AMERICAN CENTURY INVESTMENT MANAGEMENT INC

American Century Investments is an independent, privately-controlled asset management firm dedicated to delivering superior investment performance and building long-term client relationships. The firm was founded by James E. Stowers, Jr. in 1958. Nearly all of our revenue is derived from investment management related activities. Ownership American Century Investments is a wholly-owned subsidiary of American Century Companies, Inc. (“ACC”). ACC has a multi class capital structure under which certain classes have different voting rights. Accordingly, as of December 31, 2025, ACC’s owners were as follows: Shareholder

Equity Interest

Voting Interest

Stowers Institute for Medical Research*

43%

67%

Nomura Holdings, Inc.**

41%

10%

Current Employees and Others

16%

23%

* Includes shares held by Stowers Resource Management Inc and Stowers Policy Institute. ** Shares are directly owned by Nomura AM Holdings USA, LLC, an indirect subsidiary of Nomura Holdings, Inc.

Stowers Resource Management Inc. (“SRM”) is a “supporting organization” (as that term is defined in the Internal Revenue Code), and as such, a public charity. Its primary function as a legal entity is to support the Stowers Institute for Medical Research (“SIMR”). Jim and Virginia Stowers founded SIMR in 1994 as a not-for-profit institute dedicated to benefiting humankind through basic research on genes and proteins that control fundamental processes in living cells to unlock the mysteries of disease (including cancer) and find the keys to their causes, treatment, and prevention. It is one of the largest endowments in the world among private basic biomedical research institutions. Through its ownership interest, SRM is entitled to over forty percent of all dividends paid by ACC. All active, eligible employees of ACC and its subsidiaries participate in ownership of the firm through the American Century Retirement Plan. Since May 19, 2016, Nomura Holdings, Inc. (“Nomura”) has held a minority interest in ACC and holds two of eleven seats on ACC’s board of directors. From investment management and general business perspectives, however, ACC and Nomura are legally and operationally independent and distinct. Our Advisory Services American Century Investments manages client portfolios based on various investment strategies within the following disciplines: Disciplined Equity, Global Growth Equity (both U.S. and Global/Non-U.S.), Global Value Equity, Global Fixed Income, Multi-Asset Strategies, Page | 4

American Century Rules-Based ETF strategies, Avantis Investors strategies, and funds and private investment funds managed by American Century Investments’ private investments team (the “American Century Private Investments Team” and such strategy/discipline, “American Century Private Investments”). American Century Investments may also provide supervisory services, such as glide path

management, asset allocation model investment portfolios or similar services. Asset allocation model portfolios generally only include American Century Investments funds or have a very significant percentage of the portfolio allocated to American Century Investments funds. These models may be provided to affiliated or unaffiliated investment advisers or financial professionals who retain discretion on behalf of their clients to implement, modify, or not implement the model portfolio we provide to them. The models are not personalized for the clients of any adviser or financial professional. In certain cases, American Century Investments may use an optimization tool to evaluate a portfolio and make recommendations with respect to asset classes included within the portfolio. Such evaluations are performed by American Century Investments utilizing inputs and data provided by the relevant financial professional. These "optimizer" model portfolios may include, but are not limited to, American Century Investments funds. The output of the optimization tool will change based on inputs provided by the relevant financial professional and results will vary over time. Whether the model portfolio is acted upon is entirely up to the adviser or other financial professional receiving the model. American Century Investments does not monitor or manage any investments made or accounts opened by clients that utilize model investment portfolios, whether those accounts are with American Century Investments, its affiliates or elsewhere. In addition, American Century Investments provides discretionary and nondiscretionary investment advice through managed account (“Traditional SMA”) or model portfolio (“Model Portfolio”) programs (collectively, Traditional SMA and Model Portfolio programs are referred to as “Managed Accounts”) for financial institution sponsors (each a “Sponsor”) and other institutional clients (“Advisory Clients”). Traditional SMA relationships may include single contract SMA programs, where American Century Investments has an advisory agreement with the Sponsor under which we manage the client’s assets in an approved strategy, and dual contract SMA programs, where American Century Investments enters into an advisory agreement directly with the end client. Managed Account portfolios are generally representative

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of an existing American Century Investments strategy that has been optimized for the Managed Account vehicle and not a replication of another fund or portfolio utilizing a similar strategy. As of December 31, 2025, American Century Investments had approximately $306,453,457,000 in total assets under supervision. 1 Of this amount, American Century Investments managed approximately $305,995,891,000 of client assets on a discretionary basis and managed approximately $457,566,000 of client assets on a non-discretionary basis.

Fees Paid by American Century Registered Investment Companies American Century Investments serves as the investment adviser for the American Century family of mutual funds and ETFs (referred to as American Century Investments funds). Each American Century Investments fund represents a series of shares issued by one of the following companies: American Century Mutual Funds, Inc., American Century World Mutual Funds, Inc., American Century Growth Funds, Inc., American Century Capital Portfolios, Inc., American Century Strategic Asset Allocations, Inc., American Century California Tax-Free and Municipal Funds, American Century Municipal Trust, American Century Government Income Trust, American Century Investment Trust, American Century Quantitative Equity Funds, Inc., American Century International Bond Funds, American Century Asset Allocation Portfolios, Inc. and American Century ETF Trust. We manage these funds in accordance with the investment objectives and policies as set forth in their respective registration statements filed with the SEC, and in accordance with the terms and conditions of the investment management agreement between us and each of the issuers of the funds. Pursuant to the investment management agreements, we are responsible for managing the investment portfolios of each American Century Investments fund and, unless the investment portfolio is managed by one or more sub-advisers, directing the purchase and sale of its investment securities. If we engage one or more sub-advisers to manage all or a portion of an investment portfolio, we are also responsible for overseeing the performance of such subadvisers. The management agreements may be terminated by either party upon sixty days' notice. For the services we provide to the American Century Investments funds, American Century Investments receives a unified management fee based on a percentage of the daily net assets American Century Investments’ regulatory assets under management are approximately $305,966,952,000. Regulatory assets under management reflect those accounts where American Century provides continuous and regular supervisory services and excludes certain accounts, such as model delivery accounts, where American Century does not have discretionary authority and does not arrange for effecting purchases and/or sales of the securities in such account.

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of each class of shares of the fund. The amount of the fee is accrued daily and deducted from fund assets monthly in arrears. Out of that fee, we pay all expenses of managing and operating the American Century Investments mutual funds (such as sub-advisory fees and custodial fees), except brokerage expenses, expenses on securities sold short, taxes, interest, fees and expenses of the independent directors (including legal counsel fees), portfolio insurance, extraordinary expenses and expenses incurred in connection with the provision of shareholder services and distribution services under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (the “Investment Company Act”). For American Century Investments ETFs and Avantis Investors mutual funds and ETFs, we pay all expenses of managing and operating the ETFs, other than the management fee, brokerage and other transaction fees and expenses relating to the acquisition and disposition of portfolio securities, acquired fund fees and expenses, interest, taxes, the fees and expenses of the independent trustees (including counsel fees), litigation expenses, extraordinary expenses, and expenses incurred in connection with the provision of shareholder and distribution services under a plan adopted pursuant to Rule 12b-1 under the Investment Company Act (if any). Basic Fee Schedule. The management agreements between American Century Investments and the funds provide that each fund, in exchange for the investment advisory services we provide, will pay us an annual management fee. The amount of the fee is based on a percentage of the net assets of the fund and is calculated daily and paid monthly in arrears. American Century Investments manages funds that utilize both flat and stepped fee schedules. Flat fee schedules do not include breakpoints, while stepped fee schedules apply breakpoints at specified asset levels, which, when reached, reduce the applicable management fee.

