Hartford Schroders Commodity Strategy ETF (HCOM US) – Portfolio Construction Methodology

The investment strategy informing the actively managed Hartford Schroders Commodity Strategy ETF pursues long-term total return by holding a net-long, actively traded portfolio of commodity-linked derivatives across the energy, agriculture, and metals complexes, implemented primarily via futures, swaps, and commodity-linked notes. Exposure to commodities is obtained through a Cayman subsidiary (≤25% of assets at the fund level), while collateral is invested in USD cash equivalents and short-term fixed income to support margin and liquidity. Contract selection, sector weights, and roll implementation are discretionary and reflect assessments of liquidity, curve structure, carry, and risk/return characteristics; the fund does not take physical delivery. The process may incorporate financially material ESG considerations where available when evaluating commodity exposures. Positioning is adjusted opportunistically, and the fund may use forward currency contracts around non-USD instruments held as collateral. The portfolio is non-diversified and trades actively with attention to counterparty, leverage, liquidity, and basis risks.

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