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Item 3 Disciplinary Information <br /> Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary <br /> events that would be material to your evaluation of NIA supervised persons who formulate investment advice <br /> for NIA's investment advisory programs ("NIA Advisory Programs"). No information is applicable to this item <br /> for Mr. Hickey. <br /> Item 4 Other Business Activities <br /> Mr. Hickey is a registered representative of affiliated broker-dealer, Nationwide Fund Distributors, LLC, head of <br /> the Nationwide Investment Management Group ("IMG") Asset Strategies team, which supports NIA, <br /> Nationwide Fund Advisors ("NFA"), Nationwide Life Insurance Company and Nationwide Life and Annuity <br /> Insurance Company. Additionally, Mr. Hickey is a member of the IMG Leadership Team, which supports and <br /> participates in strategic initiatives and implements plans for the IMG lines of business, including the review and <br /> approval of investment-related matters affecting NFA and the Nationwide Funds. <br /> In addition, Mr. Hickey manages several investment portfolios for NFA, an SEC-registered affiliated investment <br /> adviser. <br /> To help mitigate potential conflicts of interest arising from Mr. Hickey's multiple roles and responsibilities, NIA <br /> maintains separate policies and procedures governing its investment process and the operation of its <br /> Investment Committee. Additional mitigating steps for NIA Advisory Programs are described below. <br /> To mitigate conflicts with respect to Nationwide ProAccount, NIA has retained an Independent Financial Expert <br /> ("IFE"), which has sole control and discretion over the development and ongoing maintenance of the <br /> Nationwide ProAccount portfolios, including periodic rebalancing and changes to asset allocation and fund <br /> selection. The IFE's fees for services provided under Nationwide ProAccount are not related to the mutual <br /> funds it selects or otherwise influenced by the revenue NIA or its affiliates may receive from such mutual <br /> funds. <br /> To mitigate conflicts with respect to the Advice Program for Plan Sponsors of Trustee Directed Retirement <br /> Plans (the "Advice Program"), NIA offers the Advice Program through Nationwide Retirement Clear Advantage. <br /> The standard asset fee that Nationwide charges in connection with Nationwide Retirement Clear Advantage is <br /> reduced by a discount, expressed in terms of basis points, that reflects the amount of mutual fund payments <br /> made to Nationwide as indicated in the Fund Selection Schedule of the applicable retirement program <br /> agreement. As a result, payments that Nationwide receives from mutual funds or their affiliates selected <br /> through the Advice Program will not increase Nationwide's overall compensation. To further mitigate these <br /> conflicts, the Portfolio Strategist that NIA has hired for the Advice Program will not consider mutual funds <br /> affiliated with Nationwide. Moreover, the Portfolio Strategist's fees for services provided under the Advice <br /> Program are not related to the mutual funds it selects or otherwise influenced by the revenue NIA or its <br /> affiliated companies may receive from these mutual funds. Please note, however, that NIA has discretion to <br /> terminate its relationship with the Portfolio Strategist at any time, upon notice to clients, and may either <br /> engage a suitable replacement or operate the Advice Program without a Portfolio Strategist. <br /> NIA uses qualitative and quantitative factors in selecting sub-advisers to the Nationwide Large Cap Growth <br /> Portfolio. NIA may recommend or have a bias towards sub-advisers who also manage assets for NFA, due to <br /> 8 <br />