth in the applicable prospectus, and, with respect to the William Blair Funds, some of these fees and expenses are paid by the William Blair Funds to William Blair or its affiliates. Clients can obtain more information by William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 9  reviewing a prospectus for the underlying mutual funds, including the William Blair Funds, or exchange traded funds. As with all investments, you should ask your PWM Advisor why the particular funds held in your advisory account are appropriate for you in consideration of your expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, the amount of the advisory fee charged and how these fees and expenses adversely affect long-term performance. Fees and expenses are exclusive of and in addition to any investment management fees we charge you. As described above, we do not charge our investment management fee in addition to a William Blair Fund’s internal investment management fee. William Blair and its affiliate, WBIM, have contractually agreed to bear some of the operational expenses for many of the William Blair Funds. The extent to which William Blair or WBIM bears these expenses varies by Fund. Therefore, when negotiating those expenses with third party service providers, William Blair and WBIM have an economic incentive to favor a fee structure that shifts expenses from the William Blair Funds for which William Blair and WBIM have a lesser (or no) reimbursement obligation. Further, to the extent William Blair has discretion to allocate client assets among the William Blair Funds, they have an incentive to allocate to the William Blair Funds where William Blair or WBIM has a limited reimbursement obligation. As always, clients have the option to purchase recommended investment products through broker-dealers or agents not affiliated with William Blair and can restrict William Blair Funds in their account. Provision of services to the William Blair Funds by William Blair or WBIM presents conflicts of interest because we are incented to invest in the William Blair Funds based on compensation to us or our affiliates rather than a client’s needs. We have an additional conflict of interest because our affiliate, WBIM, compensates us and PWM Advisors to invest our client’s assets in the William Blair Funds. To help manage conflicts, we have implemented various controls including the following: • We maintain a Code, which detail our fiduciary duty to put clients’ interests ahead of our own and conduct annual training on our Code; • We monitor portfolio holdings to ensure they are consistent with each client’s objectives; • A client can restrict the purchase of William Blair Funds; • Conflicts of interest are disclosed in documents including but not limited to, this Wrap Brochure, William Blair’s Brochure, Form CRS, advisory agreements, prospectuses and other offering documents, separate client account opening documentation and/or separate disclosure forms; and • We offset investment management fees on a client’s assets held in the William Blair Funds if such funds charge a separate management fee. Other Fees and Expenses Related to William Blair Investment Management, LLC Sub-Advisory Accounts If authorized by the client, PWM Advisors may use their discretion to hire our affiliate, WBIM, as a sub-manager. PWM Advisors do not conduct initial or ongoing due diligence on WBIM. AWBIM Sub-Advisory Account is subject to a separate addendum setting forth all fees (including an investment management fee, which offsets William Blair’s advisory fee) and expenses (including execution costs, which will be in addition to any advisory fee).. For further information, please see William Blair’s Brochure, advisory agreement, and WBIM’s Form 2A or ask your PMW Advisor. Fees and Expenses Related to WBIM Separate Accounts As discussed above, PWM Advisors may recommend to certain clients that they establish WBIM Separate Accounts. William Blair and PWM Advisors do not conduct initial or ongoing due diligence on our affiliate, WBIM. If a PWM client accepts our recommendation, the client would enter into a separate investment advisory agreement with WBIM setting forth all fees (including an investment management fee) and expenses (including execution costs). This arrangement is NOT part of the Comprehensive Fee Program and is subject to a separate agreement with WBIM (including an investment management fee) and expenses (including execution costs). For further information, please see William Blair’s Brochure, and WBIM’s Form 2A or ask your PMW Advisor. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 10  Compensation The PWM Advisor who manages your Wrap Fee Program account receives a portion of the comprehensive fee you pay to us as compensation for his or her services. William Blair and its affiliates have established an internal referral program to support growth across the organization. William Blair employees can be paid direct compensation for generating qualified leads across William Blair and affiliates. Therefore, employees are incented to refer a client to our Wrap Fee Program. William Blair employees, including when the employees are acting in their role as registered representatives, receive compensation for their clients’ investment in securities or other investment products, including asset-based compensation when the clients invest in mutual funds, including the William Blair Funds, except for William Blair’s Wrap Fee Program accounts. This practice constitutes a conflict of interest for the William Blair employee (and, indirectly, William Blair) in that it gives them an incentive to recommend investment products based on the compensation received. As discussed above, when you invest in William Blair Private Funds or open a WBIM Separate Account or when we invest in shares of the William Blair Funds in your account or (subject to below) allocate assets to WBIM Sub-Advisory Accounts, you are subject to the William Blair Funds’ or William Blair Private Funds’ internal management fees and other expenses and William Blair Investment Management LLC’s management fees and execution costs (as described above); however, we do not charge our investment management fee in addition to the management fees earned by our affiliate. However, as discussed more fully above, William Blair does receive compensation from our affiliate, WBIM, based on PWM’s clients’ assets invested in William Blair Funds, William Blair Private Funds and in WBIM Sub- Advisory and WBIM Separate Accounts, creating a conflict of interest. Notwithstanding the foregoing, in certain instances in connection with WBIM Sub-Advisory Accounts, William Blair Funds or William Blair Private Funds, we may include the assets managed by WBIM in William Blair’s investment management fee, so long as WBIM does not charge a separate or additional investment management fee to the client for the assets on which it sub-advises or otherwise manages. In this regard, William Blair will share a portion of its advisory fee with WBIM. In addition, clients should review the prospectuses and other offering materials for the William Blair Funds. The William Blair Funds’ prospectuses and other offering materials are available on the William Blair Funds’ website at www.williamblairfunds.com or by calling 1-800-742-7272. Clients should review the Private Fund offering materials. In addition, for a WBIM Separate Account, clients should review the investment management agreement and WBIM’s Brochure. William Blair has entered into agreements with NFS whereby NFS acts as a clearing broker and provides custodial, brokerage and certain other services for certain retail clients of William Blair. Pursuant to an agreement with NFS, in addition to a one-time payment by NFS to William Blair upon contract renewal in 2023, William Blair receives certain fees and credit including, but not limited to, those set forth in this section. NFS reimburses William Blair for certain transition fees incurred in moving new client assets to the NFS platform (the “Transition Credit”). In certain cases, the Transition Credit may exceed the costs incurred by the client in moving assets from their prior custodian to NFS. If William Blair terminates its agreements with NFS, William Blair repays NFS a portion of the Transition Credit. Also pursuant to an agreement with NFS, William Blair receives from NFS a portion of the fees it charges or credits it pays related to certain other services, including securities lending, multi-margin accounts, non-purpose loans and certain fixed income trades executed through systems made available by NFS, among other services offered for certain types of client accounts as disclosed in separate agreements with NFS. If you choose to enter a multi-margin relationship, our advisory fees increase as the market value of your investment portfolio increases. Our offer to provide margin as a strategy creates a conflict of interest since we stand to receive increased advisory fees and William Blair earns margin revenue from NFS based on your interest payments. If you choose to loan your securities, NFS pays you a fee based on the loan. NFS reduces the amount of the loan fee paid to you by the amount that NFS pays to William Blair. Our continued receipt of our advisory fee on the security as if it were not loaned as well as NFS paying us a portion of your loan fee creates a conflict of interest. In addition, because we receive this fee and have discretionary authority over purchases and sales of securities in your account, we are incented to purchase and hold securities that are available to be loaned (or generate a larger loan fee) instead of those that are ineligible to be William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 11  loaned or garner a lower fee. PWM Advisors are compensated on multi-margin and securities lending. NFS offers non-purpose loans, for a fee, collateralized by assets in your advisory accounts. NFS shares with William Blair a portion of the interest earned on non-purpose loans. As with multi-margin, William Blair’s receipt of a portion of NFS’ interest fees on non-purpose loans create a conflict of interest and incentivizes William Blair to recommend NFS over other providers. In addition, William Blair charges its advisory clients certain operational fees such as: fees for account transfer (“ACAT Exit Fees), wire transfers, foreign exchanges, bounced checks, IRA terminations, as well as other fees described in the client account documentation. The amount that William Blair charges its clients is higher than the amount that William Blair pays to NFS in connection with those services. William Blair keeps the difference