abrdn Investments Ltd

Our Firm abrdn Investments Limited (“aIL”) is headquartered in Edinburgh, United Kingdom, and is a wholly-owned subsidiary of abrdn Holdings Limited, abrdn Holdings Limited is a wholly owned subsidiary of Aberdeen Group plc. The asset management business of Aberdeen operates under the name Aberdeen Investments. In addition to aIL, abrdn Asia Ltd., and abrdn Inc. are wholly owned subsidiaries of abrdn Holdings Limited. abrdn Investments Limited, abrdn Inc., & abrdn Asia Ltd., (collectively, “Aberdeen Investments” or “the Advisers”) are registered as investment advisers with the Securities and Exchange Commission (the "SEC"). In rendering investment advisory services, the Advisers may share resources, including personnel and facilities, and research information. The Advisers may also use the resources of other Aberdeen Group plc subsidiaries. The Advisers have entered into Memorandums of Understanding (“MOU”) and have elected to appoint as associated persons certain individuals who are employed by affiliated offshore unregistered advisers. These individuals render portfolio management, research and trading services to the Advisers' clients. aIL has been registered with the SEC as an investment adviser since 28 March 2012. aIL succeeded to the registration of its affiliate, Aberdeen Asset Management Investment Services Limited (“AAMISL”), following a merger of AAMISL into aIL on March 1, 2012. Advisory Services aIL provides its clients with discretionary, non-discretionary and advisory asset management and related services across a broad range of investment strategies and asset classes. Our business is predominantly the active management of financial assets, using first-hand research to make our investment decisions. Managed asset classes include equities, fixed income securities,real assets, as well as multi-manager research, selection and portfolio management for hedge funds strategies (“Hedge Funds” or “Alternative Investment Strategies”). We may also serve as a manager of managers, in which circumstance we hire sub-advisers to provide day-today securities selection. We are responsible for selecting sub-advisers and determining the portion of a fund’s assets to be allocated to each sub-adviser. Additionally, we offer solutions that can blend our abilities across different asset classes to provide tailored investment outcomes to meet specific client needs. See Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) for additional information regarding our advisory services. Our investment expertise is delivered through both segregated and pooled products – allowing us to serve a range of clients from institutions to private investors. We offer investment advisory services with regard to investments in both domestic and global securities to a variety of clients, insurance products, and pooled funds, including investment companies registered under the Investment Company Act of 1940, as amended (“1940 Act”). We provide a variety of asset management capabilities, including: • managing or sub-advising various open-end, mutual funds, ETFs, and closed-end investment companies registered under 1940 Act; • offering professional money management services for separately managed accounts, which include providing continuous advice to clients based on individual needs concerning the investment of funds and related activities including, but not limited to trading, and cash management; • providing investment services to international open-end and closed-end funds, collective investment trusts, and various private or institutional mandates sourced globally; • offering investment services to certain limited partnerships and similar private funds; • offering segregated and pooled vehicles focusing on European, or other global property mandates; • offering global and regional fund of funds products (hedge fund, private equity, venture capital, real assets and property); • offering model investment portfolios that can be bought through sponsor firms; and • customizing solutions for clients, including but not limited to those seeking specific exposure or risk/return characteristics within their alternative investment allocations.

Tailoring Services to Client Needs We typically manage client accounts on a discretionary basis; however, we will manage client accounts on a non-discretionary or advisory basis subject to client instruction. We make investments for clients in accordance with mutually agreed upon written investment guidelines and provide continuous supervision of client portfolios. Investment services may be tailored for each client’s specific needs and objectives, and clients may impose reasonable restrictions on investing in certain securities or types of securities. We have established procedures and controls to help ensure compliance with each client’s specific investment guidelines and any client-imposed restrictions. Where we are the investment adviser to a pooled investment vehicle, investment objectives, guidelines and any investment restrictions are not typically tailored to the needs of individual investors in those vehicles, but rather are described in the prospectus or other relevant offering document for the vehicle. The advisory or subadvisory fee is subject to negotiation and is fully disclosed to clients. Upon request, clients may also receive investment advice on a more limited basis through advisory or consulting-like services, including advice on isolated areas of concern such as special projects or a specific topic. Clients wishing to engage Aberdeen Investments for consulting services will be required to enter into a written agreement and may be subject to certain fees and conditions. We may, sometimes , enter into “side letter” agreements with certain prospective or existing investors (including investors affiliated with Aberdeen Investments) granting them, among other things, fee waivers or reductions, future capacity rights in a fund, interests or shares having different voting rights or restrictions, reduced minimum subscription amounts, additional rights to reports and other information and other more favorable terms than the terms that are described in the relevant offering memorandum. The funds that enter into these arrangements have no obligation to offer such differing or additional rights, terms or conditions to all interest holders, and Aberdeen Investments may or may not offer similar differing or additional rights, terms or conditions to other clients in customized discretionary accounts it manages or to advisory and nondiscretionary accounts to which it provides investment advice. In rare instances where Aberdeen Investments is provided with enhanced portfolio disclosure from other managers (including potentially material non-public information concerning the portfolio holdings of an underlying fund pursuant to a confidentiality agreement with the underlying fund or its manager), Aberdeen Investments will not be able to share information concerning such holdings or information or the fact of the existence of such a confidentiality agreement with advisory clients unless specifically authorized to do so by the underlying fund or its manager. The relevant disclosuers regarding markets, risks, strategy, benchmarks, fees, expenses and other investment details will be detailed in the offering memorandum of the vehicle Model Delivery UMA/SMA aIL may participate as an investment manager in Separately Managed Account programs (“SMAs”) sponsored by third party firms (the “Sponsor”), turnkey asset management programs (“TAMP”), including single and dual contract SMAs. The investor contracts with the Sponsor or Registered Investment Adviser (“RIA”) in a single contract SMA. In dual contract SMAs, the investor contracts with the Sponsor and aIL as investment manager. SMAs are offered by non-affiliated Sponsor or TAMP entities and may involve strategies of other outside managers in addition to our own. In these arrangements, Aberdeen Investments provides investment management services on an advisory or discretionary basis to that client in accordance with one or more model portfolios selected by the client. The Sponsor would typically perform the trades for Sponsor clients in SMA’s that invest in equity strategies, but the investment manager may do so based on investment strategy or in order to seek best execution, which may result in additional fees to clients. In fixed income strategies we perform the trading. The Sponsor or RIA typically has primary responsibility for client communications and service, but we are available to the client for consultation. Additionally, aIL provides advisory investment advice whereby aIL provides investment recommendations in the form of a model portfolio to a Sponsor or overlay manager which then utilizes all or part of the model in managing its clients’ accounts. Model delivery programs are often referred to as Unified Managed Accounts (“UMAs”). In these arrangements, Aberdeen Investments does not place trades or exercise trading discretion for the client accounts.

