GLENMEDE INVESTMENT MANAGEMENT, LP

Item 1 – Cover Page Glenmede Investment Management LP 1650 Market Street, Suite 1200 Philadelphia, PA 19103 Telephone: (215) 419- 6000 http://www.glenmedeim.com As of March 31, 2025 This Brochure provides information about the qualifications and business practices of Glenmede Investment Management LP (“GIM”). If you have any questions about the contents of this Brochure, please contact the Chief Compliance Officer, Maria R. McGarry at (215) 419-6092 and/or maria.mcgarry@glenmede.com. 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. Glenmede Investment Management LP is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. Additional information about Glenmede Investment Management LP also is available on the SEC’s website at www.adviserinfo.sec.gov. i  Item 2 – Material Changes SEC Rules require that you receive, annually and free of charge, 1) an updated Brochure (with the material changes from the previous Brochure summarized in this Item) 2) within 120 days of the close of our business’ fiscal year (December 31). We may provide a new Brochure or other ongoing disclosure information about material changes as necessary at no charge to you. If we have not amended the Brochure since the last annual update, and the Brochure continues to be accurate in all material respects, we will not redeliver the Brochure or prepare or deliver a summary of material changes. GIM’s last annual update was as of March 31, 2024. As of December 31, 2024, GIM made the strategic decision to exit the fixed income business. After a thorough review, management concluded that GIM’s fixed income products did not have the scale to effectively compete with large, fixed income asset managers offering similar products and subsequently the firm decided to cease coverage of this asset class. In the late Fall of 2024, the President of the Advisor, Kent Weaver, decided to pursue other opportunities and was succeeded by Elizabeth Eldridge. Finally, though we do not view this as material, the names of several of our strategies changed in early 2025 to clarify and better describe our process for those products. There are no other material changes for the firm as of the reporting period ending March 31, 2025. R. McGarry, Chief Compliance Officer at (215) 419-6092 Other changes have been made which may not be deemed material, including typographical changes and clarifications relating to existing practices in disclosures. Currently, our Brochure may be requested by contacting Maria or maria.mcgarry@glenmede.com. Additional information about Glenmede Investment Management is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with GIM who are registered as investment advisor representatives of GIM. ii  Item 3 -Table of Contents Item 1 – Cover Page .......................................................................................................................................... i Item 2 – Material Changes .............................................................................................................................. ii Item 3 -Table of Contents .............................................................................................................................. iii Item 4 – Advisory Business ............................................................................................................................ 1 Item 5 – Fees and Compensation ................................................................................................................. 1 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................... 3 Item 7 – Types of Clients ............................................................................................................................... 3 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 4 Item 9 – Disciplinary Information ............................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 12 Item 11 – Code of Ethics .............................................................................................................................. 12 Item 12 – Brokerage Practices .................................................................................................................... 13 Item 13 – Review of Accounts .................................................................................................................... 16 Item 14 – Client Referrals and Other Compensation ............................................................................. 17 Item 15 – Custody ......................................................................................................................................... 17 Item 16 – Investment Discretion ................................................................................................................ 17 Item 17 – Voting Client Securities .............................................................................................................. 17 Item 18 – Financial Information .................................................................................................................. 18 Item 19 – Privacy Policy ............................................................................................................................... 18 iii  Item 4 – Advisory Business Glenmede Investment Management LP (“GIM”), successor to Glenmede Advisers, is a wholly owned subsidiary of The Glenmede Trust Company, N.A. (“Trust Company”). GIM offers an array of equity, fixed income and some liquid alternatives portfolios that invest primarily in U.S. markets. GIM is headquartered in Philadelphia, Pennsylvania. As of December 31, 2024, GIM managed a total of $ 7,069,365,851 in assets of which $6,588,293,413 were on a discretionary basis and $ 481,072,438 were on a non-discretionary basis. GIM’s services are provided on a discretionary basis to institutional investors, including registered investment companies (The Glenmede Fund, Inc. collectively, the “Glenmede Funds”), CITs, corporations, pension plans, charitable institutions and to high-net-worth investors. In addition, GIM serves as sub-advisor to high-net-worth individuals who are wealth management clients of the Trust Company. GIM does not provide tactical asset allocation or full-service investment advice; rather, clients select from among GIM’s offered products. From time to time, GIM may accept certain client restrictions, for example, with respect to investing in certain companies or industries. Clients should be aware, however, that some restrictions can limit GIM’s ability to act and as a result, the account’s performance may differ from and be less successful than that of other accounts that have not limited its discretion. GIM offers several of its strategies to wrap platform sponsors (typically broker-dealers or investment advisers). A wrap program is an investment advisory program under which a client typically pays a single fee to the sponsor based on assets under management. Fees paid are not based directly upon transactions in the client’s account or in the execution of client transactions. Wrap program clients typically select GIM’s strategy from a list of investment advisors and strategies presented to clients by the sponsor. Wrap program clients are generally high net worth individuals but can sometimes include institutional investors. The program sponsor has primary responsibility for client communications and service, and GIM provides investment management services to the clients. The program sponsor typically executes the client’s portfolio transactions and, in most cases, provides custodial services. GIM is paid a portion of the wrap fee for its services by the program sponsor. GIM also advises model only investment programs where program sponsors utilize a GIM portfolio to implement an investment program for investors (“overlay programs” or “UMA Programs”) and such sponsors (“overlay sponsors” or “UMA Sponsors”). In overlay or UMA programs, GIM receives a management fee from the sponsor based on the assets managed by the sponsor in accordance with the model portfolio. For equity investment programs, these accounts and assets are considered non-discretionary portfolios, because GIM does not execute the trades and has no control over whether they are in fact executed. All clients who enroll in these types of accounts or programs should carefully review the fee structure and other program documents provided by the sponsor. Investment decisions for wrap program clients and other non-wrap accounts are made in the same investment style. There may be differences between holdings and performance, however, at the individual account level due to (1) restrictions or limitations imposed on GIM by the wrap program account holder or sponsor; (2) differences between taxable and tax-exempt accounts; (3) differences in cash flow in or out of the account; or (4) the use of a fixed rotation schedule