Bridgewater Associates

Bridgewater provides discretionary investment management services to pooled investment vehicles and single investor funds (“funds”), and managed account clients (collectively, “Clients”). Bridgewater also provides non-discretionary investment advisory services to non-affiliated entities. Bridgewater began investment operations in 1975, initially providing consulting services in global markets, and in 1985, Bridgewater began managing assets for institutional investors. In 1990, Bridgewater registered as an investment adviser with the SEC. Additionally, Bridgewater publishes The Bridgewater Daily Observations, which is Bridgewater's flagship research publication. In 2022, Bridgewater completed the formal transition of control of Bridgewater Associates, LP to a board of directors. In July 2025, Bridgewater repurchased the last remaining ownership shares held by Ray Dalio-related entities. The consistency of Bridgewater’s investment philosophy and people has been a trademark of Bridgewater for 50 years. Bridgewater is and has always been independent and employee-controlled. Bridgewater’s client and fund investor base consists of a wide array of institutional investors globally, which include, but are not limited to, corporate and public pension funds, foreign governments and central banks, university endowments, charitable foundations, family offices, fund of funds and similar third-party entities, registered investment companies, and union/Taft Hartley plans. Bridgewater structures portfolios in a manner designed to produce consistent returns. Bridgewater believes that building portfolios based on risk allocations is more effective than using capital allocations and that investors should consider their strategic asset allocation (beta) separate from tactical moves (alpha). Bridgewater believes investors can improve their portfolios’ overall results by separately creating a well-diversified beta portfolio that is balanced against environmental biases and calibrated to one's targeted returns, and a well-diversified alpha portfolio that reduces systematic biases (and is calibrated to one's targeted returns). Bridgewater applies this approach to investing across the portfolios it manages. Pure Alpha is what we consider to be our optimal Alpha, which seeks to generate high returns with no bias to markets or other managers. All Weather is our optimal beta strategy, which seeks to capture the risk premiums embedded in assets as consistently as possible by balancing its exposure to the primary drivers of market volatility. We are also dedicated to building other portfolio solutions that seek to help our clients achieve their goals, including innovative ways to hold different kinds of beta, alphas that play a distinct role in a total portfolio (such as being structurally diversifying to the rest of the portfolio), new sources of alpha (such as using artificial intelligence and machine learning to generate returns in markets), and solutions that draw on both alpha and beta (such as portfolios designed to offer more geographic diversification and boost portfolio resiliency). In most cases, clients access these strategies through our commingled funds, though in select cases, Bridgewater can tailor these strategies through a single investor fund or managed account and apply any client specific requirements or restrictions. Bridgewater’s Investment Committee is responsible for all aspects of our investment process, including portfolio risk management, performance oversight of all portfolios and investment systems, and the governance and delegation of investment decision-making authority. While its membership evolves over time, the Committee currently is led by Co-CIOs Bob Prince, Greg Jensen, and Karen Karniol-Tambour and is further comprised of other senior investors. Bridgewater and its funds utilize the processes and technology of Bank of New York Mellon (“BNY”) and Northern Trust (“NT”) as primary and secondary providers of fund administration, middle/back office, and custodial services. Bridgewater retains overall responsibility for the monitoring of these services and has implemented a tri-party model whereby a secondary provider independently replicates and verifies certain activities of the primary provider. This model adds an additional level of protection and security for our clients and enhances business continuity capabilities. As of December 31, 2025, Bridgewater manages Client assets on a discretionary basis in the amount of approximately $102,400,000,000.

Bridgewater’s only direct owners are (i) Bridgewater Associates Intermediate Holdings, LP (“Intermediate Holdings”), a general partner and limited partner of Bridgewater and (ii) Bridgewater Partner, LLC (“BP LLC”), a limited partner of Bridgewater. Intermediate Holdings is the sole Member of BP LLC, and as a result, is effectively Bridgewater’s sole direct owner. Bridgewater Associates Holdings, LLC (“BAH LLC”) is the ultimate parent entity and owns approximately 80% of Intermediate Holdings, with the remaining approximately 20% being held by a small group of external institutional investors in the form of non-voting, limited partnership units. For detail regarding ownership of BAH LLC, please see Bridgewater’s Form ADV Part 1. BAH LLC, Intermediate Holdings, BP LLC and Bridgewater are all Delaware entities. Bridgewater’s ADV Part 1, including a listing of direct owners and executive officers, is publicly available on the SEC’s website at www.adviserinfo.sec.gov.