American Century Investments Funds with a Stepped Fee Schedule. For each American Century Investments fund with a stepped fee schedule, the rate of the management fee is determined by applying the formula indicated in the fund’s prospectus. In some cases, this formula takes into account the assets of the fund, as well as certain assets, if any, of our other clients of the advisor outside the American Century Investments fund family (such as funds we sub-advise and separate accounts), as well as exchange-traded funds managed by the advisor that use very similar investment teams and strategies (strategy assets). The use of strategy assets, rather than fund assets alone, in calculating a fund’s fee rate could allow the fund to realize scheduled cost savings more quickly. However, it is possible that a fund’s strategy assets will not include assets of other client accounts or that any such assets may not be sufficient to result in a lower fee rate.

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For certain other American Century Investments funds, the annual rate at which our management fee is assessed is determined daily in a two-step process. First, the assets of certain accounts within the same broad investment category are included in the pool of assets used to determine a category rate (the “Investment Category Fee”). For example, when calculating our management fee for a money market fund, the assets of all money market funds that we manage are aggregated to determine the Investment Category Fee. Currently, American Century Investments funds fall within one of the following three investment categories: money market funds, bond funds and certain equity funds. Second, the assets of all mutual funds managed by American Century Investments and distributed by American Century Investment Services, Inc. are aggregated to determine a separate rate referred to as the "Complex Fee." The Investment Category Fee and the Complex Fee are then combined to determine a fund-level fee rate. The use of Complex Fee and Investment Category Fee schedules in calculating the fund-level fee rate for a particular fund could allow that fund to realize scheduled cost savings more quickly if we acquire additional assets under management (in addition to the fund's assets) within a Complex Category and Investment Category. Fees Paid by Private Investment Funds The fees applicable to the private investment funds are described in such fund’s limited partnership agreement, operating agreement and/or other offering documents, including any offering memoranda (together, the “Fund Documents”). Investors in the private investment funds are generally charged an annual management fee, paid quarterly in advance, ranging from 0-2%, which may be based on a percentage of capital commitments, invested capital or otherwise as described in the applicable Fund Documents. Additionally, American Century Investments and its affiliates have the potential to earn performance-based compensation with respect to the private investment funds in the form of carried interest distributions. The amount, as well as the manner of calculation and application of the management fees and carried interest allocations are disclosed in the applicable Fund Documents. Certain investors of the private investment funds may negotiate different or lower management fees or carried interest distributions on a case-by-case basis. The carried interest will fully comply with Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Private Investment Fund Expenses. Generally, each private investment fund is responsible for its organizational and operating expenses in accordance with such private investment fund’s Fund Documents. Fees by Type of Client The prospectus of each American Century Investments fund and Fund Documents for each private investment fund sets forth the applicable fees and expenses.

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The management fees for our advisory services are negotiable, and, except for investors in the private investment funds as noted above, no fees are paid by clients in advance. Our fee for providing advisory services to separate account clients (which includes pension, profit sharing and other retirement plans, charitable institutions, endowment funds and foundations, state and municipal government entities, sovereign funds, and other U.S. and foreign institutions), as well as discretionary and nondiscretionary advisory services to Managed Account clients ranges, from 0.10% to 0.95% of the net asset value of assets under management for equity portfolios and may be calculated on the basis of average daily value of the portfolio or the average of the month end balances of the applicable period or based on the quarter end balance (depending upon the terms of the management agreement). These fees generally are billed to the client quarterly in arrears (unless the terms of the management agreement provide otherwise) and are negotiable. Fees for Managed Accounts provided to Sponsors are paid to American Century Investments by each Sponsor from the single fee a client pays to the Sponsor. Fees for Managed Accounts provided to Advisory Clients may be based on a percentage of assets under advisement or may be a fixed amount. These fees generally are billed and paid quarterly in arrears (unless the terms of the management agreement provide otherwise) and are negotiable. Our fee charged for providing advisory services to group trusts ranges from 0.135% to 0.76% of the net asset value of the group trust, depending upon the investment objective of the group trust. The client has the option of either having these fees deducted from the client’s assets quarterly in arrears or billed to the client quarterly in arrears. Our management fees for group trusts are negotiable. For asset allocation model portfolios, American Century Investments may or may not charge a fee for making the model available to Managed Account Sponsors, advisers, broker-dealers, turnkey asset management programs (TAMPs) or other financial intermediaries. Even if the model portfolio is provided without any direct fees, American Century does receive compensation indirectly by virtue of the management fees it receives for advisory services provided to the American Century Investments funds included in the model. This structure results in more revenue to American Century Investments and its affiliates than would result from an allocation to unaffiliated funds or products. Clients should consult their own independent professional advisor(s) to determine whether such arrangement is appropriate and in their continuing best interests. Details regarding the fees and expenses charged by any such American Century Investments funds, including the applicable management fee rate, are discussed above and are also disclosed in the prospectus for each such fund. American Century Investments fund prospectuses are available at americancentury.com at any time for any investor.

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American Century Investments also serves as the investment manager of non-U.S. funds or ETFs structured as Undertakings for Collective Investments in Transferable Securities (“UCITS”) and organized under the laws of Ireland. The UCITS funds employ a single fee structure with each fund paying a flat fee out of the assets of the relevant fund (the “total expense ratio” or “TER”). The TER is calculated and accrued on a daily basis and is deducted from the fund’s assets monthly in arrears at annual rates described in the UCITS prospectus and the applicable fund’s supplement. Where all of the costs and expenses of a fund or class of the UCITS are met and exceeded by the TER, we receive any excess from the TER as the investment management fee. Our fee for providing advisory services as a sub-adviser to mutual funds, UCITS and other pooled vehicles that are not American Century Investments funds ranges from 0.10% to 0.80% of the net asset value of the funds. These fees are calculated based upon the average daily value of the portfolio during the applicable period. The above fees are generally paid to us by the investment adviser of the fund monthly or quarterly in arrears (depending upon the terms of the fund’s management agreement) and are negotiable. No fees are payable in advance. With respect to certain investors in non-U.S. funds which American Century Investments acts as investment manager or sub-adviser, we may rebate all or a portion of our investment management fees and/or provide reimbursements relating to certain expense types or specified amounts of expenses. In addition to an asset-based fee, certain “qualified clients” (as such term is defined in Rule 205-3 under the Advisers Act) may be charged a negotiable performance-based fee. The performance-based fee is based on a portion of the capital gains or capital appreciation of a client's account, subject to certain conditions. The performance-based fee is authorized by the investment management agreement with the client and/or disclosed in portfolio disclosure documents. The fee is calculated by multiplying a certain, negotiated percentage by the amount, if any, by which the fund’s performance exceeds a set base rate. The fee is subject to a fee cap and is billed upon contract terms, either quarterly or annually based upon the cumulative performance of the fund. The performance-based fee will fully comply with Rule 205-3 under the Advisers Act.

Methods and Analysis American Century Investments employs a variety of methods of analysis and investment strategies in managing client assets. These methods of analysis and strategies are generally designed for strategic, long-term investing. The resulting investment returns are highly dependent on the value of the underlying securities and are impacted by trends in their respective investment markets. The methods of analysis that we use include: Fundamental research and analysis – This method uses qualitative and quantitative factors to determine the intrinsic value of a company or asset, an industry or sector and relate that to the current environment. At the security level, fundamental analysis is the evaluation of factors that can affect a security’s value, including company-specific factors (such as financial statements and company management) and/or macroeconomic factors (such as overall economy and industry conditions), with the goal of determining the intrinsic value of the asset given its future expectations and comparing that to the current price of the security. Quantitative factors are numeric, measurable characteristics used in evaluating the security. These can include data from income statements and balance sheets of a company, as well as other factors relating to the management of the asset. Qualitative factors include subjective judgment on non-

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quantifiable information, such as management skill, industry cycles, brand value and pricing power. These factors are less tangible and more subjective than quantitative factors. Quantitative research and analysis – This method seeks to understand behavior of a security by using complex mathematical and statistical modeling, measurement, and research. The application of this methodology utilizes computer-based models to disseminate financial data in order to make valid projections about the future performance of the company or asset. These models also determine the attractiveness of a security in relation to the overall portfolio and its investment objective. Technical analysis – This method analyzes statistics generated by market activity, such as security price and trading volume. These statistics are then charted to identify patterns that may be recurrent or predictable. Risk analysis – This method includes the identification and quantification of a variety of risk factors in order to adjust a portfolio to an appropriate risk level given its objective or to confirm that the risk factors are in line with the expectations of the portfolio managers. Associated risks. All of the above methods of analysis rely on, among other things, data used to predict the current or future value of an investment. Such data may be sourced from external sources. While the data and information we source is generally considered reliable, we cannot guarantee, nor have we verified, its accuracy. In addition, some of the data utilized is subjective and may be open to interpretation. Additionally, there is an element of human risk in that portfolio managers may not execute effectively on the portfolio’s stated investment strategy. Both quantitative and technical analysis rely more on the objective evaluation of data in driving investment decisions. These analyses may not take into account subjective elements about an investment, which may be relevant when determining the value of the investment. Investing in securities involves a risk of loss that each client should be prepared to bear. At any given time, it is possible to lose money by investing in a portfolio we manage.

