BROWN BROTHERS HARRIMAN & CO

This Brochure provides an overview of the investment management services of a “Separately Identifiable Department” (the “Adviser”) of Brown Brothers Harriman & Co. (“BBH”). The Adviser, also known as the “Brown Brothers Harriman Mutual Fund Advisory Department,” is an SEC registered investment adviser that is an adviser or sub-adviser to mutual funds that are registered under the Investment Company Act of 1940, as amended (“Investment Company Act”) (“Mutual Funds”), to Exchange Traded Funds that is registered under the Investment Company Act, as amended (“ETFs”), and to collective investment funds organized as Undertakings for Collective Investments in Transferable Securities (“UCITS Funds”). In this Brochure, we refer to Mutual Funds, ETFs and UCITS Funds together as “Funds.” The Adviser first registered with the SEC in 2001. BBH is a bank, organized as a New York limited partnership. As a bank, BBH is excepted from registration with the SEC as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). This Brochure is not intended to state or imply that BBH is a registered investment adviser or that it is subject to the requirements of the Advisers Act, other than as identified below. This Brochure is not an offering document for the Funds, and all descriptions of the Funds and their objectives, strategies, and risks are set forth in their entirety in the Prospectus and Statement of Additional Information for the Mutual Funds and the Prospectus, the Packaged Retail and Insurance-based Investment Product Key Information Document, and the Key Investor Information Document for the UCITS Funds. BBH was founded in 1818 and remains one of the oldest continuously operated partnership banks in the United States. In addition to offering a range of investment management services for individuals, families and institutions, BBH participates in businesses, including, but not limited to global custody, foreign exchange, lending, private equity investing, and personal trust & estate administration. Licensed by the New York State Department of Financial Services (“NYSDFS”) as a Private Banker, BBH is authorized to accept deposits, grant loans, and generally conduct a banking business including acting as a custodian of funds and securities. Assets held at BBH are not Federal Deposit Insurance Corporation ( “ FDIC”) insured and are subject to investment risks, including possible loss of principal invested. The Adviser has hired third-party investment advisers to provide sub-advisory and other investment-related services to certain Funds. These sub-advisers may themselves be advisers to other investment advisers or vehicles, including their own proprietary products. The Adviser reviews each sub-advised portfolio’s compliance with the applicable Fund’s portfolio investment guidelines. As of January 1, 2026, the Adviser had $7,152,290,266 in discretionary assets under management (net assets in the Funds). The Adviser does not manage any assets on a non-discretionary basis.

❖ Management/Sub-Advisory Fees Generally, the Adviser charges fees based on a percentage of net assets under management. Fees are set forth in each Fund’s prospectus or other offering documents or may be negotiated between the adviser who has retained the Adviser, as stated in their respective sub-advisory agreement. Advisory fees may be billed either monthly or quarterly, in advance or in arrears, and are deducted from the Fund’s assets or billed to the Fund or adviser, depending upon the Adviser’s contract with the Fund or adviser. Typically, either the Adviser or a Fund may terminate an investment management contract at any time by written notice given to the other party at least 30 days prior to the date on which such termination is to take place, or as may otherwise be provided in the agreement. In the event of termination or if fees are charged in arrears, fees will be pro-rated based on the termination date. ❖ Additional Fees In most cases, a third-party broker executing a trade on the Fund’s behalf will charge a commission (equity securities) or earn a mark-up/mark-down (fixed income securities). Neither the Adviser nor BBH earns commissions or other transaction fees in connection with directing investment advisory trade orders to third party brokers for execution; however, the Adviser does receive credits from certain brokers toward the receipt of qualifying research or other services in accordance with applicable law. The Adviser does not execute transactions through an affiliated broker-dealer. Please refer to Item 12, “Brokerage Practices,” for additional information. Certain of the Mutual Funds have adopted a distribution plan pursuant to Rule 12b-1 under the Investment Company Act, for retail class shares that allows the Mutual Funds to pay distribution fees for the sale of their shares and for services provided to shareholders. Because these fees are paid out of the retail class shares’ assets continuously, over time, these fees will increase the cost of an investment in such shares and may cost more than paying for other types of sales charges, such as a one-time front-end or back-end sales charge.

