AQR CAPITAL MANAGEMENT LLC

Overview AQR is a global investment management firm, founded in 1998, that takes a systematic research-driven approach to managing alternative and traditional strategies. The Adviser commenced operations as an investment adviser in January 1998 and has been registered with the SEC since May 13, 1998. AQR is wholly owned by AQR Capital Management Holdings, LLC (“AQR Holdings”). AQR Holdings’ majority owner is AQR Capital Management Group, L.P. (“AQR Group”). AQR Holdings’ minority owner is Affiliated Managers Group, Inc. (“AMG”)1, a publicly traded holding company. The general partner of AQR Group is AQR Capital Management Group GP, LLC. Clifford S. Asness is the principal owner of AQR through such intermediate entities. Clifford S. Asness, David G. Kabiller and John M. Liew are founding principals of AQR. Advisory Services AQR specializes in quantitative investment analysis, which relies on proprietary models, utilizing a broad set of signals to generate views on investments and applying them in a disciplined and systematic process. AQR provides investment advice to its Clients (as defined below) on a variety of securities and instruments in accordance with agreed upon investment objectives and strategies.2 AQR offers its investment strategies through the following investment vehicles and portfolios. Mutual Funds. AQR provides advisory services to investment companies registered under the Investment Company Act of 1940, as amended (the “Company Act”)—commonly known as mutual funds (each a “Mutual Fund” and collectively, along with their wholly-owned and controlled foreign corporation subsidiaries, “Mutual Funds”)—sponsored by AQR (the “AQR Mutual Funds”), and Mutual Funds sponsored by advisers unaffiliated with AQR (“Sub-Advised Mutual Funds”). AQR is the adviser to the AQR Funds, which is an open-end registered investment company, organized as a Delaware statutory trust on September 4, 2008 and is comprised of multiple active series (each a “Series Fund” which, together with their wholly-owned and controlled foreign corporation subsidiaries, comprise the AQR Mutual Funds). UCITS. AQR provides advisory or sub-advisory services to certain European collective investment schemes pursuant to the Undertakings for Collective Investment in Transferable Securities—commonly known as UCITS funds—sponsored by AQR (the AQR UCITS Funds and AQR UCITS Funds II, collectively, “AQR UCITS”), and UCITS funds sponsored by management companies unaffiliated with AQR (“Sub-Advised UCITS”). Sponsored Funds and Managed Accounts. AQR provides advisory services to United States, Cayman Islands, and Luxembourg-domiciled privately placed investment vehicles (“Private Funds”), collective investment trusts (“CITs”), and Australian investment vehicles (“Australian Funds”, and collectively with CITs and Private Funds, “Sponsored Funds”), as well as to separately managed accounts for institutional investors (together with SubAdvised Mutual Funds and Sub-Advised UCITS, “Institutional Managed Accounts”). AQR also provides advisory services to independent registered investment advisors, family offices, high net worth individuals and other individual investor clients (“Independent / RIA Accounts”). AQR Mutual Funds, AQR UCITS, Sponsored Funds, Institutional Managed Accounts, and Independent / RIA Accounts shall be collectively referred to herein as “Clients”.3

AMG holds other equity and financial interests in certain other investment advisers unaffiliated with AQR. AMG does not have a controlling interest in AQR Holdings or a role with respect to the day-to-day business of AQR and as such is not a control person. Please see Item 14 – Client Referrals and Other Compensation for more information on AMG.

AQR has an ownership interest in AQR Arbitrage, LLC (“AQR Arbitrage”), a Delaware limited liability company and SEC-registered investment adviser (SEC Number 801-60678). AQR Arbitrage provides discretionary investment management services, specializing in global merger arbitrage, global convertible arbitrage and other event driven strategies. AQR Arbitrage serves as sub-adviser to certain AQR Clients, as defined below. AQR Arbitrage receives a portion of the fees paid to AQR when acting as a sub-adviser. At times, AQR markets interests of Private Funds sponsored by AQR Arbitrage. In addition, in certain circumstances, AQR directs Clients to invest in AQR Arbitrage advised vehicles. For additional information regarding AQR Arbitrage, please see Item 10 – Other Financial Industry Activities and Affiliations below.

AQR or persons affiliated with AQR, from time to time and as permitted by applicable law, create seed or incubator funds (“Seed Funds”) in

AQR provides advice to Clients based on specific investment objectives and strategies. Under certain circumstances, AQR tailors advisory services to the individual needs or requirements of a Client. For example, certain investors impose restrictions on their managed accounts, such as prohibiting certain securities or certain types of securities, or controlling sector and industry concentrations in their portfolios or directing AQR to trade in a particular manner or within a certain timeframe. Likewise, other Clients may request certain customization to address specific tax or investment needs. AQR also provides non-discretionary model portfolio recommendations to unaffiliated model portfolio platforms or sponsors (“Model Platforms”). Such model portfolio recommendations employ the same or similar strategies utilized for AQR’s discretionary Clients and include baskets or portfolios of individual securities (Unified Managed Accounts (“UMA”)). In addition, AQR may also participate in Model Platforms in which AQR provides one or more model portfolios that allocate exclusively to a number of Series Funds (Fund Strategist Program (“FSP”)). AQR is not responsible for determining the suitability of AQR’s strategy for the underlying clients of the Model Platforms and AQR does not determine the timing or manner of execution with respect to any of the securities or investments related to a model portfolio. Clients receiving model portfolio recommendations, their overlay managers, Model Platforms or others retain investment discretion to utilize the model portfolio recommendations, and may deviate from AQR’s recommendations. Assets Under Management As of December 31, 2025, AQR had approximately $187,180,600,000 in Client net assets under management 4 (“AUM”), all of which were managed on a discretionary basis.

order to develop one or more performance track records in new investment products and/or strategies before offering them to outside investors. In certain circumstances, a Seed Fund may not be made available to outside investors. Similarly, AQR or persons affiliated with AQR, from time to time and as permitted by applicable law, create proprietary reference funds (“Reference Funds”) to implement certain model portfolio strategies or other products. For the avoidance of doubt, the term Clients includes Seed Funds and Reference Funds. In addition, AQR also advises certain other Clients whose assets include or are comprised solely of those of persons affiliated with AQR.

Includes assets sub-advised by AQR Arbitrage.

AQR is compensated through various fee structures, including asset-based fees and performance-based fees.5 Asset-based fees are typically annual fixed fees based on AUM. A performance fee is based upon a percentage of the net profits of the account being managed. Typically, when calculating net profits, performance fees are based on absolute or benchmark-relative returns over an agreed upon time period, and are subject to high water marks or loss carryforwards. As more fully described below, AQR either bills or deducts fees in advance or in arrears, according to the terms of the pertinent investment management agreement or other governing documentation. Under certain circumstances, fees are negotiable. AQR Mutual Funds Advisory fees for the AQR Mutual Funds range up to 3.50% of AUM (generally including, but not limited to, cash balances and cash invested in money market funds, closed end funds, and ETFs). Additional operating expenses apply as described more fully in the relevant offering materials. With respect to a Series Fund that allocates to other Series Funds, AQR receives compensation for managing the Series Fund indirectly through advisory fees received from the underlying Series Funds. If AQR selects underlying Series Funds with higher advisory fees, then AQR will receive more compensation. Detailed information concerning the AQR Mutual Funds is contained in each Series Fund’s prospectus, which can be downloaded from https://funds.aqr.com. Each Series Fund is distributed by ALPS Distributors, Inc. AQR UCITS Advisory fees for the AQR UCITS range up to 1.80% of AUM (generally including, but not limited to, cash balances and cash invested in money market funds, closed end funds, and ETFs). Additional operating expenses apply as described more fully in the relevant offering materials. Certain AQR UCITS also include a performance fee of up to 30% of net profits. AQR and its affiliates reserve the right to enter into written agreements with investors (“Side Letters”) in AQR UCITS sub-funds to waive or modify the standard fee terms of such sub-fund in respect to a particular investor. More information about the AQR UCITS can be found at https://ucits.aqr.com/. Sponsored Funds The basic fee schedule for Sponsored Funds includes an annual fixed fee (or, in certain cases, a tiered fee schedule) of up to 2.90% of AUM (generally including, but not limited to, cash balances and cash invested in money market funds, closed end funds, and ETFs), typically payable either monthly or quarterly in advance. Certain fee schedules also include a performance fee of up to 36% of net profits.6 Additional operating expenses apply as described more fully in the relevant offering materials. Investors in certain Sponsored Funds may be subject to “lock-up” periods or gates with respect to withdrawals/redemptions and incur withdrawal/redemption fees, in accordance with the provisions of the applicable fund documentation. AQR and its affiliates enter into Side Letters with investors in Sponsored Funds (“Subscribers”) to waive or modify the standard terms of such Sponsored Fund in respect of a particular Subscriber. Certain Subscribers are not charged any management fees, are not charged any performance fees, are charged fees in arrears rather than in advance or have a differing fee structure because of their overall relationship with AQR or its affiliates or their investment approach. In particular, certain Subscribers in a Private Fund that are employees (including certain former employees), business associates and other “friends and family” of AQR, its affiliates or their personnel will typically not pay management fees or performance fees in connection with their investment in a Private Fund or may pay a reduced rate. Consequently, fees charged to certain Subscribers may deviate from the standard fees disclosed in a Sponsored Fund’s offering documents. For its Sponsored Funds, AQR has the absolute discretion, subject to its fiduciary duty, to agree with Subscribers, particularly with respect to those Subscribers who are large or strategic investors, to waive or modify the application of any provision of a Sponsored Fund agreement (including, but not limited to, those relating to liquidity, investment capacity, fees, and transparency). Moreover, with respect to such Subscribers, AQR remains subject to its fiduciary