In such programs, the Sponsor typically charges the client a comprehensive fee, inclusive of the advisory fee charged by aIL together with the fee for all other services being provided by the Sponsor. The Sponsor generally executes client portfolio transactions on behalf of Aberdeen Investments and provides custodial services for the client’s assets. Except for execution charges for certain transactions executed away from the Sponsor, clients pay a single, all-inclusive (or “wrap”, “Wrap programme”) fee charged by the Sponsor based on the value of the client’s account assets for asset management, trade execution, custody, performance monitoring and reporting through the Sponsor. The wrap fee often, but not always, includes the advisory fees charged by aIL and other participating managers through the program. The Sponsor typically assists the client in defining the client’s investment objectives based on information provided by the client, aids in the selection of one or more investment managers to manage the client’s account, and periodically contacts the client to ascertain whether there have been any changes in the client’s financial circumstances or objectives that warrant a change in the management of the client’s assets. In certain Wrap Programs, the Sponsor contracts with other investment advisers to perform these services. In a Wrap Program, the Sponsor pays the investment advisers, such as aIL, a fee based on the assets of clients invested in the applicable strategy in the Wrap Program. In certain cases, aIL may instead be paid fees based on the size of the total Wrap Program assets under management. aIL may retain a portion of the Wrap Program fee when it participates as manager in Wrap Program arrangements. Wrap fee accounts and other client accounts following a strategy with the same name managed by the same portfolio management team may be managed differently. For example, the Sponsor or client may impose investment restrictions or administrative requirements upon us in managing accounts that could cause those accounts to be managed differently from other client accounts in the same strategy managed by the same portfolio management team that were not subject to those restrictions or requirements. For example, if a Wrap Fee Program sponsor or client imposes investment restrictions on an account which prohibits investment in a security that is held in the selected strategy, the security may not be replaced with a directly comparable security and the client’s account may be overweight other positions or hold a larger cash position than other clients in that strategy. Not all strategies managed by aIL are available in such programs. A portfolio constructed for a model delivery or SMA account may differ from how the same strategy is constructed for our other accounts. For example, we may use an affiliated registered investment company to purchase locally traded securities, where ADRs are not available (known as a “Completion Fund”). ADRs are generally used in model delivery/SMA programs as local lines of a security generally cannot be traded in those programs. Please also see the “Fees and Compensation” and “Brokerage Practices” items of this Brochure for more information on differences between wrap program arrangements and other types of client accounts. Assets under Management As of December 31, 2025, aIL had approximately $202 billion in assets under management (AUM) on a discretionary basis, and approximately $4.1 billion in assets under advisement on a non-discretionary basis, and total assets under management/advisement of approximately $206 billion.

aIL’s advisory fees are negotiable, and generally vary depending on the services being provided according to the schedule agreed to by the client and included in their investment management agreement. Fee arrangements will vary by client, and are based on a number of different factors, including investment mandate, services performed, and account size. Fees and allocations may be fixed, fixed plus performance or performance only. Please refer to Item 6 of this Brochure for additional information about performance-based fees. Generally, fees are paid monthly or quarterly in arrears based on account balances at the close of each month, quarter or the average of the month-ends within a quarter, or in advance based on assets outstanding at the end of prior month or quarter, pursuant to the prospectus, investment management agreements or other relevant offering document for the vehicle. We will either invoice clients for these fees, or in certain situations deduct these fees from the client’s custody account. In some instances, fee schedules are negotiable and can vary depending on a variety of factors such as the client, size of the account, and the investment strategy selected. aIL may also charge fees for certain services at a fixed or hourly rate. These fees are negotiable and depend upon the needs of the client, complexity of the situation, and experience of the personnel providing services under these arrangements. Some clients may from time to time seek to negotiate most favored nation (“MFN”) clauses in their investment management agreements with Aberdeen Investments. These clauses may require us to notify the MFN client if we subsequently enter into an investment management agreement with another client that offers more favorable pricing or other contractual terms than those currently offered to the MFN client. The applicability of an MFN clause will depend on the degree of similarity between clients, including the type of client, the scope of investment discretion, reporting and other servicing requirements, the amount of assets under management, the fee structure and the particular investment strategy (and therefore the relevant investment adviser) selected by each client. We have sole discretion over whether or not to grant any MFN clause in all circumstances. All advisory arrangements may be terminated by either party upon prior written notice, according to the termination provisions outlined in the investment management agreement. If a contract is terminated, all advisory fees are subject to a pro-rata adjustment based upon the date of termination. Upon termination of the agreement, any prepaid, unearned fee will be promptly refunded, and any earned, unpaid fees will be due and payable. For our standard segregated and/or commingled account fee schedules for U.S. clients and investors, please refer to Appendix A of this brochure. Registered Fund Fees With respect to U.S. SEC registered open-end and closed-end funds advised or sub-advised by aIL, each fund’s prospectus sets forth the applicable fees and expenses. On an annual basis, the Board of Directors/Trustees (the “Board”) of each registered Investment Company reguistered under the 1940 Act (“Registered Fund”),, including the independent Board members, considers renewal of the Registered Fund’s investment management services agreement, including the advisory fee paid by the Registered Fund to the Fund’s Adviser or Sub Adviser. These fees are typically higher than the representative fee schedules shown in Appendix A. Sub-advised Mutual Funds and Other Pooled Vehicle Fees We serve in a sub-advisory capacity for U.S. and offshore investment companies both registered and unregistered that are managed by third parties. Fees for such services are negotiated with the manager, and may be set forth in the fund’s registration statement or other similar offering document. Aberdeen Investments may have the opportunity to participate in co-investments alongside a manager that we have invested with through one of our portfolios. This occurs mostly viainvestment in private equity. The manager may choose to waive the management fee for the co-investment if abrdn is invested in the managers main fund. In these instances, some portfolios may benefit by receiving a fee waiver on the co-investment because another Aberdeen Investements portfolio is invested within the main fund. This could lead to a perceived conflict of interest where one portfolio makes an investment to benefit others. This potential conflict is mitigated by the investment due diligence and approval process.

Model Delivery and Wrap Programs aIL may participate in arrangements where it provides a model portfolio to clients of Sponsors or RIAs but does not exercise investment discretion or trade in the client’s account, including, but not limited to, UMAs. aIL’s actual fees, minimum fees, and minimum account sizes may be negotiable, and in arrangements where it provides a model portfolio, may be lower than those for providing investment advisory services where it has full discretion, depending on the circumstances. Payment of a bundled asset-based wrap fee may or may not produce accounting, bookkeeping, or income tax results better than those resulting from the separate payment of securities commissions and other execution costs on a trade-by-trade basis and advisory fees. With respect to SMA programs for which aIL is not the Sponsor, the client pays an asset-based fee to the Sponsor Firm or RIA and the Sponsor firm or RIA is responsible for paying the investment advisory fee to aIL. aIL’s fees from the Sponsor firm are negotiable and differ from program to program. Program fee paid by clients covers trading charges only when transactions are executed through the Sponsor or its affiliates. To the extent that trades are “stepped-out” to broker-dealers other than the Sponsor (or executed away from the Sponsor), additional fees may be incurred by the client (e.g. commissions on transactions executed by a brokerdealer other than the Sponsor or program’s designated broker-dealer(s), dealer mark-ups, mark-downs and expenses with respect to investments in pooled vehicles). The Sponsor’s Program Brochure generally contains information on minimum account sizes and fees payable to the Sponsor and participating investment managers. Accordingly, aIL’s fees for managing SMA program accounts may be lower than those for providing investment advisory services outside the SMA programme. Clients should contact their program Sponsor or RIA for more information on the fees payable to aIL in connection with such program. Alternative Investment Strategies (Hedge Funds) Investors and prospective investors should review the confidential private placement memorandum, limited partnership agreement and other governing documents (collectively, the “Governing Documents”) of each Hedge Fund in conjunction with this brochure for complete information on the fees and compensation payable with respect to that particular Hedge Fund. Different Hedge Funds and advisory accounts may be subject to different management fees and performance-based compensation arrangements. In certain circumstances, the advisory fees payable to aIL by individual investors are negotiable and are waived for certain investors. aIL is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Hedge Funds. Payments of advisory fees are made in accordance with the terms set forth in the Governing Documents. Please refer to the Governing Documents of each of the Hedge Funds for complete information on the timing of advisory fee payments. Management fees are generally paid quarterly in arrears, are tiered in some cases based upon the net assets under management for the Hedge Fund or account, are subject to breakpoint discounts in some cases based upon capital under management by aIL, and are generally up to 2.00% annually, as described in the relevant Governing Documents. The formulas for calculation of performance-based compensation arrangements vary by Hedge Fund but are generally up to 20% of investment performance, subject to a hurdle rate and/or loss, carry forward in some cases, as described in the relevant Governing Documents. Unless otherwise noted in the Governing Document, performance-based compensation is generally assessed and payable at the end of each calendar quarter. Such management and performance-based compensation is calculated after application of underlying manager fees and expenses. As described below, aIL provides services to Hedge Funds, that invest in other investment vehicles (“underlying funds”) whose managers (“underlying managers”) typically charge: (i) an asset-based fee (that generally is in the range of 1% to 2% annually) and (ii) a profits-based fee (that generally is approximately 20%), and in some cases higher rates, and which fee rates vary for each such underlying fund. Additionally, the fees of aIL do not include the expenses of any service providers hired by the Hedge Funds and/or any operating and overhead expense reimbursements paid to aIL and do not include expenses indirectly borne through investments in underlying funds or customized portfolios (e.g., redemption fees may be charged by certain hedge funds). Each Hedge Fund sets forth any such additional operational expenses in the relevant Governing Documents.

