AFLAC ASSET MANAGEMENT LLC

Aflac Asset Management LLC (“Aflac GI”) is a direct, wholly-owned subsidiary of Aflac Incorporated, a publicly held company (NYSE Ticker: “AFL”). Aflac GI, also known as Aflac Global Investments, was founded in October 2017 as a Delaware limited liability company. Aflac GI serves as the investment manager to Aflac Incorporated, insurance companies affiliated with Aflac GI through Aflac Incorporated (“Insurance Company Clients”), and other pooled investment vehicles in which some Insurance Company Clients invest (each a “Client” and collectively, the “Clients”). The pooled investment vehicles are exempt from registration under the Investment Company Act of 1940, as amended. Aflac GI provides comprehensive asset management services including credit portfolio management, asset allocation solutions, derivatives solutions and management, and other strategic and tactical portfolio management services. We utilize external managers for expertise in certain asset classes and, in certain cases, we employ derivatives to manage risks of our investment strategies and other Client activity. Portfolio Management – Fixed Income, Derivatives, and Alternative Solutions Aflac GI’s disciplined process uses a strategic asset allocation to seek long-term risk-adjusted investment returns and stable income within the regulatory and capital objectives of its Clients. To achieve this objective, Aflac GI typically invests in fixed income securities including investment-grade and below-investment-grade bonds, loans and structured securities, both publicly traded and privately originated. In using derivative instruments, Aflac GI seeks to mitigate various risks associated with its Clients’ investment portfolios and forecasted cash flows, including currency and interest rate risk. Aflac GI also manages a program of alternative assets, primarily private fund investments. Asset Allocation Services Aflac GI offers asset allocation services and multi-asset advisory services across asset classes and through its investments in portfolios and other investment vehicles that are managed by third-party managers. Externally-managed asset classes include but are not limited to commercial mortgages, transitional real estate loans, infrastructure debt, middle market loans, public equity and alternative investments such as private and real estate equity. Each third-party manager must meet certain requirements relating to the respective asset class at the time of manager selection. Third-party managers are responsible for determining the investments or securities that are purchased, sold or retained under their respective investment mandates for Aflac GI’s Clients. Other Aflac GI provides discretionary advisory services to sub-trusts of Global Alternatives Trust I, a Cayman Islands unit trust formed in 2019 (the “Fund”), the Global Alternatives Fund SPC and its related segregated portfolios. The only investors in the Fund are certain Insurance Company Clients, and Aflac GI does not customize its advisory services for each individual investor in the Fund.

The assets of the Fund are invested in accordance with its offering memorandum, deed of trust, and other governing documents (the “Governing Fund Documents”). The investment strategy of the Fund is described in greater detail under Alternative Assets in Item 8 below. Aflac GI also serves as a sub-advisor to Aflac Asset Management Japan Ltd. (“AAMJ”), an affiliated investment adviser licensed with the Japan Financial Services Agency. Aflac GI provides asset management services on behalf of AAMJ to Aflac Life Insurance Japan Ltd (“ALIJ”), an insurance company affiliated with Aflac GI. Subject to the sub-advisory investment guidelines and applicable law, Aflac GI advises AAMJ about the manner in which ALIJ invests in certain trust and other investment vehicles which, in some cases, are also Clients of Aflac GI. Aflac GI also provides portfolio management services to two Delaware statutory trusts that hold interests in a diversified pool of leveraged loans and in which ALIJ holds all the trust interests. Aflac GI managed approximately $118,596,150,569 of Client assets on a discretionary basis and $14,874,976,639 of Client assets on a non-discretionary basis, as of December 31, 2025.

