Calamos Advisors LLC

Calamos Advisors LLC is an investment adviser registered with the U.S. Securities and Exchange Commission (the “SEC”) effective May 29, 1987 and a wholly owned subsidiary of Calamos Investments LLC (“CILLC”). Calamos Asset Management, Inc. (“CAM”) is the sole manager of Calamos Investments LLC, which owns and manages our operating companies. Unless the context otherwise requires, references to “we,” “us,” “our,” “the firm,” “our company” and “Calamos” refer to Calamos Advisors LLC (“CAL”). Please note our use of the term “registered” throughout this brochure does not imply a certain level of skill or training. The firm’s roots date back to 1977 when John P. Calamos, Sr. began serving clients with an emphasis on investment strategies that sought to maximize the potential of convertible securities to manage risk and build wealth. Our firm, headquartered in Naperville, Illinois, has grown organically and through acquisitions with offices based in New York, San Francisco, Portland, Milwaukee, Chicago and Coral Gables. As of December 31, 2025, 77.718% of CILLC was owned by Calamos Partners LLC (“CPL”), 22.2402% by CAM, and .0418% by Calamos Equity Partners LLC (“CEP”). CPL was owned by John S. Koudounis and Calamos Family Partners, Inc. (“CFP”) with CFP beneficially owned by members of the Calamos family, including John P. Calamos, Sr. CAM was owned by John P. Calamos, Sr. and John S. Koudounis. CEP was owned by John S. Koudounis and Daniel L. Dufresne. INVESTMENT SERVICES Since the introduction of the firm’s first convertible strategy in 1977, Calamos has continued to expand its product offerings. In 1989, the firm introduced an equity strategy that invests in equity and equity sensitive securities, and in 1990, the firm introduced its U.S. equity growth strategy. In subsequent years, investment offerings expanded to include high yield, alternative, fixed income, enhanced fixed income, international growth equity, global long/short, small-cap, SMID and sustainable equity investment strategies. The firm offers and earns advisory fees on the following types of investment products: open-end mutual funds, closed-end funds, ETFs, interval funds, institutional accounts, separately managed accounts, commingled privately placed funds and offshore funds. CAL also offers the Calamos Global Convertible Fund and the Calamos Growth and Income Fund, each an Undertakings for Collective Investments in Transferable Securities (UCITS), and a series or sub-fund of GemCap Investment Funds (Ireland) PLC umbrella fund for which CAL serves as investment manager. Also, CAL offers the Calamos Antetokounmpo US Sustainable Equities Fund, a sub-fund of the Calamos Antetokounmpo Global Funds SICAV which qualifies as an UCITS and is organized under the laws of Luxembourg. Calamos also provides discretionary investment management services directly to institutional investors. Products are distributed through Intermediaries, such as investment advisers and broker-dealers both in the U.S. and abroad; Institutional Platforms; and Wealth Management for high net-worth individuals and private foundations. CAL also serves as a sub-investment adviser to investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”). In addition to providing discretionary and non-discretionary investment management services through separate accounts, pooled investment vehicles, and single strategy model portfolios, the Adviser offers asset allocation and multi-asset investment strategies (“Asset Allocation Strategies”). Asset Allocation Strategies involve the construction portfolios across multiple asset classes, which may include, but are not limited to, U.S. registered open-end, closed-end, and exchange-traded funds, interval and tender offer funds, as well as equities and cash or cash equivalents.

These strategies may invest in investment products managed by the Adviser or its affiliates, third-party investment products, individual securities, or a combination thereof. We do not sponsor any “wrap-fee” programs, however Calamos participates in several “wrap-fee” and unified managed accounts (“UMA”) programs (collectively, the “Wrap Programs”), which are sponsored by unaffiliated (third-party) investment advisory and/or brokerage firms (each a “Sponsor” and collectively, the “Sponsors”). We participate as a non-discretionary sub-adviser in Wrap Programs. In these Wrap Programs, a third-party Sponsor offers our firm’s strategies to its clients. We receive a fee from the third party as an investment adviser in these Wrap Programs. Calamos provides, to third-party investment advisers, Model Portfolios/Portfolio Emulations Services (“Model Portfolio”) for a fee. Model Portfolios contain Calamos’ current investment recommendations based on one of its investment strategies and other investment parameters as agreed to between Calamos and a third-party client or program Sponsor for the client’s or Sponsor’s use in advising its clients. Although Calamos provides recommendations, it does not have the authority or responsibility to implement those recommendations for any particular account. Rather, the client or third-party program Sponsor receiving the model and any updates to the model controls all investment decisions and executes the securities transactions on behalf of its own account or for the account of its clients. Therefore, there will likely be differences between these Model Portfolios and the discretionary portfolios managed by the firm for its other clients, including cash availability, investment restrictions, account size, holding limits, tax considerations, trade executions and other factors. As a result, the performance of our discretionary advisory clients and that of the Model Portfolios using the same investment strategies will differ. In addition, separate account, and model delivery programs (“Other Accounts”) of CAL have same day access to their portfolio holdings, and their advisors have access to representative portfolio holdings and may grant same day access to these portfolio holdings to their clients, their investors, and/or to one or more affiliated and unaffiliated service providers. In addition, information about non-public portfolio holdings information attributable to Other Accounts managed or advised by CAL may be available to one or more affiliated or unaffiliated service providers to those accounts. Some of the Other Accounts have substantially similar, or in some cases nearly identical, portfolio holdings to Calamos Funds. These Other Accounts are not subject to the portfolio holdings disclosure policies of the Funds to which they are similar and may disclose their similar or nearly identical portfolio holdings information in different forms and at different times than the Fund. TAILORED SERVICES For most types of accounts for which Calamos has investment discretion, we allow clients to customize their investments, upon their request, by imposing reasonable investment restrictions on certain securities, industries or sectors. In these cases, the client will provide Calamos with written instructions. These requests are typically received at account inception, but reasonable restrictions may be requested, in writing, at any time thereafter, and must be agreed to by Calamos. OTHER Given the multiple potential services that Calamos may provide to a client including a Fund or Funds in which clients may invest, conflicts of interest will arise. When using multiple Calamos (or affiliate) products and services (e.g., consulting and portfolio management), a client should be aware of the conflicts that may arise, consult its own adviser(s), and satisfy itself that the arrangement is appropriate and in its continuing best interests. Calamos and its affiliates are not required to devote their full-time or attention to managing your assets. We conduct other business and also provide investment counseling services to other clients that can be competitive with the activities provided to you. In advising other accounts, we give advice and make recommendations to such

accounts, which can be the same, similar to or different from those rendered to you. Differing compensation arrangements with other clients create incentives for us to favor such other clients. Calamos personnel may have more than one role at the company. Certain portfolio managers also serve as traders, investment risk managers, or research analysts. Further, certain research analysts offer investment ideas for teammanaged products. Personnel with multiple roles may have an incentive to favor certain accounts or responsibilities over others. John P. Calamos, Sr., Founder, Chairman and Global Chief Investment Officer, and his family have controlling interest in the firm. This affiliation creates a conflict of interest between our duty to act in your best interest while acting in the best interest of the firm. The firm has in place policies and procedures to address conflicts of interest or potential conflicts of interest. These policies and procedures are described throughout this brochure and include requirements that Calamos employees act in the best interest of the client. Generative Artificial Intelligence (GenAI): The Firm has adopted a Generative Artificial Intelligence (GenAI) Policy that governs the use of AI tools capable of generating new content such as text, images, and other data. The firm has established specific guidelines, oversight mechanisms, and risk controls for the use of these technologies. A Technology Steering Committee and AI Advisory Council oversee the implementation and approval of AI use cases across the organization. Key risks associated with GenAI that the firm actively monitors and manages include:

Data security risks, including potential loss of sensitive or proprietary information Accuracy concerns, as AI may generate content that appears authoritative but contains inaccuracies or hallucinations Privacy and confidentiality risks related to client and business information Intellectual property considerations, including potential copyright infringement Content-related risks such as bias or unnatural language in AI-generated materials

To mitigate these risks, Calamos has implemented strict controls including: • Pre-approval requirements for GenAI use cases • Restrictions on inputting sensitive data into public AI tools • Mandatory review and verification of AI-generated content by appropriate personnel • AI generated content is reviewed by appropriate personnel • Regular employee training on appropriate AI usage • Clear guidelines for protecting client and proprietary information The firm continually evaluates and updates its AI policies and procedures as this technology evolves to ensure responsible use while maintaining our commitment to client service and security. Please note: CAL does not utilize AI technology for portfolio design or autonomous decision making. While investment professionals may use AI tools for research summarization and data analysis, all investment decisions are made by human portfolio managers. AI does not generate investment recommendations or execute trades.

ASSETS UNDER MANAGEMENT As of December 31, 2025, Calamos had approximately $43.8 billion total assets under management.

Separate accounts are individual portfolios of securities managed to meet clients’ unique needs and include institutional accounts and managed accounts. Generally, the minimum account size for a separate account ranges from $1 million to $25 million depending on the strategy selected. The minimum account size for wrap-fee and UMA programs is typically $75,000 to $250,000, depending on the strategy and Sponsor minimums. Calamos reserves the right to waive or reduce the minimum account size at our discretion. Separate account fees are based upon a percentage of assets under management, typically calculated and invoiced at the end of each calendar quarter and are normally payable quarterly in advance. Fees may also be payable in arrears. Please see your Investment Management Agreement to determine your fee schedule. Below is the standard fee schedule.

STRATEGY NAME

MINIMUM INVESTMENT

INVESTMENT AMOUNT

FEES

Convertible Arbitrage

$50,000,000

0.80%

Dynamic Intermediate Tax-Efficient

$1,000,000

on first $10m

0.40%

next $15m next $50m next $150m on first $50m next $50m next $50m on first $25m on first $25m next $50m on first $25m next $50m

0.30% 0.25% 0.20% 0.15% 0.10% 0.95% 0.85% 0.80% 0.70% 0.85% 0.70% 0.65% 0.90% 0.75% 0.65% 0.60% 0.90% 0.75% 0.65% 0.60%

on first $25m

0.75% 0.70%

Emerging Economies

$25,000,000

Global Convertible

$25,000,000

Global Growth

$25,000,000

Global Opportunities

$25,000,000

Global Sustainable Equities

$5,000,000

Hedged Equity

$25,000,000

High Income Opportunities

$25,000,000

International Growth

$25,000,000

International Growth Concentrated

$25,000,000

next $50m on first $25m

0.65% 0.60% 0.60% 0.50% 0.45%

on first $50m next $50m on first $25m next $50m

0.60% 0.50% 0.40% 0.90% 0.75% 0.65% 0.60%

on first $25m

0.90%

next $50m

0.75% 0.65% 0.60%

International Small Cap Growth

$25,000,000

International Sustainable Equities

on first $50m next $50m

0.95% 0.85% 0.75%

$5,000,000

Market Neutral Income

$100,000,000

Merger Arbitrage Phineus Long/Short

$25,000,000 $10,000,000

Short-Term Bond

$10,000,000

Small Cap Growth

$5,000,000

on first $25m next $50m on first $100m next $100m on first $25m next $50m on first $25m on first $25m

0.80% 0.75% 0.70% 0.65% 0.75% 0.70% 0.65% 0.80% 1.25% 1.00% 0.90% 0.80% 0.30% 0.25% 0.20% 0.90% 0.85%

next $50m

0.75%

SMID Growth

$5,000,000

Preferred Securities

$10,000,000

U.S. All Cap Growth

$5,000,000

U.S. Convertible

$25,000,000

U.S. Core Plus Fixed Income

$25,000,000

U.S. Mid Cap Growth

$5,000,000

U.S. Opportunities

$25,000,000

U.S. Sustainable Equities

$5,000,000

U.S. Select Equity

$5,000,000

U.S. Select Equity Growth

$5,000,000

U.S. Select Tech Plus

$5,000,000

on first $25m $25-50m $50-100m above $100m on first $50m next $50m on first $25m on first $25m

0.65% 0.95% 0.90% 0.85% 0.70% 0.40% 0.35% 0.30% 0.75% 0.70% 0.65% 0.50% 0.75% 0.70% 0.65%

on first $25m on first $25m on first $25m on first $25m next $50m on first $25m on first $25m on first $25m

0.50% 0.40% 0.30% 0.75% 0.70% 0.65% 0.50% 0.75% 0.70% 0.65% 0.70% 0.65% 0.60% 0.55% 0.75% 0.70% 0.65% 0.50% 0.75% 0.70% 0.65% 0.50% 0.75%

80/20 Convertible

$25,000,000

80/20 Global Convertible

$25,000,000

on first $25m on first $25m

0.70% 0.65% 0.50% 0.75% 0.70% 0.65% 0.85% 0.70% 0.65%

A description of the investment strategies available in separate accounts is provided in Item 8. Please note that there are CAL strategies provided in Item 8 that are only offered to Calamos Wealth Management LLC (“CWM”) clients 1; see CWM Form ADV 2A for information on those fee schedules. Limited Negotiability of Advisory Fees: Although Calamos has established the standard fee structure set forth above, we retain the discretion to negotiate or waive fees on a client-by-client basis. Also, pre-existing advisory clients are subject to our minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship with us. The applicable minimum account requirements as well as advisory fees paid will differ among clients, and other clients may pay less than you or have lower minimums. In determining the fee structure for your account, we consider the nature of our proposed advisory relationship with you. The nature of our proposed advisory relationship is determined by the assets to be placed under our management, anticipated future additional assets, services provided, other accounts you may have with us, account type, portfolio style, account composition, and reporting, among other factors. We may group certain of your accounts for the purposes of meeting the minimum account size requirements and determining the annualized fee. Your specific annual fee structure is described in your investment advisory agreement. Discounts are offered to the firm’s employees, their family members, and friends. It should be noted that while we believe our fees are reasonable, similar advisory services may be available from other investment advisers for lower fees. Similarly, certain of the investment products that we recommend for your account will be available through other brokers or intermediaries that are not affiliated with Calamos. The only compensation received by Calamos for affecting securities transactions for clients is its advisory fees. Calamos will also receive certain non-financial soft dollar benefits. See Item 12 Brokerage Practices for more details. Termination of the Advisory Relationship: Under our current form of the advisory agreement, the agreement may be terminated at any time, by either party, for any reason upon receipt of 30 days written notice. Upon termination of your account, any prepaid, unearned fees will be refunded to you promptly. Calamos will issue you an invoice for any unpaid fees. In calculating your remaining fee or reimbursement, we will prorate the fee or reimbursement according to the number of days remaining in the billing period.