Bridgewater offers fee arrangements which vary by strategy and involve management fees (“Management Fees”, generally a percentage of assets), performance fees/allocations (“Profit Participation”, generally a percentage of profits) or some combination of the two. Fees are negotiable, and individual arrangements are based on the specific investment strategy as well as Client and/or fund investor specific factors, including, but not limited to, assets under management, the risk/return parameters of the investment, the structure of the investment, and the structure of the Management Fees and Profit Participation, negotiated by each specific fund investor. Management Fees are asset-based fees as described in each Client’s offering memorandum, investment management agreement, or other governing document, as applicable. For certain Clients, Bridgewater is entitled to receive a Profit Participation, that is typically based on a percentage of profits for each calendar quarter or year, as applicable. Profit Participations can be subject to adjustments for any previous unrecovered net losses (or underperformance relative to an applicable benchmark). Note that Bridgewater has waived, reduced, and/or otherwise modified Management Fees and/or Profit Participations for certain Clients (or fund investors therein, as applicable) and can do so in the future. Similarly, Bridgewater has substituted Management Fees in whole or in part with Profit Participations (or vice versa) as agreed to with Clients (or fund investors therein, as applicable) and can do so in the future. Bridgewater charges fees to certain non-discretionary clients based on a percentage of the market value of assets under management and that are negotiated with the client. In addition to external investors, investments in Bridgewater funds can be made by Bridgewater and by certain employees and officers of Bridgewater (including members of the portfolio management team and other senior employees, or entities formed for investment purposes by such employees and officers for their own benefit). Such officers and employees may not be charged Management Fees or a Profit Participation but will be subject to the same rights and obligations, including redemption rights, expenses and transaction costs, as those of the other investors. Bridgewater manages investments through separate Client accounts and/or commingled fund vehicles. In both cases, in addition to the fees stated above, there are additional fees and expenses borne by Clients, such as auditor fees, custodian fees, back and middle office fees, regulatory and legal expenses (including class action and collective claim recovery and administration fees), transaction expenses (including brokerage fees), and government filing fees. Clients may be charged additional fees by their service providers, such as a fee from a bank to wire money. Bridgewater funds also bear, either directly or indirectly, the cost of certain organizational, administrative, offering and other expenses as set forth below. In addition to the fees and expenses referred to above, each fund will bear all of its ongoing offering expenses (including, in some cases, initial organizational expenses, which may be amortized over a period of 36 months). Each fund will also bear either directly or indirectly all of its ongoing operating and other expenses. The expenses incurred by each fund are expected to include: investment expenses, including expenses which Bridgewater determines to be related to the investment of the assets of a fund such as: fees, expenses, charges and other costs relating to short sales; clearing and settlement fees, expenses, charges and other costs; custodial fees, expenses, charges and other costs (including initial costs associated with the establishment of custodial, settlement agency or other service provider relationships); fees, expenses, charges and other costs relating to trade confirmation; fees, expenses, charges and other costs relating to trade settlement (including overdraft charges or fees incurred in the normal course of trading and other brokerage fees and futures commission merchant fees, commissions and expenses); fees, expenses, charges and other costs of margin and collateral management and reconciliation of trades and holdings; fees, expenses, charges and other costs incurred in connection with entering into trading documentation, including costs associated with any periodic amendments to such trading documentation; fees, expenses, charges and other costs of terminals; fees, expenses, charges and other costs relating to reorganizations, restructurings and workouts involving a fund’s investments, including any portion thereof allocated to a fund by the relevant issuer or its service providers; bank service fees, expenses, charges and other costs, including cost of account maintenance, wiring fees and other associated costs; fees, expenses, charges and other costs associated with borrowing or obtaining leverage, including interest expenses, upfront facility fees, ongoing maintenance fees and similar costs; extraordinary expenses; and fees, expenses, charges and other costs incurred in connection with identifying and investigating investments that are ultimately not consummated and investment strategies that are

ultimately not included as part of a fund's investment program; research expenses, including expenses and costs of research resources utilized by Bridgewater generally in connection with the management of various Clients (certain of which research resources may or may not be used directly in connection with the investments of the strategies); fees and expenses associated with data, information systems and technology utilized directly or indirectly by Bridgewater for purposes of developing, acquiring, analyzing or reviewing investment research, investment analysis, portfolio management or other related process, including any research resources utilized in connection with such activities, hardware expenses (e.g., internal servers, circuits, routers, equipment rental, data transmission lines, communications equipment and other equipment used to access data), software expenses, subscription costs to access data, technology and other third-party platforms (e.g., third-party technology provider platforms, risk monitoring platforms, cloud computing platforms and other internet access costs), and fees and expenses of third-parties retained to assist in such activities; professional fees (including, fees and expenses of consultants, experts, accountants, advisors and outside counsel, whether retained by a fund, Bridgewater or another Bridgewater party); fees, expenses, charges and other costs relating to the drafting, negotiating and filing of the organizational and offering documents and subscription agreements of the funds, including any fees, expenses, charges and other costs associated with modifying, supplementing, amending or otherwise adjusting such documents; fees, expenses, charges and other costs associated with distributing any documentation to persons considering making an initial or additional investment in a fund, including any fees, expenses, charges and other costs incurred in connection with the preparation and distribution of reports and notices and the negotiation of the terms of any such investment (e.g., side letters or other similar contracts); costs of currency conversions; costs of currency hedges ; legal fees and expenses, including fees, expenses, charges and other costs of outside counsel, whether retained by a fund, Bridgewater or another Bridgewater party; fees, expenses, charges and other costs of proxy voting services, third-party investment sourcing fees, including fees and expenses payable to investment banks and other market participants; accounting, auditing, and tax advisor fees and expenses; administration fees and expenses; expenses of other agents of the fund (including, expenses of a “tax matters partner” or “partnership representative” of the fund, if applicable); director fees (including any reasonable travel, accommodation, or other expenses incurred in carrying out their duties as directors, if applicable), expenses, charges and other costs; administration fees, expenses, charges and other costs; fees, expenses, charges and other costs of other agents of a fund; taxes, governmental fees, expenses, charges and other costs and similar amounts; printing and mailing fees, expenses, charges and other costs; fees, out-of-pocket expenses, charges and other costs of any service company retained to provide accounting, middle/back-office services, bookkeeping, reconciliation, data aggregation, trade processing, reporting, monitoring, quality control (including shadow services), class action and collective claim recovery and administration services, risk management products, models and services or other services to the funds or Bridgewater relating to the funds, including, any service provider assisting the funds, the general partner of a fund (whether on behalf of itself or on behalf of a fund) or Bridgewater (whether on behalf of itself or on behalf of a fund) in connection with their respective regulatory, legal and/or compliance obligations under applicable law, such as costs and expenses incurred in connection with the preparation and/or filing by a general partner or Bridgewater (in each case either on behalf of itself or on behalf of the funds) of various filings or registrations with, or licenses obtainable from, any U.S. federal, state or local, non-U.S. or multinational governmental, regulatory, self-regulatory or other authority (e.g., Form PF, Form CPO-PQR, or any corresponding form filed, or registration made, with any non-U.S. regulator on behalf of Bridgewater or any of its affiliates, any filings or registrations required to be made under the AIFMD or any other multinational compliance regime, any filings required under U.S. securities laws, such as Section 13 or 16 of the U.S. Securities Exchange Act of 1934, as amended, any filings required to be made pursuant to the lobbyist registration laws of any jurisdiction in which interests in the funds are marketed and any other regulatory, legal and/or compliance filings, registrations or licenses which are required to be made or obtained, as applicable, as well as newly-arising and/or unanticipated costs or expenses arising from newly-imposed regulations and self-regulatory requirements); quotation or valuation fees, expenses, charges and other costs (including fees, expenses, charges and other costs of any third parties engaged to provide valuation services to the funds); insurance premiums and other similar fees, expenses, charges and other costs, including a fund’s share of any insurance premiums and other similar fees, expenses, charges and other costs associated with obtaining insurance for any Bridgewater person; compliance fees, expenses, charges and other costs; a portion of the operating expenses of the general partner; extraordinary fees, expenses, chares and other costs including: fees, expenses and other costs incurred in connection with any litigation, government investigation, or dispute in connection with the business of a fund, and the amount of any judgment or settlement paid in connection therewith, or the enforcement of a fund’s rights against