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Methods of Analysis and Investment Strategies We utilize various investment approaches when managing discretionary client accounts and providing recommendations to advisory or non-discretionary clients. We have described below the various methods of analysis and investment strategies, as well as the primary risks associated with the investment strategies. These include Equities, Fixed Income, Alternative Investments Real Estate., Private Equity and Venture Capital. Equities At Aberdeen Investments, we believe that fundamental research into companies, mediated through team debate and a rigorous stock selection process, is the key to unlocking investment insight and driving investment returns in portfolios. We utilize a bottom-up, fundamental stock-picking approach, where sector, regional and country allocations are a residual of our bottom-up stock selection decisions, constrained by appropriate risk controls. Our scale affords coverage of a wide and dynamic universe, with in-depth, locally-sourced insights. We have experienced equity professionals across the world, each engaged in fundamental stock research and insight generation. Broad research coverage is organized on a sector basis. We also have fund managers that undertake specialized fund-specific research. We may also use quantitative screening tools and risk tools to help us identify interesting stock opportunities and the most appropriate coverage universe. Aberdeen Investments evaluates every company against quality criteria and builds conviction using a teambased approach and peer review process. The quality assessment covers five key factors: 1) the durability of the business model, 2) the attractiveness of the industry, 3) the strength of financials, 4) the capability of management, and 5) the most material environmental, social and governance (“ESG”) factors impacting a company.As ESG information is just one investment consideration, ESG considerations generally are not solely determinative in any investment decision made by the Adviser. Aberdeen Investments seeks to understand what is changing in companies, industries and markets but is not being priced into the market or is being mispriced. Through fundamental research, supported by a global research presence and proprietary tools, Aberdeen Investments seeks to identify companies whose quality is not yet fully recognized by the market. To leverage the benefits of our research resources, our equity teams use a common investment language and research framework that structures how we express our thinking on companies. Our investment ideas are subject to peer review, both at regular meetings and on an ad hoc basis. This facilitates the effective articulation of research insights. The generation of research insights combined with rigorous peer review allows our fund managers to effectively assess the investment potential of companies for any of our distinct client outcomes. Portfolios are built from the bottom up, prioritizing high conviction stock ideas in a risk aware framework. Portfolio risk budgets are derived from our clients’ investment objectives and required outcomes. As active equity investors we express our research views through a principled portfolio construction process which actively takes appropriate and intentional risk to drive return. We expect that the largest component of our active risk will be stock-specific along with appropriate levels of diversification. We use a variety of both proprietary and external quantitative tools to support this decision making. Our risk systems monitor and analyze risk exposures across multiple perspectives. We are able to break down the risk within the portfolio by industry and country factors, by currency and macro factors, and by other fundamental factors (quality, momentum, etc.). We can thus highlight the stocks with the highest marginal contribution to risk and the largest diversification benefit which can be usefully combined with our view of the return we expect from each stock. We also have pre-trade functionality which can simulate changes to our current portfolio and assess how any changes would impact the overall risk profile of the fund. We can then manage that risk with the objective of maximizing risk-adjusted returns and ensuring appropriate diversification. Continuous coverage and monitoring of both the company fundamentals and price action allow us to review any stock’s position in the portfolio.

Fixed Income Our investment teams seek to generate investment alpha within their specialist areas utilizing a foundation of fundamentally-driven top-down and bottom up research. Strategies are tailored to meet individual portfolio and client objectives and benefit from independent risk monitoring and oversight. Key points • Active management, operating globally, aiming to deliver outperformance • Utilising diversified sources of alpha to improve risk-return profiles • Specialist decision makers, working within allocated risk budgets. • Collaborative research process with global perspective • Derivatives capability for both active and liability management We seek to give our client added value by exploiting market inefficiencies in interest rates, currency, inflation expectations, investment grade credit, emerging market debt and high yield. Aberdeen Investments has dedicated portfolio managers and analysts in the United Kingdom, North America and Asia that operate as teams, delegating investment decision-making to specialists, depending on their knowledge and expertise. Our investment structure enables us not only to follow a disciplined investment process while allowing flexibility to manage portfolios for a wide variety of client requirements. This may range from strategies which employ multiple sources of uncorrelated returns to those that are focused on a particular specialist area. We aim to deliver superior performance across the full range of our fixed income capabilities. We use derivatives, such as interest rate and credit default swaps, for efficient portfolio management to identify opportunities to add value and to match liability exposures. Aberdeen Investments examines the material risks of an investment across a spectrum of considerations including financial metrics, regional and national conditions, industry specific factors and ESG risks. Although ESG investing is not a principal strategy for most fixed income products, Aberdeen Investments considers and assesses how these issues are managed and mitigated as well as the opportunities they might create for the issuer. A subset of the Fixed Income Investment Team also offers a Fund Finance private credit strategy, which is focused on debt investment into syndicated subscription line loans (also known as capital call facilities) to closed end, private markets funds that are owned or controlled by private equity, real estate fund, infra-structure fund, secondary fund, private credit fund, or other private investment vehicles (“Financial Sponsors”). These loans are used by Financial Sponsors to bridge fund investment activity and are typically structured as multicurrency, revolving credit facilities with a legal tenor under 3 years. The loans are collateralized by the uncalled commitments fund LPs. The decision to make a loan is heavily dependent on the credit quality and diversification of the collateral, the presence of formal first ranking security over the collateral and the level of overcollateralization supporting the loan. The investment manager targets loans which are supported by a robust level of uncalled commitments from high credit quality, institutional investors which may or may not have an external credit rating. The investment manager will conduct legal due diligence on both the fund documentation and the credit facility documentation (including all security arrangements) before making any investment. The investment manager will undertake a detailed analysis of the credit quality and experience of the Financial Sponsor, including the Financial Sponsor’s capital under management, its investment strategy, performance track-record, decision making structures and governance. The investment manager will also diligence the credit quality of the financial sponsor through meeting the Financial Sponsor and/or reference calls to Limited Partners, intermediaries and other lenders and service providers.

Alternative Investment Strategies (Hedge Funds) We consider hedge fund strategies as a set of investment trading strategies that can offer potential diversification benefits for investors in traditional asset classes. Due to the potential non-traditional nature of hedge strategy returns, performance is not necessarily correlated with traditional investment markets or indices, such as equities or bonds. We believe that, through understanding the properties and behavior of different strategies, portfolios can be created that are not solely dependent on market direction for returns. Such investments can therefore be potentially diversifying for investors in traditional asset classes. In this regard we offer both active and passive approaches to these non-traditional sources of returns. In constructing active portfolios, we believe one of the key focuses should be the understanding, monitoring and management of risk. Risk exposures and market sensitivities must be appropriate to the longer-term investment objective. We also believe that value can be added through active portfolio management to reflect strategic and tactical views and opportunities. Throughout the investment process, we believe that the best outcomes are delivered by making team-based, high-conviction decisions. We have a track record of building multi-manager hedge fund portfolios, through: • Proprietary research and understanding prospective managers and their strategies well. This is how we understand the investment proposition and develop conviction in a manager’s ability to deliver on their stated investment strategy. • Conduct proprietary style and strategy research to develop views on different strategies, their potential return characteristics and the underlying drivers of their future returns. • Thoroughly investigate the non-investment risks associated with various investments, and do not invest if these risks are deemed too high regardless of the perceived strength of an investment proposition. • Assess the collective risks in a portfolio of strategies and managers. • Understand the overall exposures in your portfolios and ensure they reflect your investment views and the portfolio objectives. While individual investments may reflect appropriate risk exposures, the aggregated portfolio may not be appropriately weighted. • Committee based approach to portfolio management and construction, led by the team’s Governance and Investment Committee.