Aflac GI provides investment advisory services to its Clients pursuant to separate Investment Management Agreements (“IMAs”) with each Client. The IMAs for each of its Clients, including the Fund, along with the Governing Fund Documents, set forth in detail the fee structure relevant to each Client. Aflac GI receives asset-based management fees for providing discretionary and non-discretionary investment advisory and consultancy services to clients. Fees for investment advisory services are payable quarterly in arrears, based on a percentage of the value of assets under management as shown on Client’s accounting books of record. Fees are individually determined based on the type of asset class for which management services are being provided, and will be calculated as a percentage of the assets under management within each asset class in a particular Client’s account. Fees are negotiable based on the individual Client. Fees will range within a given asset class, as described in the applicable fee schedule. Derivatives transactions, if any, are generally charged based on the quarter-end notional value, but may also be charged based on the absolute value of the quarter-end market value, as outlined in each Client’s agreement. Fees for public and private equity will be based on fair market value as determined in accordance with our valuation policies and procedures, and fees for all other assets will be based on book value. In addition to Aflac GI’s investment management fees, Clients are generally responsible for other trading costs and custodial fees related to their accounts, unless described otherwise in the applicable governing documents. Clients invested in the Fund are generally responsible for the portfolio’s expenses, including but not limited to management fees, fees and expenses of the directors, custodians, administrators, independent pricing vendors and other agents, transaction fees, taxes and fees for tax reporting. For more information on trading costs, please see Item 12 – Brokerage Practices below. To the extent that Clients’ accounts are invested in mutual funds, private funds or other collective investment vehicles, these funds charge a separate layer of management, performance, trading, and administrative expenses, which are borne indirectly by the investors in each such fund. Accordingly, where a Client invests in such funds, it will bear its share of such costs.

Aflac GI bills its Clients for its investment advisory services and does not deduct the fees from Clients’ assets. Aflac GI’s fees are exclusive of other fees and expenses that are incurred by, or on behalf of, the Client as documented in a written agreement with the Client. If any such expenses are paid by Aflac GI, Aflac GI will provide Client an invoice reflecting such expenses and the Client will reimburse Aflac GI or its affiliates for those expenses. In certain instances, our supervised persons will recommend that an Insurance Company Client invest in a private fund or other products that we or an affiliate sponsor, advise or otherwise provide services to. In such instances, the Client will generally pay two layers of fees, including underlying fees and expenses associated with the product, in addition to advisory fees charged by Aflac GI. Aflac GI has a conflict of interest to recommend that Clients invest in affiliated products, as Aflac GI and/or its affiliates will receive additional compensation in connection with such investments than if the Client invested in an unaffiliated product. Aflac GI addresses such conflicts of interests through disclosure and policies and procedures to ensure that any investment recommendation made to a Client is in accordance with its fiduciary duty. Further, in certain instances, Aflac GI will waive its advisory fee in connection with a Client’s investment in an affiliated product. Please see Item 10 of this Brochure for additional information.

As noted above in Item 4 – Advisory Business, Aflac GI’s disciplined process uses a strategic asset allocation to seek long-term risk-adjusted investment returns and stable income within the regulatory and capital objectives of its Clients. Aflac GI devises investment strategies based on each Client’s eligibility and suitability for investments. In doing so, Aflac GI considers risk return tolerances, holding periods, liquidity requirements, tax constraints and other Client-imposed limits and policies. Below is a summary of the investment strategies and methods of analysis employed by Aflac GI.