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Investment Strategies Equity, Fixed Income and Multi-Asset Strategies – Generally Most client portfolios managed by American Century Investments pursue an investment strategy using an equity, fixed income or multi-asset approach. Information about these approaches and the risks associated with each is provided below. Despite the investment strategy pursued, all portfolios managed by American Century Investments are exposed to other risks as well. The value of our client portfolios depends on the value of the securities owned. The value of the individual securities held in a client’s portfolio will go up and down depending on the performance of the companies that issued them, general market and economic conditions, and investor confidence. When pursuing the investment strategies for our clients’ portfolios, we assume that the financial markets will go up over the long-term, which may not be the case. Additionally, there is a risk that the segment of the market in which a portfolio is invested will not perform in line with the overall financial markets. Our portfolio managers do not attempt to time the market. Instead, under normal market conditions, they intend to keep the portfolios generally fully invested regardless of the movement of prices. All portfolios are also exposed to investment strategy risk. Market performance tends to be cyclical, and, in the various cycles, certain investment styles may fall in and out of favor. If the market is not favoring the investment strategy used by a particular equity portfolio, the portfolio’s gains may not be as big as, or its losses may be bigger than, those of other equity portfolios using a different investment strategy. The performance of some portfolios is tied more closely to the performance of a benchmark. As such, if a portfolio’s benchmark performance goes down, it is likely that the portfolio’s performance will also go down. Some portfolios we manage are diversified while others are non-diversified. A non-diversified portfolio may invest a greater percentage of its assets in a smaller number of securities than a diversified portfolio. This gives the portfolio managers the flexibility to hold larger positions in a smaller number of securities. If so, a price change in any one of those securities may have greater impact on the portfolio’s share price than would be the case in a diversified portfolio. A portfolio’s value may fluctuate significantly in the short term. The following sections provide a summary of the principal risks associated with investments in each of the approaches we use. This is a summary only. You should review the respective investment management agreement, as well as any applicable offering memorandum or risk disclosures. For a mutual fund or exchange traded fund, you should review the applicable Page | 14

Prospectus and Statement of Additional Information; and for a private investment fund, the applicable Fund Documents. Equity Portfolios Overview. We offer and manage a broad range of equity investment strategies. These strategies can be specific to an investment style, including growth, core, and value, or may be designed to be “style-neutral.” Some strategies focus on specific capitalization ranges, such as large cap, mid cap, or small cap, while others may invest in more than one capitalization category or across all capitalization levels. In addition, we manage strategies that are global/multinational or may be focused on particular geographic regions or a specific country. We manage diversified strategies which invest across industry sectors, as well as strategies that concentrate on specific industry sectors. Our equity strategies may be based on fundamental research and analysis or may instead rely primarily on quantitative tools and techniques or technical analytical methods and strategies. We may utilize strategies that take both long and short positions in equities, issued by companies across all market capitalizations, based on whether we believe a security is likely to increase or decrease in value, respectively. Principal Risks. Market performance tends to be cyclical and, in the various cycles, certain investment styles (growth, core, value, fundamental, quantitative) may fall in and out of favor. If the market is not favoring the specific style used and/or the securities within the portfolio’s benchmark, the portfolio’s gains may not be as big as, or its losses may be bigger than, other equity portfolios using different investment styles. For strategies that favor a growth style, growth stocks are typically priced higher than other stocks in relation to earnings and other measures, because investors believe they have more growth potential. This potential may or may not be realized. If the portfolio managers’ assessment of a company’s prospects for earnings growth or how other investors will value the company’s earnings growth is incorrect, the price of the company’s stock may fall or fail to reach the value the portfolio managers have placed on it. Growth stock prices tend to fluctuate more dramatically than the overall stock market. For strategies that favor a value style, if the market does not consider the individual stocks purchased by a value portfolio to be undervalued, the value of the securities it holds may not rise as high as other portfolios and may in fact decline, even if stock prices generally are increasing. Because certain portfolios may be more heavily invested in companies of a certain size, while others are multi-capitalization portfolios that invest in companies of all sizes, each portfolio is exposed to a degree of capitalization risk. Small- and medium-sized companies may present greater opportunities for capital growth than larger companies, but may be more volatile and subject to greater risk. Smaller companies may have limited financial resources, product lines Page | 15

and markets, and their securities may trade less frequently and in more limited volumes than the securities of larger companies. In addition, smaller companies may have less publicly available information. The portfolio managers may buy a large amount of a company’s stock quickly and may dispose of it quickly. While the portfolio managers believe this strategy provides substantial appreciation potential over the long term, in the short term it can create a significant amount of share price volatility. This volatility can be greater than that of the average stock portfolio. Investing in a particular geographic region or country has certain unique risks. These risks include increased exposure to political, social, and economic events in world markets; limited availability of public information about a company; less-developed trading markets and regulatory practices; and a lack of uniform financial reporting practices. Securities of issuers in certain regions or countries may be less liquid, more volatile, and harder to value. Investing in securities of companies located in emerging market countries generally is also riskier than investing in securities of companies located in developed countries. Emerging market countries may have unstable governments and/or economies that are subject to sudden change. These changes may be magnified by the countries’ emergent financial markets, resulting in significant volatility to investments in these countries. These countries also may lack the legal, business, and social framework to support securities markets. Additionally, U.S. law requires that Public Company Accounting Oversight Board (“PCAOB”) registered accounting firms, which prepare or issue audit opinions for U.S.-listed issuers, submit to PCAOB inspections and produce audit work papers. This requirement applies to audit opinions for all U.S.-listed issuers, regardless of the domicile of the issuer. Certain jurisdictions do not provide the PCAOB with sufficient access to inspect audit work papers and practices, or otherwise do not cooperate with U.S. regulators. This lack of access and cooperation potentially exposes investors in U.S. capital markets to significant risks of capital loss and limits the rights and remedies available to funds and shareholders. In addition, investments in foreign countries are subject to currency risk, meaning that, because a strategy’s investments are generally denominated in foreign currencies, the strategy could experience gains or losses based solely on changes in the exchange rate between foreign currencies and the base currency of the strategy. If the market price of a security increases after a security is borrowed and sold short, the portfolio will suffer a loss when it replaces the borrowed security at the higher price. Any loss will be increased by the amount of compensation, interest or dividends, and transaction costs paid to a lender of the security. Stocks selected by the portfolio managers using quantitative models may perform differently than expected due to the portfolio managers' judgments regarding the factors used in the Page | 16

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American Century Investments provides portfolio management services to the following types of clients: SEC-registered mutual funds, exchange traded funds (ETFs), pension, profit sharing and other retirement plans, charitable institutions, foundations, endowment funds, state and municipal government entities, pooled investment vehicles (including non-U.S. funds such as UCITS and Australia unit trusts registered as managed investment schemes), commingled investment trusts, Managed Accounts, private investment funds, trust programs, sovereignwealth funds, Japanese investment trusts, insurance companies, central banks, financial institutions (including registered investment advisers) and other U.S. and non-U.S. institutions. Each type of client or vehicle will generally be representative of an investment strategy managed by American Century Investments that has been optimized for that client account or vehicle type. As such, different client account or vehicle types, even if they utilize the same investment strategy, may not be a replication of another fund or portfolio, and thus seek only to replicate the performance contour of the investment strategy. While most vehicles share a model strategy, the investment team constructs the portfolios in each vehicle independently and in accordance with vehicle-specific requirements.