Introduction The Adviser’s equity investment philosophy centers on active management and fundamental analysis of individual com pani es . The Adviser seeks to invest primarily in cash generative businesses that are leading providers of essential products and services. The Adviser believes that purchasing the equity securities of such companies when they are trading at a discount to its estimate of intrinsic value is an effective way to enjoy the benefits of equity ownership (namely, higher capital appreciation over time) while reducing the risk of permanent capital loss over the long term. While the Adviser typically takes a long-term investment approach to managing the Funds, the Adviser may at times engage in short-term trading (i.e., holding securities less than 30 days). The Adviser uses a fundamental, value-based approach to fixed income management. Its fixed income management philosophy is grounded in the belief that credit spreads are more volatile than underlying fundamentals, creating substantial misalignments of value and price. To take advantage of these opportunities, the Adviser follows a value-driven strategy. The Adviser’s investment approach includes the consideration of a variety of fundamental factors, including industry structure, competitive positioning, financial strength, and environmental, social and governance (“ESG”) factors, all of which could enhance its ability to manage risk and to achieve its long-term investment objectives. In response to adverse market, economic, political and other conditions, the Adviser may make temporary investments that are not consistent with a Fund’s investment objective and principal investment strategies. Such investments may be inconsistent with a Fund’s ability to reach its investment objective. Environmental, Social and Governance Factors The Adviser believes that the evaluation of material ESG risk factors may enhance its ability to manage overall risk and achieve clients’ long-term objectives. The ESG risk profile of an investment is one of many considerations used in the investment process. The Adviser does not perform an ESG analysis for securities issued by the U.S. government or its agencies. The Adviser places in-depth, fundamental analysis at the core of its investment process which includes material ESG assessments. An ESG risk factor is deemed to be material if it has the potential to impact the enterprise value of a company or the credit quality of an issuer. The Adviser’s ongoing consideration of material ESG risk factors does not indicate that it places restrictions on the investment universe or that the associated strategy, Fund or portfolio will have any particular characteristic. A less favourable ESG profile may not preclude the Adviser from investing in a company or issuer, as the consideration of ESG factors is not more influential than the consideration of other investment criteria.

Equity Securities ❖ Investment Strategies The types of equity securities that the Adviser may invest in on behalf of the Funds include, without limitation, exchange-listed securities, securities traded over-the-counter, and foreign securities. The Adviser may also invest, when appropriate, in derivative instruments such as warrants, American depository receipts, global depository receipts, commodity interests (e.g., forwards, futures and swaps) and options. In most cases, derivative investments will involve greater volatility and more limited liquidity than cash market investments. The potential for gain or loss exists in both the cash and derivatives markets. There is no guarantee that a particular Fund will achieve its investment objective. ❖ Methods of Analysis The equity investment teams consist of portfolio managers and research analysts who work collaboratively to identify, analyze, and monitor investments. The equity investment teams closely study industry structure and competitive trends, communicating regularly with knowledgeable industry participants and company management teams to assess whether companies meet the Adviser’s fundamental and valuation criteria. The equity investment teams also explicitly identify key business risks and variables outside of management’s control, as well as value active investments and prospective investment opportunities. Outside research materials/analytical tools used include but are not limited to: company management meetings; annual reports and quarterly reports; prospectuses; proxies; filings; company press releases and presentations; inspections of corporate facilities and activities when possible; industry and investment conferences and trade shows; financial newspapers and industry publications/websites; expert networks; and research provided by third parties. Specific Service Offerings The descriptions of equity strategies below, as applied to a particular Fund, are qualified in their entirety by the Fund’s prospectus, Key Investor Information Document (for UCITS Funds), or other offering document. The strategies are offered in diversified and non-diversified portfolios.