1 Calamos Wealth Management LLC is an affiliated wealth manager providing wealth management services, including asset allocation, to

high net worth individuals, family offices, private foundations, guardians of persons and estates, custodians for individuals, retirement plans for self-employed persons, and institutional plans such as Taft-Hartley plans and those of Corporations.

“WRAP-FEE” AND SIMILAR ARRANGEMENTS Calamos participates in several Wrap Programs. As a client in a Wrap Program, you should carefully review the Sponsor’s Form ADV Part 2A for complete details regarding the Wrap Program. The typical minimum account size is $75,000 to $100,000 depending on the strategy and Sponsor minimums. Calamos reserves the right to establish higher minimums for select strategies and to waive or reduce the minimum account size at our discretion. If we execute your trades through a broker-dealer other than the Sponsor, those trades will likely be subject to brokerage commissions and equivalents, markups and markdowns, and transaction fees. A client participating in these Wrap Programs should be aware that the Sponsor will charge various program fees; e.g. trade away fees, in addition to the advisory fee charged by Calamos. All such fee disclosures are provided in the Sponsor’s Form ADV Part 2A. MUTUAL FUNDS CAL receives investment advisory, and distribution fees, as described below, as a service provider to the Calamos Funds (the “Mutual Funds”), which are registered under the 1940 Act. CAL receives distribution fees (12b-1 fees) on C share purchases for the first year after purchase because CAL pays the broker dealer or investment adviser 1% at the time of the client’s share purchase. After the first year, the distribution fees revert to the broker dealer listed on the account. These and other fees are charged by the funds and are described in the Mutual Funds’ registration statements, shareholder reports, and the funds’ prospectuses, which are available online at https://www.calamos.com/resources#mutualfunds. Please refer to them for additional information. CAL also acts as sub-adviser to affiliated 2 and unaffiliated mutual funds and the fees associated with those funds are described in the registration statements and/or financial filings of those funds. Certain Calamos supervised persons and related sales personnel are also associated with Calamos Financial Services LLC (“CFS”), an affiliated limited purpose broker-dealer, and in that capacity engage in marketing or selling activities with respect to shares in the Mutual Funds. Supervised persons and related sales personnel are compensated for successful marketing or selling activities with respect to shares in the Mutual Funds. These compensation arrangements create potential conflicts of interest that give Calamos and its supervised persons and related sales personnel an incentive to recommend particular Mutual Funds to potential investors based on the compensation received rather than on a mutual fund investor’s need. The Calamos Mutual Funds website provides information describing Wholesaler compensation at: https://www.calamos.com/globalassets/media/fundinvestor/literature/wholesaler/calamosinvestmentswholesal ercompensation_focusfunds.pdf Additionally, the Mutual Funds’ prospectuses provide additional details to help prospective investors understand potential conflicts of interest associated with the compensation of the intermediaries that sell fund shares. We do not receive revenue sharing payments from funds or other advisers. CLOSED-END FUNDS The investment advisory fees that we receive as an investment adviser to the Calamos Closed-End Funds are described in the registration statements and financial filings of those funds. Registration Statements, financial filings and press releases are also available online at https://www.calamos.com/resources#closedendfunds.

CAL acts as subadvisor to the Calamos Antetokounmpo Sustainable Equities Fund and Calamos Antetokounmpo Global Sustainable Equities ETF.

INTERVAL FUNDS Calamos serves as investment adviser to the Calamos Aksia Alternative Credit and Income Fund, Calamos Aksia Private Equity and Alternatives Fund, and the Calamos Aksia Hedged Strategies Fund which are interval funds. The investment advisory fees that we receive as investment adviser to the fund are described in the registration statements and financial filings for each fund. Registration Statements, financial filings and press releases are also available online at https://www.calamos.com/resources/#intervalfunds. EXCHANGE TRADED FUNDS The investment advisory fees that we receive as an investment adviser to the Calamos ETFs are described in the registration statement and/or financial filings of the funds. Registration Statements, financial filings and press releases are also available online at https://www.calamos.com/resources/#exchangetradedfunds. UNDERTAKING FOR COLLECTIVE INVESTMENTS Calamos serves as investment manager to the Calamos Global Convertible Fund and the Calamos Growth and Income Fund, each a UCITS, and a sub-fund of GemCap Investment Funds (Ireland) PLC 3 which is an open-ended umbrella investment company with variable capital incorporated with limited liability and segregated liability between Funds. In addition, Calamos serves as sub-investment manager to the Calamos Antetokounmpo US Sustainable Equities Fund, a sub-fund of the Calamos Antetokounmpo Global Funds SICAV which qualifies as an UCITS and is organized under the laws of Luxembourg. The fees that we receive for investment management or sub-investment management services are described in the supplement to the prospectus of each Fund which is available online at Global Convertible | Calamos Investments, Growth and Income | Calamos Investments and Calamos Antetokounmpo US Sustainable Equities | Calamos Investments . The UCITS are available to non-U.S. clients only. POOLED INVESTMENT VEHICLES Calamos also serves as General Partner and investment adviser to the Calamos Global Opportunities Fund Limited Partnership. Fees relating to the Calamos Global Opportunities Fund Limited Partnership are further described in the Confidential Private Offering Memoranda. These products are available to accredited investors only. Calamos serves as the Investment Manager and General Partner to the Calamos Ares Quant Fund I, LP. This fund is not currently offered to investors. CUSTODY FEES Calamos does not maintain custody of account assets except in relation to its role as General Partner to several private funds. See Item 15. Rather, you must establish a custody account with an unaffiliated custodian. Your custodian will charge you fees for providing custody services for the assets held by them. OTHER FEES OR EXPENSES In addition to the fees and expenses described in the foregoing section, you will also pay costs such as brokerage commissions and equivalents, markups and markdowns, transaction fees, custodial fees, transfer taxes, wire transfer fees, and other fees and taxes charged to brokerage accounts and securities transactions, which are in addition to the advisory fee collected by Calamos (See Item 12 for more details). Open-end mutual funds, closed-end funds, ETFs, interval funds and UCITS are subject to various fees and expenses, While the name of the management company has changed from Gemini Capital Management (Ireland) Limited to Ascender Fund Partners (Ireland) Limited, the UCITS umbrella is still named GemCap Investment Funds (Ireland) Plc. https://registers.centralbank.ie/FundRegisterDataPage.aspx?fundReferenceNumber=C67292&register=28

