Harbor Commodity All-Weather Strategy 

The Harbor Commodity All-Weather Strategy ETF (HGER) seeks to construct a diverse portfolio of commodities, specifically targeting those most responsive to U.S. consumer price inflation. Its selection methodology begins by pinpointing the 24 most actively traded commodity futures. These are then thoroughly assessed for their economic relevance and inherent quality, taking into account factors like market liquidity (open interest), associated costs (holding and trading), and their sensitivity to inflation. The underlying index generally includes a minimum of 15 commodity futures. Most of these assets are allocated weights ranging from 2% to 20%, with gold being an exception, potentially accounting for up to 40% of the portfolio. An exclusive, in-house developed "scarcity debasement" metric evaluates the prevailing inflationary conditions; this evaluation then informs the precise weighting of gold within the portfolio. The index undergoes rebalancing and reconstitution every three months. The index's performance is calculated on a total return basis, incorporating both gains from futures contracts and earnings derived from the strategic management of the fund's cash reserves. HGER conducts its investments predominantly via excess return swaps, utilizing a fully owned subsidiary based in the Cayman Islands. This operational structure is designed to exempt investors from receiving K-1 tax forms. Before March 6, 2023, this fund was known as the Harbor All-Weather Inflation Focus ETF and followed the Harbor Inflation Index.