Real Estate and Real Assets Real Estate Multi-Manager (“REMM”) The core aspects of Aberdeen’s Investments investment philosophy in real estate are as follows: • We can manage risk, we cannot manage market returns. This means every investment decision is essentially a risk bundle selection decision. We think long-term, taking advantage of short-term, irrational behavior. • We follow a process, which does not allow distraction from long-term goals. Our process is global, but implemented locally. This provides a common language for team-based decision making. • We build high-conviction portfolios, bottom up. We do our own research, only investing in what we understand. • We invest on the basis of quality. The focus on risk selection is encapsulated in the investment thesis approach – a comprehensive understanding of macro and capital markets risk factors like interest rates and capital flows on the one hand, and fundamentals and micro risk factors like supply and demand on the other, to select at every point in the cycle, the appropriate risks bundle. This in turn leads to an understanding of the return drivers of a strategy, and an awareness of when to realize those returns. The focus on risk management and investment thesis define our investment philosophy and approach. In investment execution and process, we are defined by quality.

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Clients Our client base comprises a variety of institutional clients, including corporate plans, non-profit organizations, public plans, governments, private investors, multi-employer plans, financial institutions, intermediaries, subadvised funds and pooled investment vehicles, encompassing both affiliated and unaffiliated U.S. and nonU.S. Registered Funds and U.S. and non-U.S. unregistered funds, among others. The requirements for opening any account will vary depending on the type of product and type of client. We have minimum account size requirements for certain accounts which may be waived at our discretion. Please refer to Item 5 of this Brochure for additional information on minimum account size requirements.

We sometimes enter into agreements for performance-based fees with qualified clients. The existence of such a performance-based fee may create conflicts of interest in the allocation of management time, resources and investment opportunities between different strategies. Additionally, collecting performance-based fees may result in instances in which a portfolio manager concurrently manages accounts with different fee structures for the same strategy. This is referred to as “side-by-side” portfolio management and, in these instances, we will not determine allocations based on whether we are participating in a trade or on the fee structure of the managed accounts participating in the trade. Furthermore, we may seed investment vehicles and make coinvestments along with clients invested in Private Markets Fund Investments. The potential management of different types of accounts and accounts with different fee arrangements for the same strategy may give rise to potential conflicts of interest. Registered funds, for example, generally pay management fees based on a fixed percentage of assets under management, while separate accounts and private funds potentially may have more varied fee structures, including performance-based incentives. Where performance is good, performance-based fee clients may be charged fees higher than the industry standard. We may have a material incentive to favor certain, more lucrative accounts over those that may be less lucrative. Additionally, we may have a material incentive to favor accounts in which we, or our affiliates, have significant proprietary interest. For example, we have an incentive to allocate better-performing securities to those accounts subject to performance fees rather than to those which are not. These performance fees may also incentivize the portfolio manager to take riskier positions than would have otherwise been initiated. Additionally, the calculation of performance fees is based upon a number of factors both within and out of our control. To mitigate these conflicts, we have adopted policies and procedures to ensure that investment decisions are made in the best interests of our clients and without consideration of our financial interests. aIL may provide concurrent advisory services to client accounts that are not charged a performance-based fee or allocation by aIL’s related persons and client accounts that are charged a performance-based fee or allocation by a related person of aIL, aIL or one of its affiliates may also provide concurrent advisory services to private equity funds, Hedge Funds, and/or separate account or investment advisory clients that are charged different performance-based fees or allocations and, in certain cases, aIL may only be permitted to take a performance-based fee or allocation from a private equity fund, Hedge Fund, or separate account client or investment advisory client after the applicable investors or client received a preferred return on their committed or contributed capital. aIL’s policies generally prohibit portfolio managers from trading in conflict with themselves – specifically, across same strategy accounts that they manage. Generally, portfolio managers are prohibited from taking an “inconsistent position”, or from holding the same security long in some accounts and short in others, unless they are materially underweight in a long only account that must hold that security at some level for benchmark tracking purposes (as this would not appear to represent a conflict of interest). Portfolio managers may, however make different investment decisions for the same security for different strategies they manage, as appropriate. In the event that a potential conflict of interest regarding portfolio managers’ trading is identified, the Department Head and the Risk & Compliance Department will discuss the conflict and take appropriate corrective action. Risk & Compliance will also review the procedures in such instances to ensure that they are appropriately crafted to identify similar future conflicts of interest. From time to time, Aberdeen Investments, its directors, officers, employees or affiliates (“affiliated persons”) may, directly or indirectly, have interests in securities owned by or recommended to our clients. As these situations may represent a potential conflict of interest, we maintain trade allocation and account valuation policies and procedures designed to address such conflicts of interest. We have adopted a Code of conduct in compliance with the requirements of Rule 17j-1 adopted under the 1940 Act and Sections 204A and 206 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), to govern personal transactions by directors, officers, and advisory personnel of Aberdeen Investments (“Access Persons”). For further detail on Aberdeen Investments Code of Conduct, please refer to Item 11 of this Brochure.

We also monitor for conflicts by implementing “best execution” trading procedures and reviewing account allocation and performance. aIL, or a related entity of aIL, as general partner of certain pooled investment vehicles, Private Equity Funds or adviser to a separate account or investment advisory client, will typically receive certain allocations or fees calculated and charged based on a share of capital gains on or capital appreciation of the assets of the pooled investment vehicle, separate account client or investment advisory client. These performance-based allocation arrangements comply with regulatory requirements. Any share of profits paid to aIL, one of its affiliates, or the general partners of the pooled investment vehicles, is separate and distinct from the advisory fees charged by aIL for advisory services. In addition to Performance-Based fees paid to the Adviser, the Funds may cover operating and organizational expenses of the Adviser, as detailed in Item 5 above. Please refer to the Governing Documents of the applicable Private Fund or pooled investment vehicles (or the investment advisory agreement of the applicable separate account client) for complete information on the performance-based compensation arrangements entered into with respect to such client. To mitigate this potential conflict of interest, investment decisions are made by aIL or an affiliate for pooled investment vehicles, separate accounts and investment advisory clients in accordance with investment allocation policies. With respect to investment opportunities that are appropriate for more than one client including a fund and/or a separate account or investment advisory client, Aberdeen Investment’s investment allocation policies take into account multiple criteria, including (but not limited to) the investment objectives and strategies of each applicable client, differences with respect to the available capital, size, and remaining life of the applicable clients, differences in risk profile at the time the opportunity becomes available, potential conflicts of interest, the nature of the security or the transaction, and current and anticipated market conditions. In the event the investment opportunity is suitable for more than one client, aIL will derive an allocation that, over a period of time, is fair and equitable to each applicable client relative to other clients, taking into account all relevant facts and circumstances.