Throughout this Brochure, the term “performance fee” means performance fee or performance allocation, as applicable.

For the avoidance of doubt, no Client is charged a combination of the highest advisory and performance fees set forth herein.

obligations, its duties under the Investment Advisers Act of 1940 (“Advisers Act”) and any terms negotiated through Side Letters. In some instances, Side Letters grant such Subscribers materially favorable terms relating to, among other things, liquidity, investment capacity, economic rights, fees, expenses, information and reporting rights, coinvestment rights, certain rights or terms necessary in light of particular legal, regulatory or policy requirements of a particular investor, veto rights, transfer rights and transparency. In addition, AQR reserves the right to waive or rebate all or a portion of its management fees and/or performance fees with respect to a Subscriber. Prospective Subscribers and existing Subscribers should consider these possible conflicts of interest in making their decision to invest or remain invested in a Sponsored Fund, as certain Side Letters can result in favoring some Subscribers over others and affect a Subscriber’s expectations as to future return and risk. AQR has agreed to provide certain Subscribers enhanced disclosure with respect to specific security positions, risk information and/or portfolio characteristics of Sponsored Funds. Accordingly, not all Subscribers will have the same degree of access to the type and/or frequency of individual position listings in connection with Sponsored Funds in which they invest. Institutional Managed Accounts Generally, advisory fees for Institutional Managed Accounts are separately negotiated with each institutional client and are based upon a percentage of AUM and vary depending upon the nature of the portfolio to be managed and the strategy employed (e.g., international equity, multi-strategy). Fees are based upon the fee methodology agreed to with each Institutional Managed Account. Institutional Managed Account advisory fees generally range up to 2.00% of AUM (generally including, but not limited to, cash balances and cash invested in money market funds, closed end funds, and ETFs), payable after the end of either the month or the quarter. AQR and Institutional Managed Accounts have, in certain circumstances, agreed to performance fees of up to 22.50% of net profits, subject to certain hurdles, in addition to or in lieu of a fixed advisory fee. In some instances, additional operating expenses apply. Independent / RIA Accounts Independent / RIA Account advisory fees payable to AQR are negotiated and generally based upon a percentage of AUM and vary depending upon the nature of the portfolio to be managed and the strategy employed. The applicable fee rate(s) typically depends upon certain factors, including but not limited to the strategy employed for the Independent / RIA Account, the overall amount of assets in Independent / RIA Accounts related to the same household, the overall amount of assets in Independent / RIA Accounts for a given RIA or family office, and/or the overall amount of assets for a given RIA or family office advised by AQR. Advisory fees payable to AQR for Independent / RIA Accounts generally range up to 2.50% of AUM (generally including, but not limited to, cash balances and cash invested in money market funds, closed end funds, and ETFs), payable after the end of the quarter. In some instances, additional operating expenses apply. Performance fees are not charged in connection with Independent / RIA Accounts. Certain Independent / RIA Accounts that are for the benefit of employees (including certain former employees), business associates and other “friends and family” of AQR, its affiliates or their personnel will typically not pay management fees or may pay a reduced rate. Model Portfolio Recommendations AQR receives fees for providing non-discretionary model portfolio recommendations to UMA Model Platforms. The fees are negotiated and vary in amount, as well as the frequency and timing of the payment. Additionally, for providing non-discretionary FSP model portfolio recommendations AQR would receive management fees from the underlying Series Funds. If AQR selects underlying Series Funds with higher management fees, then AQR will receive more compensation. Additional Information The investment terms offered to different Clients pursuing similar investment objectives in many cases differ, as do the investment terms offered to Subscribers in investment vehicles pursuing the same or similar investment objectives. For example, certain Institutional Managed Accounts have information sharing terms that are more extensive and/or timely than other Clients. As another example, certain Institutional Managed Accounts have different liquidity terms than other Subscribers pursuing the same or similar investment objectives in a Sponsored Fund. Sponsored Funds generally have less frequent liquidity terms than Mutual Funds or UCITS Funds that pursue the same or similar investment objective as the Sponsored Funds. Certain Subscribers of Sponsored Funds

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Methods of Analysis As noted in Item 4 – Advisory Business, AQR specializes in quantitative investment analysis, which relies on proprietary models, utilizing a broad set of signals to generate views on investments and applying them in a systematic process. In addition to quantitative investment analysis, AQR also utilizes discretionary and/or hybrid strategies through a combination of quantitative and fundamental techniques. Quantitative investment analysis is a method of evaluating securities and other assets by analyzing a large amount of traditional and non-traditional data through the use of algorithms—or models—to generate investment decisions. Depending on the given strategy or mandate, AQR’s models may consider a wide breadth of factors, including, for example, traditional valuation measures, momentum indicators, price signals, textual analysis of information (e.g., financial reporting, terms of trade information, and unstructured text). These diverse sets of inputs, combined with AQR’s proprietary signal construction methodology, optimization process, and trading approach, are the foundation of AQR’s investment process. There are certain risks specific to firms specializing in quantitative investment analysis. Please see below under “Investment Risks” for a summary of some of the risks specific to quantitative investment analysis. AQR performs research internally. Once an investment approach is identified, AQR builds a model to test the strategy’s viability. The model building process generally consists of two steps: (1) designing an investing strategy to implement the given approach; and (2) producing testable implications. AQR performs ongoing research to monitor and maintain the effectiveness of its models over time. AQR uses both internally-built datasets and external data (e.g., Refinitiv, Bloomberg and other data services) in developing its quantitative forecasting computer models. Investment Strategies The Adviser utilizes several investment strategies, including both alternative and traditional investment strategies. With regards to alternative strategies, AQR offers both absolute return strategies, which target zero net beta exposure to traditional markets, either at all times, or on average; and total return strategies, which usually maintain some positive beta to traditional markets. AQR also assists our clients with achieving their Environmental, Social and Governance (“ESG”) goals and objectives. AQR also offers tax-aware implementation of some of our strategies, which may help taxable investors better reach their after-tax investment goals. Each of AQR’s investment strategies is managed by a team of portfolio managers in a manner consistent with our approach to investing.