or timing of trade communications to overlay managers. A list of those sponsors to whom GIM provides investment management services is contained in Part 1 of Form ADV. Item 5 – Fees and Compensation GIM’s fees are typically charged based on a percentage of the value of the client’s assets under management on a suggested minimum account size as indicated in the chart below. While it is generally GIM’s policy to charge fees in accordance with the fee schedules in effect at the time the investment management Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 1  agreement is signed, fees are subject to negotiation. GIM may waive its minimum fee or account size, or charge fees different from those set forth below depending on facts and circumstances; for example, fees may vary based upon certain criteria such as anticipated growth of investable assets, relationship with the Trust Company, other historic relationships, related accounts, account composition, and the outcome of any client negotiations. The details of all fee arrangements are set forth in the investment management agreement with GIM. GIM generally bills its fees on a quarterly basis, in arrears. GIM accounts which select the Trust Company as custodian may elect to have fees debited directly from their accounts. There were no such accounts in 2024. Accounts held in custody elsewhere are billed separately. A client may terminate its investment advisory agreement by providing written notice within the parameters set forth in the management agreement. Upon termination, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Management fees charged to the Glenmede Funds are set forth in the prospectus, for CITs in the Offering Memorandum and the management fee charged in a wrap or model delivery program is subject to negotiation with the relevant Sponsor. GIM’s standard fee schedule for Separately Managed Accounts is set forth below: Product Type: Small Cap Small Cap Equity* Disciplined U.S. Small Cap Equity* Fee Schedule: First $50 million 0.75% on market value Next $50 million 0.70% on market value Thereafter 0.60% on market value Minimum investment = $10 million SMID Cap Equity First $50 million 0.70% on market value Next $50 million 0.60% on market value Thereafter 0.50% on market value Minimum investment = $10 million Mid Cap Equity First $50 million 0.65% on market value Next $50 million 0.55% on market value Thereafter 0.45% on market value Minimum investment = $10 million Fee Schedule: First $50 million 0.60% on market value Next $50 million 0. 45% on market value Thereafter 0.35% on market value Minimum investment = $10 million Product: Large Cap Disciplined U.S. Value Equity* Disciplined U.S. Growth Equity* Disciplined U.S. Equity * Disciplined U.S.Environmental Equity Disciplined U.S. Low Carbon Equity Disciplined International Equity* Disciplined U.S. Faith Based Equity Environmental Accountability Equity * Women in Leadership U.S. Equity* Equity Income* Strategic Equity* Product: Liquid Alternatives Total Market Plus Equity* Fee Schedule: 0.75% on market value Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 2  Minimum investment = $10 million Long/Short Equity * 1.00% on market value Minimum investment = $10 million Secured Options* Global Secured Options* First $10 million 0.55% on market value Next $40 million 0.45% on market value Thereafter 0.35% on market value Minimum investment =$10 million * Available as a mutual fund investment. Please ask for a prospectus for minimum investment, fee and expense information. All fees and minimums are subject to negotiation. Please note that several of the strategies above were recently renamed. Specifically, all those beginning “Disciplined” were formerly known as “Quantitative.” In addition, the Environmental Accountability Strategy was formerly Responsible ESG strategy. Long/Short Equity was formerly Quantitative U.S. Long/Short Equity Portfolio. Total Market Plus Equity was formerly Quantitative U.S. Total Market Equity Portfolio. In addition to the fees described above, clients may bear other costs associated with investments or account maintenance including but not limited to: (1) custodial charges, brokerage fees, commissions and related costs (see Item 12 for more detail regarding brokerage); (ii) interest expenses; (iii) taxes, duties and other governmental charges; (iv) transfer and registration fees or other similar expenses and (v) if relevant, external management fees and costs; which, if imposed by an unaffiliated Fund, are disclosed in that Fund’s prospectus. In connection with the sale of the Glenmede Funds through certain institutions (“fund supermarkets” or “fund platforms”), GIM may pay, from its advisory fee, between 5 and 40 basis points to such platforms in return for their provision of administrative services and client account maintenance which GIM or its affiliates would otherwise be required to provide. These payments are not made for the purpose of obtaining any preferred status at those institutions. Investors in the Glenmede Funds who are also Trust Company clients pay only the mutual fund management fee, and no account level fee is charged on the value of those assets. Where GIM charges no management fee, the Trust Company charges an account level fee on those assets. Item 6 – Performance-Based Fees and Side-By-Side Management GIM does not currently charge performance fees in any of its accounts. If it does charge performance fees in the future, GIM will do so consistent with the requirements of Section 205(a)(1) of the Investment Advisers Act of 1940 (The “Advisers Act”) and Rule 205-3 thereunder. Item 7 – Types of Clients GIM offers its services to corporate pension and profit-sharing plans, Taft-Hartley plans, charitable institutions, foundations, endowments, municipalities, corporations, and the Glenmede Funds. In addition, GIM provides its services to high-net-worth individuals through sub-advisory contracts with its parent company, the Trust Company. GIM generally requires its separate account clients to have a minimum new account size consistent with the schedule contained in Item 5 but will waive that requirement because of Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 3  long-standing relationships with that client or its affiliates, because of that client’s relationship with the Trust Company, anticipated client additions to assets under management or for a variety of other reasons. GIM also offers its investment advisory services to clients of Wrap Sponsors. In accounts introduced to GIM by a Sponsor, the client either enters into agreements directly with both GIM and the Sponsor, or solely with the Sponsor, or related entity. Minimum account size in these arrangements is typically $100,000. In addition, GIM provides model investment portfolios to overlay or UMA sponsors for negotiated fees. Under these arrangements, all or a portion of the securities transactions for accounts of the overlay sponsor’s clients are implemented by the overlay sponsor or its agent based on the model furnished. Minimum account size in these arrangements is set by the sponsor. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss GIM offers an array of equity and liquid alternatives strategies in separately managed accounts, collective investment trusts, and mutual fund products. Fundamental equity strategies include large and small-cap stocks using a blend of growth and value styles. GIM also features quantitatively oriented domestic and foreign equity strategies (the “Disciplined Equity” strategies. Using quantitative analysis in the Disciplined Equity products, GIM creates proprietary multi factor models to select stocks that the models identify as having good fundamentals and rising earnings expectations. Models rank securities based on certain criteria including material environmental, social and governance (”ESG”) criteria. ESG considerations are generally not solely determinative in any investment decisions. The Disciplined Equity international strategy invests in equity securities of foreign companies, directly and/or through American Depositary Receipts (“ADRs”). ADRs are depositary receipts issued in registered form by a U.S. bank or trust company evidencing ownership of underlying securities issued by foreign companies. Under normal market circumstances, the strategy will invest, directly and/or through ADRs in companies based in at least three countries other than the United States in primarily developed markets. Liquid Alternatives include long/short strategies (Total Market Plus Equity and Long/Short Equity) and secured options strategies (Secured Options and Global Secured Options). Glenmede believes that a portfolio using long and short-equity positions based on multi factor stock ranking models, overlaid with upside and downside risk screens, can contribute to long-term capital appreciation consistent with reasonable risk to principal. In addition, Glenmede