We are committed to providing clients with service of the highest quality and we are guided by the principle that we act in the best interests of our clients. Nevertheless, there are circumstances where client interests conflict with our interests or the interests of other clients. Some of these conflicts of interest are inherent to our business. We have policies and procedures that are designed to ensure that we are always acting in the best interests of our clients. We are a wholly owned subsidiary of Aberdeen Group plc, a global financial services company. We are affiliated with various U.S.-registered investment advisers, broker-dealers, and pooled investment vehicles, among other financial entities. We occasionally may engage in business activities with some or all of these companies, subject to our policies and procedures governing how we handle conflicts of interest. We may use our affiliates to provide other services to our clients to the extent permitted under applicable law. We provide advice for numerous clients. We may advise some clients or take actions for them that differ from recommendations or actions taken for other clients. We are not obligated to recommend to clients any investments that we may recommend to or purchase or sell for other clients. Our employees regularly share information, perceptions, advice and recommendations about market trends, the valuations of individual securities, and investment strategies, except where prohibited by ethical walls established by us or by applicable law or regulation. Persons associated with us may have investments in securities that are recommended to clients or held in client accounts, subject to compliance with our policies regarding personal securities trading. Broker-Dealer and Registered Representatives Aberdeen Fund Distributors LLC (“AFD”), an affiliate of aIL and a wholly owned subsidiary of abrdn Inc., is a limited-purpose broker-dealer formed to distribute our proprietary mutual funds and coordinate the private placement of our private funds. There are no trades executed through AFD. Certain of our management persons are registered, or have an application pending to register, as registered representatives of AFD. The ETFs are distributed by ALPS Distributors, Inc. (“ALPS”), which is an unaffiliated third-party broker dealer. AFD and ALPS have entered into a distribution agreement, allowing representatives of ALPS to sell funds managed by abrdn Inc., and representatives of AFD to sell the ETFs. No solicitation fees are paid under either agreement, and distribution staff does not receive direct incentive or economic benefits for sales performance, other than the regular salary and bonus paid by abrdn Inc. Investment Companies We serve as an investment adviser and administrator for a number of U.S. registered investment companies. We also serve as a sub-adviser for various other U.S. registered investment companies. Investment Advisers In rendering investment advisory services, we may use the resources of additional investment adviser subsidiaries of Aberdeen Group plc. These affiliates have entered into an MOU with us pursuant to which investment professionals from each affiliate may render portfolio management, research or trading services to our clients. We may share personnel, research and other resources with our affiliated U.S. registered investment advisers (abrdn Asia Limited in Singapore and abrdn Inc in the United States), and a number of unregistered foreign entities under our personnel sharing procedures. Additionally, abrdn ETFs Advisors LLC is a whollyowned subsidiary of abrdn Inc. and a registered investment adviser with the SEC. abrdn ETFs Advisors LLC is a CPO registered with the NFA. In executing trades on behalf of our clients, we may use the resources of our Aberdeen Group affiliates. These affiliates have entered into a global trading agreement pursuant to which professionals from each affiliate may execute trades on behalf of our clients. The use of affiliates to execute trades under the global trading agreement does not alter or change the entity making investment decisions for the client accounts. Limited Partnerships or Similar Private Funds

We sponsor and serve as investment adviser to several private funds organized as limited partnerships, limited liability companies or non-U.S. entities. aIL and its affiliates may also serve as the general partner or managing member of these private investment vehicles. Our affiliates registered subsidiaries also serve as investment adviser to certain private funds and provide investment management services to limited partnership vehicles with U.S. investors. These funds may be domiciled in the U.S., as in the case of a Delaware partnership, or outside the U.S., as in the case of a Cayman corporation. Participation in Privately Offered Investment Vehicles aIL, its affiliates, officers and employees may participate individually in privately offered investment vehicles in which clients are solicited to invest. aIL or its affiliates may act as adviser or general partner (or in a similar capacity) to these investment vehicles, may receive management fees, and may participate in any profits generated by these investment vehicles. Participation by affiliates, officers and employees in such investments on such terms and the receipt of such compensation may be an incentive for such employees to devote an increased amount of time to the management of such vehicles to the detriment of other client account or investment vehicles. Aberdeen Investments has policies and procedures in place to mitigate this conflict. Other Material Relationships Principals and employees of Aberdeen Investments may serve as officers, advisors, directors or provide comparable management functions for public companies and/or portfolio companies in which clients directly or indirectly invest, as well as for investment institutions that may invest in Aberdeen Investments -managed funds. In addition, such principals and employees may provide other services to public companies and/or portfolio companies and may receive compensation in connection therewith. Principals and employees of Aberdeen Investments may be provided access to confidential information relating to public companies and/or portfolio companies in which clients may directly or indirectly invest. As a result, clients may, under certain circumstances, be prohibited for a period of time from engaging in transactions with respect to the securities of such public companies and/or portfolio companies, which prohibition may have an adverse effect on clients. Selection or Recommendation of Other Advisers Aberdeen Investments may select other investment advisers for its clients. Business Alliances Our strategic partnerships and associate businesses play a vital role in our global distribution model as an effective way to reach clients in key markets around the world. The following summary provides an overview of our significant business alliances: Standard Life (formerly Phoenix Group) In February 2021, Aberdeen Group announced the reshape and refocus of the existing relationship with Phoenix Group (“Phoenix”) so that both companies can be strong independent partners for the next 10 years, focused on growing their own respective businesses and growing their partnership in asset management. To this end, Aberdeen Group sold the Standard Life brand to Phoenix Group which simplifies and clarifies the original sale of our Standard Life long-term insurance business. In February 2025, Phoenix completed its name change to Standard Life PLC (“Standard Life”). Aberdeen Group currently owns 10% of Standard Life. Heng An Standard Life Heng An Standard Life (HASL) is a life insurer owned 50% by Aberdeen Group and based in Tianjin, China. It is not a listed company. It was formed in 2003 as a joint venture between Standard Life plc and Tianjin TEDA International (“TEDA”). TEDA is the Tianjin Economic-Technological Development Area; it is the state-owned Tianjin economic enterprise board. HASL has 10 provincial branches across 8 provinces and sales offices over 80 cities and offers a comprehensive suite of health, life and savings products. Assets are predominantly managed by HASL’s in-house investment team. Assets are managed by HASL’s in-house investments team. In July 2020 HASL purchased an insurance subsidiary in Hong Kong from Aberdeen Group

In January 2021 HASL was granted permission to open a pensions insurance company in China and recently launched its first pension product. Archax In August 2022, Aberdeen Group made a $20m Investment in Archax, a UK-based digital asset exchange. Aberdeen Investments then made a follow-on investment of $1m in October 2025 brining Aberdeen Investments stake in Archax to 11.0%. Archax provides access to blockchain-based digital assets and is the first digital securities exchange to be approved by the FCA with permissions covering trading, custody and brokerage. Aberdeen Group plc strategic partnership with Archax allows investors to access investment opportunities through digital securities, connect to existing offerings in a new way through tokenisation and facilitate a shift towards greater operating efficiencies through the adoption of new technologies like blockchain. Stagecoach Aberdeen has agreed to replace Stagecoach as the sponsoring employer of the Stagecoach Group Pension Scheme (“SGPS”). This deal enhances benefits for over 22,000 members and includes and initial uplift of 1.5% to pensions and better inflation protection. abrdn Investments Limited will manage the SGPS assets ensuring long-term security and potential for further benefits linked to the scheme financial performance.

Code of Conduct and Personal Trading From time to time, aIL or our directors, officers, employees or affiliates may, directly or indirectly, have interests in securities owned by or recommended to our clients. These situations may represent a potential conflict of interest, so we have adopted a Code of Conduct (the Access Person Code of Conduct, herein the “Code”), in accordance with Rule 204A-1 of the Adviser’s Act, to govern personal transactions by our directors, officers, and employees (“Access Persons”) in order to ensure that their interests do not conflict with the interests of our clients. The Code mitigates potential conflicts of interest by requiring, among other things, pre-clearance of transactions in Reportable Securities (as defined in the Code) placed in reportable accounts. The Code restricts the purchase and sale by Access Persons for their accounts of Reportable Securities, which have been purchased or sold for funds or clients within specified time limits. Except under certain limited circumstances, Access Persons may not engage in a personal transaction in a Reportable Security for which an order for a fund or client is pending or within seven (7) calendar days before or after execution of a client order. This blackout period does not apply to transactions in certain large cap securities of a de minimis value. Access Persons are subject to reporting obligations, including completing quarterly transaction and annual holdings reports. Access Persons are required to direct their brokers to send copies of all brokerage confirmations and statements to their local Risk & Compliance Department. Alternatively, Access Persons can have the information sent by the broker via electronic feed, if available. Our procedures recognize that some Access Persons either reside in countries or maintain brokers where such statements are not regularly issued or available, and therefore these individuals are exempt from providing quarterly statements within a specific time period. In such circumstances, brokerage statements or their equivalent holdings reports must be provided as available. Employees must fully acknowledge the terms of the Code, on an annual basis. Any employee who violates the Code may be subject to verbal or written warnings and censures, monetary sanctions, disgorgement, suspensions or dismissal, among other punitive actions. Additionally, the Code includes provisions for employees relating to the confidentiality of client information, a prohibition on insider trading, a rumors policy, dollar restrictions on the value of accepted gifts and entertainment, and requires that certain outside business activities are approved in advance. Clients or prospective clients may request a free copy of the Code by contacting Aberdeen Group at (+44) 131 372 9444. Our Approach to Potential Conflicts of Interest Various parts of our brochure discuss potential conflicts of interest that arise from our asset management business model. We disclose these conflicts due to the fiduciary relationship we have with our clients. Where potential conflicts of interest arise from our fiduciary activities, we take steps to mitigate, or at least disclose, them. Conflicts arising from fiduciary activities that we cannot avoid are mitigated through written policies and procedures and/or otherwise disclosed. Potential conflicts may arise from new products or services, operational changes, new reporting lines and market developments. Gifts and Entertainment We have policies and procedures in place which prohibit employees from accepting gifts, entertainment and other things of material value that may create a conflict of interest or give the appearance of a conflict of interest. Additionally, our employees may not offer gifts, entertainment or other things of material value that could be viewed as attempting to unduly influence the decision-making of any client or other business partner. In general, our policies dictate that giving and receiving gifts or participating in entertainment cannot occur if the value and/or the frequency of the gift or entertainment are deemed excessive or extravagant. The policies impose specific dollar restrictions and require compliance approval of gifts and entertainment. Additional restrictions regarding gifts apply to our employees who are registered representatives of our affiliated brokerdealer.

