AEGON ASSET MANAGEMENT UK PLC

Firm overview Aegon Asset Management UK plc (hereafter, “Aegon AM UK”) is a UK domiciled specialist investment management business. From our offices in Edinburgh and London we manage $52.6 billion (£39.3billion)* on behalf of it’s clients internationally, including financial institutions, collective investment trusts, and financial advisers. Aegon AM UK has been a registered investment adviser with the SEC since September 2017 under the name “Kames Capital”, and offers its services to U.S. domiciled institutions, pension funds and financial advisers. Aegon AM UK manages a variety of products and strategies specifically for non-US investors, such as UCITS funds. However, the information contained herein is focused on Aegon AM UK’s US business and activities unless otherwise indicated. Aegon AM UK was incorporated in Scotland on 21 September 1988 as Dunwilco (131) Limited, changing name to Scottish Equitable Investment Management Limited on 16 June 1989, and then Aegon Asset Management UK plc on 28 December 2000. It became Kames Capital on 1 September 2011 and subsequently changed its name to Aegon Asset Management UK on 7th September 2020. Aegon AM UK is a wholly owned subsidiary of Aegon Asset Management UK Holdings Limited and an indirect wholly owned subsidiary of Aegon Ltd. Aegon AM UK is part of a broader investment firm using the brand name Aegon Asset Management. References to Aegon Asset Management includes varied affiliated investment advisory, operational and distribution business units including Aegon USA Investment Management LLC, which utilizes the primary business name Aegon Asset Management US (“Aegon AM US”), and Aegon USA Realty Advisors LLC (“Aegon Real Assets US”), each an SEC registered investment advisor, and various unregistered foreign affiliates (and joint ventures), including Aegon Asset Management Pan-Europe BV, Aegon Asset Management Hungary B.V., Aegon Administration y Servicios AIE (“Aegon Spain”) , Aegon Industrial Fund Management Co. Ltd, Aegon Investment Management B.V. (“Aegon AM NL”), and LBP AM. Additionally, Transamerica Asset Management, Inc. (“TAM”), an SEC-registered investment adviser and an affiliate of Aegon AM UK, operates as a separate and distinct business unit within the Aegon Asset Management family of companies, under a separate brand. Though legally distinct, the Aegon Asset Management affiliates coordinate with one another. Through the use of distinct investment platforms, Aegon AM UK collaborates with various Aegon Asset Management affiliates to deliver products and services globally. We believe that this structure helps us better serve our clients’ needs. Through its affiliation with Aegon Asset Management group companies, Aegon AM UK has access to global resources that augment and complement its own investment expertise. For additional information regarding Aegon AM UK’s legal and governance structures, refer to Item 10, Other Financial Industry Activities and Affiliations. *Source: AEGON AM UK as at 31 December 2025.

B

Advisory services Aegon AM UK offers a range of investment strategies, covering asset classes including fixed income, equities and multi-asset.

C

Tailoring services to client needs Our dedicated client management team works closely with clients to provide a high-quality service and to understand and meet their reporting needs. Aegon AM UK manages portfolios on a discretionary basis and will establish a separate Investment Management Agreement for each separately managed account, or pooled investment vehicle. This includes mutually-agreed investment guidelines and restrictions such as investing in certain securities or types of securities. These restrictions are then centrally documented and recorded on our order management system, which includes automated restriction monitoring. Monthly and quarterly reporting is available to all institutional clients. Any additional reporting requirements can be discussed and agreed with the appointed Client Director as part of the account opening process.

D

Assets under management Aegon AM UK’s regulatory assets under management attributable to US clients are currently $739.2 million. For a description of the strategies available in the U.S., refer to Item 8.A. Methods of analysis, investment strategies and risk of loss. Note that disclosures in the brochure are specific to strategies offered in the U.S. only.

A

Fee schedule Aegon AM UK charges investment management fees consistent with the terms agreed in the clientspecific Investment Management Agreement (IMA) in the form of an Annual Management Charge (AMC). Fees are typically based on clients’ assets under management and are negotiable. Our standard fee structure for managing segregated investment portfolios is categorised by the specific investment strategy.

B

Client billing Clients are invoiced for investment management fees due to Aegon AM UK. We do not deduct fees from clients’ assets. Typically, the management fee is calculated and accrued monthly and payable quarterly in arrears but client specific arrangements can be accommodated.

C

Other fees and expenses Aegon AM UK investment management fees are exclusive of brokerage commissions, transaction fees and other related costs and expenses that are typically incurred by clients. Clients may also incur additional fees when account assets are invested in mutual funds, ETFs and other pooled investment vehicles. These vehicles charge internal management fees, which are disclosed in their respective offering documents. No portion of these fees offset the fees Aegon AM UK charges for its services. Client assets are maintained by independent custodians, and clients pay all custody fees directly to their custodian.