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We believe our competitive advantage or value as an investment manager is our ability to evaluate businesses strategically by marrying top-down insights with rigorous bottom-up fundamental research. We employ an active, high-conviction investment approach to building portfolios. A collaborative team-managed approach allows us to fully evaluate all elements of an investment idea. Top-down perspective, proprietary fundamental research and risk-management drive the portfolio construction process across all strategies. Our investment organization is structured so that each portfolio management team maintains a dedicated focus on their area of expertise, while drawing on our shared perspectives. We believe this focus on specialization is essential because the diverse investment strategies that we offer require distinct skill sets to capitalize on investment opportunities. For certain Funds, CAL takes sustainability factors into account when making investment decisions. Chaired by John P. Calamos, Sr., the Calamos Investment Committee establishes our firm’s top-down views on the macro environment, market direction, country/sector positioning, asset allocation, and secular/cyclical themes. The Investment Committee is also responsible for reviewing portfolio risk metrics, positioning, and investment performance across strategies, as well as recommending enhancements to the investment process. Our bottom-up research utilizes both qualitative and quantitative criteria. Quantitative research provides a starting point that allows us to target investment candidates for deeper qualitative analysis. To meet the diverse investment requirements of clients, we offer a range of investment strategies, including equity, convertible, fixed income, global, alternative and sustainable strategies. Risk management is a shared function across the investment team undertaken by the co-portfolio managers and research analysts on a daily basis as we analyze risk at the issuing company, security and portfolio levels as well as across our investment firm. Our strategies also benefit from the contributions of a dedicated team focused on risk management. See also Risk Factors below. INVESTMENT PROCESS: ALTERNATIVES Global Long/Short The long/short investment process is led by a macro top-down and fundamental bottom-up approach that seeks long and short opportunities in worldwide markets as well as in companies that exhibit enduring (on the long side) or eroding (on the short side) franchise value. The investment process is global, fundamental and incorporates a blend of top-down and bottom-up considerations. The approach emphasizes: 1) a comprehensive assessment of what drives share prices; 2) how companies and industries are analyzed; and 3) the flexible management of style, capitalization and country factors. While the approach is primarily derived from the team’s assessment of corporate and economic fundamentals, all investment styles are considered depending upon a company’s business model, prevailing market conditions and

the economic cycle. Central to the philosophy is a rigorous and collaborative process of fundamental research on companies and industries. This includes proprietary and independent research as well as analysis of publicly available information. The approach emphasizes: 1) a multi-year perspective of corporate prospects; 2) the ability to incorporate a global perspective when analyzing companies’ fundamentals; and 3) analytical breadth and lateral thinking when judging technological shifts and their impact upon business models. While investments are rarely sourced only on the basis of a macro view, the process is alert to macro risks as well as rotational, liquidity, correlation and other risks. Quantitative tools are used to monitor the exposure to style and other common risk factors. The portfolio aims to achieve its investment objective primarily by investing globally in publicly listed equity securities of issuers that operate in the knowledge-based sectors such as technology, communications and media, as well as financial services and healthcare, and other investment vehicles, including exchange-traded funds (“ETFs”) that track or otherwise provide exposure to such sectors. We believe the heterogeneous, disruptive and volatile nature of many of these sectors are well suited for long/short equity investing. Other sectors are considered if, in our opinion, such long and short exposures have favorable potential for contributing value including areas traditionally considered to be more cyclically oriented including, but not limited to, industrials, energy and commodities. The strategy may maintain long and short positions through the use of derivative instruments such as options, futures and forward contracts. The strategy may also invest in cash and equivalents. Market Neutral Income For our Market Neutral Income, Hedged Equity, Convertible Arbitrage and Merger strategies, the team employs a combination of rigorous quantitative and fundamental research to evaluate securities that may offer compelling hedging opportunities. The team’s analysis of volatility, valuation research, and the identification of market mispricing or dislocations lead to investment ideas in the convertible arbitrage portion of alternative strategies. Analysis of valuation, correlation, tracking error and volatility pricing are utilized in the hedged equity portion. Alternative Strategies Strategies that go beyond the traditional ways of investing. These strategies tend to behave differently than typical stock and bond investments and may provide broader diversification, reduce risk, and enhance returns. Phineus Long/Short Strategy – A fundamental, global process that incorporates a blend of top-down and bottom-up considerations as the adviser employs a flexible asset allocation across the global equity universe. The strategy allows for all investment styles (growth, value, etc.) to be considered. Market Neutral Income – A lower volatility strategy that invests in convertible arbitrage and hedged equity strategies. Convertible arbitrage includes the purchase of convertible securities and the shorting of stock related to the underlying equity of the convertible holding. Hedged equity includes a broadly diversified portfolio of U.S. common stock as well as the writing (or sale) of index call options and/or entering into other option strategies on equity securities and/or broad-based indices. Hedged Equity – A lower volatility, U.S. equity strategy that invests in a broadly diversified portfolio of U.S. common stock while also writing (selling) index call options and/or entering into other option strategies on equity securities and/or broad based indices. Convertible Arbitrage - A strategy that seeks capital preservation by generating absolute returns to equity and fixed income markets. Merger Arbitrage - An absolute return strategy that focuses on identifying risk-adjusted opportunities to capture the “spread” in pending merger, takeover and other corporate reorganizations, with the goal of

profiting from the timely completion of these transactions. Structured Protection – Strategies that utilize options-based strategies to deliver upside participation up to a stated cap with significant downside protection over pre-determined outcome periods and are offered for various underlying equity index exposures. Closed-End Arbitrage – A strategy that seeks to pay high current income with the potential to deliver capital appreciation through investments in discounted closed-end funds that are believed to be positioned to benefit from narrowing discounts. Autocallable Income – Strategies that seek to generate high, stable monthly income while providing a degree of downside risk mitigation through exposure to a diversified, laddered portfolio of autocallable yield notes tied to equity market performance. INVESTMENT PROCESS: CONVERTIBLES & EQUITY Our strategies pair bottom-up fundamental research with our top-down analysis of secular themes, macro trends and other factors. Our strategies benefit from a team-based approach and decades of experience. While we view ourselves as fundamental investors, our research blends both qualitative and quantitative analysis, with the latter helping to frame and focus our deeper fundamental research. Before investing, we carefully consider a security's impact on a portfolio's industry and sector allocations, referencing our macroeconomic outlook and thematic considerations. We also utilize quantitative analysis to help us more efficiently analyze fundamental and market dynamics. Since our founding in the 1970s, our capabilities have included comprehensive capital structure research. We believe this experience is a key differentiator that can help us identify the most compelling opportunities from a risk/reward standpoint and the market dynamics affecting pricing and risk. Company analysis includes identifying opportunities from a bottom-up perspective. The end goal is to determine the economic value of a company. We evaluate the overall attractiveness of a business—how fast its market is growing, the company’s distinctive competitiveness and the ability to grow its market share and improve its profitability. We analyze a business as would a buyer of the entire company; this involves developing an investment thesis that incorporates growth drivers, potential risks and valuations. Once we understand the value of a business, we seek to determine the value of each security across the company's capital structure and closely analyze each security's upside and downside potential. Our research process lends itself to identifying investment opportunities with a variety of characteristics whether companies that offer above average and sustainable growth potential or more stable companies (e.g., those that are effective stewards of capital with quality management) that are undervalued by the market but have a nearterm catalyst that we believe can move their security prices higher. Additionally, we incorporate our own credit analysis as part of our convertible research process as well as part of our capital structure research. Convertible Strategies Strategies that seek to pursue equity market upside with potentially less downside than an all-equity portfolio, by investing primarily in convertible securities. Global Convertible – A global convertible strategy that seeks to leverage our capital structure research by investing in convertible securities in an effort to generate consistent alpha and manage downside volatility. U.S. Convertible – A U.S. convertible strategy that seeks to leverage our capital structure research by investing in convertible securities in an effort to generate consistent alpha and manage downside volatility. Equity Sensitive Convertible – A U.S. convertible strategy that seeks to deliver total returns through capital appreciation and current income, by investing largely in a portfolio of US convertible securities exhibiting a high level of equity sensitivity.

