Harbor Capital Advisors, Inc.

Harbor Capital Advisors, Inc. is a registered investment adviser founded in 1983, offering discretionary and non-discretionary investment advisory services. The firm provides services to various investment vehicles, including mutual funds, exchange-traded funds (ETFs), collective investment trusts (CITs), and model portfolios. Harbor Capital has assets under management totaling $64.79 billion as of December 31, 2024, managed on a discretionary basis. The firm is a wholly owned subsidiary of ORIX Corporation, a global financial services company based in Tokyo, Japan. Harbor Capital charges advisory fees based on the average net assets of each fund or ETF, with fees paid monthly in arrears. The firm may provide marketing and research support to the broader HANetf sales team and may receive compensation from its affiliates for services provided. Harbor Capital acts as a fiduciary, providing investment discretion to manage client assets. The firm conducts due diligence on subadvisers, monitors their performance, and may replace them if necessary. Investment strategies at Harbor Capital are underpinned by a systematic approach focused on identifying business cycle regimes. The firm's investment process includes regime identification, asset-specific return generation, portfolio optimization, and qualitative discretion. Harbor Capital has adopted a Code of Ethics and Proxy Voting Policies to ensure compliance and transparency in its operations. For further details or specific voting information, clients can contact Harbor Capital's Legal & Compliance department. The firm reports quarterly to clients on performance and compliance matters. Harbor Capital does not act as a custodian for client accounts and has no financial conditions impairing its ability to meet commitments.