D

Advance payment of fees Aegon AM UK calculates invoices in arrears. No fees are paid in advance.

E

Compensation for the sale of securities or other investment products Aegon AM UK does not receive compensation for the sale of securities or investment products held within the underlying mandates we manage for our clients. Aegon AM UK aligns the interests of employees with those of clients via our long-term incentive performance plan. Part of our remuneration package includes eligibility for a discretionary bonus. Our sales team receive bonuses based on introducing new clients. Our remuneration package ensures that our investment professionals are focused on a range of Key Performance Indicators which align the interests of staff with our clients’ interests, incentivising us to continue to meet our client needs.

risks A

Analysis and investment strategies Aegon Asset Management runs a broad range of investment strategies, covering fixed income, equity and multi asset portfolios. These strategies seek to cater to a wide range of investor objectives including income, total return and absolute return. Each strategy will implement its own tailored process, which reflects the specific nature of the strategy and its objectives. However, a common theme across Aegon AM UK’s strategies is that they employ active management and seek to use detailed analysis and portfolio construction techniques to add value for clients. Key elements of our process The specific investment process employed will vary from strategy to strategy, in order to reflect the nuances of the asset class and the focus of the particular strategy. Each process is designed to provide the best possible opportunity set for the strategy to achieve its investment objectives whilst ensuring it remains within its stated risk parameters. The process for each strategy will combine quantitative and qualitative elements. Quantitative analysis may involve elements such as screening the investable universe for securities with certain characteristics. It should be emphasised though that final investment decisions are not taken purely on the basis of quantitative analysis. Qualitative aspects of the process will involve further analysis on individual assets and portfolio construction techniques used by the investment team. For equity securities, we consider business fundamentals, valuations and technical factors in the analysis process. For fixed income securities there is a similar framework which covers

Fundamentals, Valuations, Technicals and Sentiment. Research is documented centrally and in a consistent manner, which makes it easy for investment ideas to be shared across multiple strategies. The process is flexible so that it is up to the analyst to determine how to weight each element in terms of importance to the overall investment case for any individual security. Aegon AM UK also has access to, and at the Portfolio Managers discretion, utilizes as part of the overall investment process, research generated by Aegon Asset Management affiliates, Aegon AM US, a US-based affiliate that is registered as an investment adviser with the SEC and Aegon Investment Management B.V. (“Aegon AM NL”), an investment adviser licensed and domiciled in the Netherlands as part of a participating affiliate arrangement. The participating affiliate arrangement is described further in Item 10.C Other Financial Industry Activities and Affiliations –Relationships and arrangement affiliates. As part of the processes outlined above, Aegon AM UK seeks to identify and consider financially material environmental, social and governance (ESG) factors into bottom-up research. These ESG considerations may help the analysts form a holistic understanding of a security’s overall fundamentals and, therefore, its financial performance. As part of research, ESG factors will be considered alongside traditional financial factors and may be no more or less determinative than these other factors to the overall investment case. In addition to the above research process, Aegon AM also runs a dedicated range of responsible investment (‘RI’) strategies, which may involve exclusionary screening and/ or the requirement for securities to pass additional analysis focused solely on ESG aspects and carried out by Aegon AM’s Responsible Investment specialists. Some RI research is performed to ensure compliance with regulatory requirements of the fund vehicle. Portfolio managers will have access to the ideas generated by the fundamental research process outlined above to construct portfolios that they think can achieve each strategy’s stated investment objective. This process will use a mixture of the portfolio managers’ skill and experience in portfolio construction and certain IT systems. The process may also involve interaction with Aegon AM’s Portfolio Risk Management team, to ensure that appropriate levels of risk are being taken in the strategy. Through interactions with the Portfolio Risk Management team, portfolio managers can also seek to understand and analyse the different sources of risk that individual portfolios are exposed to, as well as considering the output of stress testing, or modelling of the effect of proposed changes to a portfolio on its overall risk exposures. Set forth below are the investment strategies Aegon AM UK offers. The objective, performance target and restrictions can be tailored to our clients’ requirements. Subject to limitations within a given investment objective, Aegon AM UK does not limit the types of securities it may recommend to clients and generally recommends a diversified portfolio.

Fixed income strategies Strategy name

Objective

Strategic global bond

The investment objective is to maximise total return (income plus capital) by investing primarily in global debt instruments in any currency, ranging from AAA government bonds through to high yield and emerging market bonds. The reference index for this strategy is Bloomberg Barclays Global Aggregate Index USD hedged.