believes there are advantages to option investments both domestically and globally as long as implied volatility trades at a premium to subsequent realized volatility. All equity strategies may buy mutual funds or exchange traded funds, although subject to the requirements of the Investment Company Act of 1940 and the rules thereunder. GIM’s selection of investments is based upon an investment process that utilizes technical, fundamental, and charting techniques based upon information obtained from financial publications, direct corporate data, proprietary and third-party research reports, proxy, 10K, 10Q and other SEC filings. The Disciplined Equity products managed by GIM also identify those Environmental, Social and Governance “ ESG”) factors which are deemed to be material to performance. The ESG specific products managed by the Disciplined Equity team are described in more detail below. GIM also seeks to integrate appropriate ESG factors into its fundamental equity strategies by assessing third- party data and development of its own proprietary materiality framework. Analysts help to identify whether Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 4  issuers are managing ESG risk exposures adequately, whether they are exposed to excessive risk through their business activities and whether an ESG factor could make an investment more attractive from a risk- adjusted return perspective. GIM strategies may utilize long and short-term trading, short sales, and options trading (in the Secured Options and Global Secured Options products only) to meet their articulated investment objectives. This section contains a discussion of the primary investment strategies used by GIM and the primary risks associated therewith. It is not possible to identify all the risks associated with investing for a particular client. While GIM seeks to manage its strategies so that risks are appropriate thereto, it is not always possible or desirable to eliminate risks. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. Clients should be prepared to bear the risk of such potential losses. The Principal Risks of the strategies are set forth in Section C. below. Fuller discussions of both the investment objectives and risks of the strategies which are also available through the Glenmede Funds are contained in the prospectus and the Statement of Additional Information for those Funds. Investors with interest in those products should read those documents prior to investment. Domestic Equity Strategies A. 1. Discipline Oriented Strategies a. Disciplined U.S. Equity, Disciplined U.S. Growth, Disciplined U.S. Value and Disciplined U.S. Small Cap Equity In the quantitatively oriented large cap investment strategies (Disciplined U.S. Equity, Disciplined U.S. Growth, Disciplined U.S. Value and Disciplined U.S. Small Cap Equity), GIM utilizes a disciplined methodology to create a portfolio that seeks superior long-term performance as compared to the relevant index with reasonable risk to principal. The relevant index for a portfolio is based primarily on market capitalization and style. GIM utilizes proprietary quantitatively oriented models based on long- term fundamentals and valuations to differentiate among securities within each sector of the market and then applies optimization models to provide broad diversification across sectors, industries and companies. The models include factors addressing ESG Risk. GIM’s managers review optimization results and have final decision with respect to which securities are to be included in the portfolio. This process is designed to result in a portfolio of securities with an attractive combination of valuation, fundamentals, earnings and technical characteristics. b. Sustainable Large Cap Strategies The investment objective of the sustainable large cap strategies (Environmental, Low Carbon, Faith Based, Environmental Accountability and Women in Leadership) is to seek superior long-term performance with reasonable risk to principal while investing consistent with a client’s environmental, social and governance (ESG) interests. These strategies reflect approaches like those used in the Large Cap Growth and Large Cap Core strategies; that is, the use of multi-factor models to select stocks which the models identify as having reasonable prices and good fundamentals. In addition, these strategies involve a combination of positive and negative screening to preference companies that meet certain predefined criteria. The Environmental strategy seeks to employ screens to exclude companies that have Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 5  international norms and principles around human rights). poor environmental practices as determined by third party ratings system. Low Carbon seeks to identify and exclude the largest carbon emitters based on third party ratings, and therefore excludes most of the energy, utilities, and chemicals sector (with specific exceptions) airlines, and cruises. The Faith Based Strategies use negative screening to exclude companies which engage in activities or industries deemed undesirable by some investors, such as alcohol, tobacco, weapons or contraceptives. The Environmental Accountability strategy uses a process to identify companies that satisfy certain criteria (including but not limited to key performance indicators around climate change, corporate governance and ethics and adherence to The Environmental Accountability strategy seeks to invest in companies whose scores in these regards are improving. The Women in Leadership strategy seeks to identify those companies that meet its criteria by including women in significant roles, including but not limited to, board chair, female executive officer, and/or at least 33% of its management positions. It may also consider data relating to pay, access to benefits and anti-harassment policies. Fundamental Strategies Equity Income, Small Cap and Strategic Equity Strategies a. Equity Income Strategy GIM’s Equity Income strategy seeks to construct a portfolio of companies that can generate not only income, but growth in income. The strategy attempts to provide a yield that is superior to the S&P 500, while generating a competitive total return over a market cycle. The strategy employs quantitative screens to identify candidates, from which the portfolio manager selects individual names based on insight from our fundamental research analysts. b. Small Cap Strategy GIM offers a Small Cap strategy which seek to provide investors with superior returns compared to the relevant index (the FTSE Russell 2000) with reasonable risk to principal. The investment philosophy underlying this strategy is that a diversified portfolio of high quality, inexpensive stocks which are exhibiting company-specific positive trends will outperform the market. A quantitative filter uses a proprietary model to identify a list of attractive securities having revenue and earnings growth potential with reasonable valuations. The portfolio managers then apply fundamental research to select which securities to buy and sell. c. Strategic Equity Strategy The Strategic Equity strategy seeks to invest primarily in large-cap stocks of well-managed companies with durable business models that can be purchased at attractive valuations. The strategy combines GIM’s proprietary multi-factor model with the insight of our fundamental research analysts. GIM has developed a list of characteristics it believes help identify companies that create shareholder value over the long term and manage risk. While few companies possess all these characteristics at any given time, we search for companies that demonstrate a majority or an appropriate mix of these characteristics. B. Liquid Alternatives Secured Options, Global Secured Options, Long/Short, and Total Market Plus Strategies Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 6  Secured Options Strategy and Global Secured Options Strategy The investment objective of both the Secured Options Strategy and the Global Secured Options Strategy is to achieve long-term capital appreciation and obtain income from option premiums consistent with reasonable risk to principal. In Secured Options, GIM seeks to achieve this objective by investing, under normal market circumstances, in a diversified portfolio of equity securities (either by buying such securities directly, or by owning stock index exchange traded funds “ETFs”) while also using option writing strategies to obtain option premiums and reduce risk. The strategy attempts to balance the upside potential of the underlying securities with downside risk management. The strategy seeks to provide positive risk adjusted returns relative to the S&P 500 and outperform the CBOE S&P 500 PutWrite Index (PWT). In Global Secured Options, GIM seeks to achieve this objective by investing, under normal market circumstances, in a diversified portfolio of US and non-US stocks or ETFs