Participation or Interest in Client Transactions Potential conflicts of interest may exist if an investment adviser or one of its related persons buys or sells for client accounts, securities in which the adviser or a related person has a material financial interest. We may recommend to clients that they buy or sell shares of an investment company or other investment product in which we have some financial interest by serving as adviser or sub-adviser to a fund or other product. Some of the investment companies, including private funds, are subject to a performance-based incentive fee. Employees providing advice to these funds may also hold interests in such performance-based funds and may also provide investment advisory services with respect to similarly managed accounts that are not subject to performance fees. We may manage accounts similarly in that we may buy or sell the same securities for private funds, Registered Funds, segregated mandates and other account types. These transactions must be consistent with our trade allocation procedures so that no client is favored over another. In addition, and only in accordance with our policies and procedures, employees are permitted to invest in securities (including those recommended to clients) for their own accounts. Aberdeen Investments may recommend to clients other products offered by aIL or our affiliates. aIL may also invest funds into other funds managed by aIL or our affiliates. In these instances, it may appear that our interest in selling the product or service could conflict with the client’s expectation. Where we direct clients into an Aberdeen Investments-managed product or strategy, we will obtain client consent. Where investing in Aberdeen Investments-managed products on behalf of fund vehicles, management fees for the affiliates fund may be waived in order to avoid conflicts of interest and to comply with applicable regulatory requirements. Our officers or directors may sit on the boards, and board committees, of publicly traded clients. In addition, employees may buy or sell securities for a client where we may have a material interest in a security or issuer of a security. A material interest could include owning a security, office, directorship, significant contract, interest or relationship which is likely to affect the person’s judgment. In these cases, aIL or our employees could benefit from the success of a client’s investments because of our interest in the security or issuer of the security. We maintain procedures to mitigate these potential conflicts. We may purchase and sell securities for accounts funded with our own assets, which also is known as “seed capital.” These accounts are intended to establish a performance history for a new or potential product or service. We may earn a profit on our seed capital investments. Adviser for Multiple Accounts We serve as investment adviser or sub-adviser to client accounts, including registered investment companies. Consistent with our fiduciary obligations, we may give advice with respect to funds or accounts we manage that may differ from action taken by our firm on behalf of other funds or accounts. We are not obligated to recommend, buy or sell–or to refrain from recommending, buying or selling–any security that any of aIL, our affiliates or our Access Persons, may buy or sell for their own accounts or for the accounts of any other client. Any company associated with aIL that wishes to purchase or sell securities of the types purchased for clients may do so only in a manner consistent with our fiduciary obligations. We are not obligated to refrain from investing in securities held by funds or accounts it manages, except if the investments violate the Code. Insider Trading and Use of Expert Networks We have adopted a market conduct policies and procedures in accordance with Section 204A of the Advisers Act, which establishes procedures to prevent the misuse of material non-public information by aIL, our officers, directors and employees. Any officer, director or employee who fails to observe the insider trading policy risks serious sanctions, including dismissal and personal liability. From time to time, employees of aIL may obtain, either voluntarily or involuntarily, material non- public information that is not available to other investors or other confidential information which, if disclosed, would likely affect an investor’s decision to buy, sell or hold a security. Such information may be provided from various possible sources including upon execution of a non-disclosure agreement, as a result of serving on the board of directors of a portfolio company or serving on ad hoc or official creditors' committees. Under applicable law, employees are generally prohibited from disclosing or using such information for their personal

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Broker-Dealer Selection and Best Execution We have established policies and procedures designed to assess and monitor the broker-dealers selected to execute client transactions. We do not adhere to a rigid formula in making the selection of a broker-dealer for portfolio transactions, but rather weigh a combination of certain factors. When selecting a broker-dealer for client transactions, we take all sufficient steps to obtain the best possible outcome by looking at price, transaction costs, reasonableness of commissions, speed, efficiency, knowledge of particular securities, likelihood of execution and settlement, size and type of transaction, settlement capabilities, reputation, nature and any other consideration relevant to the best execution of that order. In selecting broker-dealers and in effecting portfolio transactions we seek to obtain best execution. As described in more detail further below under Commision Rates, we will not select broker-dealers solely on the basis of commission rates and steps associated with seeking best execution include: (1) determining each client’s trading requirements; (2) selecting appropriate trading methods, venues, and agents to execute the trades under the circumstances; (3) evaluating market liquidity of each security and taking appropriate steps to avoid excessive market impact; (4) maintaining client confidentiality and proprietary information inherent in the decision to trade; and (5) reviewing the results on a periodic basis. We review the above criteria on an ongoing basis. We do not consider the sales of shares of Registered Funds it advises as a factor in the selection of broker-dealers to execute portfolio transactions for a Registered Fund. When selecting or recommending for client transactions, a broker or service provider, we will consider, among other things, the following: • • • •

Professional reputation; Ability to provide clear, impartial and expert advice; Understanding of and presence in the relevant market; and Potential for or actual conflicts of interest.

If a client requires preauthorization of trades, such trades may not be commingled or “batched” for purposes of execution with orders for the same securities for other accounts we manage. Therefore, such trades may be executed subsequent to the trades executed for other accounts we manage and at different prices and commission rates which may be better or worse than the rates received for batched trades. We may use Electronic Communications Networks (“ECN”) or Alternative Trading Systems (“ATS”) to execute when, in our judgment, the use of an ECN or ATS may result in equal or more favorable overall executions for the transactions. With regards to our Alternatives Investment Solutions (“AIS”) products, we do not arrange trades with any broker or dealer; our fund of hedge funds does not typically use brokers to transact for funds or third-party clients as the investments made for such clients are generally in open-ended investment funds engaged in a continuous offering. In assessing a firm’s trading controls, AIS would expect the Manager to have in place a formal best execution policy prescribing the roles and processes involved in order to achieve the desired trading outcomes. AIS will discuss with the third-party Manager how best execution of trading is formally reviewed as a part of the firm’s risk committee and that sufficient reporting is produced detailing performance and exceptions. AIS would also expect to see a daily review of executed trades undertaken whereby any trades with an inconsistent price relative to similar trades in instruments at the time of execution would be investigated. AIS will also review the oversight of Compliance in terms of the sufficiency of the sample size reviewed relative to the firm’s overall trading, examples of where Compliance monitoring of best execution has identified failures or weaknesses and an assessment as to what extent Compliance is confirming procedures have been followed versus challenging whether best execution has actually been achieved. The advice and investment activity conducted with regards to property funds generally relates to privately offered securities in partnerships or similar relevant structures that invest in real estate or real estate-related assets. We may invest in property funds which are marketed to aIL by placement agents; either the fund or the third-party manager bears the associated placement agent fees. Occasionally, we may recommend the purchase of a secondary interest in a privately offered security being offered by a broker. In such cases, clients may be required to pay a fee to the broker offering the interest on behalf of a seller. We do not receive client referrals