Global high yield bond

The investment objective is to maximise total return (income plus capital) by investing primarily in high yield bonds in any currency, which may be corporate or government, and which may be at a fixed or floating rate, rated or unrated. Selected investment grade bonds and cash may also be held. The reference index for this strategy is the BofA Merrill Lynch Global High Yield Constrained USD Hedged.

Global absolute return bond

The investment objective is to generate positive absolute returns for investors over a rolling 3-year period irrespective of market conditions. The strategy will seek to achieve its investment objective by investing in global debt instruments in any currency, ranging from AAA government bonds through to high yield and emerging market bonds.

Global investment grade bond

The investment objective is to maximise total return (income plus capital) by investing primarily in investment grade corporate and government bonds in any currency which may be at a fixed or floating rate, rated or unrated. Selected high yield bonds and cash may also be held. The benchmark for this strategy is the Bloomberg Barclays Capital Global Aggregate Corporate Index USD Hedged.

Equity strategies Strategy name

Objective

Global equity income

The investment objective is to provide income and capital growth by investing in the global equities market. The strategy will aim to deliver a yield higher than that generally available from investment in global equities. The benchmark for this strategy is MSCI ACWI.

Global sustainable equity

The investment objective is to maximise total return (income plus capital) by investing directly in a portfolio of global equity securities which meet predefined sustainability criteria. The benchmark for this strategy is MSCI ACWI.

US sustainable equity

The investment objective is to maximize total return gained from the combination of dividend yield, growth of dividends and capital appreciation. The strategy will aim to deliver a yield higher than that generally available from investment in US equities (as defined by the Russell 1000 Index). It will invest only in companies which meet predefined sustainability criteria.

US equity

The investment objective is to outperform the S&P 500 index by investing directly in a portfolio of US equity securities. The strategy

is managed with awareness of sector and style exposures versus the index and seeks to keep these within tightly controlled ranges.

Multi-asset strategies Strategy name

Objective

Diversified growth

The investment objective is to maximise total return (income plus capital) at a lower risk than global equity markets by investing in a diversified portfolio of global assets. The benchmark for this strategy is US Consumer Price Index (CPI).

Diversified income

The investment objective is to provide income with the potential for capital growth by investing in a diversified portfolio of global assets.

European Leveraged Loan Strategy North Westerly Collateralised Loan Obligations (“CLOs”) are managed by Aegon AM UK for the benefit of their Issuers and represent securitisations of sub-investment grade loans selected by Aegon AM on a "long-only", take-and-hold basis, with reinvestment criteria determined by the credit rating agencies that assign public ratings to such CLOs. B Material risks Investing in securities or derivatives involves a risk of loss that clients should be prepared to bear. Aegon AM UK cannot guarantee it will achieve client investment objectives, that a client will receive a return on its investment, or any performance results. All investments include the potential for loss of the principal amount invested and unrealized profits. Past performance is not an indication or guarantee of future performance. The discussion below is of a general nature and is intended to describe various risk factors which may be associated with an investment. These are not intended to be exhaustive and there may be other considerations that should be taken into account in relation to an investment. Clients should take all steps necessary in terms of internal or external advice or governance before considering an investment. Past performance is not an indication or guarantee of future performance. The following risks are relevant to the strategies listed above: Active Trading Risk: The Aegon AM UK investment strategies are actively managed and will purchase and sell securities and other assets without regard to the length of time held. Active trading will impact performance by increasing transaction costs and potentially generating greater amounts of net short-term capital gains, which, for investors with taxable accounts, would be subject to income tax at ordinary income tax rates. During periods of market volatility, active trading risks may be more pronounced. Convertible Securities Risk: Convertible securities share investment characteristics of both fixed income and equity securities. The value of convertible securities also tends to exhibit lower volatility than the underlying common stock. Convertible securities generally offer lower interest or dividend yields than nonconvertible securities of similar quality. Investors could lose money if the issuer of a convertible security is unable to meet its financial obligations or goes bankrupt. Convertible security prices may be negatively impacted by rising rates, especially when convertible trades are out-of-the-money. Convertible securities can be less liquid than corporate bonds, especially in times of market stress. The equity price may never reach the conversion price, thereby negating the value of the option to convert. Counterparty Risk: Investments such as derivatives are made using financial contracts with third parties. Those third parties may fail to meet their obligations due to events beyond our control, and therefore the value of the investment could fall because of: (i) loss of monies owed by the counterparty; and/or (ii) the cost of replacement financial contracts. Credit Risk: An issuer of bonds may be unable to make payments due to the investor (known as a default). The value of bonds may fall as default becomes more likely. Both default and expected default may cause the portfolio value to fall. High yield bonds generally offer higher returns because of their higher default risk and investment grade bonds generally offer lower returns because of their lower default risk. Currency Risk: Certain strategies may have foreign exchange risk. Investments may be denominated in a range of currencies which differ from the base currency. Fluctuations in these currencies may increase the risk of losses to the portfolio where hedging is not used or is incomplete or unsuccessful.