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With respect to institutional separate account and Managed Account clients, before American Century Investments agrees to manage a prospective client’s account, we may require the prospective client to provide, or commit to provide within a certain timeframe, a minimum dollar amount of assets to be managed by us. We may also require a client to maintain a minimum dollar amount under our management in order to remain our client. These minimum dollar amounts, when applicable, are determined by the officers of American Century Investments, depend upon circumstances that they deem pertinent, and may vary from client to client. Minimum account size for Managed Account programs typically depends on various factors, including the product type, investment strategy, and any Sponsor specific requirements. The American Century Private Investments Team provides services to private investment funds. Interests in certain private investment funds that are exempt from registration under the Investment Company Act are only offered to “accredited investors” as defined in Regulation D of the Securities Act of 1933, as amended, and who meet other suitability requirements as may be determined by American Century Investments. The Fund Documents for each private investment fund set forth further information with respect to suitability and minimum investment requirements for an investment in such private investment fund.

As noted above, American Century Investments may charge performance-based fees or carried interest to certain “qualified clients.” Performance-based fees and carried interest are based on a portion of the capital gains or capital appreciation of the client's account. We manage accounts that are charged performance-based fees and carried interest while at the same time managing accounts (perhaps with similar objectives) that are not charged performance-based fees or carried interest, for example, accounts that are charged another type of fee, such as a Page | 10

flat fee or asset-based fee ("side-by side management"). Performance-based fees and carried interest and side-by-side management may create conflicts of interest, which we have identified and described in the following paragraph. Performance-based fees and carried interest may create an incentive for our firm to make investments that are riskier or more speculative than would be the case absent such arrangement. In order to address this potential conflict of interest, the investment oversight committee of our firm periodically reviews the implementation of investment strategies to ensure that investments are suitable and that the strategy is being managed according to the strategy's investment objectives and risk parameters. Performance-based fees and carried interest may also create an incentive for us to overvalue investments that lack a market quotation. In order to address such conflict, we have adopted policies and procedures that require us to "fair value" any investments that do not have a readily ascertainable value. Sideby-side management might provide an incentive for our firm to favor accounts for which we receive a performance-based fee or carried interest. For example, we may have an incentive to allocate limited investment opportunities, such as initial public offerings, to clients who are charged performance-based fees or carried interest over clients who are charged asset-based fees only. To address this conflict of interest, we have instituted policies and procedures that require our firm to allocate investment opportunities (if they are suitable) fairly, regardless of whether the client is charged performance fees or carried interest.

American Century Investments is under common control with the following entities that also provide financial services:

American Century Investment Services, Inc. (“ACIS”) is a broker-dealer registered with the SEC and the distributor for the American Century Investments mutual funds. American Century Investments Private Client Group, Inc. (“ACIPCG”) is an investment adviser registered with the SEC. Page | 25

American Century Investment Management (UK) Limited (“ACIM UK”) is an investment adviser registered with the United Kingdom’s Financial Conduct Authority. American Century Investment Management (Asia Pacific) Limited (“ACIM HK”) is registered with Hong Kong’s Securities and Futures Commission with Type 1 (Dealing in Securities) and Type 4 (Advising on Securities) licenses. American Century Investment Management (AU) Pty Limited (ACIM AU) is registered with the Australian Securities & Commission. American Century Investments (EU) GmbH (ACI EU) is registered with Germany’s Federal Financial Authority (BaFin).

ACIS solicits the sale of shares of the mutual funds that we advise to intermediary and retail clients. ACIS does not act as a broker-dealer with respect to the portfolio securities held in our client’s accounts. ACIS and most of its registered representatives provide various services for us, including, without limitation, the services of marketing, underwriting and selling shares of the mutual funds, the marketing of institutional investment management services, and soliciting advisory business on our behalf. We compensate ACIS for performing these services for us. The compensation of ACIS’s registered representatives may be impacted by their success in marketing our advisory services and investment products. ACIPCG is an investment adviser that offers the American Century Wrap Fee Program. The program includes discretionary investment management and financial planning services, along with other personal financial solutions, to individuals, trusts, estates, charitable organizations, and business entities. ACIM UK, ACIM HK, ACIM AU, and ACI EU market and distribute our investment products and advisory services in certain foreign markets. We compensate ACIM UK, ACIM HK, ACIM AU, and ACI EU for performing these services. In addition to marketing and distribution services, ACIM HK also assists us with transacting in securities held in our clients’ accounts. We compensate ACIM HK for these services. Each of the American Century Investments funds is a series of an investment company registered with the SEC under the Investment Company Act, as amended, and is a related person and client of American Century Investments. Each of these investment companies has entered into an investment management agreement with us. Certain affiliates of American Century Investments serve as the general partner of certain private investments funds that are structured as limited partnerships. In the ordinary course of business, and subject to compliance with applicable regulatory requirements, American Century Investments or its related persons may provide initial funding Page | 26

(“seed capital”) necessary to establish new funds or strategies. Seed capital may be provided for registered investment companies, private funds, non-U.S. funds or other pooled vehicles, and may be used to invest in the same securities as other client accounts. Seed capital can be redeemed at any time as permitted by the governing documents for such fund and any applicable regulatory requirements. From time to time, American Century Investments may use investment management services provided to it by “participating affiliates” (as such term is used in relief granted by the staff of the SEC in a series of no-action letters allowing a registered adviser to use portfolio management, trading, research services, and resources provided by an unregistered affiliate subject to the supervision of the registered adviser). We have entered into agreements with ACIM UK and ACIM HK, asset management affiliates of American Century Investments, pursuant to which ACIM UK and ACIM HK are considered participating affiliates of ours. ACIM UK and ACIM HK and the employees listed below have been deemed associated persons of American Century Investments and (subject to our supervision) may provide portfolio management, research and trading services in connection with our management of one or more portfolios or client accounts. ACIM UK and ACIM HK are not registered with the SEC.

Cecile Rihouey, Senior Corporate Analyst, was born in 1979. Prior to joining American Century Investments in 2014, she was a credit analyst at Pictet Asset Management Limited. She has a master of science degree in management from SKEMA Business School, with a specialization in financial markets, and is a CFA charterholder.

Vital Magnin, Vice President and Senior Investment Analyst, was born in 1976. He joined American Century Investments in 2008 as an Investment Analyst and was promoted to Senior Investment Analyst in 2012. He was promoted to Vice President in 2016. He has a master degree in finance from Ecole Superieure de Commerce de Paris and is a CFA charterholder.

Paul Findlay, Vice President and Senior Trader, was born in 1975. He joined American Century Investments in 2020.

Alison Cheung, Vice President and Senior Trader, was born in 1979. She joined American Century Investments in 2021.

Rob Chapman, Senior Trader, was born in 1978. He joined American Century Investments in 2023.