❖ Large Cap/Core Select. The “Large Cap/Core Select” strategy seeks to provide investors with longterm growth of capital. The strategy normally will invest at least 80% of its net assets, plus the amount of any borrowings for investment purposes, in large capitalization publicly traded equity securities. Such securities will be issued by domestic and foreign issuers both directly and in the form of sponsored and unsponsored depository receipts representing an interest in these securities. The Fund primarily seeks to buy common stock and may also invest in preferred stock. The Adviser considers large cap securities to be equity securities that the time of purchase have a market capitalization within the range of companies included in the S&P 500 Index. The Large Cap/Core Select strategy is based on fundamental business analysis and a long-term orientation that blends aspects of growth and value investing. The Large Cap strategy seeks to invest in approximately 2550 different companies, while the Core Select Strategy seeks to invest in 25-35 different companies that meet the Adviser’s prescriptive fundamental criteria. The strategy typically invests in companies that are headquartered in North America, as well as in certain global firms located in other developed regions. The Adviser selects companies based on their qualitative merits, competitive profile and prospective value creation potential. The strategy follows a “buy and own” approach that does not typically make use of short-term trades in pursuit of small gains. The criteria that the Adviser seeks in each area, where appropriate, are as follows: ➢ Business Criteria – (i) essential products or services, (ii) loyal customers, (iii) leadership in an attractive market niche or industry, (iv) sustainable competitive advantages, (v) high returns on invested capital, and (vi) strong free cash flow; ➢ Management Criteria – (i) high levels of integrity, (ii) excellent operators, and (iii) good longterm strategy and capital allocation; and ➢ Valuation Criteria – attractively valued compared to an estimated intrinsic value per share range. Intrinsic value calculations are based on the Adviser’s analyses of free cash flow, return on invested capital and other relevant financial criteria. The Adviser’s time horizon when purchasing a company is typically three to five years but is not subject to any minimum or maximum period. Investments may be sold if they appreciate to levels at or near the higher end of the Adviser’s estimated ranges of intrinsic value. ❖ Mid Cap. The “Mid Cap” strategy seeks to provide investors with long-term growth of capital. The strategy invests at least 80% of its net assets, plus the amount of any borrowings for investment purposes, in middle capitalization publicly traded equity securities, commonly referred to as mid cap stocks. Such securities may be issued by domestic or foreign issuers. Domestic securities include companies that are incorporated or headquartered in the U.S. The strategy may also invest in securities issued by foreign issuers, that are not incorporated or headquartered in the U.S., both directly and in the form of sponsored and unsponsored depository receipts, representing an interest in these foreign securities. The Adviser considers mid cap securities to be securities that at the time of purchase have a market capitalization within the range of companies included in the Russell Midcap Index. The strategy may also invest in large cap and small cap publicly traded equity securities. From time to time, the strategy may invest in shares of companies through “new issues”