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Aegon AM UK manages assets on behalf of clients internationally, including public funds (e.g., US mutual funds), collective investment trusts, financial institutions, endowments, foundations, wealth managers, wrap programs, family offices and individuals. Aegon AM UK typically requires a minimum investment, which may differ depending upon the particular investment strategy, product or client type. In the US, Aegon AM UK’s currently manages assets for US mutual funds, pension plans, and offshore collateralized loan obligations (CLOs) privately placed to institutional US investors.

Client portfolios may include a performance-based fee in the event that this is negotiated between the client and Aegon AM UK and documented in the Investment Management Agreement (IMA). Although each performance fee is calculated differently in line with client specifications, it will generally stipulate a base rate, a participation rate and a maximum fee. The participation rate specifies the percentage of an account’s capital gains or capital appreciation that will be paid as a fee to Aegon AM UK. Aegon AM UK will structure a performance-fee or incentive-fee arrangement subject to Section 205(a)(1) of the Investment Advisers Act of 1940 (the “Act”), as amended, and in accordance with the available exemptions thereunder, including the exemptions set forth in Rule 205-3 under the Act. There are inherent conflicts of interest in the side-by-side management of performance fee and nonperformance fee accounts. Performance-fee arrangements create an incentive for an adviser to take risks in managing assets that would not otherwise be taken in the absence of such arrangements. Similarly larger accounts could be favoured because they generate more revenue for the adviser. We strive to mitigate these potential conflicts through policies and procedures designed to ensure all clients are treated equitably over time, and through employee education. See Item 12, Brokerage Practices - Trade Aggregation and Allocation, for additional information about Aegon AM UK’s trade aggregation and allocation practices.

Aegon AM UK is a direct wholly-owned subsidiary of Aegon Asset Management UK Holdings Limited. Aegon Asset Management UK Holdings Limited, and in turn Aegon AM UK, are indirect wholly-owned subsidiaries of Aegon Ltd. Aegon AM UKs day-to-day affairs are overseen by a local Board of Managers and managed by local officers. While maintaining local leadership, accountability, oversight and control, Aegon AM UK operates with the Aegon Asset Management global framework. Within that global framework, the global management board and various committees of Aegon Asset Management provide management and oversight of the global activities and operations of Aegon Asset Management. A

Registration as a broker-dealer or registered representative Neither Aegon AM UK nor any of its management persons are registered or have a registration pending as a broker-dealer or registered representatives. Aegon AM UK has arrangements with affiliated personnel who are registered representatives of an unaffiliated broker-dealer. These arrangements support wholesaling of Aegon Asset Management’s products in the US offshore market but are not significant to Aegon AM UK’ core institutional investment management activities.

B

Registration as a futures commission merchant, commodity pool operator, commodities trading advisor or associated person Aegon AM UK is not registered as a futures commission merchant, commodity pool operator, commodities trading adviser or associated person.

C

Relationships and arrangement with affiliates Globally, certain affiliates (e.g. Aegon Asset Management Pan-Europe B.V. and Aegon Investment Management BV) assist Aegon AM UK in various capacities including identifying prospective clients, understanding the regulatory requirements in certain foreign jurisdictions, and managing client relationships.

In the US, Aegon USA Investment Management LLC (Aegon AM US), a group company, provides administration and US sales support to Aegon AM UK.

In particular Aegon AM US:

Provides an additional line of approval for all marketing material to be used in the US; Provides legal and compliance support with respect to Aegon AM UK’s compliance with US regulations and requirements; and Provides sales support for the strategies of Aegon AM UK which are marketed in the US and the broader Americas.

Aegon AM UK serves as investment adviser to an insurance company (Scottish Equitable plc) which is an affiliate part of the Aegon family of companies. Aegon AM UK serves as sub-adviser to Transamerica Asset Management Inc.. Aegon AM UK, Aegon AM US, and Aegon AM NL share a Global Research Platform. Aegon AM UK may share investment research, and recommendations on corporate and sovereign debt issuers and securities with certain Aegon AM NL and Aegon AM US personnel. The inputs from Aegon AM US and Aegon AM NL to Aegon AM UK are facilitated through a Global Sharing Agreement. Aegon AM NL and Aegon AM US personnel, with respect to their global research activities, are considered Aegon AM UK associated persons, and are subject to certain of Aegon AM UK’s compliance policies and procedures (and related monitoring by Aegon AM UK and Aegon AM NL). Aegon AM UK maintains a list of the employees for each affiliate that Aegon AM UK has deemed an associated person, which Aegon AM UK will make available to current and prospective clients upon request. Aegon Asset Management affiliates (e.g. Aegon AM US, Aegon Investment Management B.V., Aegon Asset Management UK plc and Aegon Asset Management Hungary B.V.) assist each other with operational support functions in various capacities to integrate and align operational activities. Aegon AM UK, Aegon AM US and Aegon AM NL independently manage investment strategies that separately utilize and depend on the Global Research Platform. Conflicts of interest, or at least the appearance of conflicts, will arise when portfolio managers from each firm invest or trade in the same securities or issuers on behalf of their respective clients. These conflicts can include advance access to investment research that results in the preferential treatment or the possibility of preferential allocation of securities trading opportunities that have limited availability. Aegon AM UK has developed compliance policies and monitoring designed to reasonably ensure that the activities performed by associated persons comply with applicable regulatory requirements and address material conflicts of interest. D