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Vienna Pang, Trader, was born in 1994. She joined American Century Investments in 2021. ACIM UK and ACIM HK will act in accordance with the series of SEC no-action letters referred to above requiring each of them, as a participating affiliates, to be subject to our supervision and the SEC in the manner contemplated in such letters. ACIM UK and ACIM HK have agreed to submit to the jurisdiction of U.S. courts for actions arising under the U.S. securities laws in connection with its investment advisory activities provided for our U.S. clients and has appointed an appropriate agent for service of process, in each case in accordance with, and subject to the requirements of, such letters. Under the aforementioned agreements, American Century Investments pays compensation to each of ACIM UK and ACIM HK for the services of the associated persons. With client consent, we may invest separate account or sub-advised clients’ assets into newly established products. These investments may provide the initial funding necessary for American Century Investments to develop new products and facilitate growth in product size or scale. We may waive all or a portion of our management fees with respect to the separate account or sub-advised assets used to seed new American Century Investments managed products. In addition, with respect to seed investors in non-U.S. funds for which we act as investment manager, American Century Investments may rebate all or a portion of the fund’s investment management fees and/or provide reimbursements relating to certain expense types or specified amounts of expenses. Seed investors may contribute all or a majority of the assets in a newly established product. There is a risk that seed investors may redeem their investments in a product, particularly after the termination of any fee waivers, rebates, or reimbursements. Such redemptions could have a negative impact on a product’s liquidity or share price. Due to business relationships in place prior to their joining American Century Investments, certain American Century Private Investments Team members responsible for managing American Century’s private investment funds also own and control, or are engaged by, a separate business through which they provide services to (and receive fees and carried interest from) other private investment funds that are not affiliated with American Century Investments and have not yet wound down (i.e., outside funds). The investment period for such outside funds has closed, and these individuals’ responsibilities with respect to the outside funds is limited to managing and disposing of current holdings (which may include seeking additional funding as needed) and winding down each outside fund pursuant to the applicable governing documents. American Century Investments has policies and procedures in place to mitigate the conflicts associated with these outside activities. Additionally, no outside activities may be conducted in American Century Investments’ office space or using American Century Investments’ systems or property. For the asset allocation model portfolios, it is expected that, with respect to all or a material portion of the portfolios, American Century Investments will recommend affiliated funds. As a Page | 28

result, American Century Investments and its affiliates will retain more fees than if American Century Investments had recommended unaffiliated funds or products.

Our business is built on trust. In our efforts to ensure that all members of our corporate family always seek to do the right thing for our clients and for each other, we have adopted a Code of Ethics and a Business Code of Conduct, each designed to help ensure that business is conducted in accordance with the law and with the highest ethical standards. Code of Ethics American Century Investments has adopted a Code of Ethics that guides the personal investment activities of our employees, officers and directors, and members of their immediate families to ensure that while conducting such activities, they make decisions in the best interest of our clients. Upon employment and at least annually thereafter, the Code of Ethics requires employees of American Century Investments, as well as employees of other companies within our corporate family, to: (i) acknowledge that they have received, read, and will comply with the Code, (ii) provide account information for reportable mutual fund and brokerage accounts, and (iii) consent to provide duplicate electronic transactions and holdings information in reportable brokerage accounts to our compliance system vendor, ComplianceAlpha. Reportable accounts include accounts held directly by the employee and accounts that are beneficially owned. The Code of Ethics prohibits employees from short term and abusive trading in the American Century Investments managed mutual funds and requires all of our employees to comply with certain trading restrictions in American Century Investments managed mutual funds. Our officers and directors, as well as certain employees that participate in providing investment advice to our clients or have access to information regarding current recommendations with respect to portfolios of our clients or real-time trading information, are required to comply with additional restrictions. These additional restrictions include, but are not limited to, pre-clearance of personal securities transactions in nonexempt securities and quarterly transaction reporting of reportable security and mutual fund transactions. Portfolio managers, traders, investment analysts, officers and directors of American Century Investments are subject to additional restrictions for trading in private placements and initial public offerings of stock. Portfolio Managers and Investment Analysts are subject to black out restrictions when trading securities held in their assigned funds. Under the Code of Ethics, certain classes of securities have been designated as exempt transactions based upon a determination that these would materially not interfere with the best Page | 29

interest of our clients. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from investment activity in a client’s account. Due to this conflict of interest between us and our clients, our compliance department continually monitors employee trading, as required by the Code of Ethics, to ensure compliance with the Code. The Code of Ethics also includes provisions regarding the treatment of confidential information of our clients. Certain employees are also required to disclose potential conflicts of interest due to their personal relationships. Failure to comply with the Code of Ethics constitutes a violation of the policy and results in sanctions, including, without limitation, formal warning with manager notification, required attendance of a Code of Ethics training session, suspension of trading privileges, disgorgement of profits, and/or suspension or termination of employment. American Century Investments will provide a copy of the Code of Ethics to any client or prospective client upon request. Our Privacy Commitment What does American Century Investments do with your personal information? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Tax Identification number • Date of birth • Investment profile • Income • Account information • User Name/Password All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons American Century Investments chooses to share and whether you can limit this sharing.

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Reasons we can share your personal information:

For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus For our marketing purposes — to offer our products and services to you For joint marketing with other financial companies For our affiliates’ everyday business purposes — information about your transactions and experiences For our affiliates’ everyday business purposes — information about your creditworthiness For nonaffiliates to market to you

Does American Century Investments share? Yes

Can you limit sharing?

Yes

Yes

No

We don’t share

Yes

No

No

We don’t share

No

We don’t share

No

Who is providing this notice? The American Century Family of Funds; American Century Investment Services, Inc.; and American Century Investments Private Client Group, Inc. How does American Century Investments protect my information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures address administrative, technical, and physical safeguards. We regularly review these safeguards and adjust them as appropriate. Our policies limit access to your personal information to those who must have it to service and maintain your account. How does American Century Investments collect my information? We collect your personal information, for example, when you: • complete an account application • make transactions on your account We also collect your personal information from consumer reporting agencies and other organizations. Why can’t I limit all sharing? Page | 31

Federal law gives you the right to limit only: • sharing for affiliates’ everyday business purposes - information about your creditworthiness • affiliates from using your information to market to you • sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. We do not share information about your creditworthiness with affiliates. Nor do we share your information with nonaffiliates for marketing purposes. We may share your information with our affiliates for marketing purposes. To opt out of receiving marketing materials about products or services from our affiliates, please call 1-800-345-2021. Your election to opt out does not expire. You may opt back in to receive these materials later if you choose. Definitions: Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Questions? Call 1-800-345-2021 or go to americancentury.com Business Code of Conduct American Century Investments has also adopted a Business Code of Conduct that expresses our commitment to the highest degree of ethical business standards and provides general guidelines for employees to use, along with their own good judgment, while conducting business. The Business Code of Conduct includes provisions relating to the protection of customers’ privacy, a prohibition on insider trading and the sharing of non-public information, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, restrictions on outside business activities, restrictions on political contributions, and personal securities trading procedures. A violation of the Business Code of Conduct may result in disciplinary action up to and including termination of the employee’s employment.

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Political Contributions Political contributions made by investment advisers and their employees to state or local government officials may raise potential conflicts of interest. Moreover, the SEC, FINRA, and the Municipal Securities Rulemaking Board have promulgated rules addressing such contributions. American Century Investments and its affiliates, generally, do not make any corporate contributions, directly or indirectly, to state or local officials or candidates, political parties, or political action committees. American Century Investments has adopted a political contributions policy which requires employees to obtain approval prior to making personal political contributions or engaging in certain political activities. Participation or Interest in Client Transactions In some circumstances, we may seek to purchase or sell a security for a client’s account that we also purchase or sell for our proprietary accounts (either for investment purposes or to test new investment strategies or methodologies prior to offering them to clients), but only if we first determine that the investment decision is appropriate for each participating account. Investments of our corporate assets in proprietary accounts may raise conflicts of interest. To mitigate these potential conflicts of interest, we have adopted policies and procedures intended to minimize the risk that trading in proprietary accounts is performed in a manner that gives improper advantage to American Century Investments to the detriment of client portfolios. We also manage or advise client accounts that pursue investment objectives similar to the investment objectives pursued by other accounts. As a result, we may also seek to buy or sell the same securities contemporaneously for multiple client accounts. This will create potential conflicts and potential differences among client accounts, particularly where there is limited availability or limited liquidity for those investments. In these circumstances, we may either purchase or sell the security separately for each account, or aggregate the orders for all participating accounts (which may include our own account(s)), but only if we determine that the aggregation of orders is consistent with our duty to seek best execution. Investors in the private investment funds may invest in partnerships or other pooled investment vehicles for which an affiliate of American Century Investments (or an affiliate of one or more members of the American Century Private Investments Team) acts as the general partner or managing member with an ownership interest and receives its applicable share of any profits or losses associated with its ownership interest. American Century Investments and/or its affiliates (or an affiliate of one or more members of the American Century Private Investments Team) also receive a management fee and/or carried interest related to its management of such private investment funds as set forth in the applicable Fund Documents. In addition, American Century Investments has adopted a Trade Aggregation Policy that is designed to (a) minimize the risk that a client could be systematically advantaged or Page | 33