Corporate Debt Aflac GI’s current investment strategy for corporate debt is to maximize net investment income in a manner consistent with the preservation of capital in accordance with client’s objectives and risk management practices and tolerances. The investment process begins with an independent approach to underwriting each issuer's fundamental credit quality. This underwriting process includes a thorough analysis of a variety of items including the issuer's country of domicile (including political, legal, and financial considerations); the industry in which the issuer competes (with an analysis of industry structure, end-market dynamics, and regulation); company specific issues (such as management, assets, earnings, cash generation, and capital needs); and contractual provisions of the instrument (such as financial covenants and position in the capital structure). Aflac GI has a team of dedicated credit analysts, each responsible for monitoring developments in their assigned industry sectors and reviewing the universe of issuers of publicly-traded bonds, privately placed debt, loans, structured finance products, infrastructure debt, or other appropriate fixed income investments which are either owned currently or have the potential to be purchased by Aflac GI for its Clients. The credit analysts closely monitor developments that may affect an instrument’s fundamental credit quality. They work closely with our team of credit portfolio managers to assess how these developments impact client objectives for income, taxes, gains/losses, and other portfolio considerations including asset liability management, diversification, and liquidity. Portfolio managers and analysts also collaborate closely with our team of corporate bond traders to stay current on technical market factors, such as new bond issuance, secondary market supply and demand, and other market issues which may impact the relative attractiveness of a current or prospective security. Aflac GI continuously seeks ways to improve the risk and/or return profile of the Client portfolios, while incorporating changing market conditions, client objectives, or both. These opportunities may be captured through new investment activity or a repositioning of existing holdings through bond sales, purchasing and trading. Derivatives Aflac GI uses derivative instruments and hedging strategies for purposes defined in IMAs and other policies associated with certain Clients and portfolios. The derivative activities are primarily used to hedge foreign exchange and interest rate risk in the Client investment portfolios as well as manage foreign exchange risk for certain forecasted cash flows of Clients. Derivatives instruments include foreign currency forward contracts, foreign currency options, foreign currency swaps, interest rate swaps, interest rate swaptions, and other instruments as determined by Aflac GI from time to time and as permitted by each Client. Alternative Assets Aflac GI invests Client assets in alternative asset classes via investment funds which are engaged in private equity and associated investment strategies, primarily through the Fund described in Item 4 above. The investment objective of the Fund is to invest in a fund-of-funds program consisting of investment funds that invest in one or more alternative asset classes, including, but not limited to private equity investments, real estate investments, leveraged loan investments, mezzanine credit investments, hedge fund investments, private asset-backed securities and infrastructure investments.

Other Asset Classes Aflac GI offers advisory services related to other asset classes to its Clients primarily through external managers (“External Manager Platform”). Under the External Manager Platform, Aflac GI manages Client assets through the selection of third-party external managers or management companies to advise separately managed accounts established for Clients that invest in asset classes that include commercial mortgage loans, collateralized loan obligations, asset-backed and mortgage-backed securities, transitional real estate, real estate equity, private and public equity, middle market loans, infrastructure debt and other instruments as determined by Aflac GI from time to time and as permitted by each Client. Aflac GI is responsible for the management and oversight of these accounts and provides evaluation, selection, integration, due diligence and reporting for the external managers of traditional and alternative asset classes. Aflac GI could potentially invest in other asset classes on behalf of its Clients that are directly managed as permitted by client IMA guidelines. Summary of Risks The description below is an overview of the material risks associated with Aflac GI’s significant investment strategies and is not intended to be complete. All investing involves the risk of loss and the investment strategies offered by Aflac GI could lose money over short or long periods, including loss of principal. Moreover, performance could be negatively impacted by a number of different market risks, some of which are described below. Clients should refer to the governing documents for their account and/or any investment products in which they are invested through for additional information regarding the risks specific to such accounts, strategies or vehicles. A. General Risks Artificial Intelligence--Artificial intelligence technologies, including machine learning and generative artificial intelligence (collectively, “AI Technology”), their potential future applications, and the laws, regulations, and standards governing their use continue to rapidly evolve. As of the date of this brochure, we do not use AI Technology to make investment decisions or provide investment advice, and AI Technology does not influence the investment advice we provide. While we utilize quantitative models and algorithms as part of our investment process, these tools do not rely on AI Technology. However, we utilize AI Technology to support certain non‐ investment operational functions, such as data processing, subject to human oversight. In addition, we rely on third-party service providers who utilize AI Technology. Although we conduct diligence on such service providers, we do not control how third parties develop, deploy, or maintain AI Technology, which may give rise to operational, legal, or regulatory risks. Use of AI Technology could exacerbate existing, or create new and unpredictable, risks to us and Client accounts, including competitive, operational, reputational, legal, and regulatory risks. For example, disruptions in the complex software and hardware systems used by AI Technology could impair our ability to use that AI Technology, process data, generate reports, or perform operational tasks. Further, the models used by AI Technology, and/or the data sets on which those models are trained, could be flawed, function in an unexpected manner, or otherwise reduce these tools’ effectiveness. Additionally, malicious use of AI Technology could also result in harm to us, including reputational harm, enablement of fraudulent activity, generation of misinformation, and increased cybersecurity threats, such as generation of deep-fakes and enablement of long-term and persistent phishing attacks. We maintain a robust governance framework to evaluate risks associated with AI Technology. Despite these precautions, the novelty