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As a firm, we apply our fundamental, systematic, and diversified approach in an effort to design high-quality portfolios that help our clients address their challenges. We consider alpha (return from outperforming in actively trading and timing markets) and beta (compensation for passively holding risky assets) as distinct building blocks. In terms of our strategies: Pure Alpha is our optimal Alpha, designed to generate high returns with no bias to markets or other managers. All Weather is our optimal beta, which seeks to capture the risk premiums embedded in assets as consistently as possible by balancing its exposure to the primary drivers of market volatility. We are also dedicated to building other portfolio solutions that seek to help our clients achieve their investment goals, including innovative ways to hold different kinds of alpha and beta that play a distinct role in a total portfolio (such as being structurally diversifying to the rest of the portfolio), new sources of alpha (such as using artificial intelligence and machine learning to generate returns in markets), and solutions that draw on both alpha and beta (such as portfolios designed to offer more geographic diversification and boost portfolio resiliency). We manage ~$100 billion in assets across these strategies for ~170 institutional clients and investors globally, including public and corporate pension funds, university endowments, charitable foundations, foreign governments, and central banks. An investment in any Bridgewater strategy involves a high degree of risk. An investment in our strategies is considered appropriate only for sophisticated or professional Clients who can afford the risks associated with trading in the markets. Each Client must have enough knowledge and experience in financial and business matters to be capable of evaluating the merits and risks of such an investment. No guarantee or representation is made that the strategies will be successful, that the targeted return and risk will be achieved or maintained, or that the various investments made in the strategies will have low correlation with each other or with the financial markets in which the strategies invest. The risk of loss in investing in the strategies can be substantial, including the potential loss of the entire amount invested by a Client in a fund. Separately managed account clients can potentially lose more than their investment. Prospective Clients should therefore carefully consider whether such an investment is suitable for them in light of their financial condition. Before investing in the strategies, prospective Clients should be aware of the risks associated with an investment in the strategies, which include, but are not limited to, the risk factors listed below. No list of risk factors can be expected to be full and complete, and the risk factors set forth herein apply to certain strategies but not necessarily all; please refer to the offering materials related to a specific strategy for additional information. Each prospective Client should discuss any proposed initial or additional investment in a strategy with such person’s investment, tax, accounting, legal and other advisers prior to making an investment. The following summary of certain material risk factors has been prepared solely to help guide those discussions and to assist each prospective Client in determining what questions, if any, he, she or it may wish to address to Bridgewater in connection with an investment decision. All references to the investments made by a strategy include investments made directly or indirectly through one or more funds. Risks of Investing in Certain Instruments Asset-Backed Securities. The strategies can invest in mortgage-backed securities and other asset-backed securities, whose investment characteristics differ from traditional debt securities. Among the major differences are that interest and principal payments are made more frequently, usually monthly, and that principal may be prepaid at any time because the underlying mortgage loans or other assets generally may be prepaid at any time. Mortgage-backed securities and asset-backed securities may also be subject to call risk and extension risk. For example, because homeowners have the option to prepay their mortgages, the duration of a security backed by home mortgages can either shorten when voluntary prepayments accelerate (i.e., call risk) or lengthen when voluntary prepayments slow (i.e., extension risk). In general, if interest rates on new mortgage loans fall sufficiently below the interest rates on existing outstanding mortgage loans, the rate of prepayment would be expected to increase. Conversely, if mortgage loan interest rates rise above the interest rates on existing outstanding mortgage loans, the rate of prepayment would be expected to decrease. In either case, a change in the prepayment rate can result in losses to investors or significantly impact the expected internal rate of return. The same would be true of other asset-backed securities, such as securities backed by car loans.