Foreign financial regulatory authority AEGON AM UK is authorised and regulated by the Financial Conduct Authority in the United Kingdom.

transactions and personal trading A

Standard of Conduct In line with Rule 204A-1 of the Investment Advisers Act Aegon AM UK has adopted a Code of Ethics Policy (“the Code”) for its officers, directors, employees and control persons (“Supervised Persons”) that sets forth Aegon AM UK’s standards of conduct and requires compliance with federal securities laws. The Code is based on the principle that Supervised Persons owe a fiduciary duty to Aegon AM UK’s clients, including the duties of loyalty and care. Aegon AM UK’s Supervised Persons who have access to non-public information regarding US client’s purchase or sale of securities, holdings, or research recommendations are deemed to be Access

Persons and subject to Code requirements specifically related to personal securities transactions and must conduct their personal trading activities in a manner that does not violate federal securities laws, interfere with client accounts, or otherwise take unfair advantage of client relationships. Similarly, certain personnel of some of Aegon AM UK affiliates (including Aegon AM NL, Aegon AM US) are also treated as Access Persons if they provide Aegon AM UK with investment research, and recommendations through the Global Research Platform. Accordingly, among other things, Aegon Asset Management Access Persons and Aegon AM UK Access Persons, may not: a. Profit, or cause others to profit, based on his or her knowledge of completed or contemplated client transactions; b. Engage in fraudulent conduct in connection with the trading of securities in a client account; or c.

Personally benefit by causing a client to act, or fail to act, in making investment decisions.

To further mitigate potential conflicts of interest, the Code imposes restrictions on personal securities transactions in which Access Persons have a beneficial interest, including preclearance and holdingperiod requirements for certain reportable securities. Aegon AM UK’s Supervised Persons have an ethical and legal obligation to avoid conflict-of-interest situations, disclose potential conflicts, and seek clarification when warranted in line with Aegon AM’s Conflict of Interest Policy. Aegon AM UK has also adopted policies that place restrictions on the giving or receipt of payments, donations, political contributions, gifts or entertainment or other non-monetary benefits to or from third parties that could constitute some form of inducement.To that end, Aegon AM UK’s Supervised Persons must comply with restrictions and reporting requirements related to the offering or receipt of gifts and entertainment. Supervised Persons must also obtain pre-approval for outside business activities that could conflict with their duties to Aegon AM UK or its clients. Conducting our business with integrity, openness and clarity is critically important to us and no single factor is more critical to our success than working diligently at every level and in every role within our organisation. A copy of Aegon AM’s Code of Ethics Policy is available on request. B

Principal trading Aegon AM UK manages accounts on behalf of related persons but does not generally engage in principal transactions involving an affiliate’s account buying securities from or selling securities to an unaffiliated client’s account. If Aegon AM UK deems it is in clients’ best interests and engages in these principal trades, it will do so in compliance with Section 206(3) of the Advisers Act (noting this does not constitute principal trading as defined by local regulations in the United Kingdom). Cross trades may present a conflict due to the firm representing both the buyer and the seller. Only where there is a benefit to all the clients concerned and where it is permitted by the client and law or regulation, will Aegon AM UK consider a cross trade. Aegon AM UK will not typically undertake cross trades for any US clients.

C

Conflicts of interest in personal trading Subject to the restrictions imposed on personal securities transactions within the Code, including blackout and minimum holding periods and preclearance requirements, Supervised Persons are permitted to transact in the same securities for their personal accounts as the firm purchases or sells on behalf of its clients. Supervised Persons also have the opportunity to invest in certain public or private investment vehicles (directly or through their individually managed pension accounts) that are advised or sub-advised by Aegon AM UK. Aegon AM UK utilises a compliance system which requires its Access Persons to obtain preclearance prior to undertaking a personal trade. Permission is only granted for a limited period and will take into account any open client orders.