and rapid evolution of AI Technology increases the likelihood of associated risks materializing. Further, it is not possible to predict the full nature or extent of current or future risks related to the use and development of AI Technology. Allocation of Client Assets—Where there is limited availability for a certain asset, Aflac GI may not always be able to allocate such assets to all eligible Client accounts. In such instances, Aflac GI will allocate investment opportunities in accordance with its allocation procedures which are designed to be fair and equitable over time and under the particular circumstances. In addition, Aflac GI may not be able to allocate a particular asset to a Client due to conflicts of interest or other restrictions which may adversely affect the value of Client assets. Bankruptcy Risk—A company in which Client assets are invested may become involved in a bankruptcy or other reorganization or liquidation proceeding. Bankruptcy may result in, among other things, a substantial reduction in the interest rate and a substantial write down of the principal of the Client’s investment. Board Participation and/or Creditors’ Committees— Aflac GI may be restricted in its investment activities if employees have representation on the board of directors and/or creditors’ committees of companies, and the fiduciary duties owed to these companies and committees may conflict with the interests of Client assets. Cash Management Risk— From time to time Aflac GI will use money market funds, cash deposits and other cash equivalents to hold uninvested funds in Client accounts. Client assets may be held in cash and cash equivalents for an indefinite period of time when Aflac GI determines that the prevailing market environment, anticipated investment opportunities or other factors warrant doing so. As a result, the Client may receive lower returns than if the Client had been fully invested in the market and the cash and cash equivalents may generate minimal or no income which could negatively impact the Client’s return on assets and ability to achieve its investment objective. Counterparty Risk—Aflac GI may transact with a counterparty that is unable to perform their contractual and/or economic obligations. In addition, centralized clearing of certain OTC derivatives exposes Clients to the risk of a default by a clearing member or clearing house with respect to its cleared derivative transactions. As such, these events could have a material adverse effect on Clients’ assets and return on investments. Currency Risks—Client assets may be invested in investments denominated in currencies other than the currency in which the Client is domiciled. Fluctuations in exchange rates may adversely affect the currency in which the investment is denominated. Cybersecurity—The information and technology systems of Aflac GI and of third party service providers to Aflac GI and its Clients are vulnerable to cybersecurity and systems-related risk, including but not limited to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors or phishing by or of their respective professionals, power outages, and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Although Aflac GI and Aflac Incorporated have implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, it may be necessary for Aflac GI to make a significant investment to fix or replace them and to seek to remedy the effect of these issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the operations of Aflac

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As outlined in Item 4 – Advisory Business above, Aflac GI generally provides investment advice to its parent company, Insurance Company Clients and pooled investment vehicles in which Insurance Company Clients invest. Aflac GI does not currently provide advisory services to unaffiliated institutional investors. Further, Aflac GI does not currently, and does not have any expectation that it will in the future, provide advisory services to retail investors. While Aflac GI does not have any specific requirements for opening or maintaining an advisory account (other than “know your customer” or other applicable regulatory eligibility requirements), Aflac GI generally only offers investment advisory services to institutional investors as described above.

Aflac GI does not charge performance-based fees (i.e., incentive allocations or carried interest). However, certain Clients are invested in third-party funds or have accounts managed by third-party managers. Such third-party managers charge a separate layer of fees and expenses, including performance-based fees, which will be borne by Clients, where applicable.