Below Investment-Grade Debt. The strategies will invest in below investment-grade fixed income securities. Bonds and other fixed income securities, including “higher yielding” (and, therefore, higher risk) below investment-grade debt securities entail certain risks. Such securities may face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer’s inability to meet timely interest and principal payments. High yield bonds (commonly known as “junk bonds”) and other debt securities that may be acquired by the strategies may be junior to the obligations of companies to senior creditors, trade creditors and employees. The lower rating of high yield debt reflects a greater possibility that adverse changes in the financial condition of the issuer or in general economic, financial, competitive, regulatory or other conditions may impair the ability of the issuer to make payments of principal and interest. High yield debt securities have historically experienced greater default rates than investment grade securities. Business/Commercial Risks. Investments by the strategies in the debt obligations of certain companies may involve a high degree of business and financial risk. Such companies may be in an early stage of development; may not have a proven operating history; may be operating at a loss or have significant variations in operating results; may be engaged in a rapidly changing business; may require substantial additional capital to support their operations, to finance expansion or to maintain their competitive position; or may otherwise have a weak financial condition. The strategies may invest in the debt obligations of companies that may be highly leveraged. Leverage may have important adverse consequences to such companies and to the strategies invested in the debt obligations of such companies. Such companies may be subject to restrictive financial and operating covenants. Leverage may impair such companies’ ability to finance their future operations and capital needs and pay their debts. As a result, such companies’ flexibility to respond to changing business and economic conditions and to business opportunities may be limited. A leveraged company’s income and net assets will tend to increase or decrease at a greater rate than if borrowed money were not used. In addition, such companies may face intense competition, including competition from companies with less leverage; greater financial resources; more extensive development, marketing and other capabilities; and a larger number of qualified personnel. As such, there can be no assurance that the strategies’ investment in the debt obligations of any such company will perform to expectations. Corporate Debt Securities. The strategies will invest in corporate debt. Corporate debt securities are subject to the risk of the issuer’s inability to meet principal and interest payments on the obligation and may also be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity. When interest rates decline, the value of the strategies’ corporate debt securities can be expected to rise, and when interest rates rise, the value of those securities can be expected to decline. Debt securities with longer maturities tend to be more sensitive to interest rate movements than those with shorter maturities. Credit Default Swaps and Other Credit Derivatives. The strategies will purchase and sell credit default swaps or other credit derivatives—both for hedging and for other purposes. The typical credit default swap contract requires the seller to pay to the buyer, in the event that a particular reference entity experiences one or more specified credit events, the difference between the notional amount of the contract and the value of a portfolio of securities issued by the reference entity. In return, the buyer agrees to make periodic payments equal to a fixed percentage of the notional amount of the contract. In circumstances in which the strategies do not own the debt securities that are deliverable under a credit default swap, the strategies are exposed to the risk that deliverable securities will not be available in the market, or will be available only at unfavorable prices, as would be the case in a so-called “short squeeze.” In certain instances of issuer defaults or restructurings, it has been unclear under the standard industry documentation for credit default swaps whether or not a “credit event” triggering the seller’s payment obligation had occurred. Certain initiatives implemented by derivatives market participants, including the International Swaps and Derivatives Association (“ISDA”), are designed to implement uniform settlement terms into standard credit default swap documentation, as well as refine the practices for the transparent conduct of the credit default swap market generally. Among these initiatives are the ISDA Credit Derivatives Determinations Committee and the implementation of market-wide cash settlement protocols applicable to all market-standard credit default swaps. These initiatives are intended to reduce both the uncertainty as to the occurrence of credit events and the risk of a “short squeeze” by providing that the ISDA Credit Derivatives Determinations

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Bridgewater provides investment management services principally to institutional clients, including, but not limited to, corporate and public pension funds, foreign governments and central banks, university endowments, charitable foundations, family offices, fund of funds and similar third-party entities, registered investment companies, and union/Taft Hartley plans, through both managed accounts and commingled fund vehicles. To invest with Bridgewater, prospective investors should familiarize themselves with the legal requirements and tax consequences specific to each fund investment or separately managed account. For fund investments, any purchase made on the basis of information inconsistent with or not contained in the offering memorandum(s) provided to the prospective investor will be at the sole risk of the investor. Prospective fund investors are required to complete a subscription agreement, which will require disclosure of certain private information required to substantiate the investor’s identity and investment qualifications. Bridgewater investors must be sophisticated investors who (i) can afford the risks associated with futures, commodities, currencies, options, forwards and other derivatives trading, and (ii) have sufficient knowledge and experience in financial and business matters to evaluate the risk of an investment in a fund or account managed by Bridgewater and determine its suitability. Generally, the minimum initial investment in a fund managed by Bridgewater is in accordance with the minimum fee requirement for that strategy, and the minimum initial investment outlined in each fund’s offering memorandum. However, the directors, general partner, manager or member manager, as applicable, of a fund, may, and sometimes do, accept initial subscription amounts below such minimum. The directors, general partner, manager and member manager of the funds, as applicable, are generally free to accept or reject subscriptions for any or no reason without obligation to disclose the underlying reason(s).

As noted in Item 5, for certain Clients Bridgewater charges performance-based compensation, which is subject to negotiation. Bridgewater structures any performance or incentive fee arrangement in accordance with Section 205(a)(1) and Rule 205-3 of the Advisers Act. With respect to Clients, Bridgewater undertakes to act in a fair and equitable manner and to identify, resolve and mitigate conflicts of interest or potential conflicts in a timely manner. Because Bridgewater has the responsibility for managing more than one account or fund, often with different mandates or fee structures, (e.g., side-by-side management), conflicts of interest can arise. First, there is a potential for providing preferential treatment to one account or fund over others in terms of allocation of management time, resources, and investment opportunities. To mitigate the risk of favoring certain Clients over others, Bridgewater has implemented policies and procedures to address participation in investment opportunities and trade allocation decisions, as well as order aggregation and brokerage allocation decisions. These policies and procedures (discussed more fully in Item 11 and Item 12) seek to ensure fair allocation of investment opportunities among all Clients. Bridgewater’s portfolio oversight and Compliance teams examine performance dispersion among accounts employing similar investment strategies to ensure that any material divergence from expected performance is adequately understood. Second, there could exist an incentive to trade some accounts more aggressively than others in an effort to maximize the profits for those accounts in which Bridgewater would benefit from a performance-based fee. To mitigate that risk, Bridgewater designs its systematic portfolio construction system and randomized trade allocation policies and procedures (discussed more fully in Item 12) to minimize the potential for such bias.

Bridgewater and/or a related person acts as general partner, manager, managing member, director or other controlling entity in private funds that invest in securities, commodities or other investments in which Bridgewater’s Clients can be solicited or wish to invest. Please note that Item 6, Item 11 and Item 12 discuss Bridgewater’s trade aggregation and allocation policies in more detail and discuss how Bridgewater seeks to minimize conflicts between its Client separately managed accounts and funds. Bridgewater is registered as a Commodity Trading Advisor and a Commodity Pool Operator with the CFTC and is a member of the National Futures Association. Bridgewater does not act in any capacity as a broker-dealer or a futures commission merchant. As discussed in Item 4, Bridgewater has contracted with Northern Trust and Bank of New York Mellon for middle and back office services, and each of those entities (or their affiliates) serves as an investment manager of certain cash management vehicles which Bridgewater, from time to time, recommends or selects for its discretionary Clients. Bridgewater selects these cash vehicles based upon the yield, safety, and liquidity they offer as well as the fact that it is inherently more operationally efficient to utilize a cash vehicle that is also managed by the account’s custodian. Bridgewater also has business relationships with other related persons that are investment advisers that are material to Bridgewater’s advisory business but do not create material conflicts of interests with Clients. As noted in Schedule D Section 7.A. of Bridgewater’s Form ADV Part 1, Bridgewater (China) Investment Management Co., Ltd. (“BCIM”) is a wholly owned foreign affiliate of Bridgewater Associates, LP located in Shanghai. BCIM was granted a Private Fund Manager (“PFM") license by the Asset Management Association of China in June 2018. BCIM does not provide investment advisory services to Bridgewater. Bridgewater Associates (Singapore) Management, PTE. LTD. (“BASM”) is a wholly owned foreign affiliate of Bridgewater Associates, LP located in Singapore. BASM was granted a Capital Markets Services license by the Monetary Authority of Singapore in July 2022 and is a foreign private adviser to Bridgewater.