between the fee its clients pay, and the amount paid to NFS for coordination and oversight of these services provided through NFS as well as to generate revenue. This presents a conflict of interest since setting a higher fee increases the revenue William Blair receives even though it results in you paying higher fees. These markups are in addition to the investment advisory fees you pay us, and you should consider the additional revenue that William Blair receives when evaluating the appropriateness of our investment advisory fees. NFS has also agreed to pay William Blair business development and technology development credits. If William Blair terminates its agreements with NFS, William Blair repays NFS a portion of these credits. These fees and credits cause conflicts of interest because: 1) they incentivize William Blair to recommend clients utilize NFS custodial and other services instead of another custodian; 2) they incentivize William Blair to recommend securities lending and margin activity; and 3) they incentivize William Blair to maintain its relationship with NFS to avoid repayment of Transition Fees and other credits. To help manage these conflicts, we rely on controls including the following: • payments and credits as well as a description of conflicts are disclosed in documents including, but not limited to, this Wrap Brochure, William Blair’s Brochure, Form CRS, advisory agreements, prospectuses and other offering materials, separate client account opening documentation and/or separate disclosure forms; • PWM Advisors are not compensated based on Transition Fees, or business, infrastructure o, technology credits (PWM Advisors are compensated on multi-margin and securities lending); • We maintain our Code, which details our fiduciary duty to put our clients’ interests ahead of our own, and conduct annual training on our Code; and • PWM Advisors are obligated to employ a standard of care and comply with clients’ investment guidelines and restrictions when selecting investments for clients’ accounts. The services and products available under the Wrap Fee Program may be available through other independent investment advisers, and in certain instances, directly via a custodian or another third-party administering a Platform. Please note that not all investment advisers and wrap programs provide the same services or services at the same cost as provided under the William Blair Wrap Fee Program. For these reasons, your PWM Advisor has a greater financial incentive to recommend a William Blair Wrap Fee Program account and make certain types of investments over other investment options. To help manage conflicts of interest that may arise, we have various controls in place including the following: • We maintain written policies (and provide periodic training) requiring our employees to uphold our fiduciary duty to place clients’ interests ahead of our own; • New accounts and client documentation are reviewed by dedicated personnel prior to opening; and We maintain procedures to periodically review portfolio holdings and transactions for unusual activity.The overall cost of a Wrap Fee Program account may be higher than you otherwise would pay if you paid our standard investment management fee schedule and negotiated transaction costs and other services such as custody through us or another financial institution. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 12  Compensation from Retirement Accounts William Blair receives compensation from clients whose assets are invested in an Individual Retirement Account (“IRA”). William Blair and its PWM Advisors have a conflict of interest when they recommend that a participant roll money out of an employer retirement plan, such as a 401(k) plan, and into an IRA that will generate ongoing fees for the firm and the PWM Advisor. Even though William Blair and its employees are NOT compensated for making the recommendation, we will receive compensation for services under an investment advisory agreement should the retirement investor follow our recommendation to rollover their money into an IRA with William Blair. Investing assets in a William Blair IRA most likely will result in higher fees than investing through an employer’s retirement plan. To help manage this conflict of interest, we have implemented the following: • acknowledging that when we provide investment advice to a retirement investor (including a recommendation to rollover retirement assets into a William Blair IRA), William Blair and the PWM Advisor are fiduciaries within the meaning of ERISA and the Code; • William Blair and the PWM Advisor will act in the retirement investors’ best interest and not put our interest • ahead of the retirement investors; Conflicts of interest are disclosed in the Brochure, Form CRS, the “Retirement Investor Acknowledgement & Fiduciary Acknowledgement” form; • Retirement investor clients and prospects are provided with “Information Regarding Transfers, Distributions, and IRA Rollovers;” • William Blair has policies, procedures and controls (including an annual, retrospective review) in place with respect to advisory accounts for retirement investors. Similarly, NFS’ affiliate acts as a record keeper for certain retirement plans whose participants are pre-existing investment advisory clients of William Blair. Certain retirement plans allow their participants to grant discretion to investment advisers to manage assets within their retirement accounts. In these instances, William Blair and the PWM Advisor have a conflict of interest in that they will receive compensation for services under an investment advisory agreement should we be hired to manage the participant’s assets within their retirement account held at NFS’ affiliate. Sweep Account Fees William Blair “sweeps” available uninvested cash balances for eligible account types that custody at NFS into deposit accounts at one or more banks participating in our Program. The compensation that William Blair receives from the Program is in addition to the account’s advisory fee that you pay (as further described in this Item 5). This means that William Blair earns two layers of fees on the cash balances in your account. William Blair receives significant compensation from your account’s use of the Program. For more information regarding our compensation, see Frequently Asked Questions at https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep- Program.aspx. The Program is a multi-bank program under which uninvested account cash balances are automatically swept into deposit accounts at participating FDIC-insured banks (and in some cases, into shares of a money market mutual fund). Clients earn interest on such deposits (and dividends on investments in a money market mutual fund, where applicable). The Program is made available and administered by NFS, which also earns fees in connection with record keeping and other services provided for the Program. Absent the fees earned by NFS under the Program, NFS would likely charge us higher fees for providing their clearing services. Fees for the Program will typically exceed the interest paid on client deposits. Under the Program, NFS generally contracts with participating banks to make specific amounts of deposit capacities available at certain all-in funding rates, which are typically tied or related to the Federal Funds Rate (or a similar type William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 13  of metric, composite, index, etc.). Client interest, as well as Program fees (i.e., the compensation received by William Blair and NFS), are paid from the bank’s all-in funding rates. All-in funding rates (generally a percentage applied to average daily program deposits at the bank), may be fixed, variable, subject to capacity and other requirements or a combination thereof. Capacity levels may be subject to minimums and maximums. Contract terms with each participating bank are unique and are expected to change over time. Accordingly, at any given time, participating banks will generally pay different all-in funding rates notwithstanding that interest earned by clients on their sweep deposits will not vary regardless of where their funds are actually swept. Moreover, changes in the Federal Funds Rate (or other applicable factor) will not immediately affect all-in funding rates paid or interest rates offered under the Program. The greater the amount of client deposits held in the Program and the longer such deposits are held, the greater the compensation William Blair and NFS receive. Different banks participating in the Program pay different all-in funding rates (and are subject to different contractual requirements), creating an incentive for NFS to direct Program deposits to banks (through how the Program bank priority list(s) are designed or changed from time to time) that result in William Blair and NFS receiving greater compensation. Both William Blair and NFS receive more compensation with respect to amounts in the Program than with respect to other sweep products. The fees William Blair receives in connection with the Program creates a conflict of interest and incentive to offer and designate the Program as the cash sweep option for client accounts. In addition, the fees William Blair receives in connection with the Program creates a conflict of interest and incentive to recommend you maintain and/or increase cash balances in your Account, as greater cash balances in your Account increase compensation to William Blair under the Program. Banks participating in the Program do not have a duty to provide William Blair clients with the highest interest rates available and will instead seek to pay a lower rate, and a rate that is lower than other options available in the market, including money market mutual funds and most certificates of deposit. Banks have the financial incentive to pay all-in funding rates as low as the market will permit. There is no necessary linkage between rates of interest paid by Program banks and the highest rates available in the market, including any money market mutual fund rates. By comparison, a money market mutual fund generally seeks to achieve the highest rate of return (less fees and expenses) consistent with the fund’s investment objective, which can be found in the fund’s prospectus. The Program operates differently depending on your account type. Please review the Bank Deposit Sweep Program (the “Program”) Disclosure Document for more information about how the Program works, including limitations, restrictions, interest rates, deposit insurance, how changes are implemented and additional discussion of William Blair’s conflicts of interest. For current