Alternative Investment Strategies – Absolute Return Absolute Return Strategy. Provides exposure to a highly diversified, broad suite of alternative strategies, while maintaining near-zero correlation to traditional markets. Apex. A comprehensive multi-strategy alternative that emphasizes innovative research and dynamic allocations to underlying sources of returns. Arbitrage Strategies. Offers convertible, merger and event-driven arbitrage strategies, or a diversified portfolio combining these strategies. Equity Market Neutral. Employs a multi-factor, market-neutral investment process based on AQR’s broadest global stock selection capabilities. Global Macro. Invests in major asset classes based on prices and macroeconomic fundamentals, using a variety of quantitative and qualitative inputs. Managed Futures. A collection of strategies that seeks to take advantage of price and fundamental trends in traditional and alternative asset classes. Opportunistic. Identifies securities that show extreme undervaluation based on both our quantitative models, as well as a thorough qualitative review. Real Return. Seeks to provide an inflation-hedging, positive real return through a diverse mix of strategies and assets. Style Premia. Seeks to harvest the return premia from well-known factors such as value, momentum, carry and defensive across asset classes and geographies. Alternative Investment Strategies – Total Return Commodities. Diversified approach to investing across a range of commodities, seeking to provide returns that are not overly reliant on any single commodity sector. Diversified Growth Strategies. Offers a wide range of return sources including market risk premia, alternative risk premia, and alpha, with less reliance on traditional assets than conventional diversified growth strategies. Long-Short Equity. Employs our investment process based on AQR’s global stock selection capabilities, with modest exposure to equity markets. Multi-Asset. Diversifies across global asset classes by risk, seeking to build a portfolio that is broadly diversified and not overly reliant on any single asset class. Multi-Strategy. Offers a diversified approach to alternatives investing, seeking to provide broad exposure to several different AQR strategies at once. Traditional Investment Strategies – Equities Single-Style. Strategies that provide pure implementations of individual styles, such as defensive, momentum and value. Multi-Style. These strategies harness the diversification and potential return benefits of investing in multiple well-known styles in an integrated fashion. Adaptive. These strategies seek to generate consistent excess returns over an equity benchmark. They combine established and proprietary signals based on rigorous research. Relaxed Constraint. Strategies that build on Adaptive, but broaden the implementation through use of limited shorting in, for example, a 130/30 context while remaining beta-1 products. 3-Alpha. These strategies extend our Enhanced capabilities by adding dedicated country and currency models, seeking to capture additional alpha opportunities.

Portable Alpha. Combines a diversifying alternative with exposure to an equity market, for an equitybenchmarked strategy. Tax-Aware Seek to deliver particular alternative or traditional strategies with a focus on being tax-efficient and potentially tax-beneficial across an investor's entire portfolio. Environmental, Social and Governance AQR’s ESG investing framework is designed to allow for the application of multiple approaches to investment, including Responsible Asset Selection and Responsible Ownership methodologies. There can be no assurance that the objectives associated with any strategies described above will be met. At any time, AQR may add, remove, modify, overweight or underweight any of the strategies or factors it employs. These methods, strategies, and investments involve risk of loss to Clients and Clients must be prepared to bear the loss of their entire investment. The methods, strategies, and investments described herein apply to Clients and Model Platforms. Investment Risks Some of the risks associated with AQR’s investment strategies, and the securities and other assets utilized to implement those strategies, include, but are not limited to, those listed below. Arbitrage Transaction Risks. If the requisite elements of an arbitrage strategy are not properly analyzed or unexpected events or price movements intervene, losses can occur which can be magnified to the extent AQR is employing leverage. Moreover, arbitrage strategies often depend upon identifying favorable “spreads,” which can also be identified, reduced, or eliminated by other market participants. Below Investment Grade Securities Risk. Although bonds rated below investment grade (also known as “junk” securities) generally pay higher rates of interest than investment grade bonds, bonds rated below investment grade are high risk, speculative investments that may cause income and principal losses to Clients. Borrowing and Embedded Leverage. Some Clients allow secured and unsecured borrowing to the maximum extent allowable under applicable credit regulations. Like other forms of leverage, the use of borrowing can enhance the risk of capital loss in the event of adverse changes in the level of market prices of the assets being financed with the borrowings. Leverage may also take the form of financial instruments, including OTC derivative instruments which are inherently leveraged, and products with embedded leverage such as futures, options, short sales, swaps, and forwards, in which an investor can lose more money than the initial cost of the investment. The use of leverage allows the Clients to increase their exposure to assets, such that total assets may be greater than capital invested. However, the use of leverage may also magnify the volatility— or the likelihood of short-term changes in value—of any portfolio. The effect of the use of leverage in a portfolio may result in losses to the portfolio that exceed losses to the portfolio if such portfolio did not utilize leverage. Capacity Constraints. A number of conflicts of interest may arise as a result of the Adviser’s or portfolio manager’s management of a number of accounts with similar investment strategies. Often, an investment opportunity may be suitable for more than one Client, but may not be available in sufficient quantities for all such Clients to participate fully. Similarly, there may be limited opportunity to sell an investment held by multiple Clients. In circumstances where the amount of total exposure to a strategy or investment type across Clients is, in the opinion of the Adviser, capacity-constrained, the availability of the strategy or investment type for one or more Client’s will be reduced in the Adviser’s discretion. A Client may therefore have reduced exposure to a capacity constrained strategy or investment type, which could adversely affect such Client’s return. The Adviser is not obligated to allocate capacity pro rata and may take its financial interest into account when allocating capacity among Clients. Among other things, capacity constraints in a particular strategy or

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AQR provides investment management services to institutional clients including, but not limited to, investment companies, pooled investment vehicles, pension and profit sharing plans, charitable organizations, state or municipal government entities, other investment advisers, insurance companies, sovereign wealth funds and foreign official institutions, corporations or other business entities. AQR also provides investment management services to independent registered investment advisors, family offices, high net worth individuals and other individual investor clients. Additionally, AQR provides investment management services to Sponsored Funds, AQR Mutual Funds and AQR UCITS, whose participants may include, but are not limited to, institutional investors as described above, as well as individuals and other investors. AQR’s investment minimums may vary according to investment strategy and vehicle (i.e., Institutional Managed Account versus investment in a Sponsored Fund), and AQR maintains the ability to waive such minimums at its discretion, as applicable. Generally, AQR’s Institutional Managed Account minimums range from $50 million to $100 million depending on the investment strategy. Independent / RIA Account minimums are typically $1 million. The standard minimum investment required to invest in a Sponsored Fund is described in each Sponsored Fund’s offering memorandum. The minimum investment required to invest in a Series Fund or in an AQR UCITS is described in each fund’s prospectus. In addition, AQR reserves the right to waive investment minimums for particular Clients or Subscribers.

Performance-Based Fees As noted above, a performance fee represents an asset manager’s compensation for managing a client account which is based upon a percentage of the net profits of the account being managed. Typically, when calculating net profits, performance fees are based on either absolute or benchmark-relative returns over an agreed upon time period, with performance fees subject to high water marks or loss carryforwards. In some instances, a performance fee represents all or a portion of AQR’s standard fee arrangement. In other instances, AQR is compensated solely through an asset-based fee (i.e., AQR is paid a percentage of the amount of assets in the account). AQR reserves the right to negotiate the rate of any applicable performance fees or asset-based fees on a case-by-case basis. With respect to AQR’s management of Client assets, performance fees give rise to certain conflicts of interest. Specifically, AQR’s entitlement to performance fees in managing one or more accounts creates an incentive to take risks in managing those accounts that in certain circumstances AQR would not otherwise take in the absence of such fee arrangements. Additionally, since performance fees reward for performance in accounts which are subject to such fees, AQR has an incentive to favor these accounts over those that have only asset-based fees with respect to trading opportunities, trade allocation, and allocation of new investment opportunities. Generally, AQR addresses these conflicts by utilizing an investment allocation policy designed to treat all Clients fairly and equitably over time. Please see below and Item 12 – Brokerage Practices for more information. Side-by-Side Management Side-by-side management of various types of accounts raises the possibility of favorable or preferential treatment of a Client account or a group of accounts arising from differences in fee arrangements, including favoring Clients with higher fee schedules over those with lower fee schedules. AQR has procedures designed and implemented in furtherance of its efforts to treat all Clients fairly and equitably over time. By utilizing these procedures, AQR believes that Clients that are subject to side-by-side management alongside other accounts are receiving fair and equitable treatment over time. AQR simultaneously manages multiple types of investment vehicles and accounts, including the AQR Mutual Funds, AQR UCITS, Sponsored Funds, Institutional Managed Accounts, and Independent / RIA Accounts, in many instances according to the same or a similar investment strategy (i.e., side-by-side management). The simultaneous management of these different investment vehicles gives rise to the types of conflicts described above, for example, the fees for the management of certain types of investment vehicles may be higher than for others or the liquidity terms may differ. Nevertheless, when managing the assets of such investment vehicles, AQR has a duty to treat all Clients fairly and equitably over time. Although AQR has a duty to treat all Clients fairly and equitably over time, each Client will not necessarily be managed the same at all times. Specifically, there is no requirement that AQR use the same investment processes consistently or at the same time across all Clients. In general, investment decisions for each Client will be made independently from those of other Clients, and will be made based on the individual needs and objectives of each Client. In addition, different account guidelines, applicable laws and regulations, and/or differences within particular investment strategies leads, in some cases, to the use of different investment processes for accounts with a similar investment strategy or investing in the same securities. Portfolio managers know the size, timing and possible market impact of Client trades. A conflict of interest exists where portfolio managers could use this information to the advantage of certain accounts they manage and to the possible detriment of other accounts. AQR will not necessarily purchase or sell the same securities at the same time, in the same direction, or in the same proportionate amounts for all eligible accounts, particularly if different accounts have different amounts of investable cash available, different existing exposures, different liquidity requirements, different strategies, or different risk tolerances. In addition, some accounts purchase long positions in certain securities while other accounts simultaneously sell short or sell to reduce exposure to those same, similar or related securities. Timing and location of execution for the Independent / RIA Accounts will differ from that for other Clients because the Independent / RIA Accounts are generally expected to utilize the custodian’s affiliated broker-dealer. In certain circumstances, AQR will adjust its trading and/or allocation process in order to efficiently and effectively launch or implement new strategies, or to account for flows. As a result of all of these differences, although AQR manages numerous accounts with similar or identical investment objectives, or may manage accounts with different objectives or