or Initial Public Offerings (“IPOs”). Subject to applicable statutory and regulatory limitations, the strategy may also invest in shares of other investment companies, consisting of mutual funds and ETFs. The Adviser’s strategy is based on fundamental business analysis and a long-term orientation. The Adviser selects companies based on their qualitative merits, competitive profile and prospective value creation potential. The strategy follows a “buy and own” approach that does not make use of short-term trades in pursuit of small gains. The Adviser believes that its long-term orientation can benefit the strategy’s net performance results. The Adviser may sell investments if they appreciate to levels at or near the higher end of the Adviser’s estimated intrinsic value range. ❖ International Equity. The “International Equity” strategy seeks to provide investors with long-term maximization of total return, primarily through capital appreciation. The strategy primarily invests at least 80% of the net assets of the Fund, plus any borrowing for investment purposes, in the equity securities of companies in the developed and emerging markets of the world, excluding the United States. The Adviser defines developed markets to include markets of securities listed in the Morgan Stanley Capital International – Europe, Australasia, and Far East Index (“MSCI-EAFE”) and Canada. The strategy may invest up to 35% of its assets, at the time of purchase, in emerging markets of the world. The Adviser defines an emerging market as a securities market located in any country that is defined as having an emerging or developing economy by the World Bank or its related organizations, or the United Nations or its authorities. The strategy primarily invests in equity securities of companies with large market capitalizations. Although the strategy is expected to invest primarily in common stocks, it may also invest in other securities with equity characteristics. The Fund may purchase these equity securities directly or in the form of sponsored and unsponsored American Depository Receipts (“ADRs”), Global Depository Receipts (“GDRs”) or other similar securities representing securities of companies based outside of the United States, national security exchanges or over-the-counter markets. Securities may be purchased in currencies other than the U.S. dollar. In managing International Equity, the Adviser allocates the Fund’s assets to two third-party subadvisers. International Equity is currently offered through an investment company registered under the Investment Company Act (the “Fund”) and, as such is subject to the general supervision by the Fund’s Board of Trustees. The Adviser oversees the sub-advisers and evaluates its performance results. The Adviser reviews portfolio performance, characteristics and changes in key personnel of the sub-adviser. The sub-advisers are primarily responsible for the day-to-day management of the Fund’s portfolio, including purchases and sales of individual securities. Other sub-advisers may be added in the future to complement the sub-adviser’s investment style. However, the Adviser may, when it deems appropriate, manage all or a portion of the Fund’s assets according to the Fund’s principal investment strategies. One of the sub-advisers focuses on identifying attractive non-U.S. publicly traded businesses with large market capitalization and investing opportunistically in these businesses when it believes that good long-term returns can be achieved. The sub-adviser defines attractive businesses as those that have achieved leading and defensible market positions through the creation of enduring franchise value. They are, in the view of the sub-adviser, both well positioned for long term growth and

resilient in difficult economic environments. The sub-adviser employs intensive and rigorous fundamental equity research in order to identify these investment opportunities. The other sub-adviser believes in an unconstrained, approach to investing that is not linked to components of any benchmark against which the performance of the portfolio is measured, and the sub-adviser intends to invest in a focused portfolio of non-U.S. common stocks of publicly traded companies, with the potential to invest in preferred stocks on a limited basis. The sub-adviser intends to select securities based on identifying important positive factors that affect a company’s earnings and cash flow prospects, which it believes to be under- recognized by the market. These factors will be identified through fundamental research and valuation methodologies. The sub-adviser’s portfolio of investment positions will mainly consist of large-capitalization companies at the time of the initial purchase. Emerging markets are expected, from time to time, to be represented in the portion of the Fund managed by the sub-adviser. Both sub-advisers may sell securities for a variety of reasons, such as to secure gains, limit losses or redeploy assets into more promising opportunities. The Fund may, from time to time, invest in a limited number of issuers. Fixed Income ❖

Investment Strategy

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The Adviser advises Mutual Funds, ETFs and UCITS Funds. Additionally, the Adviser sub-advises Mutual Funds and an ETF that are sponsored by third parties.

The Adviser offers investment advisory services to multiple Funds with different investment objectives, guidelines and policies, and with different fee structures. The Adviser does not receive performance-based fees. However, certain supervised persons of the Adviser manage both BBH client accounts that charge performance-based fees and Adviser client accounts that do not charge performance-based fees. Supervised persons of the adviser have an incentive to allocate certain investment opportunities to these performancebased fee accounts rather than the Funds in order to increase the account’s performance and thus improve the supervised person’s chances of receiving the performance fee. However, BBH and the Adviser have implemented policies and procedures designed to ensure that investment opportunities are allocated equitably between the Funds and other accounts with similar investment strategies.

