SHRM Promoters Disclosure

This disclosure is being provided to you in accordance with Rule 206(4)-3 under the Investment Advisers Act of 1940, as amended (“Advisers Act”).

Society for Human Resource Management (“SHRM”) has entered into an agreement with Raymond James & Associates, Inc. (“RJA”) and Raymond James Financial Services Advisors, Inc. (“RJFSA”) (collectively, “Raymond James”) pursuant to which SHRM allows Raymond James to market investment advisory services to SHRM members and conference attendees via priority booth and brand placement at SHRM conferences, as well as co-authorship of marketing materials. SHRM will also provide to Raymond James the names and contact information of attendees at SHRM conferences In exchange for the marketing benefits listed above, Raymond James will pay SHRM an annual flat fee.

Raymond James may attempt to contact conference attendees based on the attendee information received from SHRM, and to the extent an attendee desires to engage Raymond James for advisory services, they would become advisory clients of Raymond James through various investment adviser representatives (“IAR”) of RJA and RJFSA. Such IARs may offer the investment advisory services of RJA and RJFSA under “doing business as” or “DBA” names.

RJA and RJFSA are each investment advisers separately registered under the Advisers Act with the U.S. Securities and Exchange Commission. SHRM and Raymond James are not affiliated and SHRM is not authorized to provide investment advice on behalf of Raymond James or to act for or bind Raymond James. No investment advisory agreement with Raymond James will become effective until accepted by Raymond James.