Bridgewater’s Code of Ethics (“Code”), adopted pursuant to Rule 204A-1 under the Advisers Act, and approved by the board of trustees of Bridgewater’s investment company clients, confirms Bridgewater’s commitment to the highest ideals of honesty, integrity and openness. Bridgewater demonstrates this commitment through its measures taken to ensure the confidentiality of Client information, prohibition of illegal insider trading and market manipulation, policies governing the acceptance of gifts and provision of political contributions, and the scrutiny applied to the personal investments and other outside activities of employees. All employees undergo Code of Ethics training when they begin employment and periodically after that, in addition to certifying annually that they have read and understand the Code. A copy of the Code is available to Clients or prospective Clients by submitting a request to Bridgewater’s Chief Compliance Officer and Counsel at Compliance@bwater.com. Aspects of Bridgewater’s personal trading policy include: 1. All full-time employees and subjected consultants (not just “access persons” as defined by the SEC) are required to provide duplicate account statements or electronic feeds of their accounts to Bridgewater’s Compliance group; 2. Pre-clearance of most trades through Bridgewater’s automated compliance system; 3. A 60-day holding period for profitable trades; 4. All investments are restricted to a list of permissible instruments and securities; 5. A requirement for employees to hold most types of accounts at an approved broker from which Bridgewater receives a direct electronic feed of trading activity; and 6. Any accounts held for the benefit of Bridgewater employees and/or trades for such accounts placed through Bridgewater's Portfolio Implementation process are exempt from the personal trading rules and pre-clearance requirements since they are subject to the same trading policies, procedures, and guideline monitoring as separately managed Client accounts and fund investments. Investment decisions are made across Client portfolios by a systematic investment process with parameters set according to specific Client targets and guidelines. The Compliance group reviews the outcome of this process for consistency across portfolios with similar investment objectives and guidelines. Bridgewater has tight controls around access to the output of the investment process, and only certain employees have access to forward-looking trade information. Bridgewater’s personal trading policy allows employees to purchase or sell similar securities to those purchased and sold for Client accounts. However, all employees are subject to restrictions and monitoring intended both to allow reasonable long-term investing and to prevent short-term trading or the ability to trade in a way that is related to Bridgewater’s trading in Client accounts. Personal trading by employees is monitored by Bridgewater’s Compliance group. Bridgewater may recommend to Clients that they buy or sell securities or investment products in which Bridgewater or a related person has a financial interest. Specifically, Bridgewater recommends that Clients invest in commingled funds where Bridgewater or a related person acts as a member manager, manager, investment manager and/or director and recommends that Clients invest in commingled funds in which Bridgewater, one of its affiliates, their respective officers, directors, partners, members, employees or agents or investment funds or accounts managed, advised or sponsored by Bridgewater has made, or may make, an investment. Bridgewater’s decision to recommend that a Client invest in any commingled fund or other securities is based solely on the suitability of the investment for the particular Client. In addition, as stated above and in Item 6, Bridgewater’s Portfolio Implementation and Compliance groups review similarly-situated accounts for any discrepancies in performance to ensure that all accounts are treated fairly and in an unbiased manner. Conflicts and Other Activities of the Investment Manager. Clients (which includes the funds and accounts for which Bridgewater is the investment manager) may be affected by actual and potential conflicts of interest arising out of other activities undertaken by Bridgewater and its employees, including activities related to different Clients. For example, and subject to Bridgewater internal policies, Bridgewater and its employees advise and manage multiple investment funds and accounts, potentially including proprietary accounts, having investments or investment strategies which are, or may be in the future, similar to, overlapping with, or different from the investments or investment strategies of a given Client. Similarly, certain Bridgewater

employees create, advise and manage seed or incubator funds or incubator strategy slices within existing funds and accounts in order to research, trade and develop performance track records in new investment products, signals and/or strategies. Lastly, Bridgewater and its employees also advise certain Clients whose assets include or are comprised solely of those of persons affiliated with or employed by Bridgewater. There are also variable management and performance fee structures, and variable portfolio management incentive compensation structures, across Clients. Bridgewater and its employees therefore have conflicts of interest when allocating investment opportunities among a given Client and the other investment funds and accounts (including seed or incubator funds and incubator strategy slices, and proprietary accounts) managed, advised or sponsored by Bridgewater or its employees. These are unavoidable conflicts that Bridgewater manages on an active basis, as between and among funds and accounts, and in a manner consistent with internal policies. Bridgewater is generally incentivized to ensure that each Client trades successfully. Merely because a conflict of interest exists does not mean that it will be acted upon to the detriment of a Client and, when making investments where a conflict of interest may arise, Bridgewater undertakes to act in a fair and equitable manner as among a given Client, other Clients, and its affiliates. Furthermore, Bridgewater’s ability to act under an actual or potential conflict may from time to time be limited by applicable law. For additional information, please see Item 12: Trade Aggregation and Allocation Policy. From time to time, Bridgewater purchases certain securities and makes investments in the funds managed by the management company to aid in its own corporate cash management and risk management. These decisions are unrelated to the investment decisions made on behalf of Clients. The Clients’ investment decisions are based on the output of proprietary investment process, while the corporate investments are based on cash flow needed for operations. The Portfolio Implementation and Trading groups oversee the purchases and sales of securities for Client accounts, via a systematic investment process and trade allocation policies. The Finance Department oversees the corporate investments for the management company. However, such investment activity by Bridgewater may result in Bridgewater purchasing or selling securities that it has recommended to Clients.