Certain officers, employees, directors and members of the Adviser’s executive management also serve as partners, employees, directors and/or executive management of Brown Brothers Harriman Credit Partners, LLC (“BBH Credit Partners”). BBH Credit Partners is registered with the SEC as an investment adviser and offers investment management and sub-advisory services to institutions, government entities, mutual funds, UCITS and collective investment trusts. Some of the Adviser’s personnel are registered representatives of Brown Brothers Harriman Investments, LLC (“BBHI”), a wholly owned subsidiary of BBH, but do not generally conduct trades for the Funds. BBHI is, an SEC registered limited purpose broker-dealer and member firm of the Financial Industry Regulatory Authority (“FINRA”). BBHI acts primarily as a distributor of the mutual funds and as a placement agent for BBH’s private investment funds. Neither the Adviser nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, Commodity Trading Advisor (“CTA”), or an associated person of the foregoing. The Adviser relies on applicable exemptions from CTA registration when conducting trading activities with respect to commodity interests, including futures. Consistent with such exemptions, when appropriate, the Adviser may also trade futures and CDS on behalf of the Funds. The Adviser is a separately identifiable department of BBH and is controlled by BBH. Certain employees, directors and members of the Adviser’s executive management also serve as employees, directors and/or executive management of BBH, BBH Credit Partners and/or serve as registered representatives or directors and/or executive management of BBHI. No material conflicts exist in relation to personnel that serves as employees, directors and/or executive management of BBH or BBH Credit Partners and also serve as registered representatives or directors and/or executive management of BBHI given that BBHI serves as a limited purpose broker-dealer as described above.

❖ Code of Ethics and Professional Conduct The Adviser has adopted a Code of Ethics and Professional Conduct (the “Code”) that requires its personnel to (a) conduct personal securities transactions that are in accordance with the Code and with the Adviser’s Personal Trading and Information Barrier and Insider Information Policies, and in such a manner as to avoid any actual or potential conflict of interest; (b) comply with applicable laws and regulations; and (c) annually provide an acknowledgment of compliance with the Code. The Code contains provisions reasonably designed to identify and address potential conflicts of interest between personal investment activities and the interests of the Funds. Of course, there can be no assurance that the Code will be effective in identifying and addressing all conflicts of interest relating to personal securities transactions. The Adviser will provide a copy of the Code to any of its clients or prospective clients upon request. BBH, including the Adviser, and any of their respective partners, principals, directors, officers, employees, affiliates or agents, face conflicts of interest when transacting in securities for their own accounts because they could benefit by trading in the same securities as the Funds, which could have an adverse effect on the Funds. However, BBH, including the Adviser, has implemented policies and procedures concerning personal trading by BBH Partners, Principals, and employees. Trading in personal accounts is permitted pursuant to these policies and procedures, which include a pre-clearance process for transactions by certain defined insiders or access persons, as well as minimum holding periods. These procedures seek to minimize conflicts of interest by restricting the type and timing of employees’ trades and are designed to prevent and detect account activity that may violate policy or applicable laws. The Adviser’s personnel are generally not permitted to purchase and sell securities that the Adviser or the sub-adviser purchases and sells for the Funds. From time to time, employees of BBH, including the Adviser, and any of their respective partners, principals, directors, officers, employees, affiliates or agents, give or receive gifts and/or entertainment to or from clients, intermediaries, or service providers to the Fund or BBH, including the Adviser, which could have the appearance of affecting or potentially affecting the judgment of the employees, or the manner in which they conduct business. BBH, including the Adviser, has implemented policies and procedures concerning gifts and entertainment to mitigate any impact on the judgment of BBH Partners and employees. ❖ Non-Exclusive Management Adviser personnel render investment management services to, and execute transactions for, affiliated accounts and for the accounts of other persons. The accounts of other persons include BBH partners and investment advisory accounts of BBH and Adviser personnel including discretionary accounts that are centrally managed as well as other Funds managed by the Adviser. The advice given to one client at times will differ from advice given to other client accounts, and transactions may be effected for the account of any client at prices, in amounts, or relating to securities which are not purchased or sold for other accounts. In order to seek to avoid potential conflicts of interest, the Adviser may preclude Funds from making an investment or selling an existing investment in, or taking other actions with respect to, securities of a company where the Adviser is advising another Fund that is making or selling an investment in the securities of the same company. In addition, there may be certain investment opportunities, investment