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Calamos provides investment management services to:

institutional clients such as corporations and financial institutions; registered investment companies, open-end funds; exchange-traded funds (“ETFs”);

closed-end funds, including interval funds; charitable institutions, foundations and endowments; corporate pensions, profit sharing and other retirement plans; municipalities; individuals;

Taft-Hartley plans; and pooled investment vehicles, including limited partnerships.

Calamos or an affiliate may receive performance-based or incentive fees from you or funds in which you invest. A performance fee arrangement creates an incentive for the portfolio manager to make investments that are riskier or more speculative than would be the case in the absence of performance fees. A performance fee arrangement may result in increased compensation to the co-portfolio managers from such accounts due to unrealized appreciation as well as realized gains in the client’s account; therefore, Calamos has an incentive to favor such accounts. Calamos is the adviser to two mutual funds that make fee adjustments based on fund performance. The Calamos International Growth Fund and the Calamos Global Equity Fund each pay a base fee, subject to possible adjustment based on the fund’s performance, as described in the fund’s prospectus. The payment and calculation of the performance adjustment is subject to the ultimate supervision of the board of trustees of the funds, Calamos will receive a positive performance adjustment even if the fund has a negative return over a performance measurement period if it otherwise outperforms its respective index during that period.

A portfolio manager will be faced with a conflict of interest when allocating investment opportunities, given the possibility of greater fees from accounts that pay performance-based fees as opposed to accounts that do not pay performance-based fees. To the extent that Calamos receives performance fees, allocations or otherwise receives higher performance fees, allocations or investment management fees from a client than it does with respect to clients generally, Calamos will have an economic incentive to allocate additional resources or investment professionals to such client and, to the extent such resources are limited, away from other clients. To address these types of conflicts, we have adopted policies and procedures that promote the allocation of investment opportunities in a manner consistent with our obligations as an investment adviser. See Item 12 for additional information on our trade allocation procedures. To further manage these types of conflicts, we have implemented policies and procedures, discussed in greater detail below, that are designed in part to manage and mitigate the potential conflicts arising from the management of traditional investment portfolios alongside alternative investment portfolios, including conflicts arising from differences in fee structures. SIDE-BY-SIDE MANAGEMENT Management of multiple portfolios gives rise to conflicts of interest. These include, for example, conflicts among investment strategies, conflicts in the allocation of investment opportunities, or conflicts due to different fees. Some accounts have higher fees than others. Fees charged to clients differ depending upon a number of factors including, but not limited to, the particular strategy, the size of the portfolio being managed, the relationship with the client, the service requirements, or the account type (e.g., separately managed accounts). Based on these factors, a client may pay higher fees than another client in the same strategy. Also, clients with larger assets under management generate more revenue for CAL than smaller accounts. These differences give rise to a conflict that a portfolio manager may favor the higher fee-paying account over the other or allocate more time to the management of one account over another. Also, Calamos serves as an adviser to long-only accounts, accounts that execute short sales, and a long/short account. Calamos sells short securities in a long-short account while oftentimes holding long the same security in another account. In this case, we could harm the performance of the long-only accounts for the benefit of accounts that execute short sales, which may include performance-based fee accounts. For example, continually selling a position short may depress the stock price, which would harm a long-only account holding the same security. As noted above (See Item 5) the portfolio manager for Calamos Phineus Long/Short Fund is incentivized to favor this fund over the other accounts he manages. To manage these conflicts, we have implemented Side-by-Side Management policies and procedures designed to set out specific requirements regarding the side-by-side management of traditional investment portfolios (e.g., long-only portfolios) and alternative investment portfolios, including without limitation, those associated with any differences in fee structures, investments in the alternative investment portfolios by Calamos or its employees and trading-related conflicts including conflicts of interest that may also be raised when Calamos investment teams take conflicting (i.e., opposite direction) positions in the same or related securities for different accounts. In addition, we have established a Side-by-Side Management Committee that seeks to ensure that such conflicts are reviewed and managed appropriately.

As noted in Item 4, our firm is an investment adviser registered with the SEC and a wholly owned subsidiary of CILLC. Calamos is a diverse financial services organization. In some cases, affiliates of Calamos have business arrangements with related persons/companies that are material to Calamos’ advisory business or to its clients. In some cases, these business arrangements create potential conflicts of interest, or the appearance of a conflict of interest between Calamos and a client. Calamos has policies and procedures in place to identify and mitigate such conflicts. In addition, Calamos has established a Conflicts of Interest Committee, which has among its responsibilities the identification and mitigation of such conflicts of interest. The following is a list of other related parties of the firm:

Calamos Advisors Trust is a Massachusetts business trust registered under the 1940 Act. Calamos Aksia Alternative Credit and Income Fund is a closed-end investment company, operated as an interval fund, registered under the 1940 Act. Calamos Aksia Alternative Credit & Income Fund (Offshore), Ltd. is a Cayman Islands exempted company whereby Calamos Advisors LLC serves as the Investment Manager. Calamos Aksia Alternative Credit & Income Fund (Offshore) I, Ltd. is a Cayman Islands exempted company whereby Calamos Advisors LLC serves as the Investment Manager. Calamos Aksia Hedge Fund Access Enhanced Alpha LP is a Delaware limited partnership whereby Calamos Advisors LLC serves as the Investment Manager and General Partner. Calamos Aksia Hedged Strategies Fund is a closed-end investment company, operated as an interval fund, registered under the 1940 Act. Calamos Aksia Private Equity LP is a Delaware limited partnership whereby Calamos Advisors LLC serves as the Investment Manager and General Partner. Calamos Aksia Private Equity and Alternatives Fund is a closed-end investment company, operated as an interval fund, registered under the 1940 Act. Calamos Aksia Private Equity (Offshore), Ltd. is a Cayman Islands exempted company whereby Calamos Advisors LLC serves as the Investment Manager. Calamos Aksia Private Equity (Offshore) I, Ltd. is a Cayman Islands exempted company whereby Calamos Advisors LLC serves as the Investment Manager. Calamos Antetokounmpo Asset Management LLC, a joint venture entity, is an investment adviser registered with the SEC. Calamos Advisors LLC is a joint venture partner. Calamos Antetokounmpo Sustainable Equities Trust, a Delaware statutory trust registered under the 1940 Act. Calamos Ares Quant Fund I, LP is a Delaware limited partnership whereby Calamos Advisors LLC serves as the Investment Manager and General Partner. Calamos Asset Management, Inc. is the sole manager of Calamos Investments LLC. Calamos Convertible and High Income Fund is a closed-end company registered under the 1940 Act. Calamos Convertible Opportunities and Income Fund is a closed-end company registered under the 1940 Act.