interest rates (and fees) applicable to the Program or a copy of the Disclosure Document, please contact your PWM Advisor or click on the following link: https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep-Program.aspx. Program Accounts other than Advisory Individual Retirement Accounts With respect to all eligible account types other than advisory individual retirement accounts, William Blair is responsible for establishing its compensation levels under the Program. Each Program bank will pay William Blair a fee equal to a percentage of the average daily deposit balance in each deposit account with the bank. Such fees differ among the participating Banks. The combined total fees that William Blair and NFS can earn will be a maximum of the Federal Funds Target Rate plus 0.25% as determined by the total deposit balances at all of the Program banks over a 12-month rolling period. The higher the compensation received by William Blair and NFS, the less available to pay client interest. William Blair will set its compensation levels for the Program based on prevailing economic and business conditions, which are subject to change at any time. It is expected that the vast majority of the all-in funding rates paid by the banks will be paid to William Blair and NFS as fees. Accordingly, the interest rate clients receive on Program deposits will be lower than the all-in funding rates paid by the banks and will likely be lower than the rate of return on (i) other investment vehicles that are not FDIC-insured, such as money market mutual funds and (ii) bank deposits offered outside of the Program. William Blair may change its compensation levels for the Program and any such reductions or increases may vary between clients. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 14  Program Accounts that are Advisory Individual Retirement Accounts With respect to advisory individual retirement accounts (“Advisory IRAs”) in the Program, the Program is made available and administered by NFS and a Program Administrator, which both earn fees in connection with record keeping and other services provided to the Advisory IRAs for the Program. For Advisory IRAs, William Blair receives a level monthly fee for each Advisory IRA participating in the Program (the “Advisory IRA Sweep Fee”). The monthly Advisory IRA Sweep Fee is determined based on the Federal Funds Target Rate expressed as a percentage. The Advisory IRA Sweep Fee schedule is included in the Bank Deposit Sweep Program Disclosure Document, available at https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep-Program.aspx. It is anticipated that William Blair’s Advisory IRA Sweep Fee will be paid from the total amounts paid by Program banks. For Advisory IRAs participating in the Program, William’s Blair’s fees, and those of NFS and the Program Administrator, reduce the interest rates that are credited to Advisory IRAs. As a result, William Blair has a significant incentive and conflict of interest in offering the Program to Advisory IRAs. Ineligible Accounts For accounts that are ineligible to sweep into the Program, William Blair will generally sweep such accounts’ uninvested cash balances into a money market mutual fund (typically offered by your custodian). When we sweep your available cash balance into unaffiliated funds, we charge our investment management fee on your total account assets. If your client account is held in custody at NFS, your available cash balance will be swept into a Fidelity money market mutual fund. FCASH Eligible accounts may also sweep uninvested available cash to FCASH. Offered by NFS, FCASH is a means for holding cash balances. FCASH is not a bank deposit or a money market mutual fund. NFS may, but is not required to, pay interest on the balances held in FCASH. Current interest rates on FCASH can be found at https://www.williamblair.com/Private-Wealth-Management/Bank-Deposit-Sweep-Program/Interest-Rate-Tiers. Note that like any cash held in or through a securities account, FCASH is protected by the Securities Investor Protection Corporation (“SIPC”), up to applicable limits. Free Credit Interest NFS benefits from deposits and credits in advisory client accounts before cash balances are invested or swept into a sweep vehicle (usually the next business day). This benefit, “free credit interest,” is in the form of income at the prevailing market rates on overnight investments averaging 0.01%. A portion of this free credit interest is retained by NFS and a portion is credited to our advisory client. Partnership and Revenue Note that William Blair is a private partnership; a primary factor in becoming a partner of the partnership is the amount of revenue generated by a particular employee. Employees are therefore incented to increase revenue, which presents conflicts of interest between our employees and you. To mitigate these conflicts, we maintain our Code of Ethics (“Code”), which details our fiduciary duty to put our clients’ interests ahead of our own, and we conduct annual training on our Code. We also have established supervisory controls and procedures to oversee the actions of our employees and their compliance with applicable law. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Requirements William Blair generally requests a minimum account size of $100,000 for the Wrap Fee Program. Mutual fund investment options considered for our Wrap Fee Programs may impose investment minimums as described in the William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 15  funds’ prospectuses, which are available from your PWM Advisor. We reserve the right to negotiate fees or accept accounts below our stated minimums. Types of Clients William Blair generally manages Wrap Fee Program accounts for the following client types: Individuals • Foundations • Retirement Plans Trusts • • High net worth clients • Note that clients may include executive officers, directors or insiders of a public company. In this regard, a PWM Advisor will be restricted from trading in a public company’s securities if an executive officer, director or any insider of that company is also a client of the PWM Advisor. This means that clients of that PWM Advisor may experience less favorable performance than others who are clients of other PWM Advisors or financial professionals of other advisory firms who are not similarly restricted. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION Comprehensive Fee Program – Portfolio Management PWM Advisors (who are William Blair employees) are primarily responsible for managing our client’s Comprehensive Fee Program portfolios. Our PWM Advisors design custom portfolios based on each client’s financial circumstances, investment objectives and risk considerations. In choosing investments for Comprehensive Fee Program portfolios, we consider a broad array of securities and investment vehicles including equity securities, debt securities, mutual funds or other investments that would be suitable for a client based on their particular circumstances. Fees for William Blair-Sponsored Wrap Programs PWM Advisors provide portfolio management services for clients in our Comprehensive Fee Program that we also sponsor. Conflicts of interest arise because our PWM Advisors are incented to recommend our Wrap Fee Programs over other suitable account options due to the nature of compensation as described in Item 4 in this Wrap Brochure. To help manage conflicts, we employ compliance controls as described in Item 4 of this Wrap Brochure. Investment Advisory Business William Blair provides discretionary and non-discretionary investment management services to individual and institutional clients for a fee through PWM Advisors. As an investment adviser, William Blair provides customized wealth management to individuals, smaller institutions, high net worth and Wrap Program clients. As of December 31, 2023, William Blair had approximately $58.3 billion in assets under management, of which, we managed approximately 90% on a discretionary basis and 10% on a non-discretionary basis. Availability of Tailored Services for Clients As a discretionary investment manager for our Wrap Fee Program clients, we provide investment advice and actively manage client accounts based on each client’s investment objectives. We accept investment restrictions from clients if the restrictions do not hinder our ability to execute our investment strategies and if such restrictions can be appropriately implemented. A client may impose reasonable restrictions on the management of account assets, such as, the designation of particular securities or types of securities that should not be purchased or that should be sold if held in the account. Client should communicate any changes in investment objectives and restrictions as well as changes in financial condition to their PWM Advisor. Performance Based Fees and Side-by-Side Management William Blair does not offer performance-based fee arrangements to its Wrap Fee Program clients. However, the general partner for MB Investments Program (the “MB General Partner”) may earn a performance-based fee, if William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 16  applicable. As more fully described in any applicable offering documents, the MB General Partner will be entitled to a portion of the profits of the limited partnership as “carried interest.” The amount of the performance-based fee and how it is calculated is fully disclosed in the applicable MB Partnership offering document. The amount of the performance-based fee may vary by MB Partnership Series. Carried interest, where applicable, is indirectly borne by limited partners who are not affiliated with the MB General Partner and/or William Blair. Limited partners should understand that the receipt of performance-based fees creates a conflict of interest as the MB General Partner has the potential to receive higher compensation. Performance-based fees create an incentive for the MB General Partner to pursue riskier or more speculative investments than might otherwise be the case in the absence of such arrangement. Additionally, the payment by some MB Partnership Series, but not all MB Partnership Series, or the payment of carried interest at varying rates creates an incentive for the MB General Partner to disproportionately allocate time, services, functions or investment opportunities to those MB Partnership Series paying carried interest or paying carried interest at a higher rate. The MB General Partner seeks to mitigate these conflicts through disclosures in this Brochure; additional disclosures in the applicable offering documents as well as policies and procedures, including