strategies or actions that the Adviser determines not to undertake on behalf of a Fund in view of the Adviser’s other Fund or firm activities. The Adviser maintains policies, procedures and related controls to appropriately maintain and guard against misuse of Confidential and Material Non-Public Information (“MNPI”). Information barrier controls include both physical and virtual barriers including segregation of systems, all of which are designed to control and contain the flow of confidential information and MNPI. Specific information barrier controls include, but are not limited to, control lists (e.g., restricted list and watch list), personal account trading surveillance, electronic communications surveillance and related information barrier training. From time to time, the Adviser may come into possession of MNPI or other information that could limit the ability of the Funds to buy and sell investments, and investment flexibility may be constrained as a consequence.

❖ Best Execution Generally, the Adviser directs equity and fixed income orders for the Funds to unaffiliated brokers and dealers for execution. The Adviser seeks to obtain best execution of such orders (where the relevant market recognizes concepts of best execution), which does not necessarily mean best price. In this regard, trades will be directed to brokers and dealers based on a number of factors including: the broker’s or dealer’s ability to execute orders without disturbing the market price; the broker’s or dealer’s reliability for on-time delivery of securities; the broker’s or dealer’s credit worthiness, reputation and integrity; the research and other investment information provided by the broker or dealer, notwithstanding that a particular client account may not be the direct or exclusive beneficiary of such service; and the commission or markup/mark-down charged by the broker or dealer. Accordingly, the commissions or fees charged by a broker or dealer may be greater than the amount another firm might charge provided that the Adviser determines, in good faith, that the amount of such commissions or fees is reasonable in relation to the value of the brokerage and research information provided. The Adviser has established an oversight committee to monitor its efforts to meet best execution obligations. Please also refer to the below sections entitled “Soft Dollar or Research/Execution Arrangements” and “Aggregation and Allocation of Transactions” for additional information on allocation. To the extent that the Adviser engages a third-party sub-adviser, the sub-adviser has direct responsibility for directing trades and seeking best execution as described above. The Adviser periodically reviews the subadviser’s performance in this regard. ❖ Soft Dollar or Research/Execution Arrangements The Adviser directs brokerage transactions and/or payment of a portion of client commissions (“soft dollars”) to specific brokers or dealers or other providers to pay for research or other appropriate services which provide, in the Adviser’s view, appropriate assistance to the Adviser in the investment decision-making process. The Adviser has adopted soft dollar policies and procedures that seek to address potential conflicts of interest. Research and services include information 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, credit analysis, risk measurement analysis, performance analysis, and analysis of corporate responsibility issues. In the past year, the Adviser has utilized soft dollars to acquire research provided directly by brokers and by third party research providers that include historical financials, corporate data and consensus estimates that analysts, including a third-party consultant, use to assist in their decision-making responsibilities. Along those lines, the Adviser has also used pricing and news services, order management systems, attended conferences, attended management meetings, used models and consulted with industry experts that were paid for through soft dollars. The Adviser’s evaluation of the brokerage and research services provided by the broker-dealer may be a significant factor in selecting a broker-dealer to effect transactions. For this purpose, the Adviser has established a voting process where equity analysts vote to establish a budget and allocation model to research providers based on the estimated value and importance of the research, which is reviewed by an oversight committee. The committee also monitors the Adviser’s efforts to meet its best execution obligations. The use of a broker that provides research and securities transaction services may result in a higher commission than that offered by a broker who does not provide such services. The Adviser will determine in good faith whether the amount of commission is reasonable in relation to the value of research and services provided and whether the services provide lawful and appropriate assistance in its investment decisionmaking responsibilities. Research or other services obtained in this manner are sometimes used in servicing any or all the Funds and other BBH client accounts, including in connection with BBH client accounts that do not pay commissions to the broker related to the research or other service arrangements. Such products and services could disproportionately benefit other BBH client accounts relative to a Fund based on the amount of brokerage commissions paid by a Fund and such other BBH client accounts. For example, the Adviser generally may not use research or other services that are paid for through one client’s commissions in managing that client’s account. However, research may be shared with another BBH strategy from time to time if approved in accordance with policies and procedures. In addition, other BBH client accounts may receive the benefit, including disproportionate benefits, of economies of scale or price discounts in connection with products and services that are provided to a Fund and to such other BBH client accounts. The Adviser does not attempt to track the benefits of brokerage and research services to the commissions associated with a particular Fund. When the Adviser uses client brokerage commissions (or markups or markdowns) to obtain research or other products or services, it receives a benefit because it does not have to produce or pay for the research, products or services. The Adviser may have an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on its clients’ interest in receiving most favorable execution. BBH, at times, receives research that is bundled with the trade execution, clearing, and/or settlement services provided by a particular broker-dealer. To the extent that BBH receives research on this basis, many of the same conflicts related to traditional soft dollars exist. For example, the research effectively will be paid by client commissions that also will be used to pay for the execution, clearing, and settlement services provided by the broker-dealer and will not be paid by BBH. BBH endeavours to execute trades through brokers who, pursuant to such arrangements, provide research or other services that BBH believes are useful in its investment decision-making process. From time to time,