while also using option writing strategies to obtain option premiums and reduce risk. This strategy seeks to provide positive risk-adjusted returns relative to the MSCI ACWI index. Long/Short and Total Market Plus Strategies Using quantitative analysis, the. Long Short strategy invests long (short) in companies with an attractive (unattractive) combination of valuation, fundamental, earnings and technical characteristics. Generally, the strategy is based on proprietary, multi-factor models which rank stocks within each sector. The Long Short Strategy uses a portfolio-optimization process. Initial buy screens are based on our quantitative multi-factor GIM Long Buy Model identifying stocks in the top three deciles of each sector. GIM takes long positions in securities that the models identify as undervalued and more likely to appreciate and takes short positions in equity securities that GIM identifies as overvalued and more likely to depreciate. GIM uses portfolio optimization tools to determine the size of each long or short position and its impact on the risk to the overall portfolio. The frequency and size of short sales will vary substantially in different periods as market opportunities change. Under normal circumstances, the Portfolio will generally have an operating target of 60-140 long positions that may range from 75% to 100% of net assets and 40-120 short positions that may range from 50% to 95% of net assets from time to time. The Total Market Plus Equity strategy invests in U.S. stocks using long equity positions that GIM believes may have superior appreciation potential, with an attractive combination of valuation, fundamental, earnings, and technical characteristics. The short equity positions include stocks that, in the manager’s view, have inferior appreciation potential with an unattractive combination of valuation, fundamentals, earnings, and technical characteristics. The stock ranking models and industry group indicators are based on deep research with the objective of seeking to provide consistent performance through different economic/market cycles and minimizing downside risk (excess return per unit of downside risk). The strategy utilizes a multi-factor approach favoring stocks with cheaper valuations, higher quality characteristics (stronger fundamentals, positive earnings estimate trends, etc.), and attractive technicals. In addition, the strategy targets benchmark agnostic long and short stock positions within sectors which we believe may result in a lower average market capitalization relative to the cap-weighted benchmark index. The strategy utilizes indicators based on a combination of economic and market factors to over or underweight industry groups (GICS) relative to benchmark weightings. These indicators are intended to allow the strategy to reflect biases based on the prevailing stage of the economic/market cycle. C. Disciplined International Equity Strategy Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 7  The investment objective of the Disciplined International Equity Strategy is maximum long-term total return consistent with reasonable risk to principal. GIM uses proprietary multi-factor models to select foreign companies that have reasonable prices, good fundamentals and rising earnings expectations. These models rank securities based on certain criteria, including valuation ratios, profitability, and earnings-related measures. Unlike some other purely quantitative strategies, GIM’s managers review optimization results and have final decision with respect to which securities are to be included in the portfolio. This process is designed to result in a portfolio of securities with an attractive combination of valuation, fundamentals, earnings, and technical characteristics. Under normal market circumstances, this strategy will invest in ADRs, or local direct shares of companies based in at least three countries other than the United States, in primarily developed markets. D. Principal Investment Risks of Strategies 1. Risks of Equity and Options Strategies Market Risk: This risk exists in all our strategies. The price of securities in a market, a sector, or an industry will fluctuate, and those movements might reduce the value of an investment. Frequent Trading Risk: Applicable to all equity strategies, but particularly to the quantitatively oriented strategies. The strategies may trade actively to achieve their respective investment objectives. A high rate of portfolio turnover involves correspondingly high transaction costs, which may adversely affect the strategies’ performance over time. High turnover may also result in the realization of short-term capital gains. Distributions derived from such gains will be treated as ordinary income for Federal income tax purposes. ADR/Foreign Securities Risk: The Secured Options, Global Secured Options and Strategic Equity strategies may invest in ADRs, which are depositary receipts issued in registered form by a U.S. bank or trust company evidencing ownership of underlying securities issued by a foreign company. This permits Americans to buy interests in foreign-based companies in U.S. markets and entitles a holder to obtain dividends and capital gains. The Disciplined International Equity Portfolio invests both in ADRs and in local direct shares in foreign companies. Investments in ADRs involve risks like those accompanying direct investments in foreign securities. Foreign investments may be riskier than U.S. investments because of factors such as foreign government restrictions, changes in currency exchange rates, incomplete financial information about the issuers of securities, and political or economic instability. Foreign stocks may be more volatile and less liquid than U.S. stocks. Investments outside the United States may also be subject to different settlement and accounting practices, and different regulatory, legal, and reporting standards and may be more difficult to value than those in the United States. IPO Risk: The Small Cap, Equity Income, and Strategic Equity strategies can invest in IPOs, although historically they have not done so. The market value of IPO shares could fluctuate considerably due to factors such as the absence of a prior public market, unseasoned trading, potentially a small number of shares available for trading and limited information about the issuer. When a strategy’s asset base is small, a significant portion of the performance could be attributable to investments in IPOs, because such investments would have a magnified impact on the strategy. Dividend Paying Security Risk: Income provided by the strategies may be affected by changes in the dividend policies of the companies in which the strategies invests and the capital resources available for such payments at such companies. Issuers that have paid regular dividends or distributions to shareholders may not continue to do so at the same level or at all in the future. Dividend paying securities can fall out of favor Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 8  with the market, causing the strategies during such periods to underperform funds that do not focus on dividends. Preferred Stock Risk: Preferred stock generally does not exhibit as great a potential for appreciation as common stock, although it ranks above common stock in its claim on income for dividend payments. In the event an issuer is liquidated or declares bankruptcy, the claims of owners of bonds take precedence over the claims of preferred and common stock owners. Preferred stock may also be subject to optional or mandatory redemption provisions. Tax Managed Risk: Some of the strategies (or versions of the strategies) are designed to reduce the impact of Federal and state income taxes on shareholder’s returns. As a result, the strategies may forego the opportunity to realize gains or reduce losses. Short Sales Risk: The Long/Short and Total Market Plus strategies are permitted to short securities as part of their strategies. Short sales are transactions in which an investor sells a security it does not own but can borrow in the market. Short selling allows the strategy to profit from a decline in market price to the extent such decline exceeds the transaction costs and the costs of borrowing the securities and to obtain a low cost means of financing long investments. If a security sold short increases in price, the strategy may have to cover its short position at a higher price than the short sale price, resulting in a loss. Other risks include the potential inability to borrow a security that GIM needs to deliver or be unable to close out a short position at an acceptable price and may have to sell related long positions earlier than it had expected. Because losses on short sales arise from increases in the value of the security sold short, such losses are theoretically unlimited. By contrast, a loss on a long position arises from decreases in the value of