Counterparty Selection. Bridgewater develops and maintains a large, diversified roster of counterparties to seek best execution and pursue conservative risk management. Establishing a large, diversified counterparty roster provides Bridgewater with the flexibility required to (1) compete trades to seek best execution, (2) explicitly limit the information distributed to individual counterparties about Bridgewater trade activity, (3) diversify limited exposure across a broad spectrum of counterparties, and (4) conservatively turn off counterparties and shift exposures without affecting the ability to achieve desired positioning. Before adding a counterparty to its roster, Bridgewater performs thorough due diligence to evaluate the prospective counterparty across three dimensions: (a) competitiveness, (b) risk, and (c) operational capability. To start, the Trading group identifies and evaluates potential new counterparties to assess whether they can provide the desired liquidity and competitive pricing. Then, from a risk perspective, the Portfolio Implementation group seeks to ensure that Bridgewater can monitor the counterparty’s health appropriately and that the counterparty is currently healthy according to its proprietary health metrics. In parallel, the Counterparty Legal group works with the Portfolio Implementation group to negotiate appropriate risk mitigation terms in the requisite legal agreements (including confidentiality provisions and terms governing collateral for open positions). Finally, potential new counterparties are evaluated by the Back Office to ensure that their operational processes meet Bridgewater’s high standards. Once onboarded, counterparties compete and win business based on the proprietary performance metrics utilized by Bridgewater’s Trading group. These metrics are intended to ensure that Bridgewater’s execution is consistent with its fiduciary duty to Clients and established standards for best execution. In essence, counterparties earn their share of trading activity based on the quality of their execution capability, among other factors. Bridgewater also actively limits the extent of the trading activity that each counterparty sees to prevent information leakage and seek best execution over time. Moreover, counterparties are only able to compete to win a share of trading activity if Bridgewater believes they have a track record of good performance, meet health requirements and are within exposure limits. Bridgewater can focus primarily on the quality of execution because it (1) does not enter into any formal soft dollar arrangements; (2) requires arm's length relationships between its employees and counterparties (for example, through policy restrictions on providing or receiving unreasonable entertainment, and other gifts); and (3) does not require research or trade ideas from counterparties. The enforcement of these practices is monitored by our Compliance group. Soft Dollar Policy. Bridgewater has full discretionary authority to manage Client accounts, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. Bridgewater’s authority is limited by its own internal policies and procedures and each Client’s investment guidelines. In selecting brokers and dealers to effect portfolio transactions for our Clients, Bridgewater seeks to obtain best execution, taking into consideration Bridgewater’s best execution policies and procedures as well its fiduciary duties to Clients. Bridgewater does not enter into any formal soft dollar arrangements for the receipt of brokerage and research services from executing broker-dealers, although it can consider the receipt of proprietary research from a broker as part of its broker selection process. Bridgewater’s best execution policies and procedures are based on several factors including, but not limited to, order execution costs, counterparty reliability, anonymity, minimal market impact, providing quality research and data, commissions charges, and trade clearing and settlement capability. Bridgewater receives services from its broker dealer counterparties that are defined as “brokerage services” or “research services” under the safe harbor provision of Section 28(e) of the Securities Exchange Act of 1934. As stated above, such brokerage and research services are not part of a formal agreement with the broker-dealer but are considered ancillary benefits resulting from Bridgewater’s use of such broker-dealers for trade execution. Examples of “brokerage services” generally include but are not limited to connectivity services and dedicated lines, algorithmic trading and routing software, messaging services for transmitting trade information or post-trade allocation, post trade matching services, short term custody related to clearance or settlement or other functionality to enable clearance or settlement. “Research services” generally include internally generated research reports covering topics on the economy, industries, groups

of securities, individual companies, statistical information, accounting and tax law interpretations, political developments, legal developments affecting portfolio securities, technical market action, pricing, credit analysis, risk measurement analysis, performance analysis, and analysis of corporate responsibility issues. Such research services are received in different formats including written reports, telephone conversations, in person interactions, data feeds, and short form communications. Brokerage and research services provided by broker-dealers generally benefit all Bridgewater Clients. In certain circumstances, Bridgewater executes transactions for only some Clients through broker-dealers who provide brokerage or research services and the brokerage or research services could be used for the benefit of one or more other Clients. Trade Aggregation and Allocation Policy. Bridgewater’s policy is to aggregate transactions where possible and when it is advantageous to our Clients. Orders are often executed in blocks (i.e., there are multiple accounts grouped into single orders) to achieve execution efficiency, cost efficiency, anonymity and to minimize volatility in prices across accounts, where possible. We prohibit any allocation of trades that would result in Bridgewater’s proprietary or affiliated accounts, or any particular Client(s) or group of Clients receiving more favorable treatment than other client accounts over time, and seek to ensure fair treatment for all accounts when allocating individual executions. To the extent permitted by applicable law, Bridgewater is authorized, but not required, to aggregate orders for a Client with orders of other Clients and to allocate the aggregate amount of the investment among accounts (including accounts in which Bridgewater or its personnel have a beneficial interest) in the manner in which Bridgewater shall determine appropriate. When portfolio decisions are made on an aggregated basis, Bridgewater often generates a large order to purchase or sell a particular instrument or security for a Client and one or more other Clients. Because of the prevailing trading activity, it is frequently not possible to receive the same price or execution on the entire volume of instruments or securities purchased or sold. When we encounter investment opportunities that are appropriate for more than one Client or Fund, or when an aggregated order is only partially filled, we will allocate the investment opportunity or a partially filled order on a fair and equitable basis. In general, Bridgewater allocates the executions to accounts in a pro-rata manner and utilizes randomization in account selection where purely proportional allocation is insufficient. When allocating different fills for a single trade, our account assignment process is intended to fairly distribute the executions to each account. Cross-Trading Policy. Cross transactions are those in which one Client account purchases securities directly from another Client account. Given the potential conflicts of interest, as well as the restrictions placed by ERISA, on engaging in cross-trades or similar transactions where a Client account that is subject to ERISA is a participant, Bridgewater generally does not engage on behalf of any of its Clients in cross-trades or other transactions where the Clients could have differing interests in the same transaction, even where Bridgewater could achieve reduced transaction costs for its Clients by doing so. In certain cases, such as the trading of futures, a broker could effect a transaction, subject to applicable laws and regulations and with or without the consent of Bridgewater, for both Bridgewater’s Client and another client account managed by Bridgewater that is on the opposite side of the transaction. The broker could receive compensation from the clients involved in such transactions. Error Policy. In accordance with internal policies, Bridgewater classifies only two types of issues as “trade errors.” The first type of trade error is the breach of a Client’s guideline objectives. In the event of such error, Bridgewater will resolve the matter in accordance with the terms of the Client’s contract. The second type of trade error is a trade execution error by Bridgewater’s trading desk that requires reversal due to a deemed inconsistency with the portfolio’s investment intent, where, for example, Bridgewater’s tradingdesk sold a security that Bridgewater intended to purchase. When such a trade execution error results in a loss to a Client’s portfolio, Bridgewater will make adjustments in the account to restore the Client’s portfolio to the position it would have been in had the execution error not occurred and, where required by the terms of the applicable Client contract, provide notification as required by such contract. A trade error will not be deemed to have occurred unless and until a Client’s guideline objectives have been breached or a trade execution error (as described above) has occurred and a Client’s account has been financially impacted. In light of the type of trading strategies and processes Bridgewater implements, the following types of issues would not be considered trade errors unless they resulted in a breach of a Client’s guideline objectives (and, accordingly, a Client would not be compensated by Bridgewater for losses related to such issues): (i) trading a different instrument or amount of exposure than