Broker-dealer selection process Aegon AM UK has discretionary authority to select broker-dealers used to place client trades unless otherwise specified by the client.

We retain a list of approved brokers in our order management system. Brokers are approved based on a number of factors, including their ability to:

Execute a trade promptly, accurately and cost effectively Provide a timely order execution report Maintain client anonymity Complete a trade Maximise the opportunity for price improvement Search for and obtain liquidity to minimise market impact and accommodate unusual market conditions Communicate with us effectively.

All new counterparties must either be proposed or supported by the Aegon Asset Management UK Plc Dealing Desk. The proposal includes a business case, anticipated volumes and measures of financial strength.

Due Diligence checks will be carried out, to determine, amongst other things, credit-strength and relevant registrations. Following which, the proposal will be tabled at the Global Investment Management Risk and Control Committee for consideration and approval. If the counterparty is approved, the Central Dealing team request information from the proposed counterparty, notably terms of business and any static supplementary questionnaires. Only when all relevant documentation has been signed-off and the counterparty has been added to the approved broker list are we free to conduct trading with the new counterparty. We constantly review our counterparties both for trading and research performance as well as general operational performance. In terms of additional reviews, an annual review will be conducted by Investment Management on trading activity of approved counterparties. In addition, the Middle Office team reviews the credit ratings for each counterparty and monitors any changes over time. Aegon AM UK does not have affiliated broker-dealers nor do we recommend any broker-dealers to our clients. Research and soft dollars The principal service Aegon AM UK provides to its clients is the provision of investment management. In providing that service, we will execute orders on behalf of our clients. When executing orders, we must ensure that we consistently obtain the best possible results, taking into account the different execution factors so far as they apply to each asset class. Research services are not paid for by client commission; Aegon AM UK pays for non-execution services from brokers. Such arrangements are overseen and governed by the Investment Research, Execution and Oversight Committee. Brokerage for client referrals Aegon AM UK does not consider client referrals in selecting a broker-dealer or directing transactions to a broker-dealer. Directed brokerage When trading financial instruments on behalf of our clients we will normally use our discretion to decide which financial instruments to trade, the size and speed at which we wish to trade, the venues on which those instruments will be available and how to access those venues. Aegon AM UK is willing to consider alternative arrangements should a client wish to direct brokerage and Aegon AM UK recommends the client appoints a third party to administer the scheme. However, clients may instruct Aegon AM UK to execute a specific order or group of orders in a certain way. Depending on the specifics of the order the client has given Aegon AM UK, we may not be able to achieve best execution because the order may prevent us from doing so. In those circumstances, we will try to achieve the best possible results we can whilst following our client’s order. If a client directs brokerage we may not be able to aggregate orders. Aggregating orders may avoid delays in execution and keep costs to a minimum, accordingly, we may group orders together so that trades for a numbers of clients in a certain instrument are executed together. In all cases, we will treat our clients fairly when aggregating orders. If aggregated orders cannot be fully executed, the financial instruments will be allocated to clients in proportion to the size of the relevant client’s interest comparative to the size of the original order.

Trade Aggregation and Allocation Aegon AM UK allocates investment opportunities among clients in a manner intended to result in fair and equitable treatment to clients over time. Factors that influence a decision to allocate investment opportunities among client accounts may include but are not limited to:

account investment objectives, guidelines, and constraints; current account holdings, including asset class, sector, industry, and issuer concentrations, both on an absolute basis and relative to the account’s benchmark; desired risk profiles of the account, including credit quality, maturity, or duration distributions, and the impact the proposed investment would have on these measures; cash availability and future cash flow expectations; legal, regulatory, and similar factors; and allocation considerations based on criteria such as round-lot provisions or minimum transaction size.

Accounts that Aegon AM UK manage may trade in the same securities. Given this, Aegon AM UK typically combines transactions for different clients into aggregated orders. This practice can enable the firm to seek more favourable executions and net prices. Portfolio managers can use any method to allocate transactions among participating accounts, provided the method is consistent with Aegon AM UK’s policy, is appropriately documented and, over time, no client is unduly favoured over another. Trade Errors Consistent with its fiduciary duties, Aegon AM UK’s policy is to take the utmost care in making and implementing investment decisions for client accounts. To the extent that trade errors occur, Aegon AM UK seeks to ensure the client’s best interests are served when correcting such errors. Aegon AM UK makes its determinations regarding trade errors on a case-by-case basis, in its discretion, based on factors it considers reasonable, including regulatory requirements and business practices. A trade error generally is compensable by Aegon AM UK when it is a mistake (whether an action or inaction), in Aegon AM UK’s reasonable view, that deviates from the applicable standard of care in managing an account. Aegon AM UK has adopted trade error policies and procedures to guide the resolution of, and to help prevent the recurrence of, such errors. Aegon AM UK will determine the amount to be reimbursed, if any, based on what it considers reasonable in light of all facts and circumstances related to such errors.