BBH chooses not to engage in the above-described arrangements to varying degrees. BBH also enters into commission sharing arrangements under which BBH executes transactions through a broker-dealer, and requests that the broker-dealer allocate a portion of the commissions or commission credits to another firm that provides research to BBH. To the extent that BBH engages in commission sharing arrangements, many of the same conflicts related to traditional soft dollars will exist. In connection with receiving brokerage and research services from broker-dealers, the Adviser, at times, receives “mixed use” services where a portion of the service assists the Adviser in its investment decisionmaking process and a portion is used for other purposes. Where a service has a mixed use, the Adviser will make a reasonable allocation of its cost according to its use and will use client commissions to pay only for the portion of the product or service that assists the Adviser in its investment decision-making process. The Adviser has an incentive to underestimate the extent of any “mixed use” or allocate the costs to uses that assist the Adviser in its investment decision-making process because the Adviser pays for such costs with client commissions rather than the Adviser’s own resources. The Adviser maintains policies and procedures reasonably designed to identify and address these potential conflicts of interest. ❖ Brokerage for Client Referrals The Adviser does not select nor recommend broker-dealers in exchange for client referrals. ❖ Client-Directed Brokerage Transactions The Adviser does not permit the Funds to direct brokerage to particular broker-dealers.

❖ Aggregation and Allocation of Transactions BBH, including the Adviser, has adopted trade allocation policies and procedures that seek to address the conflicts associated with portfolio managers managing multiple Funds and BBH client accounts. As a result of allocation issues, the amount, timing, structuring or terms of an investment by some Funds may differ from, and performance may be lower than, investments and performance of other Funds and/or accounts. Funds that do not receive allocations that perform well may experience lower performance as a result. Certain conflicts of interest may arise in connection with a portfolio manager’s management of a Fund’s investments and the investments of other funds or accounts for which the portfolio manager is responsible. For example, it is possible that the various funds or accounts managed by BBH could have different investment strategies that, at times, might conflict with one another to the possible detriment of a Fund. Alternatively, the investment methods and strategies that the Adviser utilizes in managing a Fund are utilized by BBH, including the Adviser, in managing investments for other funds and accounts. From time to time, BBH, including the Adviser, establishes, sponsors and is affiliated with other investment pools and accounts which engage in the same or similar businesses as a Fund using the same or similar investment strategies. To the extent that the same investment opportunities might be desirable for more than one account or fund, possible conflicts could arise in determining how to allocate them because BBH may have an incentive to allocate investment opportunities to certain accounts or funds. For example, BBH may act as adviser to private funds with investment strategies similar to a Fund. Those private funds may pay BBH a performance fee in addition to the stated investment advisory fee. In such cases, BBH may have an incentive to allocate

