VictoryShares US 500 Volatility Wtd ETF (CFA US) – Portfolio Construction Methodology

The underlying Nasdaq Victory US Large Cap 500 Volatility Weighted Index offers U.S. large-cap exposure by selecting up to the 500 largest U.S. constituents of the Nasdaq Global Index that have positive net earnings in each of the last four quarters. Constituents are weighted by the inverse of their realized volatility, defined as the daily standard deviation of returns over the prior 180 trading days; weights are then normalized to 100%, with sector caps at 25% to mitigate concentration. Liquidity and investability follow the parent universe’s trading and listing standards. The index reconstitutes and rebalances semiannually after the close on the third Friday of March and September using data through the preceding month-end, so changes reflect updated size, earnings eligibility, and volatility profiles while maintaining capacity and sector diversification.

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