Calamos Dynamic Convertible and Income Fund is a closed-end investment company registered under the 1940 Act. Calamos Equity Partners LLC is a Delaware limited liability company owned by John S. Koudounis and Daniel L. Dufresne. Calamos ETF Trust is a Delaware statutory trust registered under the 1940 Act. Calamos Family Partners, Inc. is a private firm in which John P. Calamos, Sr. owns a controlling interest. Calamos Financial Services LLC is registered under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), as a limited purpose broker‐dealer. Its operations consist primarily of the distribution and sale of the Calamos Family of Mutual Funds and ETFs. Certain members of CAL’s management team are registered representatives of Calamos Financial Services LLC. Calamos Global Dynamic Income Fund is a closed-end company registered under the 1940 Act. Calamos Global Opportunities Fund LP is a Delaware limited partnership whereby Calamos Advisors LLC serves as the Investment Manager and General Partner. Calamos Global Total Return Fund is a closed-end company registered under the 1940 Act. Calamos Investments LLC is a holding company. Through its subsidiaries, the firm provides investment management and distribution related services to its clients. Calamos Investment Trust is a Massachusetts business trust registered under the 1940 Act. Calamos Long/Short Equity & Dynamic Income Trust is a closed-end investment company registered under the 1940 Act. Calamos Opis LLC is a Delaware limited liability company formed to manage proprietary investments. Calamos Partners LLC is a Delaware limited liability company owned by Calamos Family Partners, Inc., and John S. Koudounis. Calamos Private Equity LLC is a Delaware limited liability company wholly owned by Calamos Investments LLC and was formed to manage private equity investments. Calamos Strategic Total Return Fund is a closed-end company registered under the 1940 Act. Calamos Wealth Management LLC is a registered investment adviser that provides wealth management services, including asset allocation and investment advisory services, to high-net-worth individuals, family offices and private foundations. CKPE Fund I, LLC, is a private equity fund, owned by Calamos Private Equity LLC, John P. Calamos, Sr., and John Koudounis, with a focus on real estate asset investments. Primacy Business Center LLC is a Delaware limited liability company wholly owned by Calamos Family Partners, Inc.

INVESTMENT COMPANIES Calamos serves as the investment adviser (or as otherwise indicated) to mutual funds, closed-end funds, ETFs, interval funds and investment manager to UCITS. Calamos Mutual Funds:

Calamos Antetokounmpo Sustainable Equities Calamos Convertible Calamos Evolving World Growth Calamos Global Convertible Calamos Global Equity

Calamos Global Opportunities Calamos Growth Calamos Growth and Income Calamos Hedged Equity Calamos High Income Opportunities Calamos International Small Cap Growth Calamos International Growth Calamos Market Neutral Income Calamos Merger Arbitrage Calamos Select Calamos Phineus Long/Short Calamos Short Term Bond Calamos Timpani Small Cap Growth Calamos Timpani SMID Growth Calamos Total Return Bond

Calamos Closed-End Funds:

Calamos Dynamic Convertible and Income (CCD) Calamos Convertible Opportunities and Income (CHI) Calamos Convertible and High Income (CHY) Calamos Global Dynamic Income (CHW) Calamos Strategic Total Return (CSQ) Calamos Global Total Return (CGO) Calamos Long/Short Equity & Dynamic Income Trust (CPZ)

Calamos ETFs:

Calamos Antetokounmpo Global Sustainable Equities ETF (SROI) Calamos Convertible Equity Alternative ETF (CVRT) Calamos CEF Income & Arbitrage ETF (CCEF) Calamos Alternative Nasdaq & Bond ETF (CANQ) Calamos Autocallable Income ETF (CAIE) Calamos Nasdaq Autocallable Income ETF (CAIQ)

Calamos Structured Protection ETFs:

Calamos S&P 500 Structured Alt Protection ETF - Monthly (Jan-Dec) Calamos Nasdaq-100 Structured Alt Protection ETF - Quarterly (June, Sep, Dec, Mar) Calamos Russell 2000 Structured Alt Protection ETF - Quarterly (June, Sep, Dec, Mar) Calamos Laddered S&P 500 Structured Alt Protection ETF (CPSL) Calamos Bitcoin Structured Alt Protection ETF – Quarterly (Jan, April, July, Oct) Calamos Laddered Bitcoin Structured Alt Protection ETF (CBOL) Calamos Bitcoin 90 Series Structured Alt Protection ETF – Quarterly (Jan, April, July, Oct) Calamos Laddered Bitcoin 90 Series Structured Alt Protection ETF (CBXL) Calamos Bitcoin 80 Series Structured Alt Protection ETF – Quarterly (Jan, April, July, Oct) Calamos Laddered Bitcoin 80 Series Structured Alt Protection ETF (CBTL)

Calamos Interval Funds:

Calamos Aksia Alternative Credit and Income Fund (CAPIX) Calamos Aksia Private Equity and Alternatives Fund (CAPVX) Calamos Aksia Hedged Strategies Fund (HEDGX)

Calamos UCITS:

Calamos Global Convertible Fund, a UCITS, and a sub-fund of GemCap Investment Funds (Ireland) PLC Calamos Growth and Income Fund, a UCITS, and a sub-fund of GemCap Investment Funds (Ireland) PLC Calamos Antetokounmpo U.S. Sustainable Equities Fund, and a sub-fund of the Calamos Antetokounmpo Global Funds SICAV (Luxembourg)

UCITS are not U.S. registered investment companies nor regulated by U.S. law and are not available to US residents. Calamos may also serve as a sub-adviser to other unaffiliated mutual funds. While we do not believe these services create a material conflict of interest between the firm and its other clients, Calamos has adopted policies and procedures to mitigate and manage any such conflicts as described throughout this brochure. POOLED INVESTMENT VEHICLES Calamos serves as Investment Manager and General Partner to the Calamos Global Opportunities Fund Limited Partnership (the “LP”). Fees relating to the LP are further described in the Confidential Private Offering Memoranda. Calamos also serves as the Investment Manager and General Partner to the Calamos Ares Quant Fund I, LP. This private fund is not currently being offered to investors.