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No person who is not a client provides an economic benefit to the Adviser for providing investment advice to its clients. Neither the Adviser nor any of its related persons directly or indirectly compensates any person for client referrals.

There are no material disciplinary events involving the Adviser or its personnel involved in providing investment advice.

The Mutual Funds and the UCITS Funds are reviewed by the Adviser at least annually. Generally, Fund reviews will include, where applicable: ➢ Checks for portfolio compliance with Fund investment objectives/guidelines; ➢ Checks for portfolio compliance with applicable law; and ➢ Checks that Fund performance is consistent with the strategy. All reviews are approved by risk officers or portfolio management personnel of the Adviser and are reported to the governing committee of the Adviser.

BBH currently serves as custodian for the funds of the BBH Trust (the “Trust”) pursuant to an agreement with the Trust, while J.P. Morgan SE, Luxembourg Branch, serves as the custodian for the UCITS.

The Adviser has investment discretion over the Funds, including the discretion to determine the securities to be bought or sold and their amount, the broker-dealers to be used, and the commission rates or fees to be paid for those executions. This discretionary authority is limited by the Funds’ offering documents and applicable law. When the Adviser engages a sub–adviser, the sub-adviser has trading and brokerage discretion over the sub-advised Fund. As part of that engagement, the Adviser considers the sub-adviser's compliance policies and procedures, including those relating to trading, brokerage and the allocation of trading opportunities and requires them, among other things, to adhere to best execution standards. It should be noted that, when deemed appropriate, the Adviser may manage all or a portion of a sub-advised Fund’s assets according to the Fund’s principal investment strategies.

The Adviser has adopted a Proxy Voting & Class Action Policy and Procedure, available to Fund investors upon request, which is designed to prevent conflicts of interest from influencing proxy voting decisions that the Adviser makes on behalf of the Funds. Actual proxy voting decisions of the Adviser may

have the effect of favoring the interests of certain clients or businesses of other divisions or units of BBH or its affiliates provided that the Adviser believes such voting decisions to be in accordance with its fiduciary obligations. Unless otherwise stated in the investment management agreement, the Adviser maintains the right to vote proxies on behalf of the Funds and utilizes the services of a third-party proxy agent in making voting decisions. The Adviser reserves the right to vote proxies in a manner that is different than the vote recommended by third-party proxy agents. When the Adviser uses a sub-adviser, the subadviser generally votes proxies on behalf of the Fund. BBH has engaged the services of a third-party service provider to participate in class action shareholder lawsuits, on a best-efforts basis, in connection with securities beneficially owned by the Funds during relevant class action periods. BBH is solely responsible for any fees paid to such third party. There may be instances in which BBH’s interests’ conflict, or appear to conflict, with client interests. BBH’s duty is to vote proxies in the best interests of the clients. BBH votes portfolio proxies without regard to any other business relationship between BBH and the company to which the portfolio votes proxies. BBH generally seeks to avoid such material conflicts of interest by maintaining separate investment decision making processes to prevent the sharing of business objectives with respect to proposed or actual actions regarding portfolio proxy voting decisions. BBH has developed procedures to help identify and mitigate conflicts that may arise. Fund investors may obtain information from the Adviser about how the Adviser voted their securities upon request. A record of the proxy votes for the Mutual Funds can be found on the Mutual Funds’ website.

The Adviser does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. The Adviser is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has the Adviser been the subject of a bankruptcy petition at any time during the past ten years.