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Bridgewater maintains relationships with certain third party distributors that advise their clients to invest, directly or indirectly, in Bridgewater strategies or funds. Certain of those third parties are compensated for such activities that give an incentive to facilitate investments in Bridgewater funds. Specifically, Bridgewater has entered into certain agreements that provide for cash compensation to third parties for direct or indirect subscriptions to certain Bridgewater funds. Pursuant to such agreements, Bridgewater pays or causes to be paid cash compensation as a fixed-fee, performance fee, or percentage of revenue of assets raised to third party distributors for soliciting subscriptions and, in certain cases, for providing investor servicing. Any such compensation is disclosed in relevant offering materials, and other materials if and as required. Many of our Clients, prospective Clients, and fund investors retain investment consultants to advise them on or facilitate the selection and review of investment managers. Bridgewater has certain Clients and fund investors that were introduced to us through consultants. These consultants or their affiliates can, in the ordinary course of their investment consulting business, recommend Bridgewater’s investment advisory services or otherwise place Bridgewater into searches or other selection processes for a particular client. Some Clients, prospective Clients, and fund investors have delegated discretion to their consultants to select and engage Bridgewater’s investment advisory services and/or fund investments on their behalf. Bridgewater has extensive dealings with investment consultants, both in the consultants’ role as adviser for their clients and, in certain cases, through independent business relationships. Specifically, Bridgewater provides consultants with information on portfolios it manages for its mutual clients, pursuant to its Clients’ and fund investors’ directions. Bridgewater also provides information on its investment processes and performance to consultants, who use that information in connection with searches they conduct for their clients. Bridgewater also responds to “Requests for Proposals” from prospective clients in connection with those searches. In certain cases, Bridgewater: • Invites consultants to events or other entertainment hosted by Bridgewater. • Pays registration or other fees for the opportunity to participate, typically along with other investment managers, in consultant-sponsored industry forums or conferences. These conferences or forums can provide Bridgewater with the opportunity to discuss a variety of business topics with consultants, Clients, prospective Clients, and fund investors. In general, Bridgewater 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 Bridgewater.

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

Bridgewater's Portfolio Implementation group is responsible for monitoring positions of discretionary portfolios on a daily basis to seek to ensure compliance with the portfolios’ guidelines. The portfolio parameters are coded into Bridgewater’s portfolio construction system for purposes of monitoring positions against account guidelines. These parameters, along with Bridgewater’s risk control process, are systematically stress-tested at the inception of each new discretionary Client portfolio and monitored thereafter. This process essentially hard-wires guidelines into Bridgewater’s portfolio management system such that constraints are examined each time a trade is generated. In addition to the enforcement of discretionary Client guidelines within the portfolio construction system, a separate and independent “back-end” process assesses whether each discretionary portfolio is within Client guidelines. In the event that a guideline violation is identified, Bridgewater’s Portfolio Implementation group will notify Compliance which would oversee resolution, and Bridgewater would comply with any applicable contractual obligations or regulatory requirements. Middle and back office service providers, monitored by Bridgewater Operations and Accounting staff, review accounts through a series of reconciliations. On a daily basis, cash, trades, and positions are reconciled between the middle office book of record and external counterparties and custodians. On a monthly basis, cash, positions (shares/par amounts and fair value), accruals, and total portfolio value are reconciled between the account’s official books and records and shadow books and records. The shadow books and records are used to independently validate the output of the primary books and records. Investors in Bridgewater’s external funds receive monthly performance and valuation statements directly from the funds’ administrators. The statements contain the number of shares held in the fund, month-end price and valuation, monthly contributions and redemptions, and monthly returns. Clients with separately managed accounts receive monthly account statements from both Bridgewater and their qualified custodians. Clients receive monthly valuation and performance statements from Bridgewater and Northern Trust. The valuation statement provides a detailed list of investments, including the quantity held, month-end price, month-end valuation and accruals. The standard performance statement provides the monthly, quarterly, and year to date account performance and if applicable, the benchmark return for comparable periods. Clients typically receive a quarterly report from Bridgewater with portfolio and market commentary.