Client Referrals Aegon AM UK has entered into compensation arrangements with its affiliate, Aegon USA Investment Management, LLC which acts as promoter. This arrangement, and others like it, shall comply with Rule 206(4)-1 (Marketing Rule) under the Act when applicable. For arrangements with third-party promoters, Aegon AM UK compensates promoters based on a percentage of the management fee it earns from the account a promoter has introduced, a one-time fee, or a combination of these. These arrangements do not increase the fees charged by Aegon AM UK to any client. Payment of compensation can cause a promoter to recommend Aegon AM UK over another adviser that does not pay compensation. When a promoter receives compensation from Aegon AM UK, such promoter will have a conflict in advising clients with respect to hiring Aegon AM UK as an investment adviser. Further, promoters might receive different amounts of compensation with respect to different Aegon AM UK strategies and therefore have incentives to favour one or more strategies over others. Aegon AM UK and its affiliates also receive client referrals from unaffiliated consultants retained by investors. While Aegon AM UK does not directly compensate consultants, Aegon AM UK may from time to time make payments to these consultants to participate in conferences sponsored by the consultants in order to, among other things, obtain information about industry trends and investor investment needs. Any of these activities are intended to enhance the quality of service Aegon AM UK provides for its clients and does not impair compliance with our fiduciary duty.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events. Aegon AM UK has no material legal or disciplinary information to disclose.

Investment managers have discretion over clients’ portfolios and review the performance and risk on a daily basis, with more frequent reviews depending on the level of activity, change and volatility within each portfolio. Client guidelines and restrictions are coded into the order management system and monitored by the Portfolio Risk Control Team. The Chief Investment Officer (CIO) chairs monthly Investment Policy Meetings where investment managers discuss market developments and challenge and debate our core views. The Head of Equities & Multi-Asset Investing and Head of UK Fixed Income chair monthly performance and risk oversight meetings which are attended by investment managers representing each of the investment areas, as well as by a member of the Portfolio Risk Management Team. The meetings include discussion on recent and long-term performance against benchmark and risk positioning in both absolute terms and against benchmark. We have an independent oversight framework which ensures that investment managers take appropriate risks and comply with all client guidelines and regulatory requirements. Client management Our dedicated client management team works closely with clients to provide services and to understand and meet their reporting needs.

Client meetings All institutional clients have a designated client service contact who manage the take-on process and the dayto-day queries on the account once live. Each institutional client also has a dedicated Client Director who formally reports on the account at regular investment and relationship meetings (frequency usually determined by the client and noted with the IMA). They attend these meetings in person/via Teams call along with the portfolio manager or investment specialist. For these meetings, tailored presentations are prepared and Aegon AM UK work closely with clients to ensure content covers all information requirements. Reporting Monthly and quarterly reporting is available to all clients. Any additional reporting requirements are captured at the onboarding stage and reflected in the IMA. Standard reporting includes:

Monthly performance reports Valuation and transaction reports Quarterly investment reports

Client satisfaction We monitor client satisfaction against key performance indicators, measured through a combination of regular contact and formal reviews. We also conduct a client survey which enables us to benchmark our services against competitors. By engaging with our clients in this way we receive honest, constructive feedback that we can act upon.

Unaffiliated clients are responsible for selecting their custodians. Aegon AM UK does not act as a qualified custodian for client accounts and, in the normal course of its duties, does not take physical custody or control of client assets. Clients should receive account statements at least quarterly from their custodian, which they should carefully review. Aegon AM UK urges clients to compare reporting received from Aegon AM UK with statements

received directly from their custodian. Please note, Aegon AM UK reporting may vary from custodial statements due to accounting practices, reporting dates or valuation methodologies.

Aegon AM UK contracts with institutional clients to provide investment management services, which are documented in an Investment Management Agreement (IMA). Typically, clients provide discretionary authority to Aegon AM UK to carry out all relevant activities required to provide the investment management service, subject to any requirements and restrictions detailed in the IMA.