allocation of investment opportunities. Our PWM Advisors manage multiple portfolios for both Wrap Fee Program clients and non-wrap fee clients using various investment strategies depending upon clients’ guidelines and restrictions. Some of these same investment strategies serve as the basis for the Non-Discretionary Model Portfolio Program. In addition, according to a client’s investment objectives and subject to reasonable restrictions, a PWM Advisor may elect to allocate all or a portion of a Comprehensive Fee Program client’s assets to one or more of William Blair’s Proprietary Home Office Models. These investment management responsibilities create conflicts of interest. We seek to conduct ourselves in a manner we consider to be the most fair and consistent with our fiduciary obligations to all of our clients and make investment decisions and recommendations based on an account’s available cash, investment objectives, restrictions, permitted investment techniques and other relevant considerations. The conflicts of interest that arise in managing multiple accounts include, for example, conflicts among investment strategies, conflicts in allocation of trades, conflicts in the allocation of investment opportunities, conflicts based on account type, or conflicts due to different fees. Some accounts have higher fees than others. Fees charged to clients differ depending upon a number of factors including, but not limited to, the particular strategy, the size of the portfolio being managed, the relationship with the client, the service requirements, or the account type (e.g., Wrap Fee Program or non-wrap fee program accounts). Based on these factors, a client could pay higher fees than another client with the same PWM Advisor or in the same strategy. Also, clients with larger assets under management generate more revenue for William Blair than smaller accounts. These differences give rise to a conflict that a PWM Advisor may favor one account over the other or allocate more time to the management of one account over another. To help manage conflicts, we have implemented various controls, including the following: • We review the performance of accounts to identify performance outliers; • For accounts managed according to strategy-based model portfolios, we confirm differences relative to account- specific guidelines; and • We have adopted trade order aggregation and allocation policies and procedures that seek to manage, monitor and, to the extent possible, minimize the effects of these conflicts. The above controls, policies and procedures seek to manage, monitor and, to the extent possible, minimize the effects of these conflicts. Methods of Analysis William Blair is an active investment manager and utilizes a variety of methods and strategies to make investment decisions and recommendations. When evaluating investment opportunities, we employ fundamental and technical research methods using various resources such as financial news sources and websites; corporate data; ratings services; third party research; SEC filings (e.g., annual reports, prospectuses); company press releases; and proprietary William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 17  research. Our PWM Advisors frequently rely upon investment information provided by our firm’s research analysts as well as our William Blair Consulting Services team for mutual fund information. Investment Strategies As described above, our PWM Advisors design custom portfolios based on each client’s financial circumstances, investment objectives and risk considerations and consider a broad array of securities and investment vehicles including equity securities, debt securities, mutual funds or other investments. RISK OF LOSS All investments in securities involve a risk of loss of your principal (invested amount) and any profits that have not been realized (i.e., the securities have not been sold to "lock in" the profit). The value of securities in an account can go up or down, sometimes rapidly or unpredictably. Local, regional or global events such as war, acts of terrorism, the spread of infectious illness or other public health issue, recessions or other events could have a significant impact on the valuation of securities. Securities may decline in value due to factors affecting securities markets in general or particular industries represented in the securities markets. The value of a security may decline due to general market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. The value of a security may also decline due to factors that affect a particular industry or industries, such as labor shortages or increased production costs and competitive conditions within an industry. During a general downturn in securities markets, including those unrelated to financial markets (such as a global pandemic), multiple asset classes may decline in value simultaneously. If an Account is not diversified, a loss in a single position or group of positions with a concentrated, aggregate exposure could have a materially adverse impact on an Account. In addition, if you enter into securities lending, margin and/or non-purpose loans arrangements, there are additional risks to your principal, as more fully described in separate account documentation, There is no guarantee that any investment strategy will achieve its stated investment objectives. William Blair does not guarantee any level of performance or that you will not experience a loss of account assets. Common Risks Associated with Equity Investments Investments in equity securities can expose you to certain specific risks such as the following: • Equity securities. Equity securities (stocks) held in your portfolio may decrease in response to activities of companies or market and economic conditions. • Growth stocks. Growth stocks may be more sensitive to market movements because their prices tend to reflect future investor expectations rather than just current profits and may underperform value stocks during given periods. • Value stocks. Value stocks may perform differently from the market as a whole and may be undervalued by the market for a long period of time and may underperform growth stocks during given periods. • Small-capitalization companies. Small cap stocks may exhibit erratic earnings patterns, competitive conditions, limited earnings history, and a reliance on one or a limited number of products. • Initial public offerings. Initial public offerings (IPOs) are subject to high volatility and limited availability. • Private placements. Private placements may be classified as illiquid and difficult to value. • Options. Purchasing options involves the risk that the underlying instrument will not change price in the manner expected, so an investor loses their premium. Selling options involves potentially greater risk because the investor is exposed to the extent of the actual price movement in the underlying security, which could result in a potentially unlimited loss. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 18  • ESG Investing. Portfolios that select securities based on, Environmental, Social and Governance (“ESG”) factors or similar criteria may forego certain market opportunities available to portfolios or strategies that do not use these criteria. In this regard, the strategy will be precluded from purchasing, or required to sell, certain investments that otherwise meet its objective and strategy and that might otherwise be advantageous to hold. The application of the ESG factors could result in performance that is better or worse than the performance of a similar strategy, depending on the performance of the excluded investments and the investments included in place of such excluded investments. Integrating ESG analysis into investment decisions requires qualitative determinations and is often subjective by nature, and there can be no assurance that the process utilized, or any judgment exercised by William Blair, will operate as expected when addressing positive environmental or social benefits. Common Risks Associated with Non-U.S. Investments Investments in non-U.S. securities can expose you to certain specific risks such as the following: • Current market conditions. In recent years, debt and equity markets, domestic and international, have experienced increased volatility and turmoil, which can adversely impact your portfolio. • Liquidity in financial markets. The financial markets in the U.S. and elsewhere have experienced a variety of difficulties and changed economic conditions, which could adversely impact the value of your portfolio’s assets. • Government intervention and market disruptions. The global financial markets recently have undergone fundamental disruptions that have led to extensive and unprecedented government intervention that could prove detrimental to the efficient functioning of the markets and adversely impact your portfolio. • International markets. International markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. • International securities. International stocks are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. • International currency exchange rates. International exchange rates may adversely affect the value of investments in international securities held in your portfolio. • Currency risks. Investments denominated in an international currency are subject to the risk that the value of a particular currency will change in relation to one or more currencies. • Emerging markets. Securities traded in certain emerging markets may be subject to risks due to the inexperience of financial intermediaries, the lack of modern technology, the lack of a sufficient capital base to expand business operations, and the possibility of temporary or permanent termination of trading. Political and economic structures in many emerging markets may be undergoing significant evolution and rapid development, and emerging markets may lack the social, political and economic stability characteristics of more developed countries. Common Risks Associated with Fixed Income Investments Investments in fixed income securities can expose you to certain specific risks such as the following: • Credit risk. Fixed income securities (bonds) are subject to the risk that the bond issuers may not be able to meet interest or principal payments when the bonds come due. • Below investment grade rated securities. Below investment grade bonds are subject to a higher probability that the issuers may not be able to meet payment of interest or principal on a timely basis or at all. These securities also may be less liquid than investment grade securities and experience higher price volatility. It may not be possible