from broker-dealers or third parties. For fund of fund, investments in open-ended investment funds are facilitated through the appropriate transfer agent. On occasion, our hedge funds client portfolios may receive security positions as part of a distribution or liquidation of an underlying fund or special purpose fund. While we generally execute transactions in these securities through the same broker-dealer where the Aberdeen Investments fund’s account was established, there are no limitations on which broker-dealers may be used or the commission rates or similar charges paid. With respect to advisory model delivery accounts (including UMA accounts) and advisory or discretionary SMA accounts, aIL will utilize a third-party service provider to deliver model portfolio recommendations and model changes to the Sponsors. aIL seeks to treat clients fairly and equitably over time, by delivering model changes to our service provider and investment instructions for our other discretionary accounts to our trading desk, where possible, simultaneously for certain strategies or approximately at the same time for other strategies. The service provider will then deliver the model changes to each Sponsor on a when traded randomized full rotation schedule. All Sponsors that receive model changes will be included in the rotation schedule.With respect to Municipal SMA accounts which do not utilize a model delivery approach, abrdn Inc. will be responsible for trading portfolio securities on behalf of the clients in a third-party trading system. Our service provider will communicate trading activity to the Sponsors at the conclusion of each business day. Brokers-dealers selected to execute purchase or sale transactions include those on the Aberdeen Investments approved list. UMA Sponsors will be responsible for determining how and whether to implement the model portfolio or model changes and implementation of any client specific investment restrictions. The Sponsors are solely responsible for determining the suitability of the model portfolio for each model delivery client, executing trades and seeking best execution for such clients. As it relates to SMA accounts, aIL will be responsible for suitability, managing the account on the basis of each client’s financial situation and objectives, the day to day investment decisions, best execution, accepting or rejecting client specific investment restrictions and performance. The SMA Sponsors or RIAs will collect suitability information. For dual contract SMAs, aIL will confirm suitability of the client in the investment strategy based on the client’s investment objectives, time horizon, and risk tolerances. Our third-party service provider will monitor client specific investment restrictions on a day to day basis, except for our Municipal SMA accounts which will be monitored by our internal team in a third-party trading system. For equity SMA accounts, trades will be traded by the Sponsor or may be executed through a “step-out transaction,”- or traded away- from the client’s Sponsor if doing so is consistent with Aberdeen Investments obligation to obtain best execution. For fixed income strategies, Aberdeen Investments, is responsible for the execution and allocation of trades. When placing trades we will generally aggregate orders where it is possible and, in the client’s, best interests. In the event we are not comfortable that a Sponsor can obtain best execution for a specific security and trading is infeasible, we may exclude the security from the model. When trading away, trading costs are not covered by the Program Fee and may result in additional costs to the client. In some instances, step-out trades are executed without any additional commission, mark-up, or markdown, but in many instances, the executing broker-dealer may impose a commission or a mark-up or markdown on the trade. Typically, the executing broker will embed the added costs into the price of the trade execution, making it difficult to determine and disclose the exact added cost to clients. In this instance, these additional trading costs will be reflected in the price received for the security, not as a separate commission, on trade confirmations or on account statements. In determining best execution for SMA accounts, Aberdeen Investments takes into consideration that the client will not pay additional trading costs or commission if executing with the Sponsor. While UMA accounts are invested in the same strategies as and may perform similarly to SMA accounts, there are expected to be performance differences between them. There will be performance dispersions between UMAs and other types of accounts because Aberdeen Investments does not have discretion over trading and there may be client specific restrictions for SMA accounts.

Certain operational differences in the trade execution process and timing of cash flows may result in Aberdeen Investments having already commenced trading for its discretionary client accounts before the model delivery and SMA accounts have executed Aberdeen Investments recommendations. In this event, trades placed for the model delivery and SMA clients may be subject to price movements, particularly with large orders or where securities are thinly traded, that may result in model delivery and SMA clients receiving less favorable prices than our other discretionary clients. Aberdeen Investments has no discretion over transactions executed by model delivery clients and is unable to control the market impact of those transactions. These timing delays or other operational factors associated with the implementation of trades may result in advisory and model delivery and SMA clients receiving materially different prices relative to other client accounts. In addition, the constitution and weights of stocks within model portfolios may not always be exactly aligned with similar discretionary accounts. This may create performance dispersions within accounts with the same or similar investment mandate. Commission Rates We seek to minimize the expenses incurred for effecting portfolio transactions to the extent consistent with the interests and policies of our clients. However, we will not select broker-dealers solely on the basis of “posted” commission rates. We will not always seek in advance competitive bidding for the most favorable commission rate applicable to any particular portfolio transaction. Although we generally seek competitive commission rates, we will not necessarily pay the lowest commission. Transactions may involve specialized services on the part of the broker-dealer involved, resulting in higher commissions. The reasonableness of commissions is based on the broker-dealer’s ability to provide best execution. For Equities, a global commission rate analysis is completed at least annually using external data, and from these results we maintain a rate card for standard execution and electronic trading. The rates used may still occasionally deviate from these in certain circumstances. Fixed income trades are placed based on best price and execution as determined by our review of solicited bids/offers. We may contact several companies in soliciting any bid/offer. Potential avenues of execution are placed in competition with one another to the extent reasonably possible whenever the portfolio managers look to buy or sell a bond. One of our measures of achieving best execution is executing a transaction with a qualified and capable counterparty that bids or offers the most favorable price under the circumstances. When buying or selling fixed income securities in dealer markets, we may prefer to deal directly with market-makers in the securities. We will typically affect these trades on a net basis, and will not pay the market-maker any commission, commission-equivalent or markup/markdown other than the “spread.” A “spread” is the difference between the price paid (or received) by our firm and the price received (or paid) by the marketmaker in trades with other broker-dealers or other customers. Brokers through whom we execute trades may receive compensation from exchanges, market-makers and other intermediaries related to orders routed by the broker to those intermediaries. In appointing a broker or service provider for client transactions, we will consider the proposed level of fee given, among other things: • • •

The scope of activities to be undertaken in relation to the client transaction; Local market rates for the activities to be undertaken in relation to the client transaction; and The ability to deliver the transaction in a timely fashion and in the best interest of the client.

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aIL may receive non-research services from broker-dealers that effect transactions in connection with Aberdeen Investments investment advice. Notwithstanding, Aberdeen Investments does not select or recommend brokers based on these non-research services. In no event will we compensate a third-party solicitor for a referral if that solicitor serves as a sponsor, decisionmaker or fiduciary of any U.S. pension or profit-sharing plan. We may engage and compensate entities to provide prime brokerage and other services (including client account statement preparation) to client accounts. In addition, other third parties may provide certain shareholder servicing and/or distribution support services in connection with the sale of shares of our mutual funds or other funds that we service. These third parties may do so either directly or through intermediaries (i.e., broker-dealers) and may, in some instances, refer clients into such funds. These third parties (and the intermediaries through whom the funds are available) may receive cash compensation for these services out of our own resources. Our firm, or our affiliates, may be compensated in connection with the sale of shares of either our mutual funds or other funds that such entity services. In addition, our sales and client service employees’ compensation may be linked to sales of our Registered Funds.

There was one administrative event in relation to aIL in the last ten year that would be material to the evaluation of our management. In October 2024 the Korean Financial Services Commission (“FSC”) levied an administrative fine on abrdn Investments Limited (“aIL”) in connection with a single breach in January 2021 of the Korean Financial Investment Services and Capital Markets Act, specifically in relation to the provisions on Short Selling. aIL, acting as a discretionary investment manager, inadvertently executed a small number of shares of a Korean stock which the client account did not own at the time of the order. The FSC levied a fine of an equivalent of KRW 24m (circa £13,500). abrdn’s systems have been fully upgraded since 2021 to prevent re-occurrence of an equivalent breach.