Under the Advisers Act, Bridgewater is deemed to have custody of client assets where it serves as a manager or managing member, or in a similar capacity, to various funds and as such has the authority to obtain possession of such funds’ securities or other assets. Each month, fund investors receive valuation statements directly from the fund administrator. Each fiscal year, each of the funds engages a Public Company Accounting Oversight Board-registered independent public accounting firm to conduct an audit of the private investment fund. The audited financial statements are also delivered to all fund investors within 120 days of the end of each fiscal year. For separately managed accounts and non-discretionary clients, Bridgewater does not have custody since it does not have the authority to hold, directly or indirectly, Client funds or securities or have the authority to obtain possession of them. Each month, separately managed account Clients of Bridgewater receive account statements directly from their qualified custodian, who maintains the Clients’ assets, in addition to receiving a statement from Bridgewater. Bridgewater encourages Clients to compare the account statement received from their custodians to the appraisal reports received from Bridgewater to determine that transactions are properly recorded.

Bridgewater, through its investment management agreements with its Clients, is generally given discretion and authority to invest, reinvest and manage a Client’s assets in accordance with Bridgewater’s trading systems, methods, models, strategies and formulas; provided, that Bridgewater complies with the specific investment guidelines and other related terms set forth in each such agreement, which may contain certain parameters or restrictions with respect to Bridgewater’s investment discretion and authority. Such parameters and restrictions may include, among others, tracking error or volatility targets, position/exposure limits, counterparty requirements and restrictions, prohibited investments, and applicable legal and regulatory restrictions. To enable Bridgewater to exercise such discretion, Bridgewater is generally authorized, as the Client’s agent and attorney-in-fact, to sign and execute all documents and agreements related to its management of the account including, but not limited to, fund subscription agreements and redemption notices, futures clearing agreements, master netting agreements, prime brokerage agreements, repurchase agreements, ISDA agreements, triparty and third party account control agreements (including documents required to establish related custodial accounts), and ancillary agreements relating to all of the foregoing (all either individually or under an umbrella agreement). Further, Bridgewater is generally authorized, as the Client’s agent and attorneyin-fact, to take all other action that Bridgewater reasonably considers necessary or advisable to carry out its duties.

Proxy Voting Policy. Bridgewater seeks to minimize potential conflicts of interest among Bridgewater and its Clients and seeks to ensure that in cases where Bridgewater votes proxies with respect to Client securities, such proxies are voted in what Bridgewater believes to be the best interests of the Client. Bridgewater engages Glass, Lewis & Co. (“Glass Lewis”) to vote proxies on behalf of its Clients, when authority has been delegated to Bridgewater by the Client. In accordance with SEC Rule 206(4)-6 under the Advisers Act (the “Proxy Voting Rule”), Bridgewater generally subscribes to certain proxy voting policies adopted by Glass Lewis but reserves the right to direct that Glass Lewis vote in a manner that is contrary to such policy where appropriate, or as specifically directed by a Client for its own account. More specifically, for portfolios with traditional risk and return objectives, Bridgewater directs Glass Lewis to apply their benchmark policy. Bridgewater fund investors are not able to direct votes for the funds in which they are invested. From time to time, Bridgewater can determine that it is in the Client’s best interest to refrain from voting a proxy. For example, Bridgewater often declines to vote if the expected costs associated with voting exceed the expected benefit or where voting would prevent Bridgewater from selling the security for a specified period of time. When a Client for whom Bridgewater manages a separately managed account retains the authority to vote proxies, solicitations will be sent directly from their custodian or a transfer agent. For non-discretionary sub-advised Clients, Bridgewater does not have proxy voting authority. If a Client would like to contact Bridgewater with questions about a particular solicitation, their client advisor is available to discuss such requests. A copy of the Glass Lewis Proxy Voting Policies, the Bridgewater Proxy Voting Policy, and actual proxy voting records, if applicable, are available to Clients upon request. The Chief Compliance Officer or delegate is responsible for oversight of the proxy voting policy and procedures and for confirming that proxies have been voted in accordance with such policy and procedures. Class Action Policy. From time to time, class action lawsuits involving trades entered into by one or more of Bridgewater’s funds result in notices being sent to class members for participation in the lawsuit. Where Bridgewater has received such notice of a lawsuit, Bridgewater or a third-party vendor, on behalf of any applicable current Bridgewater fund, may submit certain proofs of claims for payment against settlements or awards in actions for which the fund(s) have received notice, unless Bridgewater determines that the costs of participating in such class actions or settlements outweigh the benefits. Amounts received as a result of participation in class actions will be credited to the participating Bridgewater fund(s) at the time the recovery amounts are received, excluding any third-party administrator fees. As a matter of policy, unless otherwise contractually obligated, Bridgewater generally refrains from serving as the lead (or named) plaintiff in class action matters. Bridgewater will generally opt out of class action membership if Bridgewater expects to bring a direct claim or if Bridgewater determines that the risk of information leakage, or the effort required to submit a claim (including the effort required to gather, consolidate, and format large volumes of transaction data) outweigh the amount of the expected recovery, otherwise determines that the costs of participating in such class action settlements outweigh the benefits, or otherwise determines participation is not in the best interest of Bridgewater’s funds. Bridgewater will generally not file claims in class action lawsuits on behalf of (i) funds that have closed or commenced the process of closing prior to Bridgewater’s receipt of notice of the lawsuit, or (ii) Clients for whom Bridgewater manages separately managed accounts. With respect to any fund that has filed one or more class action claims that remain outstanding when the process of closing has commenced, Bridgewater may seek to liquidate any such claim and distribute proceeds of the liquidation to the fund prior to closing. Whether Bridgewater actually liquidates any such claim will depend on several factors, including the ability to locate a buyer offering a reasonable price for the claim. Settlement amounts received after a fund has been liquidated will generally not be distributed to former investors in such fund. Certain jurisdictions outside of the United States have legal systems that do not provide for class action lawsuits. Lawsuits may occur from time to time in such jurisdictions under proceedings that are analogous to class actions, but which require each plaintiff to individually opt in and become a named plaintiff in the proceeding. Bridgewater will generally opt in to such a proceeding only if Bridgewater determines that the benefits of participating in such class actions or settlements outweigh the costs and that it is in the best interests of the applicable Bridgewater fund to do so.

There is no financial condition that is reasonably likely to impair Bridgewater’s ability to meet contractual commitments to its Clients. Bridgewater has not been subject to a bankruptcy petition within the past 10 years.