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Brokerage Discretion and the Selection of Broker-Dealers American Century Investments is authorized to select the broker-dealers ("brokers") who effect securities and currency transactions for the accounts of most of our clients, negotiate transaction costs, including commissions or bid-ask spreads, and enter into brokerage and other trading agreements with such brokers on behalf of our clients. In placing orders for the purchase and sale of assets of our clients’ accounts and selecting brokers or dealers, we use our best efforts to seek, on behalf of our clients, “best execution,” or the most favorable results Page | 37

under the circumstances (taking into account all relevant factors). In assessing the best overall terms available for any transaction, we consider all factors that we deem relevant, including the breadth of the market in the security, the portfolio manager’s investment intentions, the price of the security, the financial condition and execution capability of the broker, and the reasonableness of the commission, both for the specific transaction and on a continuing basis. American Century Investments generally does not select broker-dealers or effect underlying securities transactions for Managed Account clients utilizing equity investment strategies or other clients who utilize model delivery investment portfolios. For Model Portfolio clients, the program Sponsor will have sole discretion and responsibility for the selection of broker-dealers and the execution of transactions in the accounts of program participants. American Century Investments is not responsible for placing orders for the execution of transactions involving assets in these types of accounts. For Traditional SMA clients utilizing equity strategies, American Century Investments' discretion as to which broker-dealers are used in effecting securities transactions is limited by the program sponsor’s or underlying client’s general direction to use a particular broker-dealer to execute transactions due to the economic benefits the client receives from trades being executed through the Sponsor. Our determination of best execution does not necessarily mean that the client is paying the lowest possible commission rate or bid-ask spread, as there are several additional factors to consider when evaluating best execution in client brokerage. In selecting brokers to effect portfolio transactions for our clients, we consider the full range and quality of a broker's research and brokerage services (as those terms are defined in Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”)), which may include the following factors:

Value of a broker’s proprietary research and other brokerage services (collectively referred to as “Research”, as defined below); Applicable commission rates and other transaction costs charged by the broker; Timeliness of broker's trade executions; Efficiency and accuracy of the broker's clearance and settlement process; Broker's ability to provide data on securities executions; Financial stability of broker; Ability to maintain confidentiality; Operational and reputational risks; and The quality of the overall brokerage and customer service provided by the broker; and Any other relevant factor.

When assessing the relative importance of these factors in broker selection, we will also consider the characteristics of the client's account, the order, the financial instrument(s) being transacted in the order and the execution venues available for such order. Each order Page | 38

executed on behalf of a client account will be unique in its characteristics due to the prevailing market conditions, liquidity, investment strategy, and investment guidelines at the time such order is executed. While the relative importance assigned to the execution factors will vary, generally American Century Investments prioritizes price and cost factors (both explicit and implicit) in obtaining best execution. However, there are instances where other factors take precedence. Such instances may include: trade costs are uniform or negligible across counterparties for fixed income products, speed of execution may be more important due to the nature of the order, or a trade order is large in comparison to the liquidity of the relevant financial instrument in the market. “Research” may include, but is not limited to, proprietary research and analysis; general market analysis; economic forecasting services; fundamental and technical advice on individual securities; market analysis; advice (either directly or indirectly through publications, written reports, or online services) as the value of securities, availability of securities or of purchasers/sellers of securities; “road show” visits; personal meetings with analysts, economists, expert referral networks, and analytic and execution management systems. American Century Investments may pay a broker who provides such brokerage and research services a commission for executing a portfolio transaction for our clients’ accounts that is in excess of the amount of commission another broker would have charged for effecting that transaction if, but only if, we determine in good faith that such commission was reasonable in relation to the value of the brokerage and research services provided by such broker, viewed in terms of that particular transaction or in terms of our overall responsibilities with respect to our clients. The reasonableness of transaction costs is based on our view of the broker’s ability to provide professional services, competitive commission rates, research, and other services that will help us in providing investment advisory services to its clients, viewed in terms of either the particular transaction or our overall responsibility to our clients. We believe that access to Research provided by independent third parties is beneficial to our investment decision-making processes and, therefore, to our clients. Receipt of independent Research allows us to supplement our own internal research and analysis and provides us with the opinions and views of, and information from, individuals and the research staffs of other firms. We often use alternative execution venues in lieu of placing transactions with a traditional brokerage firm, or computer-driven order routing techniques (such as “algorithmic trading”) to facilitate best execution and to reduce other transaction costs. Brokers used to execute trades for Subadvised Funds are selected by the Third-Party Subadvisers in accordance with their policies and procedures and their duty to seek best execution.

Equity Securities: American Century Investments executes transactions in securities (other than those for which an exchange is the primary market) with a dealer acting as principal, with a market maker, or a broker. We will execute a security transaction on a brokerage basis when we believe that the facilities, expert personnel and technological systems of a broker enable Page | 39

our clients to secure as good a net price as when dealing with a market maker. Equity securities transactions in Managed Accounts generally are executed through the Sponsor without a separate commission charge or at a fixed commission amount per trade negotiated by the Sponsor.

Fixed Income Securities: American Century Investments purchases fixed income securities for client accounts directly from issuers, underwriters, broker-dealers or banks. In many transactions, we select the broker-dealer based on the availability of the desired security and its offering price. In both purchase and sale transactions, we also select the broker-dealer based on the selection of market and the negotiation of price, as well as the broker-dealer's general execution, operational and financial capabilities in the type of transaction involved.

Derivatives Transactions: Whenever practicable, American Century Investments will seek to aggregate transactions in derivatives such as futures, swaps, and currency forwards among eligible client accounts. Because many derivatives require negotiation and execution of trading agreements between each client and each counterparty, some counterparties may be available to some client accounts and not others. When the counterparty that we believe can provide best execution for a particular transaction is unavailable to some of our client accounts participating in that transaction, we will trade first with that counterparty on behalf of the accounts to which that counterparty is available, and then trade the excluded client accounts with such other counterparty as we believe is most desirable among the counterparties available to those accounts. Under certain circumstances, we may not follow this approach, and instead, may choose only among counterparties available to all relevant client accounts if we believe the benefits of aggregating the transaction exceed the benefit of choosing the most desirable counterparty among those available to each client. We will make such decisions subject to our obligation to treat all client accounts in a manner we believe is fair and equitable over time. The top ten broker-dealers based on commissions paid that provided Research to American Century Investments during the past year were (in alphabetical order) Barclays Capital Inc., Bernstein Institutional Services LLC, Bloomberg, BofA Securities, Inc., Citigroup Global Markets Inc., Goldman Sachs & Co. LLC, J.P. Morgan Securities LLC, Jefferies LLC, Morgan Stanley & Co. LLC and UBS Securities LLC. A full list of broker-dealers providing Research is available to clients upon request. American Century Investments does not engage in "brokerage for sales" practices, whereby we would direct trades in our clients' accounts to a broker as remuneration for client leads or referrals. The factors utilized by American Century Investments in selecting broker-dealers to execute trades are described above. Subject to applicable law, American Century Investments will occasionally effect “cross” transactions between client accounts, including registered investment companies. In these Page | 40