Account Review Process We strive to ensure compliance with a client’s investment guidelines consistent with our fiduciary responsibility to manage an account in the best interest of our clients, and we aim to complete reviews on an ongoing and continuous basis through the order management system Aberdeen Investments utilizes. Most client accounts are also subject to a daily process to ensure they adhere to internal guidelines and investment restrictions. Reviews of accounts also occur when investment strategies and objectives are changed by a client. Our relationship managers work closely with the fund management teams and other internal teams to ensure that each client’s guidelines are implemented, where applicable. Depending on the asset class and account type, we employ various methods of pre- and/or post-trade controls and monitoring techniques through automated or manual procedures to ensure that portfolios are managed in accordance with client-specific guidelines or restrictions as well as applicable regulatory requirements and internal policies. Periodic reviews may also be undertaken to ensure compliance with client investment guidelines. We have policies and procedures in place to address any investment guideline breaches. Private Markets Fund investments are generally not monitored on our trade order management system. However, due to these mandates having broad restrictions and because subscriptions and redemptions in these asset classes are generally only offered periodically, compliance with their investment guidelines are performed as part of the ongoing investment due diligence process. AIS portfolio guidelines are coded into another order management system, which provides systematic pre-trade and post-trade guideline checking. For investment guidelines which cannot be automated in a system, the private market teams undertake manual monitoring on a risk-based approach. Reports to Clients We provide each client with written monthly or quarterly market and investment reports, which include cash balance, transaction records, position reports and account valuation. Additional reports may be provided upon a client’s request.

We do not act as a custodian for client assets. Clients typically receive statements from their account custodians at least quarterly and are encouraged to compare statements received from us with statements received from their client account custodians. Clients should carefully review their custodian statements to ensure they reflect the appropriate activity in their account. If there are differences between a client’s custodian statement and an Aberdeen Investments account statement, or if a client has not received their account custodian statement, clients are asked to contact their client service representative.

Depending upon the terms of an investment management agreement entered into with each client, we may have discretionary authority to make the following determinations without client consultation or consent prior to effecting each transaction: • • • •

the securities that are to be bought or sold; the total amount of the securities to be bought or sold; the broker-dealer through whom securities are to be bought or sold; and the commission rates at which securities transactions for client accounts are effected.

We exercise discretion in a manner consistent with the stated investment objectives for a particular client account. We may accept advisory accounts with limited or no discretion or non-discretionary accounts where investments are client-directed pursuant to an investment management agreement. We may also be limited in the type or quantity of securities purchased or held due to certain regulatory or internal compliance restrictions. Client investment guidelines and restrictions must be provided to us in writing. As it relates to discretionary arrangements, Aberdeen Investments generally is not required to provide notice to, consult with, or seek the consent of its clients prior to engaging in transactions. Please refer to Item 4 of this Brochure for additional information on clients’ ability to tailor investment guidelines.

Where clients appoint aIL to vote proxies on their behalf. Policies have been established to vote these proxies in the best interests of our clients. As of August 31, of each year, investment managers that are required to file reports under Section 13(f) are required to report their proxy voting records on Form N-PX for the twelvemonth period ended June 30, with respect to certain shareholder advisory votes on executive compensation (those required by Section 14A of the Exchange Act). We employ ISS as a service provider facilitate electronic voting. We require ISS to provide recommendations based on our own customized voting policy which is tailored to Aberdeen Investments views and approach, but remain conscious that all voting decisions, where we have been given voting authority, are our own on behalf of our clients. We consider ISS’s recommendations and those based on our custom policy as input to our voting decisions. We make use of the ISS benchmark research and recommendations and those recommendations based on our own custom policy as input to our voting decisions. Where our analysts make a voting decision that is different from the costum policy recommendations policy they will provide a rationale for such a decisions which will be made upon request. In order to make proxy voting decisions an Aberdeen Investments analyst assesses the resolutions at general meetings of companies held in our active investment portfolios. This analysis will be based on our knowledge of the company, but will also make use of the custom and benchmark recommendations provided by ISS as described above. The product of this analysis will be a final voting decision instructed through ISS and applied to all funds for which Aberdeen Investments has been appointed to vote There may be certain circumstances where aIL may take a more limited role in voting proxies. We will not vote proxies for client accounts in which the client contract specifies that aIL will not vote. We may abstain from voting a client proxy if the voting is uneconomic or otherwise not in clients’ best interests. For companies held only in passively managed portfolios, custom policy recommendations provided by ISS will be used to automatically apply ourv otes. We have scope to intervene to test that this delivers appropriate results, and will on occasions opt to instruct a vote different to custom recommendations if we consider this to be in the clients’ best interests. If voting securities are part of a securities lending program, we may be unable to vote while the securities are on loan. However, we have the ability to recall shares on loan or to restrict lending when required, in order to ensure all shares have voted. In addition, certain jurisdictions may impose share-blocking restrictions at various times which may prevent aIL from exercising our voting authority. We recognize that there may be situations in which we vote at a company meeting where we encounter a conflict of interest. Such situations include, but are not limited to: • An investee company that is also a segregated client. • An investee company where an Executive Director or Officer of our company or that of Aberdeen Investments or another affiliate is also a Director of that company. • An investee company where an employee of Aberdeen Group plc or an affiliate or subsidiary is a Director of that company. • A significant distributor of our products. • Any other companies which may be relevant from time to time. We have adopted procedures within our proxy voting process to identify where a conflict exists. These procedures are designed to ensure that our voting decisions are based on our client’s best interests and are not impacted by any conflict. Clients may obtain a free copy of aIL’s proxy voting policies and procedures and/or proxy voting records for their account by contacting us at (+44) 131 372 9444. Aberdeen Investments publishes Investment Principles & Voting Policies, which describe our approach tostewardship, engagement and proxy voting across companies worldwide. Voting decisions and rationales are available upon request. Clients that have not granted aIL voting authority over securities held in their accounts will receive their proxies in accordance with the arrangements they have made with their service providers.

Aberdeen Investmnets may file claims on behalf od clients in class actions where we have the authority to do so. In other instances, Aberdeen Investments may provide a client with the appropriate holdings and trade information to enable the client to participate or opt-out of the class action at the client’s discretion.

Registered investment advisers are required to provide you with certain financial information or disclosures about aIL’s financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients. In addition, we have not been the subject of a bankruptcy proceeding.

APPENDIX A - Fee Schedules The following are our standard segregated account fee schedules. However, fees and other compensation are negotiated in certain circumstances, and arrangements with any particular client may vary. Alternative asset class fees are all negotiable Equities: Fee Schedule Category

Strategies

GEM Single Country

APAC & GEM Smaller

Dev Market & Global Smaller

Dev Market, Global & GEM Equity Specialist Dev Market & Global Mid Cap

Dev Market, Global & GEM Equity

First $50m bps.

Next $50m bps.

Next $150m bps.

Next $250m bps.

Over $500m bps.

China, India, Latin America, Thailand, Singapore Equity

Asia, China Small & Mid Cap

GEM Small Cap

Global, Europe, Japan, UK, US, EAFE Small Cap

US Small Cap

GEM Equity

Asia incl. Income; GEM Income, Sustainable, ex China; US incl. Income; Europe incl. Income; Global incl. Income, Infrastructure, Impact; Japan UK incl. Income, Value, Ethical; EAFE Single Country

Equity funds where e.g. Art. 9, Impact, SDG, where there is a client outcome in addition to performance target UK Mid Cap Global Mid Cap US Mid Cap

Fixed Income:

Fee Schedule Category

Strategies

EM Aggregate Specialist

First $100m bps.

Next $150m bps.

Next $250m bps.

Over $500m bps.

Frontier Bonds

EM Credit – Specialist

SDG

EM Credit

EM Corporate, Sustainable

EM Sovereign

EMD - Sovereign Hard Currency, EMD - Sovereign Local Currency

EM Credit – Single market

Indian Bonds

APAC Credit – Specialist

High Yield

APAC – Credit

Asian Bond/Credit

Global & Dev Market Credit Specialist

High Yield - Global, European Climate/Article 9

Global & Dev Market Aggregate

Strategic Bond

Global & Dev Market Credit

Global, European, UK, US Corporate, Sustainable Corporate

Global Rates

Global Government Bonds, Global Inflation Linked

Global & Dev Market Short Term

Short Dated Enhanced Income, Short duration GILB, Short Duration Corporate

Dev Market Rates

Euro Government Bonds

Sterling Rates

Sterling Government Bonds

US Municipal Bonds

National, Ultra Short Duration, Short Duration High Yield, Intermediate