Active Ownership policy For separately managed accounts or sub-advisory activity for pooled vehicles, the voting policy is completely individual to the client and the policy and procedure between the client and Aegon AM UK is agreed within the Investment Management Agreement (IMA). Clients can choose to retain control of all proxy voting, to set their own proxy voting policy (whereby Aegon AM UK is responsible for the administration of voting), or to delegate voting to Aegon AM UK. Delegation particulars can be specified at client request. Where Aegon AM UK is given discretion to vote, and unless otherwise dictated by a client’s preferences, our Active Ownership Policy provides a framework for the process involved, and our UK Stewardship Code Compliance Statement provides a framework for overseeing the performance of the companies in which we invest. In particular, it deals with our responsibilities, as set out by the Financial Reporting Council’s UK Stewardship Code and our adherence to the Dutch Governance Code, although we endeavour to apply the same principles to all client holdings regardless of their listing or domicile as long as consistent with applicable law and a given client’s investment objective. We consider all shareholder resolutions put forward by the UK-listed and Dutch companies in which we invest and any non-UK listed companies where we own greater than or equal to 0.1% of the issued share capital. The exception to this is the strategies that are identified by name as sustainable and ethical where we shall undertake all reasonable efforts to vote at all eligible meetings. Votes held by Aegon AM UK are used to promote the long-term interests of our clients as shareholders. When voting UK-listed companies this generally means the company must follow the UK Corporate Governance Code, which sets out best practices on corporate governance in the UK. However, we recognise that companies are not homogenous in this respect and we strongly support the “comply or explain” model of corporate governance. For this approach to work, companies have to be willing to provide good quality and detailed explanations of the reasons for deviation from established best practice. When voting outside of the UK, we follow the appropriate regional best practice, where this is defined. Where regional best practice is not defined, we look to international best practice codes such as the Organisation for Economic Co-Operation and Development (OECD) Principles of Corporate Governance. Where we have a voting-related concern, within practical limits we contact the company ahead of the meeting to discuss our concerns. When we vote against or abstain on an issue, we also write to the company explaining why we have done so and what actions they need to take to ensure our support in the future. We use the voting advisory services of both The Investment Association (a United Kingdom financial services trade body) and Institutional Shareholder Services, although we review all governance issues on a case-bycase basis and in a pragmatic manner with input from both the Responsible Investment (RI) team and our investment managers. Once we have made a decision, we use the proxy agency voting platform to cast the votes on our behalf. We strive to ensure that votes cast on our behalf by proxy agencies are done so in a manner that is consistent with our voting policies. Where appropriate, we may attend the general meetings of the companies in which we invest.

Our normal practice is to agree engagement and final voting decisions between both our RI team and the relevant investment manager in line with our Active Ownership Policy. Where controversial issues are identified or there is disagreement, the issue is escalated to the desk head and in the case of a disagreement, the final arbiter is the Chief Investment Officer. We endeavour to avoid lending securities during the proxy-voting period for each company we hold, in order to avoid the loss of shareholder votes which this would entail. Where we have lent securities, in accordance with best practice, we recall those securities to enable proxy voting. Records We record all votes cast and other relevant corporate governance actions on behalf of US clients in accordance with the SEC Investment Advisers Act Rule 204-2(c)(2). These records allow us to monitor each company’s progress towards compliance with the appropriate governance codes and to demonstrate to our clients the approach we have taken. In addition, our voting processes and stewardship activities are independently reviewed annually as part of our responsibilities under the review of internal controls (ISAE 3402). Details of our Active Ownership Policy, as well as our engagement and voting activities are provided on our website at www.aegonam.com/en/responsible-investing. Managing conflicts of interest Asset management is Aegon AM UK’s only business and our policies reflect a commitment to acting in the best interests of our investors. We recognise that situations may arise that could lead to conflicts of interest. Such considerations are covered in our firm-wide Conflicts of Interest Policy. This policy is available at: www.aegonam.com/en/responsibleinvesting. Our overriding principle when considering any such conflicts is our fiduciary duty and Treating Customers Fairly (TCF). The obligations under TCF help ensure that we identify our fiduciary responsibilities and act accordingly in the best interests of our clients. Examples of conflicts of interest that may arise during our voting and stewardship activities include: when an investee company is also a client; where we own both debt and equity in a given company; or where directors of an investee company also sit on the board of Aegon AM UK or our parent company Aegon Ltd. In such instances, we always prioritise the interests of clients. For those proxies involving a potential conflict of interest, the RI team will inform the Head of Compliance – UK and the Chief Investment Officer of the rationale for any decisions taken and the decision shall be recorded and report such matters to the Aegon AM UK Risk Control Committee ona quarterly basis. Our legal and compliance teams may also be consulted as appropriate. Aegon AM UK does not vote the shares that it holds in the listed entity Aegon Ltd.

As a registered investment adviser Aegon AM UK is required to provide financial information and disclosures about its financial condition. A

Prepayment Aegon AM UK does not require or solicit prepayment of its investment advisory fee, six months or more in advance.

B

Discretionary authority Aegon AM UK does not have financial commitments that impair its ability to meet contractual and fiduciary commitments to clients.

C

Bankruptcy Aegon AM UK has not been the subject of a bankruptcy petition at any time.