strategies that trade in the same, similar or related securities, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, may differ from account to account and, accordingly, Client to Client. Changes to, or modifications in, the investment strategies employed by the Adviser may be implemented incrementally, rather than simultaneously, across Clients pursuing similar or identical investment objectives. In certain circumstances, investment opportunities that are in limited supply and/or have limited return potential in light of administrative costs of pursuing such investments (e.g., IPOs, as defined below) are only allocated to Clients where the given opportunity is more closely aligned with the applicable strategy and/or trading approach. Side-by-side management also affects instances where AQR provides model portfolio recommendations to Model Platforms. The timing of updates to model portfolios will not necessarily occur at the same time. In these circumstances, AQR’s Reference Funds will typically commence trading before other recipients of model portfolio recommendations have received or had the opportunity to evaluate or act on AQR’s recommendations. As such, model portfolio trades ultimately placed by such Model Platforms or others, for themselves, their clients, or for others may be subject to price movements, particularly with large orders or where the securities are thinly traded, that may result in those parties receiving prices that are less favorable than the prices obtained by AQR for its other Clients. Because AQR does not control the execution of transactions related to a model portfolio, AQR cannot attempt to control the market impact of such transactions to the same extent that it would for its discretionary Clients. Please see Item 12 – Brokerage Practices below for a more detailed discussion of AQR’s trade allocation and aggregation policy and procedures.

Affiliated Broker-Dealer In connection with the marketing of shares of the Series Funds and interests in certain Private Funds and CITs, certain AQR personnel are registered representatives of AQR Investments, an affiliated SEC-registered brokerdealer, member of FINRA and the Securities Investor Protection Corporation. Please see Item 5 – Fees and Compensation above for a discussion of potential conflicts of interest with respect to such employees. AQR Investments does not: (1) engage in underwriting or market making activities; (2) handle or custody customer funds or securities; (3) engage in execution, clearance or settlement of transactions; or (4) hold investments. CFTC Registration Status AQR is registered with the CFTC as a commodity pool operator and commodity trading adviser and is a member of NFA. Material Relationships or Arrangements with Industry Participants AQR and CNH Capital Management, LLC (“CNH CM”) are members of AQR Arbitrage. AQR Arbitrage is a Delaware limited liability company, SEC-registered investment adviser (SEC Number 801-60678), CFTC-registered commodity trading adviser and commodity pool operator, and a member of the NFA. Mark L. Mitchell and Todd Pulvino are founding principals of AQR Arbitrage. AQR Arbitrage provides discretionary investment management services, specializing in global merger arbitrage, global convertible arbitrage, and other event driven strategies. AQR Arbitrage serves as sub-adviser to certain AQR Clients, including certain Sponsored Funds, Series Funds, Institutional Managed Accounts and AQR UCITS. AQR Arbitrage utilizes the infrastructure of AQR for non-portfolio management functions. CNH CM is not a registered investment adviser and does not have investment management agreements or discretionary authority over AQR or AQR Arbitrage clients. AQR Arbitrage provides AQR with research and investment management support services. Mr. Kabiller is Chairman and Founding Partner of Arqitel Investment Management, LP (“Arqitel”), a company engaged in investing in private, multi-family real estate on behalf of pooled private funds. Mr. Kabiller provides strategic advice to the management team of Arqitel and participates on Arqitel’s investment committee. Mr. Kabiller is not involved in the day-to-day activities of Arqitel such as managing investments or executing transactions, nor does he participate in the solicitation or sales of Arqitel’s funds to investors. Arqitel is not a publicly traded company. AQR or affiliated entities may also from time-to-time act as general partner or managing member to certain Sponsored Funds formed as limited partnerships or limited liability companies. AQR or affiliated entities may act as general partner to both the master fund (the “Master Fund”) and the feeder fund (the “Feeder Fund”) in a Sponsored Fund that is set up in a master-feeder structure. The following AQR-affiliated entities serve as general partner or managing member to one or more Sponsored Funds:

• AQR Principal Global Asset Allocation, LLC • AQR Capital Management GP II Ltd. • AQR Capital Management GP Ltd. • AQR Capital Management II, LLC • AQR Capital Management III, LLC • AQR Corporate Arbitrage GP, LLC • AQR Tax Advantaged GP, LLC • AQR Tax Advantaged GP II, LLC • AQR Tax Aware GP IV, LLC

• AQR SPAC Opportunities GP, LLC • AQR Apex MS GP, LLC • AQR Lux S.a.r.l. AQR, where appropriate, may recommend that one or more Sponsored Funds or Series Funds invest in other Sponsored Funds or Series Funds, respectively, or funds managed or sub-advised by AQR Arbitrage. Investments in affiliated funds may be made either through the Master Fund and/or Feeder Fund or one or more of the Series Funds. AQR also employs AQR Arbitrage to perform research and investment management support services. AQR serves as the investment adviser to, and one related person serves on the Board of Trustees of, the AQR Funds. Subject to the overall authority of the Board of Trustees, AQR furnishes continuous investment supervision and management to the Series Funds’ portfolios and also furnishes office space, equipment and management personnel, including persons satisfactory to the Board of Trustees to serve as officers of the Series Funds, and also provides certain other administrative services to each Series Fund. AQR Arbitrage serves as the sub-adviser for the AQR Diversified Arbitrage Fund. AQR owns AQR Pty Limited, an Australian propriety company domiciled in Sydney, Australia. AQR Pty Limited provides AQR with investment management marketing services in Australia under a Financial Services License with the Australian Securities and Investments Commission. AQR also owns AQR Capital Management (UK Services) Limited (“AQR UK”), a United Kingdom private limited company incorporated on May 10, 2012 in England and Wales. AQR UK is the managing member of AQR Capital Management (Europe) LLP (“AQR Europe”). AQR Europe is a UK limited liability partnership that is authorized by the UK’s Financial Conduct Authority (“FCA”) for advising, arranging, managing, dealing as agent (for professional investors only), and for managing unauthorized alternative investment funds (Firm FCA Ref. No. 567411). AQR Europe is domiciled in England and Wales and was formed on May 12, 2012. AQR Europe owns AQR Capital Management (DK Service) Aps (“AQR DK Service”), a Danish private limited company incorporated on July 1, 2012 and domiciled in Denmark. AQR DK Service provides AQR with research services in Denmark. AQR Capital Management (Germany) GmbH (“AQR Germany”), incorporated in Germany and an affiliate of AQR, has received from the Bundesanstalt für Finanzdienstleistungsaufsicht (“BaFin”) permission to provide financial services in the form of investment advice and investment brokering to clients in Germany and outbound passporting throughout the European Economic Area (“EEA”) in respect of such authorizations. AQR Capital Management (Asia) Limited is a wholly-owned subsidiary of AQR and is licensed to conduct Type 1 (Dealing in Securities) regulated activity in Hong Kong from the Hong Kong Securities and Futures Commission.