As noted in Item 4, Aflac GI is a direct, wholly-owned subsidiary of Aflac Incorporated. Aflac GI is also affiliated with, and serves as investment manager or a sub-adviser to a number of affiliated insurance companies as well as certain investment vehicles in which some of the affiliated insurance companies invest. The Clients consist of Aflac Incorporated, direct and indirect subsidiaries of Aflac Incorporated, and investment vehicles including the Fund in which the only investors are direct and indirect subsidiaries of Aflac Incorporated. In certain instances, Aflac GI will recommend Clients invest in a private fund or other products that we or an affiliate sponsor, advise or otherwise provide services to. In such instances, the Client will generally pay two layers of fees, including underlying fees and expenses associated with the product, in addition to advisory fees charged by Aflac GI. Aflac GI has a conflict of interest to recommend that Clients invest in affiliated products, as Aflac GI and/or its affiliates will receive additional compensation in connection with such investments than if the Client invested in an unaffiliated product. Aflac GI addresses such conflicts of interests through disclosure and by adopting policies and procedures to ensure that any investment recommendation made to a Client is in accordance with its fiduciary duty. Further, in certain instances, Aflac GI will waive its advisory fee in connection with a Client’s investment in an affiliated product. Aflac GI Holdings LLC owns a minority interest in Sound Point Commercial Real Estate Finance LLC (“SPCREF”), a registered investment adviser focused on commercial real estate investments, mortgage backed securities and other investments. SPCREF’s clients include certain affiliates and clients of Aflac GI. Aflac GI also has certain representatives that serve on SPCREF’s advisory board. Aflac GI has selected Sound Point Capital Management, L.P., the principal owner of SPCREF, to manage certain instruments on behalf of Clients and also recommends programs administered by Sound Point Capital Management, L.P. and SPCREF to Clients. As a result, Aflac GI Holdings LLC receives a financial benefit, including a share of the management fees Clients pay to SPCREF and any carried interest that may accrue. Additionally, certain Aflac GI clients holding real estate equity acquired through their mortgage programs enter into operating agreements for the special-purpose entities that hold real estate assets with SPCREF or a third party, which operating agreements set out that such SPCREF or third party will be responsible for the day-today management of the acquired real estate assets. Additionally, property managers can subcontract their obligations under the property management agreements to third party property managers or servicers. Subject to the terms of the specific written property management agreement and (in addition to the payment of assetrelated expenses of the portfolio property) the client will typically pay a property management fee payable monthly in advance, development fees, leasing fees, and construction management fees equal to a percentage of the cost of any interior and exterior construction, renovation, or repair of a portfolio property (other than ordinary maintenance and repairs). Aflac GI Holdings LLC owns a minority interest in Denham Sustainable Infra Management LP (“DSIM”), a registered investment adviser. DSIM’s clients include certain affiliates and clients of Aflac GI. Aflac GI also has certain representatives that serve on DSIM’s board. As a result, Aflac GI Holdings LLC receives a financial benefit, including a share of the management fees Clients of Aflac GI pay to DSIM and any carried interest that may accrue. 15 | P a g e