the security and is limited by the fact that a security’s value cannot decrease below zero. By investing the proceeds received from selling securities short, the strategies could be deemed to be employing a form of leverage, which creates special risks. The use of leverage may increase exposure to long securities positions and make any change in the overall value of the strategy larger than it would be without the use of leverage. This could result in increased volatility of returns. Due to these risks, GIM’s strategies seek to limit the amount of short selling in each strategy. Small Cap Risk: The Small Cap and Mid Cap strategies invest in stocks of smaller and sometimes newer issuers which may be more volatile and speculative than the stocks of larger issuers. Smaller companies tend to have limited resources, product lines and market share. As a result, their share prices tend to fluctuate more than those of larger companies. Their shares may also trade less frequently and in limited volume, making them potentially less liquid. The price of small company stocks might fall regardless of trends in the broader market. Options Risk: The Secured Options and Global Secured Options Strategies use options writing strategies. Writing and purchasing call and put options are highly specialized activities and entail greater than ordinary investment risks. The successful use of options depends in part on the future price fluctuations and the degree of correlation between the options and the securities markets. The value of the strategy’s positions in options fluctuates in response to changes in the value of the underlying security or index, as applicable. The strategy also risks losing all or part of the cash paid for purchasing call and put options. Strategy assets covering written options cannot be sold while the option is outstanding, unless replaced with similar assets. As a result, there is a possibility that segregation of a large percentage of the strategy’s assets could affect its portfolio management as well as the ability of the strategy to meet redemption requests or other current obligations. Unusual market conditions or the lack of a ready market for any option at a specific time may reduce the effectiveness of this strategy’s option strategies, and for these and other reasons the option strategies utilized may not reduce the strategy’s volatility to the extent desired. The strategy may reduce its holdings of put options resulting in an increased exposure to a market decline. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 9  Sustainable Strategies and ESG Risks: The application of social environmental and governance standards will affect exposure to certain issuers, industries, sectors, regions and countries and may impact the relative financial performance of any such strategy – positively or negatively – depending on whether such investments are in or out of favor An investment’s ESG performance or the investment adviser’s assessment of such performance may change over time, which could cause strategies to temporarily hold securities that do not comply with their articulated ESG investment criteria. In evaluating securities, GIM is dependent upon information and data that may be incomplete, inaccurate, or unavailable, which could adversely affect the analysis of the ESG factors relevant to a particular investment. Successful application of investment strategy will depend on the investment adviser’s skill in properly identifying and analyzing material ESG issues. Value Style Risk. Although these strategies take long positions in stocks GIM believes to be undervalued, there is no guarantee that the prices of these stocks will not move even lower. In addition, the value investment style can shift into and out of favor with investors, depending on market and economic conditions. As a result, value-oriented portfolios may at times outperform or underperform other funds that invest more broadly or employ a different investment style. Model Risk. All our quantitative products use proprietary models that incorporate quantitative analysis. Investments selected using these models may perform differently than as forecasted due to the factors incorporated into the models and the weighting of each factor, changes from historical trends, and issues in the construction and implementation of the models (including, but not limited to, software issues and other technological issues). There is no guarantee that use of these models will result in effective investment decisions. The information and data used in the models may be supplied by third parties. Inaccurate or incomplete data may limit the effectiveness of the models. In addition, some of the data uses is historical data, which may not accurately predict future market movement. There is a risk that the models will not be successful in selecting investments or in determining the weighting of investment positions that will enable strategies to achieve their investment objectives. 2. Risks of Fixed Income and Cash Management Strategies From time to time, certain strategies may have positions in fixed income securities and Treasuries for various purposes. These risks are associated with those positions. Credit Risk: Fixed income securities are also subject to the risk that an issuer will be unable to make principal and interest payments when due. Although generally GIM seeks to invest in obligations rated A or better at the time of purchase, the strategies may invest in shares of registered investment companies (primarily ETF’s) rated BBB- or higher by S&P or Baa3 or higher by Moody’s or if unrated, determined to be of comparable quality at the time of purchase. Securities rated BBB- or Baa3 are considered medium-grade obligations with speculative characteristics and are more vulnerable to adverse business or economic conditions than higher rated securities. Government Agency Risk: Direct obligations of the U.S. Government such as Treasury bills, notes and bonds are supported by its full faith and credit. Indirect obligations issued by Federal agencies and government- sponsored entities generally are not backed by the full faith and credit of the U.S. Treasury. Accordingly, while U.S. Government agencies and instrumentalities may be chartered or sponsored by Acts of Congress, their securities are neither issued nor guaranteed by the U.S. Treasury. Some of these indirect obligations may be supported by the right of the issuer to borrow from the Treasury; others are supported by the discretionary authority of the U.S. Government to purchase the agency’s obligations; still others are supported only by the credit of the instrumentality. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 10  Frequent Trading Risk: The strategies may actively trade portfolio securities to achieve the principal investment strategies. A high rate of turnover involves correspondingly high transaction costs, which may adversely affect the strategies’ performance over time. High turnover may also result in the realization of short-term capital gains. Distributions derived from such gains will be treated as ordinary income for Federal income tax purposes. Default Risk: The strategies may make loans through collateralized repurchase agreements. They may also borrow money through reverse repurchase agreements. Although loans made by the strategies are collateralized with the borrower’s securities, the strategies could suffer a loss if the borrower defaults on its obligation to buy the securities back under the terms of the repurchase agreement. 2. Risks Applicable to All Strategies Cybersecurity Risks —GIM is dependent on the effectiveness of the information and cybersecurity policies it uses to protect the confidentiality, integrity, and availability of its computer and telecommunications systems and the data that resides on or is transmitted through them. Given a variety of factors, including the prevalence of technology, and the proliferation of both state sponsored and private hackers, GIM has become potentially more susceptible to operational and information security risks. A cybersecurity breach can result from either a deliberate attack or an unintentional event. Cybersecurity breaches may involve such items as viruses or other malicious code, or unauthorized access to information systems, networks or devices through “hacking” or other means, for the purpose of misappropriating assets or sensitive information (including, for example, clients’ personal information), corrupting data or causing operational disruption or failures in the physical infrastructure or operating systems used by GIM. These risks could result in increased costs associated with corrective measures or other financial loss. GIM has business continuity plans, and a cybersecurity program designed to prevent or reduce the impact of such attacks, but the tactics are constantly changing, and there is a possibility that