to sell these securities at the desired price and within a given time period. • High yield securities. High yield securities are rated in the lower rating categories by the various credit agencies and are subject to greater risk of loss of principal and interest than higher rated securities. High yield securities William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 19  generally are considered predominantly speculative with respect to the issuer’s capacity to pay interest and repay principal. • Interest rates. Interest rates may adversely affect the value of an investment. An increase in interest rates typically causes the value of bonds and other fixed income securities to fall. Interest rates continue to be at historic lows. Investments with longer maturities, which typically provide higher yields than securities with shorter maturities, may subject a portfolio to increased price changes resulting from market yield fluctuations. Under extreme circumstances, a substantial decrease in interest rates may lead to a negative yield on investments. • Income risk. The income received by a portfolio may decrease as a result of a decline in interest rates. • Liquidity risk. Investments that trade less can be more difficult or more costly to buy, or to sell, than more liquid or active investments. It may not be possible to sell or otherwise dispose of illiquid securities both at the price and within a time period deemed desirable. Securities subject to liquidity risk include emerging market securities, Rule 144A securities, below investment grade securities and other securities without an established market. • Prepayment risk. There is a risk of prepayment of high interest rates in mortgage- and asset-backed securities. This risk arises when market interest rates are below the interest rates charged on the loans that comprise the securities. Elevated prepayment activity may result in losses in these securities. Common Risks Associated with Alternative Investments Investments in alternatives investment strategies including structured notes can expose you to certain specific risks, including risks associated with equity and fixed income investments (in the U.S. and Non-U.S. investments) previously described above, as well as the following: • Derivative securities. Derivatives may be difficult to value, may be illiquid and may be subject to wide swings in valuation caused by changes in value of the underlying security. The use of derivatives can result in losses that substantially exceed the initial amount paid or received. • Short sales. A short sale involves the risk of a theoretically unlimited increase in the market price of a security sold short, which could result in an inability to cover the short position and a theoretical unlimited loss. • Commodity and futures contracts. Commodities futures markets (including financial futures) are highly volatile and are influenced by factors such as changing supply and demand, governmental programs and policies, national and international political and economic events and changes in interest rates. A high degree of leverage is typical in commodities futures trading, and as a result, a relatively small price movement may result in substantial losses. • Leverage. The use of borrowing (leverage) exposes an investor to additional levels of risk including greater losses from investments than would otherwise have been the case without borrowing; margin calls or changes in margin requirements may force premature liquidations of investments; and losses on investments where the investment fails to earn a return that equals or exceeds the cost of the leverage. • Lack of diversification. The portfolio may not generally be as diversified as other investment vehicles. Accordingly, investments may be subject to more rapid change in value than would be the case if the portfolio were required to maintain a wide diversification among types of securities, geographical areas, issuers and industries. Accordingly, a loss in a single position could have a materially adverse impact on a portfolio. • Liquidity. A portfolio’s assets may, at any given time, include securities and other financial instruments or obligations that are thinly traded or for which no market exists and/or which are restricted as to their transferability under applicable securities laws. The sale of any such investments may be possible only at substantial discounts, and it may be extremely difficult to value accurately any such investments. • Event-driven trading. Event-driven trading involves the risk that the event identified may not occur as anticipated or may not have the anticipated effect, which may result in a negative impact upon the market price of securities held in the portfolio. Common Risks Associated with Private Funds William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 20  Investors in private funds must be prepared to bear the risk of a complete loss of their investments. In addition to the material risks affecting financial markets generally (as described above), investments in affiliated and unaffiliated private funds include but are not limited to the following specific risks: • Long-Term Investment; Illiquidity of Investments. Unlike liquid investments, private fund investments do not provide daily liquidity or pricing. In fact, investment in certain private funds requires a long-term commitment, with limited or no liquidity opportunities and no certainty of return. The return of capital and the realization of gains and other income, if any, from an investment may not occur until several years after such investment is made, if at all. Given that certain private funds are expected to operate over several years, substantial changes to the business, economic, political, and regulatory and technology environment may have a more profound effect on private fund investments. • Limited Transferability of Interests. Certain private funds (William Blair Private Funds) and applicable securities laws impose substantial restrictions upon the transferability of private fund interests. There is no public market or other market for most private fund interests. • Valuation. The underlying investments in certain private funds consists of significant amounts of securities and other financial instruments that are very thinly traded, or for which no market exists, or which are restricted as to their transferability. As discussed above, William Blair relies on the issuers and custodians to provide a good faith, fair market value with respect to interests in private funds. The process of valuing securities for which reliable market quotations are not readily available is based on inherent uncertainties and likely results in values that would differ had an active market existed for such securities. The good faith fair market value determinations will most likely differ from the value of such securities when ultimately sold. As discussed above, William Blair charges an advisory fee based on the fair market value of unaffiliated private fund interests held in advisory accounts. • Limited Operating History. Certain private funds have limited operating histories and there can be no assurance that the private funds’ investments will achieve results similar to those achieved by previous investments (including performance of predecessor private funds). • Competition. The activity of opportunistically identifying, completing and realizing attractive investments is highly competitive and involves a high degree of uncertainty. Private funds will be competing with other established funds and investment organizations with substantial resources and experience. • Limited Number of Investments/Lack of Diversity. Except as set forth in each private fund’s offering documents, private funds are under no obligation to diversify its investments, whether by reference to amount invested or industries or geographical areas in which the investments are made. Accordingly, private funds participate in a limited number of investments and, as a consequence, the aggregate return of any private fund may be substantially adversely affected by the unfavorable performance of even a single investment. The common risks of loss described in this section are intended as a high-level overview. Please see other disclosure documents for a complete discussion of the risks attributable to an individual investment including, but not limited to, prospectuses, private placement memorandum and structured note, margin and option documentation. Voting Client Securities Clients have the option of voting proxies directly or delegating proxy voting discretion to William Blair or a third party. In cases where William Blair has proxy voting authority, we will vote the proxies solely in the interest of our clients. We act with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. We are not responsible for voting proxies we do not receive in a timely manner. For clients participating in a securities lending program via their custodian, we will not be eligible to vote proxies for the portion of shares on loan. For clients where we vote proxies, unless a client otherwise notifies William Blair, in writing, contact information will not be distributed to third-party solicitors. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 21  Generally, when William Blair votes proxies, we rely upon a Proxy Administrator, Institutional Shareholder Services (“ISS”) to facilitate our proxy voting activities. ISS reviews all proxies received, subject to the requirement that all votes shall be cast solely in the best interest of the clients in their capacity as shareholders of a company. ISS votes the proxies according to the firm’s selected voting guidelines (domestic or international), which are designed to address matters typically arising in proxy votes.2 Accordingly, if the voting guidelines indicate a vote “for”, ISS will vote in favor of the matter; if the voting guidelines indicate a vote “against,” ISS will not vote in favor of the matter. We do not intend our voting guidelines to be exhaustive; hundreds of issues appear on proxy ballots and it is neither practical nor productive to fashion a guideline for each. Rather, our voting guidelines are intended to cover the most significant and frequent proxy issues that arise. In the rare instance where the voting guidelines have no recommendation or indicate a vote on a “case-by-case” basis, ISS will vote in the manner directed by William Blair, based on what we believe is in the best interest of our client. ISS is an independent third-party research provider that analyzes each vote from the shareholder vantage point. ISS provides proxy voting, maintenance, reporting, analysis and recordkeeping services. For information regarding proxy voting for private funds, including Blair Private Funds and MB Partnership, please see each fund’s offering materials. Share-Blocking Policy for International Markets In international markets where share blocking applies, we typically will not, but reserve the right to, vote proxies due to liquidity constraints. Share blocking is the “freezing” of shares for trading purposes at the custodian/sub-custodian bank level in order to vote proxies. Share blocking typically takes place between 1 and 20 days before an upcoming shareholder meeting, depending on the market. While shares are frozen, they may not be traded. Therefore, the potential exists for a pending trade to fail if trade settlement falls on a date during the blocking period. We do not subordinate the interests of participants and beneficiaries to unrelated objectives. Oversight of Proxy Administrator William Blair and its affiliate, WBIM utilize ISS as their proxy administrator. William Blair relies on WBIM for oversight of ISS. For more information related to ISS oversight, please see WBIM’s Form ADV. We periodically review a random sample of votes for consistency with the voting guidelines. How to Obtain Proxy Records and Voting Policy We will make available to our clients a report on proxy votes cast on their behalf upon their request. Clients can contact us at 312-236-1600 or pwmcompliancegroup@williamblair.com for this information. Clients and prospects also can obtain a copy of our proxy voting policies and procedures upon request by contacting us at (312) 236-1600 or pwmcompliancegroup@williamblair.com. For information regarding how proxies were voted for the William Blair Funds, please refer to the William Blair Funds’ website at www.williamblairfunds.com and select Proxy Voting Information. The William Blair Funds’ proxy voting records also are available on the SEC’s EDGAR website at www.sec.gov/edgar. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Because our PWM Advisors serve as portfolio manager for their own Wrap Fee Program clients, they are able to gain comprehensive knowledge about clients’ unique financial situations, investment objectives and risk considerations. The PWM Advisors also are able to address clients’ specific investment restrictions since portfolios are managed on an 2 The voting guidelines are available on ISS’s website at https://www.issgovernance.com/policy-gateway/voting-policies. William Blair typically follows the BenchmarkProxy Voting Guidelines. Clients can also instruct William Blair to follow other ISS voting guidelines. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 22  individualized basis. PWM Advisors solicit this information from clients during the account opening process. PWM Advisors periodically communicate with their clients and solicit information regarding changes to clients’ information. Clients should communicate any changes in investment objectives and restrictions as well as changes in financial condition to the William Blair PWM Advisor. ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS Because our PWM Advisors serve as portfolio managers for their Wrap Fee Program clients, they are available to speak with clients as needed and routinely communicate with clients to solicit information regarding any changes to clients’ financial circumstances or investment objectives. Clients should communicate any changes in investment objectives and restrictions as well as changes in financial condition to the William Blair PWM Advisor. ITEM 9 – ADDITIONAL INFORMATION Disciplinary Information William Blair & Company L.L.C. and WBIM (collectively for purposes of this paragraph, William Blair) have entered into a settlement with the SEC in connection with the agency’s industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement requires William Blair to pay a civil monetary penalty of $10,000,000 and retain a compliance consultant for a period of one year, following the format for all other recent electronic communications settlements. William Blair cooperated with the government’s inquiry and has already taken significant steps to further strengthen the firm’s compliance environment as it relates to electronic communications. In May 2017, the SEC found that from 2010 until 2014, as a result of erroneous payments, William Blair negligently used mutual fund assets to pay for (i) distribution and marketing of fund shares outside of a written, board- approved rule 12b-1 plan and (ii) sub-transfer agent ("Sub-TA") services in excess of board-approved limits. These payments totaled approximately $1.25 million and rendered certain of William Blair Funds' disclosures concerning payments for distribution and Sub-TA services inaccurate. As a result of this conduct, William Blair violated Section 206(2) of the Investment Advisers Act and Section 34(b) of the Investment Company Act, and caused the William Blair Funds to violate Section 12(b) of the Investment Company Act and Rule 12b-1 thereunder. The SEC alleged that William Blair also failed to fully disclose to the William Blair Funds' Board of Trustees that William Blair (and not a third-party service provider) would retain a fee for providing shareholder administration services to the William Blair Funds under a shareholder administration services agreement between certain of the Funds and William Blair. As a result of this conduct, William Blair violated Section 206(2) of the Investment Advisers Act. Without admitting or denying the findings, except as to the SEC's jurisdiction over it and the subject matter of these proceedings, which are admitted, William Blair consented to the entry of an order instituting cease-and- desist proceedings, pursuant to Section 203(k) of the Investment Advisers Act and Section 9(f) of the Investment Company Act, making findings, and imposing a cease-and-desist order. William Blair also was assessed by the SEC a civil money penalty in the amount of $4,500,000. Our Form ADV Part 1A describes these and several disciplinary items relating to our business as a broker-dealer. Our Form ADV Part 1A is available for review on the SEC’s web site at www.adviserinfo.sec.gov. Other Financial Industry Activities and Affiliations William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 23  As described in William Blair Brochure, William Blair is a global investment firm with diverse financial services activities by the firm and its affiliates including the following: • Securities Broker/Dealer Business • Commodities and Futures Registrations • Affiliated Mutual Funds (William Blair Funds) • • • Sub-Advisory Activities for Other Pooled Funds Investment Banking Private Investment Offerings (e.g., limited partnerships, funds-of-hedge funds, multi-advisor commodity pools), including William Blair Private Funds • Model Portfolio Provider • • • • Financial Planning, Consulting and Advisory Corporate and Executive Services Sell Side Equity Research Institutional Sales and Trading • SYSTM, an SEC registered investment adviser, that operates a fee-based platform which affiliated investment advisers (such as William Blair) and unaffiliated investment advisers can utilize to trade Proprietary Home Office Models and to recommend, select, retain, fire and monitor sub-managers and model providers. In addition, William Blair provides consulting services to SYSTM. SYSTM pays William Blair a fee for these consulting services. For more details on conflicts of interest related to SYSTM, please see William Blair’s Brochure and Form CRS as well as SYSTM’s Brochure and Form CRS. Code of Ethics William Blair has adopted a Code of Ethics pursuant to Rule 204A-1 under the Investment Advisers Act of 1940 that governs a number of conflicts of interest we have when providing our advisory services to our clients. We have designed our Code to help ensure we meet our fiduciary obligation to our clients to emphasize a culture of compliance within our firm. We distribute our Code to each employee, including Access Persons (as defined under Rule 204A-1 under the Investment Advisers Act), at the time of hire and annually thereafter. We also supplement the Code with annual training and monitor activity on an on-going basis. In accordance with our Code, employees must: • Report their transactions in reportable securities quarterly and disclose reportable securities holdings annually; • Disclose all securities accounts in which they have a beneficial interest (i.e., they are the account owner or have a present economic interest in the account); Protect material non-public information; • • Not purchase securities in an initial public offering (IPO) and obtain prior approval for participation in private placements; • Receive approval prior to engaging in outside business activities, including serving on any Board of Directors of a public company; • Report gifts and business entertainment; and Certify on an annual basis as to compliance with our Code. • If you would like a copy of PWM’s Code of Ethics, please contact our Compliance team at (312) 236-1600, pwmcompliancegroup@williamblair.com or write to us at the following address: William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 24  William Blair & Company, L.L.C. Attn: PWM Compliance 150 North Riverside Plaza Chicago, IL 60606 Securities in which William Blair has a Financial Interest Because of our diverse financial services activities, William Blair or its affiliates have financial interests in various securities including, but not limited to, the William Blair Funds, William Blair SICAV, William Blair Private Funds, SYSTM, and a partnership that holds minority interests in other registered investment advisers (which may be clients in a non-discretionary model portfolio program offered by William Blair, clients of SYSTM, purchase equity & consulting research and/or pay us referral fees for insurance products) as well as securities of corporations to which we provide investment banking and other corporate and executive services. We or our affiliates also have financial interests in securities for which WBIM serves as sub-manager (such as other mutual funds or collective investment trusts). In certain instances, William Blair utilizes a platform provider for the purchase and sale of structured notes. Certain partners and employees of William Blair own an interest in the structured note platform provider. The structured note platform provider is a non-controlling minority investor in SYSTM. In addition, the reference assets for certain structured notes available on this platform are based on William Blair’s Sell Side Equity Research. William Blair