Aflac GI Holdings LLC owns a minority interest in Tree Line Capital Partners, LLC (“TLCP”), a registered investment adviser, and an indirect minority interest in Tree Line Capital Markets, LLC, a registered brokerdealer. TLCP’s clients include certain affiliates and clients of Aflac GI. Aflac GI also has certain representatives that serve on TLCP’s board. As a result, Aflac GI Holdings LLC receives a financial benefit, including a share of the management fees Clients of Aflac GI pay to TLCP and any carried interest that may accrue. From time-to-time Aflac GI Holdings LLC may acquire equity stakes in registered investment advisers which Aflac GI may select to manage investments on behalf of its Clients. In these circumstances, Aflac GI Holdings LLC may receive a financial benefit through its equity ownership. Aflac GI is not aware of all the relationships and dealings of SPCREF, DSIM, TLCP and/or their affiliates within the financial services sector or otherwise. As a result, Aflac GI is not aware of and therefore could not mitigate potential conflicts of interest that could arise in connection with the business of SPCREF, DSIM, TLCP or their affiliates. For example, clients of Aflac GI could be limited partners in the private funds of private equity sponsors to the portfolio companies of which DSIM, TLCP, or SPCREF provides financing. Similarly, affiliates of Aflac could provide insurance products to portfolio companies in which SPCREF, TLCP, or DSIM Clients invest. As described above, Aflac GI is affiliated with the following insurance companies that are admitted insurers in all 50 states, the District of Columbia, and several U.S. territories: Aflac Columbus, Aflac NY, CAIC and TOIC. Aflac GI is also affiliated with ALIJ, an insurance company incorporated in Japan, and Aflac Re Bermuda Ltd., a reinsurance company incorporated in Bermuda. Aflac GI has a sub-advisory agreement with AAMJ to assist AAMJ in providing asset management services to ALIJ. Aflac GI also has advisory agreements with sub-trusts of the Global Alternatives Trust I, i.e. the Fund, the Global Alternatives Fund SPC and its segregated portfolios. As part of its overall investment advisory arrangement with Aflac Columbus and AAMJ (as sub-adviser to ALIJ), Aflac GI provides advice with respect to investment in the Fund. Aflac GI has material business relationships with all of its Clients. Often personnel from Aflac GI and its Clients work together to manage Client portfolios and provide related services, including client liaison, investment monitoring, and account administration. Moreover, some of Aflac GI’s officers and all of its board members serve in a dual capacity as officers and/or board members of Aflac GI as well as officers and/or employees of Aflac Incorporated and/or one or more of its affiliates. These persons are shared with and provide services to Aflac GI under a service agreement with Aflac Incorporated (which has a services agreement with one or more affiliated companies). These persons are subject to the control of Aflac or its affiliates and might take actions that are different from the actions that individuals who are not employed by Aflac or its affiliates would take. Additionally, some Aflac GI employees serve on investment or other business committees of one or more of Aflac GI’s affiliates. Where Aflac GI employees have investment decision making authority for both Aflac GI and the Aflac GI affiliate, this creates actual and potential conflicts of interest, including but not limited to, a division of time and attention away from Aflac GI and its clients, as well as with regard to allocation of investment opportunities. Aflac GI has 16 | P a g e

implemented procedures to address actual and potential conflicts of interest that arise as a result of these situations. When Aflac GI’s investment professionals are performing work for more than one Aflac GI Client, the investment professional has an incentive to favor accounts that have larger assets under management than other accounts. Although this does not impact individual compensation, in such instances, the investment professional has an incentive to favor these accounts over others. However, all Aflac GI investment professionals are required to follow procedures for dealing with conflicts found in Aflac GI’s Code (see definition in Item 11 below) and the various policies that make up Aflac GI’s Compliance Manual (the “Compliance Manual”), which include Trade Allocation, Best Execution and Conflicts of Interest Policies. The Code and Compliance Manual require investment professionals to address all conflicts of interest.

Personal Trading Pursuant to Rule 204A-1 of the Advisers Act, Aflac GI has adopted a written Code of Ethics (the “Code”). The Code is designed to address and avoid potential conflicts of interest and is applicable to all officers, directors, members, partners or employees of Aflac GI and certain additional personnel of Aflac who support Aflac GI (the “Employees”), and is available to Clients and prospective clients upon request. The Code is also designed to prevent and detect personal trading activities that may interfere or be in conflict with Client interests. Aflac GI’s Code includes requirements intended to ensure that Aflac GI complies with the Investment Advisers Act of 1940. The Code requires that our Employees adhere to the highest ethical standards and comply with applicable federal securities laws. Aflac GI distributes the Code to each employee and each employee is required to acknowledge receipt of the Code. The Compliance Team performs ongoing reviews of the Code, including monitoring of employee trading to ensure employees do not engage in improper transactions, and documents any violations. Aflac GI Employees may, from time to time, acquire or sell securities for their personal accounts that are also purchased, sold or held for the account of Clients. In addition, at times Employees may trade in a security at or around the same time as a Client. While this creates a conflict of interest, Aflac GI has policies and procedures in place to ensure that Employees always act in the Clients’ best interest, and Employees are not receiving better treatment with respect to their investments than Clients. The Code generally requires that all transactions in securities by Aflac GI Access Persons (as each term is defined in the Code) be cleared prior to execution through processes administered by the Compliance Team. Personal securities transactions also are subject to quarterly reporting requirements, annual certification requirements and related compliance obligations. Employees are also required to report to the Chief Compliance Officer (“CCO”) any violations of the Code that come to their attention. Among other things, the Code requires Aflac GI and its Employees to act in clients’ best interests, abide by all applicable regulations, avoid even the appearance of insider trading, and preclear and report on certain types of personal securities transactions. Employees are generally not permitted to trade alongside Client accounts. Aflac GI’s restrictions on personal securities trading apply to Employees, as well as Employees’ family members living in the same household. The Code of Ethics also covers matters such as outside business activities, gifts and entertainment, and political contributions.