certain risks will not be avoided. Although GIM does have systems to evaluate the security of its vendors and communications with such vendors as well as clients, it is possible that a cybersecurity event can affect a vendor or vendors and can cause a disruption or loss of data. Cybersecurity risks may also impact issuers of securities in which GIM invests, which may cause those investments to lose value. Operational Events– To the extent that a strategy relies on proprietary and third-party data analysis and systems to support investment decision making, there is a risk of software or other technology malfunctions, programming inaccuracies, or cybersecurity events that may impair the performance of these systems and therefore, affect investment performance. Loss of investment — An investor may lose money by investing in any strategy. The likelihood of loss may be greater if the investor invests for a shorter period. Natural and Unavoidable Events: Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term and wide-spread effects on the world economies and markets generally. Clients may have exposure to countries and markets impacted by such events, which could result in material losses. Investments are not guaranteed — Investments the strategies are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other governmental agency, entity or person. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 11  Item 9 – Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of GIM or the integrity of GIM’s management. GIM has no information about the firm applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations GIM's affiliate, the Trust Company, is a trust company chartered under the National Bank Act and supervised by the Office of the Comptroller of the Currency (OCC). The Trust Company provides trust and investment advisory services to high-net-worth individuals and institutions. It also acts as non-member manager of several alternative investment pools exempt from registration under the Investment Company Act of 1940 pursuant to Sections 3(c)(1) or 3(c)(7) (hedge funds, real estate, and private equity funds). None of those pools own or trade the same types of securities as GIM uses for its strategies. GIM and the Trust Company provide services to one another and share various resources. For example, the Trust Company provides back office, valuation, IT and legal support to GIM and GIM clients, while GIM provides equity trading services and investment management services to Trust Company clients in SMAs. In addition, GIM and the Trust Company share office space and the services of certain vendors, such as ISS- SToxx, which is used to analyze and vote proxies by both GIM and the Trust Company. GIM relies on the Trust Company’s Business Continuity and Disaster Recovery facilities and plan, which incorporates provisions to meet GIM’s needs. The Trust Company and GIM periodically assess the services provided to one another to determine whether and in what magnitude payments from one to the other should be made. GIM serves as advisor to the Glenmede Funds, which are registered investment companies, for management fees described in the relevant prospectus. The Trust Company also provides anti-money laundering, sub- transfer agent and other services to the Glenmede Funds. Both GIM and the Trust Company waive fees to the Glenmede Funds under certain circumstances articulated in the prospectus. Trust Company clients comprise a significant portion of the Funds’ assets. GTC excludes the value of any Glenmede Funds holding when calculating its account-level management fee if the fund has collected a management fee for GIM. GIM also may, from time to time, support various seminars or training programs for Wrap Sponsors. GIM is not a broker-dealer, does not receive transaction-related compensation and is registered with no federal regulator other than the SEC. It files exemptions with the CFTC and NFA as a Commodity Pool Operator on behalf of the funds it advises which do use (or might use) options. GIM does not actively solicit business outside of the United States. Item 11 – Code of Ethics GIM has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition on manipulation, restrictions, and reporting requirements with respect to gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at GIM must acknowledge the terms of the Code of Ethics annually, or as amended. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 12  GIM manages most of its accounts on a discretionary basis. From time to time, GIM may cause such accounts to purchase or sell securities (or recommend that a prospect purchase or sell securities) in which GIM or its related persons have a financial interest. These types of transactions present a conflict of interest in that employees or related persons might benefit from market activity by a client in a security held by such employee or related person. To reasonably prevent such conflicts, GIM monitors the personal trading of employees and other associated persons. The Code of Ethics requires pre-clearance of most securities transactions and restricts trading in close proximity to client trading activity. GIM also has a guideline minimum holding period of 30 days for most personal securities transactions. GIM’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Maria R. McGarry, Chief Compliance Officer at (215) 419-6092. Item 12 – Brokerage Practices A. Selection of Brokers, Dealers and Other Trading Venues. GIM will generally select brokers and dealers that will execute transactions initiated by GIM for an Account and select the markets in which the portfolio transactions will be executed in accordance with its best execution policies and procedures. Best execution consists of seeking the most favorable result, considering a full range of services provided, under prevailing market conditions. Best execution is not necessarily measured by the circumstances surrounding a single transaction but may be measured over time. While GIM seeks competitive pricing or commission rates, it does not necessarily pay the lowest spread or commission available. As a result, in selecting broker-dealers, GIM may take into account many factors, including but not limited to the following: size of the order, price of the security; execution difficulty; liquidity; market and exchange conditions; macro-economic conditions; current news events; order flow information; speed of execution; broker ability to execute a large or small trade; ability or inability of electronic communication network to handle transactions; value of brokerage and research services provided to GIM and commission cost. GIM periodically reviews execution performance of the broker- dealers used to execute trades. As described further in Section D below, GIM generally executes equity trades for wrap accounts at the platform sponsor or its affiliate because those clients are typically paying a fee which includes trade execution. Accordingly, the factors described above may not be relevant to determination of best execution for such clients. All execution decisions relating to overlay accounts, including the decision regarding whether to trade at all, are made by the platform sponsor or custodian. B. Payments for Research and Other Services (“Soft Dollars”). GIM may direct client brokerage to broker-dealers who provide research and brokerage services to GIM and its affiliates. Such arrangements are subject to GIM’s best execution policies and are intended to comply with the safe harbor of Section 28(e) of the Securities Exchange Act of 1934 which permits the payment of commissions that exceed commissions other broker-dealers may charge if GIM determines that such commissions are reasonable in relation to the research or brokerage services provided. Generally, the research provided may include technology, quantitative analytical software, macroeconomic, strategy or specialty research that takes the form of subscriptions, data and analysis provided either orally, electronically or in writing. Research and brokerage services received may include proprietary research generated by the broker-dealers that execute the transactions as well as research generated by third parties. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 13  A broker-dealer might also furnish GIM or its affiliates with a mixed-use product or service that is useful both in making investment decisions for managed accounts and in performing administrative or other non- research functions. Where this occurs, GIM allocates the cost of the product or service such that the portion or specific component that assists in the investment decision-making process is obtained with commissions and the portion or specific component that provides non-research assistance is paid for in “hard dollars” by GIM or its affiliates. GIM may select a broker-dealer based on its or its affiliate’s interest in receiving the research or other products or services, rather than on its clients’ interest in receiving the most favorable execution. Also, GIM may incur obligations to pay for research with its own funds to the extent that the services are not fully paid for by client brokerage. Such obligation presents a conflict between GIM’s interest in avoiding payment for research services with its own funds and GIM’s interest in seeking best execution for client transactions. GIM believes that the investment research and information provided by brokers or dealers and their ability to achieve quality executions and other brokerage services is important to all GIM’s clients. Therefore, GIM does not attempt to put a specific dollar value on the brokerage or research services of any broker or dealer or to allocate the relative costs or benefits of those services among clients. Thus, the research received for an account’s brokerage commissions may or may not be useful to GIM or its affiliates with respect to investment management of any client’s account but may be useful as to accounts of other clients. Similarly, the research received for the commissions of accounts of other clients of GIM or its affiliates may be useful to GIM with respect to investment management of a given account. As it is generally difficult to trade fixed income instruments in a fashion which generates soft dollars, fixed income research is acquired using soft dollars that have been garnered from equity executions. The Best Execution Committee reviews quarterly the firm’s trading, including the use of client commissions to obtain research and brokerage services. It evaluates such matters as the types and costs of services received, the commissions used to obtain such services and the allocation of any mixed-used items. C. Brokerage for Client Referrals. In selecting broker-dealers, GIM does not consider whether it receives client referrals from the broker dealer or third party. GIM does from time to time execute transactions through at least one firm whose affiliates sponsor wrap or overlay platforms on which GIM products are featured. Commissions paid are in no way tied to those platforms. Rarely, a client may direct GIM to use the services of a particular broker-dealer in executing transactions for that client’s account. In some cases, the directed broker may have recommended GIM as a manager for that account. D. Directed Brokerage and Other Client Restrictions. GIM may accept a client’s instructions for direction of a portion of the client’s brokerage transactions to a particular broker-dealer, although it rarely does so. For any such directed brokerage arrangement, GIM will not be responsible for negotiating commissions, may not obtain volume discounts or price improvements, and best execution may not be obtained. Clients who instruct GIM to direct brokerage business are responsible for negotiating commission rates. Higher commission costs, transaction and other fees may apply, even though similar services may be obtained from other broker dealers at lower costs. Directing GIM to use a particular broker-dealer might also affect the timing of a client’s transaction, and not all broker-dealers have the systems or expertise to effectively process transactions. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 14  Investment decisions are generally applied to all accounts participating in a particular investment strategy. These decisions may consider specific client restrictions or instructions, as well as cash balance requirements and tax related issues. Disparities are possible among clients in the strategy for securities purchased, pricing, and commissions paid because of these restrictions. Wrap programs or other sponsor accounts may direct GIM to direct trades through or with the Sponsor or other broker or dealer. In such cases, clients may pay higher commission rates. If GIM effects transactions through a non-Sponsor broker-dealer, the client may pay commissions or commission equivalents in addition to any trade execution compensation already agreed upon between the client and the Sponsor as part of the Sponsor’s fee. Due to this additional cost, GIM will typically cause most trades for clients who have already agreed to such compensation to be executed by the Sponsor. E. Trade Aggregation and Allocation. When buying or selling the same security for multiple clients, GIM will generally aggregate client orders to achieve a timely and fair execution. An order will not be aggregated if there is a specific account or client limitation, such as investment guidelines, tax status, or brokerage direction, which would prevent it. GIM’s policy is to allocate securities to its clients in a fair and equitable manner to assure that no client is routinely favored or disfavored. Accordingly, each client participating in an aggregated order that has been fully filled will receive the full pro-rata allocation at the average price for the transaction. Transaction costs are shared on a pro-rata basis. Allocations are generally made on the day the order was executed. If an allocation is not completed the same day, the remaining amount will be executed pro-rata on the next day. Partial fills are generally allocated pro rata based on the client’s participation in the aggregated order at an average price. Orders are allocated to the appropriate accounts by the end of the day the order was executed. A partial fill may not be allocated pro rata if such a small amount has been transacted that pro rata allocation among accounts would result, in GIM’s judgment, in a non-meaningful allocation. In these cases, GIM will use best efforts to allocate such de minimis amounts to the accounts in an equitable manner. F. Trade Rotation. GIM does not negotiate fees or brokerage commissions with wrap sponsors on behalf of wrap clients. These commissions are generally included in the “wrap” fee charged by the sponsor. Typically, GIM executes orders for equity wrap accounts separately from transactions for its institutional accounts due to operational constraints. For wrap accounts, GIM has adopted a trade rotation policy to assure that orders executed for equity wrap clients and communicated to overlay sponsors are fair and equitable to all clients. GIM employs equity “wrap traders” who are responsible for communicating model changes to overlay clients and/or executing trades for equity wrap clients. The equity wrap desk maintains a fixed rotation schedule for each product which includes each equity wrap sponsor and GIM’s trading desk. Certain wrap platforms may be bundled together at the discretion of the equity wrap trade desk to assure that all platforms obtain the most efficient execution. As dictated by that schedule, the wrap desk executes the required transactions on behalf of the equity wrap program or informs the GIM trade desk that it can trade. To the extent that Sponsor accounts are traded on the Sponsor’s system, GIM may be unable to execute orders for such accounts at the time otherwise dictated by the fixed rotation schedule if the Sponsor’s system is unavailable. The equity wrap desk communicates trades to overlay sponsors typically upon conclusion of the fixed rotation schedule. GIM makes every effort to treat all its wrap and overlay clients fairly; however, it does not guarantee that any wrap or overlay program will be in the market by itself when trades are communicated to or executed for other such programs. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 15  G. Trade Errors. GIM’s policy is to identify and resolve trade errors promptly. Consistent with its fiduciary duty to its clients, GIM seeks to put the client in the same position that the client would have been in if the error had not occurred. Generally speaking, a trade error is the result of action or inaction by a GIM employee which prevents an account from being traded in a manner consistent with instructions provided by the manager or the client, results in the execution of an unintended trade or causes a violation of any applicable policy or law, such as buying or selling the wrong securities in the wrong quantities or failing to trade as required. GIM will determine on a case-by-case basis whether any remuneration is required and how it is calculated. As the goal is to put clients in the same position had the error not occurred, Clients will neither absorb losses nor ordinarily receive gains as the result of an error or its correction. Clients will not ordinarily be notified of an error unless the error is, in GIM’s sole view, material. H. Opposite Direction Trades. GIM may sometimes trade the same securities in opposite directions for multiple accounts. This means that GIM may be buying the same security for a strategy and selling that same security in another; or holding a security in one transaction and selling long or short in another. This may be due to having different strategies with different objectives