Personal Trading CODE OF ETHICS & PERSONAL TRADING Calamos has adopted a Code of Ethics and Insider Trading Policy (“Code of Ethics”) which sets forth high ethical standards of business conduct required of our employees, including compliance with applicable federal securities laws. Our firm and our personnel owe a duty of loyalty, fairness and good faith toward you, our clients, and have an obligation to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. To mitigate the conflicts of interest caused by trading or other activities engaged in by our employees, our Code of Ethics requirements include the following controls:

Employees and their household members must maintain their brokerage accounts at a limited number of brokerage firms approved by Compliance; Employees must receive written approval from Compliance prior to transacting in “reportable securities” (as defined under Investment Adviser Act Rule 204(A)-1 (pre-clearance required); Employees and their household members must provide to Compliance quarterly trade confirmations or statements and annual security holdings reports; Employee requests to trade a reportable security (excluding Broad-based Securities 4) will generally be denied if a client traded in the same reportable security within the previous six business days. Trades in an

A Broad-based Security generally refers to any security index that would not be classified as a narrow-based security index under the

amount less than $10,000 in a 30 calendar day period in companies that have a market capitalization of at least $100 billion are exempt from the prohibitions with respect to whether Calamos is trading the same or equivalent security for the accounts of its clients of this Code. (An exception to selling transactions in covered securities is applicable for a limited time when an employee begins employment with the firm); Employee trade requests will be denied if a security is on the restricted list; Employees must hold securities for a minimum holding period of 60 calendar days to reduce excess and short-term or speculative trading. The holding period may be waived if the security is trading at a 20% or greater loss from where the employee purchased the security; Employees must obtain Management and Compliance approval prior to engaging in any outside business activity and their proposed activity will be vetted to ensure it does not create a conflict of interest with our clients, or that the firm is in a position to mitigate and manage any such conflict; Gifts given or accepted by employees must be reported to Compliance; Entertainment provided or received by employees must be reported to Compliance; Employees may not participate in Initial Public Offerings (“IPOs”); and Employees are prohibited from using Material Non-Public Information (“MNPI”) either professionally or personally.

Direct obligations of the U.S. Government (US Treasury bills, notes and bonds), money market instruments (including commercial paper and repurchase agreements), commodities including crypto currencies, shares of open-end mutual funds not advised or sub-advised by Calamos or units in 529 College Savings Plans are not included in the definition of covered securities and have been designated as exempt securities under the Code. Therefore the transactions are exempt in conjunction with the associated rules of the Code. The Code is designed to seek to ensure that the personal securities transactions, activities and interests of our employees will not interfere with making decisions that are in the best interest of advisory clients. The Code therefore restricts trading in close proximity to client trading and restricts personal trading of securities of which the firm is in possession of MNPI, as noted above. Under unusual circumstances, such as a personal financial emergency, or when it is determined that no conflict of interest or other breach of duty is involved, application for an exemption from certain restrictions on trading (excluding pre-clearance and reporting requirements) under this Code may be made to the CCO, which application may be denied or granted in the CCO’s discretion. From time to time, Calamos receives MNPI. This is information that is not available to other investors or other confidential information which, if disclosed, would likely affect an investor’s decision to buy, sell or hold a security. This information is received voluntarily and involuntarily and under varying circumstances including, but not limited to, upon execution of a non-disclosure agreement, as a result of serving on the board of directors of a company, serving on ad hoc or official creditor committees and participation in risk, advisory or other committees for various trading platforms and other market infrastructure related entities and organizations. Under applicable law, Calamos and its employees are generally prohibited from disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether that person is a client. Our Code of Ethics includes provisions governing oversight, enforcement, and recordkeeping. Access Persons’ trading is continually monitored under the Code to reasonably prevent conflicts of interest between Calamos

definitions or exclusions set forth in the Commodity Exchange Act and the Exchange Act or that meets certain criteria specified jointly by the U.S. Commodities Futures Trading Commission (“CFTC”) and the U.S. Securities and Exchange Commission. An example of a Broadbased Security is the S&P 500.

employees and Calamos clients. All Access Persons must annually acknowledge their understanding of the terms of the Code. A copy of the Calamos Code of Ethics is available to you by contacting us at caminfo@calamos.com, or by calling us at 800-582-6959. PARTICIPATING IN CLIENT TRANSACTIONS Calamos and its related parties may participate or have an interest in client transactions in one of several ways. For example, Calamos and its related parties may have positions or interests in equity or fixed-income securities, including shares of mutual Funds, closed-end funds, ETFs, interval funds, UCITS, pooled investment vehicles, and separately managed accounts in which its clients also are invested. Also, Calamos’ officers and employees are encouraged to invest in Calamos products. While Calamos’ Mutual Funds are not part of the core 401K offering, employees may specifically select them through a Personal Choice Retirement Account (PCRA), which is a brokerage account linked to the employees 401k account. Calamos’ aggregate fee revenues increase with purchases, by clients and others, of shares of these funds (mutual funds, closed-end funds, ETFs, interval funds, UCITS, and pooled investment vehicles). The greater CAL’s assets, the greater the fees we earn. From time to time, Calamos and its related parties invest in products (e.g. Calamos Mutual Fund) managed by Calamos to support the continued growth of those investment products and strategies. For example, Calamos or a related party may invest the initial investment capital in or “seed” a product and, as a result, hold a substantial proprietary interest in the product for a period of time after the product’s inception. When consistent with the client’s investment objectives, Calamos recommends to clients the purchase of these same investments in which Calamos or its employees or affiliates have a financial interest. The Mutual Funds are generally sold to the public on a “load” basis involving the payment of commission to an intermediary. However, there are certain share classes that have no load or where the sales load is, or may be, waived by the Calamos Fund’s Adviser. Calamos employees do not pay a sales load when purchasing Calamos openend funds. Calamos, its related parties and our employees have an incentive to favor the accounts in which we or they own a substantial interest. This conflict could result in our treating Calamos related accounts more favorably than other client accounts including in connection with the allocation of limited investment opportunities (such as IPOs) or the allocation of aggregated trade orders. In addition, Calamos’ or a related party’s disposition of such seed investment may adversely affect the price or liquidity of the product’s shares. With regard to its Mutual Fund investments, from time to time, Calamos or a related party may, for tax purposes, redeem a portion of its Mutual Fund holdings, reinvesting in shares of the same Mutual Fund shortly thereafter. These transactions are subject to the Mutual Funds’ excessive trading policies and procedures and will only be consummated if they are determined not to be disruptive to the management of the Mutual Fund. In determining whether trading is disruptive, consideration will be given to the purpose of the trades, the effects on the portfolio or shareholders, and whether the portfolio or shareholders will be made whole for any costs or administrative charges the Mutual Fund may incur as a result of the trade. In addition, these transactions will not be made if Calamos or its affiliate, as the case may be, is aware of any MNPI with respect to the Mutual Fund. Where we have an interest in a client transaction, we endeavor to make all investment decisions in our clients’ best interests. In addition, pursuant to our policies and procedures, our transactions generally are aggregated with, or effected after, client orders and we are allocated investment opportunities on a pro rata basis with our clients.

Further, we believe our and our employees’ investments in Calamos products helps to ensure our interests are aligned with those of our clients. Investments made by CAM, CILLC, CPL, CFP and the Calamos Family in products managed by CAL are not subject to restrictions of the Code of Ethics regarding short-term or speculative trading. As a result, such entities or individuals may hedge corporate or personal investments in such products. However, these hedging transactions are subject to oversight by the Compliance department. All other provisions of the Calamos Code of Ethics are otherwise applicable. See Item 10 for a list of related parties or affiliates. Calamos adopted policies and procedures designed to mitigate and manage these conflicts, including the following:

All Calamos employees have a fiduciary responsibility to act in the best interest of our clients and to put our clients’ interests in front of Calamos’ interests; Trade Order Aggregation and Allocation policies and procedures: o that seek to manage, monitor and, to the extent possible, minimize the effects of these conflicts o designed to allocate investment decisions and trades fairly and equitably over time among client accounts participating in each transaction; Dispersion testing, wherein we review the performance of accounts with similar investment strategies to identify performance outliers; Cross-Trade Policy (see below for information on our Cross-Trade Policy); Conflicts of Interest Committee that seeks to ensure all conflicts are identified and policies and procedures have been implemented to manage and mitigate them; and Compliance reviews trading after the fact to seek to ensure procedures and controls are effective.