Personal Trading Code of Ethics AQR’s officers, principals, and employees (collectively “Covered Persons”) must abide by AQR’s Business Conduct Manual and Code of Ethics (the “Business Conduct Manual”), which includes AQR’s Personal Trading Policy (which is also applicable to members of their household). Covered Persons may hold and transact in securities only if they comply with the Personal Trading Policy. AQR has implemented the Personal Trading Policy in order to reduce conflicts of interest between trading for Clients and the personal trading activities of Covered Persons. Covered Persons are permitted to invest in AQR- and AQR Arbitrage-advised investment vehicles and portfolios, subject to certain restrictions. At times, Covered Persons invest in the same or related securities as those that AQR or an affiliate invests in for Clients, including doing so before, or at or about the same time as a Client transaction is effected. The Personal Trading Policy also prohibits certain personal transactions, imposes restrictions on personal trading, requires pre-clearance of certain personal trades, and requires Covered Persons to make certain reports regarding their personal trading and private investments. AQR is firmly committed to making its Covered Persons aware of the requirements within AQR’s Business Conduct Manual. All Covered Persons are provided with the Business Conduct Manual at the time of hire and must certify that they have received a copy of the Business Conduct Manual and have read and understand its provisions. Covered Persons are also required to certify at least annually that they have complied with the terms of the Business Conduct Manual. Additionally, AQR conducts periodic compliance training that addresses the requirements of the Business Conduct Manual. Clients or prospective Clients may obtain a copy of the Business Conduct Manual upon request. Client Transactions in Securities Where Adviser has a Material Financial Interest AQR, where appropriate, may recommend that one or more Sponsored Funds or Series Funds invest in other Sponsored Funds or Series Funds, respectively, or funds managed or sub-advised by AQR Arbitrage. In certain circumstances, AQR Arbitrage performs research and investment management support services for AQR. These practices create a conflict of interest because AQR or persons affiliated with AQR have an incentive to recommend its products to Clients based on its own financial interests or those of its affiliated persons, rather than solely the interests of a Client. Investing in Securities Recommended to Clients When AQR determines that it would be appropriate for one or more Clients, including Seed Funds or Reference Funds, to participate in an investment opportunity, AQR will seek to execute orders for all the participating accounts, including Seed Funds and Reference Funds, on an equitable basis. In certain circumstances, Clients take an opposite investment position (e.g., a long position versus a short position) in the same security held by other Clients (including Seed Funds or Reference Funds). Subject to applicable laws and/or Client restrictions, and in certain circumstances, AQR instructs on the purchase, sale or holding of a certain security or securities for a Client (including a Seed Fund or Reference Fund) while also instructing other Clients (including Seed Funds or Reference Funds) to enter into a different or opposite investment decision regarding the same security or securities. Hence, AQR sometimes directs the purchase or sale of the same securities for more than one advisory Client (including Seed Funds or Reference Funds) account on the same day (including at the same time) in the same direction, the opposite direction, or a combination of the two directions. There are certain disadvantages when one or more Clients simultaneously seeks to buy or sell commonly held securities and other investment positions. AQR will seek to allocate investment opportunities and trades fairly. “Fair” treatment does not mean identical treatment of all Clients. Rather, it means that AQR does not discriminate on an impermissible basis against one Client or group of Clients. When AQR transacts in securities or instruments for more than one Client, the investment opportunities and trades will be allocated in a manner consistent with AQR’s policies and procedures. Please refer to Item 12 – Brokerage Practices for a description of AQR’s trade aggregation and allocation procedures.

Certain AQR personnel maintain personal private investment holdings, which include private companies and/or private funds. Certain of these investments are maintained with third-party investment managers who sponsor investment vehicles that compete with AQR or that AQR or certain AQR affiliates may recommend to its clients. Furthermore, certain of these personal investments have terms that are more favorable than those routinely offered by the unaffiliated investment manager (e.g., reduced fees). AQR reserves the right to waive or rebate all or a portion of the management fees and/or performance fees, or to impose different management fees and/or performance fees (including, without limitation, those that are higher, lower, calculated in a different manner or payable at different times) with respect to its affiliated persons or other designated investors, including former employees. These personal investments may give rise to potential or actual conflicts of interest between AQR’s Clients on the one hand, and AQR and its affiliates, on the other hand. Accordingly, AQR’s personal securities investment and reporting policies, which require the pre-approval from the Chief Compliance Officer, or his designee, on any personal private fund or private company investment, seek to address any potential or actual conflicts of interest relating to personal private investments. Investing in Securities Issued by Clients, Counterparties, and Related Parties To the extent permitted by law and account guidelines, and in certain circumstances, AQR recommends the purchase, sale or holding of securities issued by companies with which AQR has business relationships, including but not limited to companies which are Clients, prospective Clients or which are affiliated with Clients, service providers, trading counterparties, lenders or investors. These transactions are subject to the requirements and limitations of the Code and related policies, as well as the requirements of the Advisers Act, the Company Act and/or other applicable laws. Conflict of Interest Created by Contemporaneous Trading In certain circumstances, AQR, on behalf of a Client, including a Seed Fund or Reference Fund, will take a position that is different from, and potentially adverse to, a position taken by another Client, invest in a different security of an issuer’s capital structure in which another Client is invested, invest in the same security but on different terms than another Client, obtain exposure to an investment using different types of securities or instruments than another Client, engage in short selling securities that another Client holds, vote securities in a different manner than another Client, and/or acquire or dispose of its interests at different times than another Client. This could have a material adverse effect on, or in some instances could benefit, one or more of such Clients, including Clients that are AQR affiliates, in which AQR has an interest, or which pay AQR higher fees or a performance fee. These transactions or investments by one or more Clients could dilute or otherwise disadvantage the values, prices, or investment strategies of such Clients. When AQR, on behalf of a Client, manages or implements a portfolio decision ahead of, or contemporaneously with, portfolio decisions of another Client, market impact, liquidity constraints, or other factors could result in such Client receiving less favorable pricing or trading results, paying higher transaction costs, or being otherwise disadvantaged. In addition, in connection with the foregoing, AQR, on behalf of a Client, is permitted to pursue or enforce rights or actions, or refrain from pursuing or enforcing rights or actions, with respect to a particular issuer in which another Client has invested, even though such actions or inaction could materially adversely affect such other Client. Certain employees have invested their own monies in investment vehicles and portfolios, including Seed Funds, managed by investment personnel of AQR and/or AQR Arbitrage. These funds hold, purchase, sell, or short the same investments in which other Clients have interests. From time to time, AQR or a related person buys or sells securities for Clients before, or at about the same time that AQR or a related person buys or sells the same securities for its own accounts. In order to minimize the conflicts stemming from situations where this type of contemporaneous trading might result in an economic benefit for AQR or its affiliated persons to the detriment of a Client, AQR has adopted the trade aggregation and allocation policies and procedures discussed in Item 12 – Brokerage Practices below and the Business Conduct Manual discussed above. In addition, persons affiliated with AQR provide initial funding or otherwise invest in vehicles managed by AQR and/or AQR Arbitrage. In certain circumstances, such affiliated investors provide ‘seed capital’ for a fund and do so with the intention of redeeming all or part of their interests at a particular future point in time or when they or AQR deem that sufficient additional capital has been invested in that fund. Such affiliated investors are also permitted to, and do, invest for purposes other than providing ‘seed capital’. To the extent permitted by applicable law, AQR and/or AQR Arbitrage may agree to waive or modify the application of any provision in the offering

documents of the subject investment vehicle (including, but not limited to, those relating to liquidity, compensation or transparency) with respect to such affiliated investors. Insider Trading/Material Nonpublic Information (“MNPI”) All AQR employees are subject to the Business Conduct Manual’s Policy to Prevent Insider Trading. This section of the Business Conduct Manual includes policies and procedures prohibiting the misuse of MNPI and is designed to prevent insider trading by an officer or employee of the Adviser. Additionally, employees are prohibited from transacting in the securities of the relevant issuer while in possession of MNPI that has been obtained in breach of a duty of trust or confidence, and disclosing such MNPI to any person, including, but not limited to, family members. In accordance with these policies, AQR maintains a “restricted list” that identifies any securities that cannot be purchased by AQR employees, including members of their household. The issuers named on this restricted list are coded as prohibited in AQR’s and AQR Arbitrage’s trading and portfolio compliance system, thus blocking the Adviser from trading in these securities without the consent of the Adviser’s Chief Compliance Officer or his designee. In certain circumstances, a Client will be restricted from transacting in a security or instrument because of MNPI received in connection with an investment opportunity that is offered to other Clients. In other circumstances, a Client will not participate in an investment opportunity to avoid AQR or AQR Arbitrage from receiving MNPI that would restrict AQR or AQR Arbitrage from transacting in a security or instrument for another Client. These restrictions may adversely impact the investment performance of Client accounts.