managed by different teams or may occur in accounts with similar investment strategies due to differing cash flows or restrictions. A manager may even choose to short sell a security as a hedge on a long position absent a specific restriction. As part of its overall review of trading, Compliance will review to assure that no products or accounts are unfairly benefitting from such trades. Item 13 – Review of Accounts GIM reviews client accounts continually as portfolio managers and others track individual securities, economic sectors, countries (if applicable), and overall strategy performance. The performance and characteristics of all client accounts are periodically reviewed by portfolio managers. In addition, all strategies are subject to an annual Strategy Review conducted by the GIM Investment Policy Committee which, among other things, investigates the investment process used by the portfolio managers for consistency with its stated investment objectives. Senior management also conducts a regular review with portfolio managers to confirm compliance with or enhancements to the investment philosophy and process along with corresponding performance. Discrepancies in performance across accounts are reported and discussed regularly. GIM provides transaction and performance reports monthly, quarterly, or annually as requested by the client. Most clients receive written account statements monthly, but not less than quarterly. In addition to a regular statement, clients receive information regarding their holdings, portfolio manager commentary, and GIM’s periodic Newsletter. Statements or other reports for wrap or overlay clients are produced by the Sponsor and/or its affiliate custodian on a monthly or quarterly basis as agreed between the Client and the Sponsor. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 16  Item 14 – Client Referrals and Other Compensation GIM does not currently compensate any third party for client referrals. If practice changes, it will happen only in accordance with applicable rules. GIM may provide investment management services to clients of consultants who introduce such clients. Though GIM does not pay for such introductions, GIM may purchase products or services from such consultants, or may pay to attend conferences hosted by such consultants. Item 15 – Custody GIM itself does not generally have custody of clients’ assets, but from time to time is deemed to have custody because its parent, the Trust Company, may act as custodian for certain accounts managed by GIM and clients may have GIM fees debited therefrom. Clients should receive at least quarterly statements from whatever qualified custodian that holds and maintains client’s investment assets. GIM urges you to carefully review such statements and compare such official custodial records to any account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion The standard investment management agreement which GIM clients are required to sign gives GIM discretionary authority to manage investments, consistent with the stated investment objectives for the client account. As GIM is not a full-service wealth manager providing customized account service, clients typically do not impose limitations on GIM’s investment discretion. GIM may choose to accept clients who have provided specific written investment guidelines or restrictions; though these limitations may result in performance differing from that of clients who did not restrict GIM’s discretion. GIM’s authority to trade securities on behalf of the Glenmede Funds may also be limited by the prospectus or certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Item 17 – Voting Client Securities GIM generally votes all voting securities held in discretionary accounts unless otherwise directed by a client. To assist in doing so, GIM engages the services of a third-party proxy advisor, currently Institutional Shareholder Services, Inc. (ISS-STOXX), to evaluate, recommend and vote shares consistent with those recommendations. GIM evaluates the summary of ISS-STOXX voting policies annually to assure that they remain consistent with firm views of the long-term interests of clients and investors. Currently, Glenmede utilizes ISS-STOXX’s Sustainability Policy for all its equity strategies, except for the Women in Leadership product, which utilizes a custom guideline developed with ISS-STOXX to further the product’s investment objectives. Proxy voting and other shareholder engagement activity (such as participation in shareholder resolutions by our explicitly ESG Thematic products) is governed by an Investment Stewardship Committee which evaluates whether proxy votes cast are consistent with the articulated policies of the ESG products and which curates whether to participate in other shareholder engagement activity consistent with the specific Shareholder Engagement Policy applicable to those thematic ESG products. This use of varying policies may result in one product voting differently from another product on a particular issue, although such conflict has been rare. ISS-STOXX is provided with holdings information and votes all securities unless they identify a conflict; for example, where ISS-STOXX has equity ownership in the issuer. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 17  From time to time, GIM might determine that it is important and in the interest of GIM’s clients to vote directly and may decline to vote in accordance with an ISS-STOXX recommendation. Where there is such a conflict, GIM’s President will decide how to vote, after consultation with relevant investment personnel. Clients may request information regarding specific proxies voted by contacting Maria McGarry, the Chief Compliance Officer, at 215-419-6092. Proxy voting records of the Funds are public and available on Form N-PX, available through the SEC’s EDGAR database. Item 18 – Financial Information Registered investment advisors are required to provide you with certain financial information or disclosures about their financial condition. GIM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. GIM does not require prepayments of fees more than $1200 more than six months in advance of services rendered. Item 19 – Privacy Policy GIM ordinarily does not have direct dealings with natural persons as clients, dealing instead with institutional intermediaries. However, to the extent it is deemed to have possession of the information of natural persons, it deals with that information as follows: Categories of information Glenmede can come into possession of and/or collects non-public personal information about our clients (the "Information"): • from applications, correspondence, account contracts, fiduciary documents and other documents and forms; from client transactions with us, account activity and holdings; and, from third parties from which clients have authorized us to obtain Information. • • Disclosures to Third Parties Glenmede does not disclose Information about our clients or former clients to third parties except as permitted by law. Third party processors or service providers may have access to Information of clients to provide or assist Glenmede in providing services to Glenmede clients. In all cases, such third parties are prohibited from using, disclosing or releasing Information outside the scope of providing such services and have executed contracts containing confidentiality provisions. We may share certain client information with government agencies as permitted or required by laws such as the Federal Right to Financial Privacy Act or the Bank Secrecy Act and other Anti-Money Laundering regulations. These disclosures are usually made for specific circumstances, for example, verifying identities to reduce fraud and identity theft or for prompt credit approval or as required by law, such as in response to a subpoena or court order. Depending on the kind of request, we may be required by law to contact a client and obtain the client’s specific consent to this disclosure. Opt Out Provisions If Glenmede intends to disclose Information to a third party that is not providing services to Glenmede, Glenmede will notify all affected clients of such intended disclosure. Each such natural person client will be advised of the nature of the disclosure and given instructions on how to opt out. At present Glenmede has no intention of disclosing Information to third parties beyond the necessary disclosures to processors and service providers and as otherwise permitted by law. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 18  Security Glenmede restricts access to Information about clients to those employees who need to know that information to provide services to such clients. Glenmede maintains physical, electronic, and procedural safeguards that comply with state and federal regulations to guard client information. Glenmede Investment Management – Form ADV Part 2A as of 3/31/2025 Page 19