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Aflac GI endeavors to execute trades in such a manner that the total costs or proceeds in each transaction are the most favorable under the circumstances. When selecting or recommending a broker-dealer, Aflac GI will consider a number of factors, ranging from price, speed and size to other elements such as funding terms and haircuts, counterparty risk, confidentiality of the broker, the promptness of execution of securities transactions, the clearance and settlement capabilities of the broker-dealer and the financial stability of the broker-dealer. The level of complexity across these factors can vary considerably based on the market structure and the assets being traded. Aflac GI's Best Execution Policy describes the requirements for choosing a broker, and all new brokers must be approved by the Trade Practices Committee. Aflac GI's Compliance Team maintains an approved list of broker-dealers and all trades must be executed by these approved broker-dealers. The officer responsible for each asset class is responsible for the approved list of broker-dealers for the asset class and all additions to or deletions from this list are approved by the Trade Practices Committee, based upon a review of the brokerdealer’s ability to meet Aflac GI's requirements to seek to provide best execution for Client accounts. Directed Brokerage Occasionally, transactions are directed to a particular broker or dealer when market conditions indicate that this method is likely to produce better net prices. With regard to certain private fund clients, most investments made by such funds involve private securities that are not traded or sold through a broker-dealer. From time to time a portfolio company in such a fund later could seek to raise capital through a public offering of its common stock. If Aflac GI elects to liquidate a fund's interest in the portfolio company in the public offering, it could be required to do so through the underwriter of the offering or a broker-dealer specified by the underwriter or the equity sponsor. In that case, Aflac GI will be limited in its ability to select a broker-dealer to effect the transaction. In addition, Aflac GI might be unable to negotiate the commissions on such trades, and the fund could pay a higher commission than it would if Aflac GI was free to select the executing broker. Soft Dollars Aflac GI does not pay higher broker commissions in order to receive research or other products or services from brokers-dealers or other parties. In other words, Aflac GI does not make soft-dollar payments to brokerdealers. Nevertheless, Aflac GI has a Soft Dollar Policy in place in the event that it engages in soft dollars in the future. In the ordinary course of business, certain broker-dealers provide Aflac GI with research or analytical data, which they make available to a broad array of potential investors. Such data is not taken into consideration by Aflac GI in selecting broker-dealers. Aflac GI believes that any such data would be made available to Aflac GI regardless of whether or not trades are placed through a given broker-dealer. Aggregation and Allocation Aflac GI will aggregate the purchase or sale of securities for various client accounts if it is believed to be in the best interest of its Clients and consistent with Aflac GI’s duty to seek best execution. 18 | P a g e

The Trade Allocation Policy governs the allocation process and requires that the allocation process must treat everyone fairly over time, which is generally accomplished through pro rata allocation or a rotational basis, subject to factors such as IMA guidelines, client eligibility and other considerations. To the extent possible, orders are pre-allocated prior to execution. However, there may be instances where pre-allocating certain trades is not feasible or practicable given the unique nature of the respective market. In addition, in instances where there is limited capacity for a particular investment, it may not be possible or practical to allocate an investment pro-rata across all eligible client accounts. In these instances, not all clients that are eligible to participate in a particular investment will receive an allocation. Aflac GI will make such allocation determinations in accordance with its policies and procedures, which are designed to allocate in a fair and equitable manner over time and in light of the particular circumstances.

Aflac GI does not directly or indirectly compensate any third-party for client referrals. Additionally, Aflac GI does not engage placement agents to introduce new investors that commit capital to the Fund.

There are no legal or disciplinary events that are material to Aflac GI’s advisory business or a Client’s or prospective client’s evaluation of Aflac GI’s business or the integrity of its management.