Clients often grant AQR responsibility for selecting brokers to execute portfolio transactions on behalf of Clients as well as negotiating any commissions or spreads paid on such transactions, except with respect to providing model portfolio recommendations or Clients that have entered into directed brokerage agreements. Other than for model portfolios and directed brokerage, securities transactions normally will be executed through brokers selected by AQR in its sole discretion without the consent of Clients. Before establishing a relationship with any counterparty selected by AQR, the Adviser’s Global Trading group (“GT”) will evaluate the counterparty based on selection factors including, but not limited to, those listed below. In addition, the Adviser’s Counterparty Risk Group will review each proposed counterparty relationship. Only after due diligence is complete will the Counterparty Risk Group approve a counterparty. The Counterparty Risk Group maintains a list of all counterparties approved to execute Client orders and will continue to review those counterparties on an on-going basis. The Best Execution Committee evaluates the selection factors listed below on an ongoing basis. With regard to inducement rules under the recast EU Markets in Financial Instruments Directive (“MIFID II”), where applicable, AQR takes a global unbundling approach and pays for external research and data out of its own or an affiliate’s assets. Brokerage Relationships AQR’s relationships with counterparties, particularly those affiliated with large financial services organizations, are complex. AQR uses various counterparties to execute orders, provide financing to investment vehicles managed by AQR on behalf of Clients, and also has other relationships with certain such firms including, but not limited to, the following examples:

• AQR invests certain Client assets in securities issued by counterparties or their affiliates; • AQR provides investment management services to certain counterparties or their affiliates; • Certain counterparties provide both internally-generated and third-party research and data to AQR; • Certain counterparties refer prospective clients to AQR, serve as placement agents or financial intermediaries, or invest themselves in AQR’s products. In addition, broker-dealers also provide electronic connectivity or direct trading lines related to executing, clearing and settling transactions. Notwithstanding such relationships or business dealings with these counterparties, AQR has a duty to Clients to seek best execution when trading with these firms and has implemented policies and procedures to monitor its efforts in this regard. Selection Factors for Counterparties Best Execution. Clients often grant AQR or its affiliates the authority to select the counterparty to be used for the purchase or sale of securities and investments. Consequently, AQR has a duty to seek best execution of transactions for Clients in which AQR or its affiliates select the broker or counterparty. “Best execution” is generally understood to mean the most favorable cost or net proceeds reasonably obtainable under the circumstances. In seeking best execution, the selection of executing brokers and their respective capabilities on behalf of Clients shall be evaluated by GT and the Best Execution Committee. Each broker evaluation shall be conducted by GT and consider factors including, but not limited to, those described below. The determining factor is not necessarily the lowest possible commission cost, but whether the transaction represents the best qualitative execution overall. The Best Execution Committee has determined that the following factors, to the extent applicable, should be considered in determining whether a broker provides best execution: competitiveness of commission rates or spreads; execution capabilities; clearance and settlement capabilities; access to various market centers; expertise in executing trades for a particular security type; reputation and business practices; overall quality of broker services, including responsiveness and technology support; ability

or willingness to maintain and commit adequate capital; and the size and volume of the broker’s order flow. Recognizing the value of these factors, AQR may select counterparties that charge a commission in excess of that which another counterparty might have charged for effecting the same transaction. AQR is not obligated to choose the counterparty offering the lowest available commission rate if, in AQR’s reasonable judgment, the total cost or proceeds from the transaction may be less favorable than what may be obtained elsewhere or if a higher commission is justified by the service provided by another counterparty. Additional Considerations. When selecting brokers to execute Client trades, employees may not consider factors that are based on a personal benefit or conflicts of interest (e.g., directing execution as a means of compensating others for personal favors). In addition, employees are required to disclose to the Compliance Department any related person of the employee who is employed by or affiliated with a bank, broker-dealer, futures broker or commodities broker, which may present a potential conflict of interest. The AQR Mutual Funds will not compensate a broker or dealer for any promotion or sale of shares of the AQR Mutual Funds by direction to the broker or dealer of the AQR Mutual Funds’ portfolio securities transactions, or any remuneration (including, but not limited to, any commission, mark-up, mark down, or other fee) received or to be received from the portfolio transactions effected through any other broker or dealer (see Rule 12b-1(h) under the Company Act). However, the AQR Mutual Funds are permitted to use a broker or dealer that promotes or sells the AQR Mutual Funds’ shares, provided the business arrangement is in compliance with the conditions required by applicable law and AQR Mutual Funds’ policies and procedures. Review of Counterparty Execution. AQR has implemented internal controls and procedures to address the conflicts of interest associated with its brokerage practices. To determine that it is receiving best execution for its transactions over time, AQR will obtain information as to the general level of commission rates being charged by the brokerage community, from time to time, and will periodically evaluate the overall reasonableness of brokerage commissions paid on Client transactions by reference to such data. To the extent AQR has been paying higher commission rates for its transactions, AQR will determine if the quality of execution and the services provided by the counterparty justify these higher commissions. AQR’s Best Execution Committee is responsible for the design, implementation and oversight of AQR’s best execution governance framework, which includes controls, processes and systems designed to provide reasonable assurance that best execution is achieved for all Clients for transactions directed by AQR, rather than by the Client. The Best Execution Committee reviews commission rates by broker, country, and investment type per Client as part of its overall responsibility. Counterparty effectiveness is evaluated on cost, connectivity, operational performance and other related factors. Moreover, the Counterparty Risk Group reviews credit quality and operational viability of the Adviser’s clearing and execution counterparties. Client Restrictions. Certain Client-imposed restrictions that constrain AQR’s operational efficiency and/or broker selection will impact AQR’s ability to achieve best execution in certain circumstances. Directed Brokerage. AQR generally does not recommend, request, or require that Clients direct AQR to execute transactions through a specified counterparty. However, from time to time, a Client will direct AQR to use a particular counterparty for all or a percentage of trades (a “directed brokerage arrangement”). The Client should consider the costs and disadvantages that may occur if a directed brokerage arrangement is employed, such as higher commissions, less than favorable execution, and/or exclusion from trade opportunities. It is AQR’s practice not to negotiate commission rates with directed counterparties unless expressly requested by the Client. Clients with directed brokerage arrangements thus should consider the following: they may pay higher commissions on some transactions than might be attained by AQR or receive less favorable execution on some transactions, or both; they may not be able to participate in the allocation of initial public offerings; AQR may wait to begin to execute transactions with directed counterparties until non-directed brokerage orders are