cases, one client account will purchase securities held by another client account. We effect these transactions only when we deem the transaction to be in the best interests of both client accounts and at a price that we have determined by reference to independent market indicators, which we believe to constitute “best execution” for both accounts. Neither American Century Investments nor any related party receives any compensation in connection with “cross” transactions. We are not obligated to seek to effect “cross” transactions and may be prohibited by legal or regulatory considerations from doing so with respect to certain types of client accounts. American Century Investments engages in foreign currency transactions in some accounts or strategies. Where available and practicable, we believe it is in a client’s best interest to trade foreign currency directly with a broker-dealer; however, third-party broker-dealer transactions are not available for certain emerging markets or certain restricted foreign securities and may be impracticable for some payments such as dividends. In these instances, we will trade foreign currency through a client’s custodian on a transaction-by-transaction basis and/or via standing instructions. We are not responsible for overseeing charges of or execution quality provided by a client’s custodian. Clients should contact their custodians directly for this information. To mitigate any conflict that could arise in the brokerage selection process due to the provision of gifts and entertainment to our personnel, we have included in our Business Code of Conduct a provision that restricts an employee’s ability to accept gifts. That provision prohibits any employee from accepting a gift, or a series of gifts, worth an aggregate of $100 each year from any person, firm, or company that American Century Investments does or seeks to do business with, provided that such gifts are in accordance with normally accepted business practices. It also requires each employee to report the gift to his or her manager and to report any gift received that is valued at more than $50 to our compliance department. In addition, our trade oversight committee monitors all gifts and entertainment provided by broker-dealers to our investment management personnel and traders. Soft Dollar Arrangements and Commission Sharing Arrangements Section 28(e) of the Exchange Act provides a safe harbor for persons who exercise investment and brokerage discretion over advisory accounts to pay for research and brokerage services with commission dollars generated by account transactions. Such arrangements are sometimes referred to as “soft dollar arrangements.” American Century Investments uses proprietary and third-party Research that it purchases with its own funds or through commissions paid to broker-dealers. Our U.S. based investment advisory firm has implemented policies and procedures to comply with U.S. laws and regulations relating to the use of brokerage commissions to purchase research. Under Section 28(e) of the 1934 Act we receive Research by sending trades and Page | 41

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We have entered into agreements with five of our affiliates:

ACIS, ACIM UK, a sister company of American Century Investments that is organized in the United Kingdom as a private limited company, and ACIM HK, a sister company of American Century Investments that is organized in Hong Kong as a private limited company, and ACI EU, a sister company of American Century Investments that is organized in Germany as a private limited company, and ACIM AU, a sister company of American Century Investments that is organized in Australia as a proprietary limited company

pursuant to which we agree to compensate each of them for efforts to promote American Century Investments’ financial products and advisory services to potential clients. In addition, we have entered into similar agreements with multiple affiliates of Nomura Holdings, Inc. (a major stockholder of our parent company) and with CIBC Asset Management, Inc., pursuant to which we agree to compensate those partners for their efforts to promote, market and introduce American Century Investments’ financial products and advisory services to potential clients. We may, from time to time, enter other solicitation agreements with third parties pursuant to which we agree to pay such parties compensation for client referral activities. In these situations, solicitations and/or referrals and any related compensation are made in accordance with applicable legal requirements. American Century Investments has compensated, and may compensate from time to time in the future, either directly or indirectly, employees or third parties, including financial intermediaries, for client referrals, client retention, and/or client servicing. Compensating third parties for the solicitation, retention, and servicing of clients may create a conflict of interest for those third parties in that the compensation they receive from us may influence the recommendation they make to their customers. Page | 51

American Century Investments, when acting as investment manager to certain unaffiliated pooled investment vehicles, including collective investment trusts, that invest in American Century Investments sponsored ETFs (“Underlying Funds”), will reimburse the pooled investment vehicle the full amount of the Underlying Funds’ acquired fund fees and expenses (“AFFE”) so that American Century Investments does not receive a financial benefit from, and the pooled investment vehicle does not incur an additional expense for, investing in the Underlying Funds. Such AFFE reimbursements may exceed the investment management fee that American Century Investments receives from the pooled investment vehicle. If you purchase an American Century Investments mutual fund or ETF through a broker-dealer or other financial intermediary (such as a bank, insurance company, retirement recordkeeper, plan sponsor, or financial professional), American Century Investments or the fund’s affiliated companies may pay the intermediary for the availability of the fund on the intermediary’s platform, the sale of fund shares, or related services. These payments may create a conflict of interest by influencing the broker-dealer or other intermediary and your salesperson to recommend our fund over another investment. Ask your salesperson or visit your financial intermediary’s website for more information. We also pay the distributor of the American Century Investments ETFs a fee for serving as principal underwriter of the funds’ shares out of our unified management fee. The distributor does not earn commissions for distributing the funds’ shares.

Under this Item, we are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of American Century Investments’ advisory business or the integrity of our management. We have no information applicable to this Item to disclose.

American Century Investments reviews clients’ portfolios on a continuous basis with the exception of some Advisory Clients where less frequent review is desired and required by contract. Equity portfolios are managed by teams of equity portfolio managers (with the assistance of analysts) who meet weekly to review the portfolios that they manage and on an informal basis as needed. Fixed-income portfolios are managed on a daily basis by teams of fixed-income portfolio managers with the assistance of securities analysts. American Century Investments provides written reports to the board of directors/trustees of each of the funds that it advises or subadvises at each boards’ quarterly meetings. These reports include, but are not limited to, reports on investment performance, risk management, the quality of our services, and compliance. We also provide the funds’ boards with additional information on an annual basis at the time the boards consider the renewal of each fund’s investment management agreement with us. We provide the fund boards with other information and reports upon request or as needed. We also provide reports to our non-mutual fund clients regarding their accounts in accordance with their instructions. Managed Account Sponsors typically receive market commentaries prepared by American Century Investments and may send such commentaries on to Managed Account clients. Reports to Advisory Clients may be less frequent, as determined by contract. Sponsors typically issue performance reports to clients on a quarterly basis. American Century Investments relies on the Managed Account Sponsor or consultant/financial adviser to provide client portfolio reporting. Upon request, American Century Investments will provide supplemental reporting to these types of clients.

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With respect to the private investment funds, portfolio investments are generally private, illiquid and long-term in nature. Accordingly, the review process is not directed toward a short-term decision to dispose of securities. American Century Investments monitors investments in which the private investment funds invest, and periodically checks to confirm that each such fund is maintained in accordance with its stated objectives. Additionally, investors in private investment funds will generally receive audited financial statements for such private investment fund within 120 days following such private investment fund’s fiscal year end. Investors also receive Forms K-1 and other tax reporting information, as applicable, as provided in each private investment fund’s Fund Documents.

Some of our clients receive account statements from the bank or other qualified custodian that holds and maintains their investment assets. American Century Investments urges these clients to carefully review such statements and compare such official custodial records to the account statements that we may provide to them. If we provide a client with an account statement, it may vary from the statement that the custodian provides due to different accounting procedures or reporting dates. With respect to the private investment funds, American Century Investments and its affiliated entities are deemed to have custody of the underlying assets of such private investment funds. The private investment funds are audited annually by a nationally recognized firm of independent accountants and the audited financial statements will be distributed to all investors in such private investment funds (as applicable) within 120 days after the close of each private investment fund’s fiscal year and American Century Investments urges investors in these funds to carefully review such audited financial statements.