receives a licensing fee on structured notes utilizing its Sell Side Equity Research. For the portion of your account invested in a structured note based on William Blair’s Sell Side Equity Research, we do not charge an account level advisory fee. William Blair allocates up to 50% of this licensing fee to the PWM Department (and, in turn, to the PWM Advisor). Therefore, William Blair has a conflict of interest in that there is an incentive to purchase structured notes (including those based on William Blair’s Sell Side Equity Research) using this platform provider. In our position as an investment adviser, we purchase or sell securities for our clients’ accounts in which we have a financial interest. In addition, our participating affiliates, William Blair International, Ltd, William Blair B.V. and William Blair International (Singapore) Pte. Ltd, may recommend to or invest in the same securities for its own clients as securities in which William Blair or its clients have an interest. As discussed above, we receive compensation from our affiliate, WBIM, based on our clients’ assets invested in William Blair Funds, William Blair Private Funds, WBIM Sub-Advisory Accounts and WBIM Separate Accounts. In addition, as discussed above, our affiliate, SYSTM, receives compensation when our clients’ access Proprietary Home Office Models and, therefore, we are incented to utilize SYSTM instead of unaffiliated Platform providers. This creates a conflict because we are incented to purchase these securities over others. A conflict also may arise in situations where we may restrict or refrain from making investment decisions on particular securities because we are actively engaged in investment banking activities, issuing sell side equity research and institutional sales and trading for issuers of those corporate securities. William Blair utilizes various technology service providers. Certain partners of William Blair own an interest in one of these technology service providers. This technology service provider is also a key technology provider to and a minority, non-controlling investor in SYSTM. William Blair has a conflict of interest in that there is an incentive to maintain and increase our business relationship with this technology service provider rather than with comparable technology service providers. To help manage these conflicts, we rely on various compliance controls including the following: • We maintain a Code, which reinforces our fiduciary duty to clients, and conduct annual training on our Code; William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 25  • We have written policies and procedures that clearly prescribe processes for employees when managing investments for our clients; • We utilize technological tools to help monitor portfolio activities; • We review clients’ portfolios to ensure investments are consistent with clients’ investment guidelines and restrictions; • We typically solicit client consent to invest in the William Blair Funds for their investment advisory accounts; • A client may decline to invest in William Blair Funds or in a Private Fund or open a WBIM Separate Account; • A client may restrict our ability to hire WBIM as a sub-manager; • Conflicts of interest are disclosed in documents including, but not limited to, this Wrap Brochure, William Blair Brochure, Form CRS, WBIM’s Form ADV, Part 2A, SYSTM’s Form ADV, Part 2A, SYSTM’s Form CRS, advisory agreements, William Blair Funds’ prospectuses and other offering documents, William Blair Private Funds’ offering documents, separate client account opening documentation and/or separate disclosure forms; • For the portion of our clients’ assets in a WBIM Separate Account, WBIM Sub-Advisory Account, William Blair Funds, structured note based on William Blair’s Sell Side Equity Research or William Blair Private Funds, we do not charge additional investment advisory fees (note that for certain Sub-Advisory Accounts, WBIM may charge an advisory fee, so long as we exclude such assets from our advisory fee); • We have information barriers in place to prevent dissemination of material, non-public information between our various business groups; • We have allocation policies in place that seek to ensure fair and equitable access to investment opportunities over time; and • We have trade rotation policies in place that seek to effect securities transactions of our clients in a fair and equitable manner. Personal Securities Trading Because William Blair permits its employees to engage in personal securities transactions, our employees may buy or sell securities that we have recommended to clients for their own personal accounts in a manner that is inconsistent with our recommendations to clients. As an example, an employee may buy a particular security that we recently have sold for clients. In addition, an employee or an employee of our affiliate, WBIM, may make a personal investment in the securities of our clients’ companies. These situations create conflicts of interest because employees could be motivated to favor their own investment interests or the interests of certain clients over other clients. To help manage these conflicts, we rely on various compliance controls including the following: • We maintain a Code which reinforces our fiduciary duty to clients and conduct annual training on our Code; and • In cases where we are purchasing or selling securities for clients’ accounts, we prohibit a client’s PWM Advisor from trading ahead in the same securities in his or her own account; and • We monitor employees’ personal securities transactions in an effort to identify patterns or improper activities. Review of Accounts William Blair reviews clients’ accounts for appropriateness and relative value of investments. We meet periodically to discuss current developments and relative merits of particular investments. We appraise account holdings and review accounts for accuracy from an administrative, accounting and investment viewpoint. A member of PWM’s senior management reviews the appropriateness of investment holdings on an ongoing basis. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 26  We determine the frequency, depth and nature of reviews based on the terms of each client’s advisory agreement, mandate and particular needs as they may be communicated to us by the client. We may review accounts during other periods based upon certain trigger factors including significant market events, changes in a client’s investment objectives or guidelines or expected or unexpected material cash flow in an account. PWM Advisors conduct the reviews. The Compliance Department also routinely assesses client accounts via electronic compliance monitoring systems. We use technological tools (as noted above) to assist with our reviews on both an account-by-account basis and on a securities holdings basis, as well as performance exceptions and other bases. We conduct reviews to determine if an account’s holdings are consistent with the investment objectives and restrictions imposed by the client. For our PWM clients, financial advisors typically construct custom portfolios based on a client’s unique objectives and restrictions and manage and review portfolios based on individualized parameters. Clients should communicate any changes in investment objectives and restrictions as well as changes in financial condition to their William Blair PWM Advisor. As clients will not be able to communicate directly with any Sub- Manager available through a Platform or with WBIM for a WBIM Sub-Advisory Sleeve Account, client should communicate these reasonable restrictions to the PWM Advisor. Account Reports William Blair provides written reports to clients periodically. These reports may include portfolio performance and portfolio positioning as of the end of the period. Portfolio performance reports are provided to clients on at least an annual basis. We will include additional detail related to transactions or other information as may be requested by clients. We also will provide reports on a monthly or other interim basis upon client request. Investors in private funds (including William Blair Private Funds) typically receive a copy of audited financial statements of the relevant private fund within 120 days after the fiscal year of each such fund. Client Referrals and Other Compensation On occasion, we can enter into an agreement with unaffiliated third-party promoters in order to pay cash compensation to the promoter for referring advisory clients to our firm. To the extent we enter into such an arrangement, we will comply with the applicable requirements under Rule 206(4)-1 of the Investment Advisers Act pertaining to compensated “endorsements.” Clients that are referred to us through such arrangements are provided a disclosure document describing the terms and conditions of the arrangement, including the compensation paid to the promoter. As discussed above, William Blair employees can be paid direct compensation for generating qualified leads across William Blair and affiliates. Therefore, third parties and employees are incented to refer a client to our Wrap Fee Program. These arrangements do not increase the client’s fees. Participation in Fidelity Wealth Advisor Solutions® William Blair participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which William Blair receives referrals from Strategic Advisers LLC (“Strategic Advisers”), a registered investment adviser and Fidelity Investments company. William Blair is independent and not affiliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise or control William Blair, and Strategic Advisershas no responsibility or oversight for William Blair’s provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a solicitor for William Blair, and William Blair pays referral fees to Strategic Advisers for each referral received based on William Blair’s assets under management attributable to each client referred by Strategic Advisers or members of each client’s household. The WAS Program is designed to help investors find an independent investment advisor, and any referral from Strategic Advisers to William Blair does not constitute a recommendation or endorsement by Strategic Advisers of William Blair’s particular investment management services or strategies. More specifically, William Blair pays the following amounts to William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 27  Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets or “cash” by Strategic Advisers and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, William Blair has agreed to pay Strategic Advisers a minimum annual fee of $50,000 to participate in the WAS