completed; and they may not generate returns equal to those Clients that do not have directed brokerage arrangements. Further, Clients who designate the use of particular counterparties should understand that they may lose the possible advantage which non-designating Clients derive from aggregation of orders for several Clients as a single transaction for the purchase or sale of a particular security. Accordingly, a Client with a directed brokerage arrangement should determine whether or not the specified counterparty could provide adequate price and execution for its transactions. Additional Service Provider for Independent / RIA Accounts. In connection with the Independent / RIA Accounts, AQR has entered into an agreement with Vestmark Outsourcing Solutions, Inc. (“Vestmark”) under which Vestmark performs certain administrative and operational functions for the Independent / RIA Accounts, including account administration, reconciliation, recordkeeping, and, in certain circumstances, order processing (including generation and transmission based on AQR’s instruction). Vestmark’s services are paid for by AQR and not by the RIAs, family offices, their clients, or other individual clients who own the Independent / RIA Accounts. AQR delivers the required information related to desired purchases and sales of financial instruments to Vestmark, who routes orders to the custodian’s affiliated broker ultimately executing trades. In certain circumstances, Vestmark aggregates orders when delivering orders for execution. Orders processed by Vestmark are not aggregated with orders for Clients that are not serviced by Vestmark. Prime Brokerage. Many Clients have one or more prime brokers through which the Client’s trade clearance and financing are coordinated. Certain prime brokers also provide AQR with research, data, reporting, and analysis tools as part of their services, which AQR will consider in connection with its broker selection process. Step-Outs. In certain circumstances, AQR uses “step-out trades” when AQR determines that the step-out trades facilitate better execution for certain Client trades or AQR is directed to use such structure. Step-out trades are transactions which are placed at one counterparty and then “given up” or “stepped out” by that counterparty to another counterparty. Step-out trades may benefit the Client by finding a natural buyer or seller of a particular security so that AQR can trade a larger block of shares more efficiently. Unless directed otherwise by the Client, AQR may use step-out trades for any Client. Soft Dollar Arrangements. The term “soft dollars” refers generally to the practice by investment advisers of paying for research and brokerage services using brokerage commissions generated by the execution of trades for their clients’ accounts. AQR does not currently use soft dollars in connection with any of the Clients we advise. To the extent AQR does use soft dollars in the future, we expect that such use will fall within the safe harbor afforded by Section 28(e) of the Securities Exchange Act of 1934, as amended. Brokerage for Client Referrals. AQR does not select counterparties based on or related to Client referrals or in connection with past or future placement of investors into AQR Mutual Funds, AQR UCITS, or Sponsored Funds. Certain broker-dealers host conferences and events for prospective investors. On occasion, representatives of AQR speak at these “capital introduction” events and meet with prospective investors or their representatives. AQR accepts subscriptions from certain investors who also provide services to Clients, including brokers and their affiliates. Relationships such as these could be viewed as creating a conflict of interest that potentially could affect AQR’s ability to seek best execution. While AQR’s relationship with brokerdealers may influence it in deciding whether to use such brokers in connection with trading, financing and other activities of Clients, AQR will not commit with any broker to allocate a particular amount of brokerage to that broker. In addition, AQR will not select any broker for trading purposes based upon any distribution related activity of that broker or one of its affiliates on a Client’s behalf. AQR conducts best execution reviews on a regular basis in an effort to mitigate potential conflicts of interest with brokerage relationships, and to provide reasonable assurance that AQR obtains best execution for all Clients. Trade Aggregation and Allocation. As a fiduciary, AQR and its personnel must exercise due care to reasonably ensure that it places the interests of its Clients first and to allocate investment opportunities fairly and equitably and in accordance with regulatory requirements. The timing, size, and frequency of trading in a Client’s portfolio will be determined by a number of factors, including, but not limited to: (1) investment objectives and guidelines; (2) regulatory restrictions; (3) risk tolerance including exposure control; (4) liquidity needs; (5) redemptions and subscriptions; (6) distance from target exposure; (7) composite dispersion; and (8) market

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Relationships with Consultants Many of AQR’s Clients and prospective Clients retain investment consultants to advise them on the selection and review of investment managers. AQR has certain Clients that were introduced to AQR through consultants. These consultants or their affiliates may, in the ordinary course of their investment consulting business, recommend AQR’s investment advisory services or otherwise place AQR into searches or other selection processes for a particular client. AQR has extensive dealings with investment consultants, both in the consultants’ role as adviser for their clients and through independent business relationships. Specifically, AQR provides consultants with information on portfolios it manages for its mutual clients, pursuant to its Clients’ directions. AQR also provides information on its investment styles and performance to consultants, who use that information in connection with searches they conduct for their clients. AQR also responds to “Requests for Proposals” from prospective clients in connection with those searches. In addition, in certain circumstances:

• AQR invites consultants to events or other entertainment hosted by AQR. • AQR pays registration or other fees for the opportunity to participate, along with other investment managers, in consultant-sponsored industry forums or conferences. These conferences or forums provide AQR with the opportunity to discuss a variety of business topics with consultants, Clients, and prospective Clients.

• In some cases, AQR serves as investment adviser for the accounts of consultants or their affiliates or as adviser or sub-adviser for funds offered by consultants and/or their affiliates. In general, AQR relies on each consultant to make appropriate disclosure to its clients of any conflict that the consultant believes to exist due to its relationship with AQR. Relationships with Brokers As discussed in Item 12 – Brokerage Practices, AQR currently does not have any soft dollar arrangements. AQR does receive research, data and brokerage services from certain counterparties that execute trades for Clients. As noted in Item 12 – Brokerage Practices, with regard to inducement rules under MiFID II, where applicable, AQR takes a global unbundling approach and pays for external research and data out of its own or an affiliate’s assets. AQR has a duty to seek overall best execution of transactions for Clients and has instituted internal controls and procedures designed to ensure that AQR is receiving best execution for Client transactions over time, taking into account all pertinent factors. Other Relationships In certain cases, AQR compensates certain third parties for investor referrals from AQR’s own resources. In other cases, and as disclosed in the relevant fund offering materials, compensation for such third-party investor referrals is paid for by the relevant fund or by the relevant investor. Any such activities will be consistent, as pertinent, with Rule 206(4)-1 under the Advisers Act or other applicable law. The cost of these referral fees is paid entirely by AQR and is not borne by the referred investor. AQR is a party to Client Service/Marketing Agreement(s) with one or more subsidiaries of AMG, under which the AMG subsidiaries provide marketing assistance and support with respect to separately managed accounts and investment funds offered by AQR in certain countries. AQR and/or certain Sponsored Funds have engaged external placement agents for placement of new fund interests. Placement agents that introduce investors to a Sponsored Fund are subject to a conflict of interest to the extent that they will be compensated in connection with their introduction activities. If a prospective investor is introduced to a Sponsored Fund through a placement agent, appropriate disclosure will be made to such prospective investor regarding the arrangement, if any, with such placement agent. If any placement agent receives compensation for its services, such compensation would be made on a fully disclosed basis as outlined in the Sponsored Fund’s offering documentation.

In certain circumstances, AQR (or an affiliate) makes payments out of its own resources to certain financial intermediaries or their affiliates based on sales or assets attributable to the intermediary, or such other criteria agreed to by AQR in connection with the sale or distribution of a Series Fund’s shares and/or the administration of shareholder accounts. AQR selects the intermediaries to which it or its affiliate makes these payments. These additional payments to intermediaries, which are sometimes referred to as “revenue sharing” payments, may represent a premium over payments made by other fund families, and investment professionals may have an added incentive to sell or recommend a Series Fund or a share class of the Series Fund over others offered by competing fund families. In certain circumstances, AQR makes other payments to broker-dealers and/or financial intermediaries to the extent permitted by SEC and FINRA rules and by other applicable laws and regulations, such as paying registration or other fees for the opportunity to participate, along with other investment managers, in industry-sponsored industry forums or conferences. These conferences or forums provide AQR with the opportunity to discuss a variety of business topics with industry participants, consultants, clients, and prospective clients.

AQR has no information to report with respect to this Item.

AQR’s portfolio managers, client administration analysts, and the Compliance Department frequently communicate with the trading and portfolio management staff to review the status of, and to provide instructions or guidance concerning, pending transactions for, and overall performance of, each Client’s account. The level of review and guidance provided by AQR’s portfolio management personnel varies based upon facts and circumstances specific to individual Clients. Generally, a review of a Client’s account includes specific instruments held, adherence to investment guidelines, and account performance. Although AQR reviews each Client’s account on a regular basis, there are facts and circumstances which will prompt ad hoc reviews. Significant market events affecting the prices of one or more instruments held by a Client, changes in investment objectives or guidelines of a particular Client, or specific arrangements with particular Clients or investors may trigger more frequent reviews of a particular Client’s account. In addition, various investment committees of the Adviser are responsible for monitoring investment strategies employed by the respective portfolios. These committees generally have an overall responsibility for monitoring the portfolios’ investments. Subscribers in Sponsored Funds are generally furnished (i) as soon as practicable after the end of each fiscal year, written annual reports of the relevant Sponsored Fund(s) that include audited financial statements prepared in accordance with U.S. generally accepted accounting principles or other acceptable accounting principles; and (ii) on a basis no less frequently than quarterly, written unaudited reports on the operations of the relevant Sponsored Fund(s) which include a statement of the net asset value of the Subscriber’s interest in such Sponsored Fund(s). Subscribers in Sponsored Funds receive reports from AQR pursuant to the terms of each Sponsored Funds’ offering memoranda or investor Side Letter. Institutional Managed Account and Independent / RIA Account Clients receive regular written reports from their custodian and receive operational reports from AQR upon request or as required in the investment management agreement. See also Item 15. Investors in AQR Mutual Funds receive, or have access to, certain written quarterly and other periodic reports of open-ended registered investment companies, which are available on the SEC’s website at www.sec.gov and certain of these reports are also posted to the AQR Mutual Funds website https://funds.aqr.com. In addition, on or about 15 days following the end of each calendar quarter, each Series Fund will make available on the AQR Mutual Funds website, a complete uncertified schedule of its portfolio holdings as of the end of the quarter. Investors in AQR UCITS receive regular written reports from AQR in accordance with the principles established in the UCITS directives.