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Clients generally retain American Century Investments on a discretionary basis to provide continuous investment advice. At the outset of our relationship with a client, we enter into an investment management agreement with the client that usually grants us discretionary investment authority to select the securities and amount of securities to be bought or sold for the client’s account. We exercise this discretionary investment authority in a manner consistent with our client’s investment objectives, limitations and restrictions. The investment management agreement and, as applicable, offering or other documents for a client generally set out the investment guidelines, restrictions and/or other types of investments in which the client’s assets may or may not, as applicable, be invested. Such documents may call for a client to specifically approve each investment or investment type prior to investment. We may also be permitted to invest client assets in all other types of investments, provided they are not specifically prohibited by the applicable investment guidelines or other restrictions, such as applicable law. For our clients that are registered mutual funds, our authority to select and trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Mutual funds and private investment funds are managed in accordance with fund guidelines and restrictions, and the strategy does not differ by investor. If you desire us to pursue a certain investment strategy while managing your account, or to observe certain investment limitations or restrictions, you must provide these investment guidelines to us in writing before or at the time we sign an agreement with you regarding our management of your assets. For Managed Account clients, Sponsors and Advisory Clients may exercise investment discretion and execute portfolio transactions based on the Sponsor’s or its designated representative’s own investment judgment. American Century Investments does not provide services to Managed Account clients based on the individual needs of any program client and does not have brokerage discretion for these clients.

American Century Investments may be delegated the responsibility for exercising the voting rights associated with the securities purchased and/or held by certain of our client accounts, including funds that we manage. In exercising our voting obligations, we are guided by general fiduciary principles. We must act prudently, solely in the interest of our clients, and for the exclusive purpose of providing benefits to them.

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We (along with the boards of the American Century Investments funds) have agreed on certain significant contributors to shareholder value with respect to a number of matters that are often the subject of proxy solicitations for shareholder meetings. Accordingly, we have adopted proxy voting policies (the “Policies”) that specifically address these considerations and establish a framework for our consideration of the vote that would be appropriate for, and in the best interest of, our clients. In particular, the Policies outline principles and factors to be considered in the exercise of voting authority for proposals addressing:

non-U.S. proxies sustainability matters routine matters o election of directors o ratification of selection of auditors compensation matters o executive and director compensation o equity-based compensation plans o non-stock incentive plans shareholder rights o one share, one vote o rights to call special shareholder meetings o right to act by written consent o proxy access anti-takeover proposals o staggered board o cumulative voting o “blank check” preferred stock o elimination of preemptive rights o non-targeted share repurchase o increase in authorized common stock o “supermajority” voting provisions or “super voting” share classes o “fair price” amendments o poison pills or shareholder rights plans o change in control agreements o reincorporation o confidential voting o opting in or out of state takeover laws transaction related proposals other matters o shareholder-sponsored proposals o director tenure Page | 54

o director share ownership Under certain circumstances, we may not be able to timely exercise the voting associated with particular securities held in a client’s account, including, but not limited to, when securities are out on loan pursuant to a securities lending program. The Adviser shall use commercially reasonable efforts to monitor for material proxy votes with respect to loaned securities. In the event the Adviser has timely knowledge of a material vote, the Adviser will attempt to recall the loaned securities and submit a proxy in accordance with these proxy guidelines. Efforts to recall loaned securities may not be successful and there can be no guarantee that a valid proxy will be submitted in all cases. The Adviser is responsible for monitoring and resolving possible conflicts between the interests of the Adviser and those of its clients with respect to proxy voting. The Adviser has adopted safeguards to address the potential that our proxy voting could be influenced by interests other than those of our fund shareholders and clients. Since our Policies are predetermined by the Adviser, application of the Policies to vote clients’ proxies should in most instances adequately address any possible conflicts of interest. However, for proxy votes inconsistent with the Policies, the Adviser’s Proxy Voting Committee reviews all such proxy votes to determine whether the portfolio manager’s voting rationale appears reasonable and is consistent with the general principles of the Policies. The Proxy Voting Committee also assesses whether certain business or other significant relationships between the Adviser and a company could have influenced an inconsistent vote on that company’s proxy. Issues raising possible conflicts of interest are referred to the Proxy Voting Committee for immediate resolution prior to the time the Adviser casts its vote. With respect to personal conflicts of interest, the Adviser’s Code of Ethics requires all employees to avoid placing themselves in a compromising position where their interests may conflict with those of our clients and restricts their ability to engage in certain outside business activities. Portfolio managers and other personnel involved with proxy voting with a personal conflict of interest regarding a particular proxy vote must recuse themselves and not participate in the voting decisions with respect to that proxy. In addition, to avoid any potential conflicts of interest that may arise when one American Century Investments fund owns shares of another, we will “echo vote” such shares, if possible. That is, we will vote the shares in the same proportion as the vote of all other holders of the shares. When this is not possible, shares will be voted in consultation with the Adviser-Voted Portfolio client or an appropriate fiduciary responsible for the client (e.g., a committee of the independent directors of a fund or the trustee of a retirement plan). A client may be able to direct how we vote shares held in its account by providing us with written voting instructions adopted by the client and communicated to and accepted by us in writing.

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American Century Investments may also retain proxy advisory firms to provide services in connection with voting proxies, including, without limitation, to provide information on shareholder meeting dates and proxy materials, translate proxy materials printed in a foreign language, provide research on proxy proposals and voting recommendations in accordance with the Policies, provide systems to assist with casting the proxy votes, and provide reports and assist with preparation of filings concerning the proxies voted. Prior to the selection of a proxy advisory firm and periodically thereafter, American Century Investments will consider whether the proxy advisory firm has the capacity and competency to adequately analyze proxy issues and the ability to make recommendations based on material accurate information in an impartial manner. Such considerations may include some or all of the following (i) periodic sampling of votes cast through the firm’s systems to determine that votes are in accordance with American Century Investments Policies and its clients best interests, (ii) onsite visits to the proxy advisory firm’s office and/or discussions with the firm to determine whether the firm continues to have the resources (e.g. staffing, personnel, technology, etc.) capacity and competency to carry out its obligations to American Century Investments, (iii) a review of the firm’s policies and procedures, with a focus on those relating to identifying and addressing conflicts of interest and monitoring that current and accurate information is used in creating recommendations, (iv) requesting that the firm notify American Century Investments if there is a change in the firm’s material policies and procedures, particularly with respect to conflicts, or material business practices (e.g., entering or exiting new lines of business), and reviewing any such change, and (v) in case of an error made by the firm, discussing the error with the firm and determining whether appropriate corrective and preventative action is being taken. In the event American Century Investments discovers an error in the research or voting recommendations provided by the firm, it will take reasonable steps to investigate the error and seek to determine whether the firm is taking reasonable steps to reduce similar errors in the future. While American Century Investments takes into account information from many different sources, including independent proxy advisory services, the decision on how to vote proxies will be made in accordance with the Policies. The Adviser reserves the right to vote contrary to the Policies when, in its opinion, the vote will do the most to maximize the investment objective of the account. American Century Investments currently utilizes Institutional Shareholder Services, Inc. (“ISS”) to provide third party proxy voting services. The services ISS provides include, but are not limited to, research and analysis of proxy matters, voting of proxies in accordance with our instructions through the ISS electronic voting platform, recordkeeping related to the voting, and providing the tools necessary for the preparation of required disclosure of the American Century Investments funds’ proxy voting histories. American Century Investments Policies are set up on the ISS electronic voting platform, allowing the ISS system to pre-populate certain ballot items Page | 56

in accordance with American Century Investments Policies. Pre-populated votes are sampled weekly, prior to the votes being cast, and all votes are sampled monthly in order to confirm proxy voting is in accordance with American Century Investments Policies. You may obtain a copy of American Century Investments’ complete Policies, as well as information regarding how we voted proxies relating to securities held in your account, upon request. In addition, the Policies and information regarding how we voted proxies relating to securities held by American Century Investments funds during the most recent 12-month period ended June 30 is available at americancentury.com/proxy. Our funds’ proxy voting record is also available on the SEC’s website at sec.gov.

As a registered investment adviser, we are required to provide you with certain information or disclosures about our financial condition. American Century Investments has no financial commitments that impair our ability to meet our contractual commitments and fiduciary responsibilities to you. We have never been the subject of a bankruptcy proceeding.

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