Clarivest Asset Management LLC

ClariVest Asset Management LLC, established in 2006 and registered as an investment adviser with the SEC in 2006, is a Delaware limited liability company specializing in domestic, international, and global equity portfolios. The firm, wholly-owned by Eagle Asset Management, uses a fundamentally based, bottom-up investment strategy supported by various quantitative tools. ClariVest's investment products cover a range of market capitalizations and styles, including growth, core, and value strategies. Clients granting investment and brokerage discretion allow ClariVest to make decisions on securities, brokers, and commissions without specific consent. The firm manages client portfolios on a fully discretionary basis, tailored to individual needs, with client-imposed restrictions accepted in writing. ClariVest may provide model portfolios to Directed Clients for self-trading. Fees are typically calculated as a percentage of assets under management, payable quarterly based on account value. ClariVest does not participate in wrap fee programs. As of September 30, 2024, the firm managed approximately $2.5 billion on a discretionary basis. ClariVest's investment philosophy focuses on behavioral finance, aiming to exploit market inefficiencies caused by human psychology. The investment process involves idea generation, portfolio construction, and implementation, integrating quantitative tools and qualitative decisions. The firm's risk control measures include quantitative and qualitative evaluations to manage active portfolio risk. ClariVest's Code of Ethics ensures compliance with federal securities laws and ethical standards, with a focus on preventing fraudulent conduct and ensuring personal securities transactions do not conflict with client interests. Proxy voting is centralized at the RJIM level, following ISS recommendations, with a focus on maximizing value for clients. ClariVest maintains a robust privacy policy to safeguard client information and restricts access to nonpublic personal information. Compliance and operational procedures ensure client accounts are reviewed for compliance with guidelines and performance standards. The firm's commitment to best execution, client confidentiality, and ethical practices underscores its dedication to serving clients' financial needs.