AQR is deemed to have custody of the assets of Private Funds and AQR UCITS by virtue of AQR’s or its affiliates’ control over such funds’ assets or role as general partner and/or managing member of such funds. Investment advisers with custody of client funds or securities are required to comply with the requirements of Rule 206(4)-2 of the Advisers Act. AQR does not have actual physical custody of any investor funds or securities invested in such funds; rather, all such assets are held in the name of each of the applicable funds by an independent qualified custodian. Each applicable fund is audited annually by an independent public accountant, and investors receive annual financial statements within 120 days following such fund’s fiscal year end, as required by applicable law.8 AQR does not custody the assets of the AQR Mutual Funds, CITs, Australian Funds, Institutional Managed Accounts, or of the Independent / RIA Accounts. Institutional Managed Accounts and Independent / RIA Accounts must make their own arrangements for custody of securities. Such custodians may be broker-dealers, prime brokers, banks, trust companies, or other qualified institutions. The qualified custodian will typically provide these Clients with at least quarterly account statements relating to the assets held within the account advised by AQR. These Clients should carefully review the qualified custodian’s statement upon receipt to determine that it completely and accurately states all holdings in the account and all account activity over the relevant period. Any discrepancies identified by a Client should be immediately reported to AQR and the qualified custodian. In addition to the account statements provided by qualified custodians to AQR’s Institutional Managed Accounts, AQR also provides account statements to Institutional Managed Accounts and Independent / RIA Accounts on a periodic basis, as agreed upon between the applicable Clients and the Adviser. These statements are intended to complement, not replace, the statements provided by the Institutional Managed Account’s or Independent / RIA Account’s qualified custodian. As such, AQR encourages Institutional Managed Accounts and Independent / RIA Accounts to compare the statements provided to them by AQR against those provided to them by their qualified custodians who hold the assets of their accounts, and to report any questions, concerns, or discrepancies to both the Adviser and the qualified custodian promptly. AQR’s statements may vary from custodial statements based on accounting procedures, reporting dates, and/or valuation methodologies of certain securities. However, please note that custodian statements reflect the official books and records for the Institutional Managed Accounts and Independent / RIA Accounts.

Private Funds that rely on CFTC Rule 4.7 provide their Subscribers with annual reports within 90 days of the Sponsored Fund’s fiscal year end.

AQR generally provides investment advisory services on a discretionary basis to Clients, though as noted above in Item 4 – Advisory Business, AQR does provide non-discretionary model portfolio recommendations to Model Platforms. Prior to assuming discretion in managing a Client’s assets, the Adviser enters into a written investment management agreement or other agreement that sets forth the scope of the Adviser’s discretion. The agreement gives the Adviser the authority to determine the timing and amount of securities and other instruments to be purchased and sold for the Client account (subject to restrictions on AQR’s activities set forth in the applicable agreement, any written investment guidelines and applicable law). Because of the differences in Client investment objectives and strategies, risk tolerances, tax status, liquidity considerations, and other criteria, there may be differences among Clients in invested positions and amounts held. Please see Item 12 – Brokerage Practices. From time to time, certain securities, non-securities contracts and/or other investment instruments that are or were held by Clients are the subject of a class action or other legal proceeding. AQR utilizes the services of Financial Recovery Technologies (“FRT”) to identify, analyze, assert and file claims in class actions and other legal proceedings on behalf of its UCITS Funds, Sponsored Funds and Series Funds and any Institutional Managed Accounts that have expressly delegated such authority to AQR. FRT retains a percentage of any recovery, subject to certain maximums, as payment for the claims that it files on behalf of AQR Clients.

AQR’s authority to vote proxies for its Clients, if granted, is established by its investment advisory agreements or comparable documents. AQR has established proxy voting policies and procedures, and AQR’s Compliance Department monitors the proxy voting process. The proxy voting procedures are designed to ensure that proxies are voted in the Clients’ best interest. AQR will generally vote proxies according to the proxy voting guidelines adopted by AQR and agreed upon with an independent third-party proxy voting advisor. From time to time, AQR will determine to vote a particular proxy contrary to the agreed upon voting guidelines which could give rise to potential conflict of interest. AQR’s Proxy Voting Policy includes guidelines to identify and resolve conflict of interests related to voting proxies on behalf of AQR’s Clients. AQR’s authority to vote proxies for its Clients is not a material component of any of AQR’s investments or strategies. AQR typically follows a systematic, research-driven approach, applying quantitative tools to process fundamental information and manage risk, significantly reducing the importance and usefulness of the proxies AQR receives and votes, or causes to be voted, on behalf of its Clients. Additionally, from time to time, AQR may not or may not be able to cast a vote prior to the cutoff date for reasons including, but not limited to, timing of transferring proxy information or account setup. AQR does not view non-voted proxy ballots to be a material issue for either the Clients or AQR’s investment strategies. Upon request, AQR will provide Clients with a copy of its proxy voting policies and procedures and information on how the Client’s proxies were instructed to be voted. In certain circumstances, Clients are permitted to direct their votes in a particular solicitation. A Client that wishes to direct its vote in a particular solicitation shall give reasonable prior written notice to AQR indicating such intention and provide written instructions directing AQR to vote in regard to the particular solicitation. Where such prior written notice is received, AQR will vote proxies in accordance with such written instructions received from the Client on a best effort’s basis. AQR from time to time discusses certain matters with issuers to represent Client interests; however, regardless of such conversations, AQR acquires securities on behalf of Clients solely for the purpose of investment and not with the purpose or intended effect of changing or influencing the control of any issuer.

This Item is not applicable.

Additional Information – Notice to Canadian Clients AQR Capital Management, LLC hereby provides notice that it has filed to rely, and is actively relying on the International Adviser Exemption in the provinces of Alberta, British Columbia, Manitoba, Nova Scotia, Ontario, Quebec, and Saskatchewan, pursuant to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (“NI 31-103”). For purposes of such exemption, AQR is required to advise you of the following: 1. AQR Capital Management, LLC is not registered as an adviser in any province or territory of Canada; 2. the jurisdiction of AQR Capital Management, LLC’s head office and principal place of business is the state of Connecticut, United States; 3. all or substantially all of AQR Capital Management, LLC’s assets are or may be situated outside of Canada; 4. there may be difficulty enforcing legal rights against AQR Capital Management, LLC in Canada because it is resident outside Canada and all or substantially all of its assets are or may be situated outside of Canada; 5. the full name and address of AQR Capital Management, LLC’s agents for service of process in each of the exempted jurisdictions of Canada, can be found below. Please note that our agents for service are solely for purposes of serving upon us notices, pleadings, subpoenas, summons or other proceedings arising out of or relating to or concerning our activities. Should you have any questions or require any information, please contact us at 203-742-3600 or info@aqr.com. AQR Capital Management, LLC has appointed the following agents for service of process in the Canadian provinces listed below:

Jurisdiction

Agent for Service of Process

Alberta

Osler, Hoskin & Harcourt LLP Suite 2700, Brookfield Place 225 – 6th Avenue S. W. Calgary, AB T2P 1N2

British Columbia

Osler, Hoskin & Harcourt LLP Suite 3000, Bentall Four 1055 Dunsmuir Street Vancouver, BC V7X 1K8

Manitoba

MLT Aikins LLP 30th Floor, 360 Main Street Winnipeg, MB R3C 4G1

Nova Scotia

Stewart McKelvey Queen’s Marque 600-1741 Lower Water Street Halifax, NS B3J 0J2

Ontario

Osler, Hoskin & Harcourt LLP 100 King Street West 1 First Canadian Place, Suite 6200 Toronto, ON M5X 1B8

Québec

Osler, Hoskin & Harcourt LLP 1000 rue de la Gauchetiere Street West Suite 2100 Montréal, QC H3B 4W5

Saskatchewan

McDougall Gauley LLP 1500 – 1881 Scarth Street Regina, SK S4P 4K9