Program. These referral fees are paid by William Blair and not the client. To receive referrals from the WAS Program, William Blair must meet certain minimum participation criteria, but William Blair may have been selected for participation in the WAS Program as a result of its other business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). Clients should refer to Item 4-Advisory Business for important information regarding William Blair’s arrangements with NFS, an affiliated entity of Strategic Advisers and FBS. As a result of its participation in the WAS Program, William Blair has a conflict of interest with respect to its decision to use certain affiliates of Strategic Advisers, including FBS, for execution, custody and clearing for certain client accounts, and Advisor has an incentive to suggest the use of FBS and its affiliates to its advisory clients, whether or not those clients were referred to William Blair as part of the WAS Program. Under an agreement with Strategic Advisers, William Blair has agreed that it will not charge clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Pursuant to these arrangements, William Blair has agreed not to solicit clients to transfer their brokerage accounts from affiliates of Strategic Advisers or establish brokerage accounts at other custodians for referred clients other than when William Blair’s fiduciary duties would so require, and William Blair has agreed to pay Strategic Advisers a one-time fee equal to 0.75% of the assets in a referred client account that is transferred from Strategic Advisers affiliates to another custodian; therefore, William Blair has an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of Strategic Advisers. However, participation in the WAS Program does not limit William Blair’s duty to seek best execution. From time to time, we also may buy from third parties certain services or products used in our investment advisory business or pay registration or other fees (including travel and lodging) toward or assist in sponsoring such parties’ industry forums, seminars or conferences. We pay these contributions and payments out of our own resources. The amount of payments and the value of items and benefits may or may not be substantial. These payments, items and benefits give the recipients incentives to favor our private wealth management services and other William Blair-affiliated investment products and services over those of investment management firms that do not provide the same payments, items and benefits. Conversely, from time to time, third parties, including NFS and Platform Providers, defray costs of William Blair sponsored training events and conferences. We make charitable contributions, underwrite, or sponsor charitable events at the request of others, including those who are affiliated with clients, program sponsors or consultants that may have referred clients to our firm. These payments create a conflict of interest in that William Blair is incented to favor products and services offered by these third parties over those third parties that do not. However, these payments are subject to our internal policies that address and, in some cases, limit payments with the overall aim to avoid compromising advice or recommendations given to clients by special incentives or compensation arrangements. Please note that William Blair pays for and receives services from Platform providers or their affiliates. William Blair receives a discount on the cost of these services based on the level of our clients’ assets on the Platform. Therefore, William Blair has a conflict of interest in that there is an incentive to increase the amount of its clients’ assets on a Platform to reduce the cost of other services received from the Platform provider or its affiliates. As discussed above, our affiliate, WBIM, compensates us and our PWM Advisors with respect to PWM’s clients’ assets invested in William Blair Funds, William Blair Private Funds, WBIM Sub-Advisory Sleeve Accounts and WBIM Separate Accounts. This practice constitutes a conflict of interest in that we and our PWM Advisors are incented to purchase William Blair Funds, recommend a WBIM Separate Account, recommend an investment in William Blair Private Funds and utilize discretion to hire WBIM as a sub-manager for a WBIM Sub-Advisory Sleeve Account. William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 28  From time to time, William Blair refers its Wrap Fee Program clients to national banks to obtain a line of credit or to insurance providers to purchase an insurance product, including annuities. William Blair receives referral fees from the banks or insurance providers if the referred Wrap Fee Program client obtains the line of credit or purchases an insurance product, respectively. These referral fees create conflicts of interest because William Blair and PWM Advisors are incented to refer clients to entities that pay referral fees instead of those that do not. William Blair has an indirect, minority ownership interest in one such insurance provider which creates an additional incentive to refer clients to this insurance provider rather than to an insurance provider where we have no ownership interest or those that do not pay a referral fee. William Blair acts as distributor for the William Blair Funds and receives for its services a shareholder/distribution services fee from certain share classes of each Fund as described in the William Blair Funds’ prospectuses and statements of additional information. This constitutes a conflict of interest for William Blair in that its employees may be incented to recommend investment in share classes subject to the above-described fees. Clients may prohibit investment in William Blair Funds. Clients also have the option to invest in securities other than the William Blair Funds. Other Financial Incentives from William Blair to PWM Advisors William Blair pays investment professionals financial incentives when they join William Blair and on an ongoing basis. PWM Advisors are eligible to receive incentives, including loans, back-end bonuses and/or other compensation (including expense accounts to cover certain expenses related to PWM Advisors’ business) if the reach certain asset levels within a specified period of time. These asset levels can be met by a combination of bringing client assets with them from their prior firm and/or garnering assets from clients new to them and William Blair. The amount paid to PWM Advisors under these arrangements is largely based on the size of the business serviced at their prior firm and the PWM Advisor achieving the target asset levels within a specific time period after joining William Blair, as well as certain qualitative factors. These payments are substantial and take various forms, including salary guarantees, loans, transition bonus payments and various form of compensation to encourage financial professionals to join William Blair. Therefore, even if the fees you pay at William Blair remain the same or are less, the transfer of your assets to William Blair contributes to your PWM Advisor’s ability to meet targets. you’re your PWM Advisor’s continued employment is based on meeting these targets. These practices create an incentive and conflict of interest for your PWM Advisor to recommend the transfer of your account assets to William Blair since a significant part of their compensation is contingent on the PWM Advisor achieving a pre-determined level of assets at William Blair. You should consider whether your PWM Advisor’s advice is aligned with your investment strategy and goals. Financial Information Clients under our Wrap Fee Program choose NFS as their custodian. It is our understanding that certain such custodial agreements or other agreements or documents may contain provisions that could result in William Blair having inadvertent custody of client account assets as a result of language permitting us, as investment adviser, to withdraw client assets upon instruction to the custodian. Our advisory agreement, however, is not intended to give us broad authority to withdraw client assets, and we disclaim such authority to the extent applicable. With respect to these concerns, our authority as it relates to custody should be considered to be limited in the ordinary course to customary trading and settlement of securities and investment transactions in the client’s account, typically on a “delivery vs payment” basis for securities transactions, as well as fee deductions in certain cases, as applicable. William Blair has custody of client accounts since some clients authorize their custodian, including NFS, to deduct William Blair’s advisory fees from their client account. In addition, pursuant to a standing letter of authorization (“SLOA”) some clients grant William Blair limited discretion to disburse funds to one or more third parties, as specifically designated by the client. After granting William Blair with this limited authorization, the client then instructs the qualified custodian for the client's account to accept William Blair’s direction on the client's behalf to William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 29  move money to the third party designated by the client on the SLOA. The qualified custodian takes that instruction in writing directly from the account holder (the client), and William Blair’s authority is limited by the terms of that instruction. We are authorized to act merely as an agent for the client. The client retains full power to change or revoke the arrangement. William Blair does NOT have discretion as to the amount, payee or timing of transfers under the SLOA. You should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains your investment assets. Investors in William Blair Private Funds will receive audited financial statements. Our investment account statements will vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. For tax and other purposes, your custodial statement is the official record of your account(s) and assets. We urge you to carefully review your custodian statements and compare them to the account statements that we may provide to you as your investment manager. William Blair has no known financial condition that we believe is likely to impair our ability to meet our commitments to our investment advisory clients. Additionally, we have not been the subject of any bankruptcy petition during the past ten years. You may obtain a copy of our most recent financial statement on our website at www.williamblair.com under “Statement of Financial Condition.” William Blair & Company, L.L.C. – Form ADV Part 2A -Appendix 1– Wrap Program Brochure-March 31, 2025 30