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Aflac GI furnishes investment advice to several affiliated Clients. Aflac GI’s officers and investment personnel who conduct portfolio transactions on behalf of these affiliated Clients periodically review the accounts to monitor performance and compliance with applicable investment objectives, Client guidelines and restrictions and regulatory requirements. Other than as described above, the Client portfolios are generally reviewed on a daily basis by Aflac GI. Reviews of Client accounts will also be triggered if a Client changes its investment objectives, or if the market, political, or economic environment changes materially. If an irregularity is noticed in the normal course of business, the CCO/Compliance Team will conduct a review in addition to the regularly scheduled reviews.

While Aflac GI is not generally deemed to have custody of Client funds and securities, Aflac GI has implemented controls to ensure the safekeeping of all assets it manages on behalf of its Clients. Such controls include the maintenance of such assets with a third-party qualified custodian (“Custodian”) which has implemented procedures to make information available to the account owners.

Aflac GI has investment discretion over Client accounts. Clients may impose restrictions on this discretion by, among other things, prohibiting the purchase of specific securities, or prohibiting the purchase of securities within a specific industry. The parameters of the discretionary authority given to Aflac GI, and any Clientimposed restrictions, are detailed in the Client’s IMA. Additionally, Aflac GI manages some Client accounts on a non-discretionary basis.

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Aflac GI has adopted and implemented written policies and procedures governing the voting of client securities, a copy of which is available to Clients upon request. Aflac GI generally seeks to vote proxies in the best interests of all of its Clients for whom it has proxy voting authority and responsibilities. Where a client elects to have Aflac GI vote proxies, such elections are shaped by the individual agreement between Aflac GI and each Client. Aflac GI does not currently manage a program of publicly-traded equities and therefore does not generally have responsibility for voting proxies with respect to publicly-traded equity securities. From time to time, however, Aflac GI may purchase or come into possession of some listed equities. In the event a proxy is received, either physically or electronically, by Aflac GI for the benefit of its Clients, Aflac GI delegates the responsibility for voting such proxy (i.e., full discretion over the proxy voting execution function) to the respective external manager. If there is a proxy for an investment that is directly managed by Aflac GI, Aflac GI has adopted certain guidelines for voting proxies but may deviate from these guidelines when it determines that the particular facts and circumstances warrant such a deviation to protect the best interests of our Clients. If Aflac GI’s CCO identifies any potential conflict of interest with regard to a proxy vote between Aflac GI and one or more of our Clients, the CCO may convene an ad-hoc committee (“Conflicts Committee”) to debate the conflict and to give a ruling on a preferred course of action. If the Conflicts Committee determines that Aflac GI has a conflict of interest in any instance, the Conflicts Committee shall provide voting instructions. Aflac GI may cause the proxies to be voted in accordance with the recommendations of a third-party proxy advisory firm that Aflac GI may use to assist in voting proxies. For private equity investments managed by Aflac GI, consisting primarily of investments in private funds, Aflac GI exercises voting and consent rights relating to amendments to limited partnership agreements and other fund agreements. Aflac GI will evaluate the necessity to participate in shareholder class action litigation and similar matters. Aflac GI will not participate in class action litigation unless Aflac GI has the authority to act on behalf of Clients, determines it would be in the best interest of its Clients and uses a third party to assist in identifying and processing class action litigation. This third party is compensated on a contingency basis whereby they will receive a percent of any recovery obtained. The Clients/Fund will bear the cost, (i.e., receive a reduced amount of any class action proceeds), if any such third party is used for class action recovery services. Aflac GI credits any class action settlements received for a Client/Fund to that Client/Fund at time of receipt. All requests for proxy voting information and voting records, including Aflac GI’s Proxy Voting and Class Actions Policy, should be directed to, Jeffrey Haywood, CCO, at (212) 510-4600 or GIComplianceUS@aflac.com. Upon receiving a Client request, the CCO will forward a copy of the Client’s quarterly voting statement. The CCO maintains copies of all Client requests and of the information that was forwarded to the Client.

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Aflac GI is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to Clients, and has never been the subject of a bankruptcy petition at any time during the past ten years.

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