Please also refer to Item 12 for additional information on trade order aggregation and allocation. Principal and Cross-Trades Calamos has adopted policies and procedures for entering into principal and cross trades under Rule 206(3)5 on behalf of its separately managed account clients and other advisory clients who are not Registered Investment Companies (“RICs”) or ERISA clients (“Client”) which are in accordance with the Advisers Act, Pursuant to these policies and procedures: (i) cross trades and principal trades should be consistent with the investment objectives and risk and liquidity profile of each Client involved, (ii) Client will be provided with full and fair disclosure of the valuation method used, potential conflicts of interest, and any costs to be incurred in connection with any cross or principal trade, provided that Calamos, its affiliated persons, and its supervised persons shall not receive commissions or any other compensation with respect to such trades; (iii) Calamos will seek best price and best execution to the extent possible for trades in securities where valuations are publicly available; and Calamos will determine a fair value for illiquid and/or restricted securities, based upon the Valuation Policy applicable to a Client and/or a private fund’s governing documents; (iv) prior to effecting any trade involving interests in underlying private funds held by a Client, Calamos will obtain written consent or other authority required to transfer such interests from the underlying private fund’s general partner/manager; (v) Calamos will obtain Client’s prospective consent authorizing any cross trade (provided that any blanket consent must state that Client may revoke consent at any time without penalty upon written notice to Calamos), and Client advance consent for any principal trade; and (vi) Calamos will send the Client at least annually a statement identifying the total number of principal trades entered into during the period, and the total commissions (if any) on such trades.

Investment Advisers Act of 1940

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Calamos has established a Brokerage Practices Committee (the “Committee”), which has responsibility for:

Approving broker-dealers through which trading for discretionary client accounts may be executed; Evaluating the performance of broker-dealers which shall include, among other things: o commission rates o execution services o reliability and coverage; Reviewing brokerage allocations; Reviewing and approving soft dollar arrangements; and Monitoring for best execution.

BROKERAGE SELECTION & BEST EXECUTION In approving a broker-dealer, Calamos will review relevant information about the broker-dealer, which may include some or all of the following:

Financial condition; Reputation and integrity; Commission rates; Trading expertise; Facilities; Willingness and ability to commit capital; Access to underwriter offering and secondary markets; Reliability in trade execution and record retention;

Fairness in resolving disputes; Financial services offered; and Value of research or other services provided.

If, after reviewing the broker-dealer’s information, Calamos reasonably believes it will benefit our clients as an executing broker-dealer, the broker-dealer will be added to the Approved Broker-Dealer list that is maintained by the Head Trader. Calamos has a duty to seek to obtain “best execution” of securities transactions for its clients. Calamos does not simply seek the lowest possible commission or cost but rather whether the transaction represents the best qualitative execution under all circumstances existing at the time of the trade. Calamos may select brokers and negotiate commissions based on research services as defined under Securities Exchange Act of 1934, as amended (the “Exchange Act”) Section 28(e) and, pay a broker a higher commission in a transaction where Calamos believes doing so is reasonable in relation to its responsibilities to all accounts for which Calamos has investment discretion. Calamos may be motivated to use client commissions rather than paying for services at its own expense or to select a broker based on the services they provide rather than the quality of their execution. This also will cause a client to pay commissions that are higher than commissions charged by brokers who do not provide the benefits listed above. However, Calamos believes that in return for paying fair and reasonable commissions, our clients will benefit. Some clients that did not directly pay for the benefits also will gain. When selecting a broker-dealer to execute a particular transaction, traders generally consider the full range of brokerage services including, but not limited to:

Execution capabilities; Commission rate/all-in transaction cost; Financial responsibility; Responsiveness; and The value of any research provided.

The traders will also consider:

The character of the market for the security; Size and type of transaction; and Number of primary markets.

Certain approved broker-dealers are also clients of Calamos or companies with which Calamos has other commercial dealings, which creates a conflict of interest. Calamos may be incented to favor these broker-dealers by directing trades to them. To mitigate or manage this risk, we have the following controls in place:

Head Trader oversees trading and spot checks trades; Monitoring execution in our clients’ portfolio transactions, including reviewing trades for best execution; If the commission rate exceeds a certain set amount, trades must be pre-approved by the Head Trader and then reported to Compliance along with the rationale for paying a higher rate; Head Trader uses third-party execution services to compare Calamos’ execution rate to those achieved by peer firms; and The Brokerage Practices Committee reviews best execution.

RESEARCH AND OTHER SOFT DOLLAR BENEFITS As stated above, Calamos has an obligation to seek best execution for clients’ transactions, and therefore to carefully utilize such commission dollars. Calamos believes using commission dollars for research and brokerage services is generally beneficial to clients; therefore, we will pay higher commissions to receive such research and brokerage services.

Calamos recognizes that while the acquisition of research and other services with client commission dollars can be valuable to any individual client, it also benefits Calamos and other Calamos clients, which creates a conflict of interest between Calamos and its clients. Section 28(e) under the Exchange Act provides a safe harbor permitting the use of client commissions to pay for certain “research” and “brokerage” products and services (these benefits received are referred to as soft dollars). Soft dollar arrangements are permitted under Section 28(e) when certain conditions are met:

Commission dollars are only used to obtain allowable brokerage or research services (as defined by Section 28(e) of the Exchange Act); Such brokerage or research must actually provide lawful and appropriate assistance in the performance of Calamos’ investment decision-making responsibilities; Calamos must in good faith determine that the amount of commission paid is reasonable in relation to the value of the brokerage and research services provided; Only commissions in agency transactions may be used to obtain such services and riskless principal transactions in equity securities; and Calamos must have investment discretion over the account.

In fulfilling our investment advisory responsibilities, when Calamos believes more than one broker can offer the brokerage services needed to obtain the best available price and most favorable execution, we will consider selecting those brokers that also supply research and brokerage services to us. We believe such services provide a net benefit to our clients as a whole. These research and brokerage products and services may include:

Information on the economy, industries, groups of securities, or individual companies; Statistical information; Analysis of Company financials; Information on political developments; Macro market commentary; Pricing and appraisal services; Credit analysis; Risk measurement analysis; Trade order management systems; Trade execution systems; and Analysis of corporate responsibility issues.

Research and brokerage products and services are provided to Calamos primarily in the form of:

Written reports; Telephone contact; Personal meetings with security analysts; Access to various computer-generated data and computer software; and Meetings arranged with corporate and industry spokespersons, economists, academicians, and government representatives.

Certain research and brokerage products and services might also be used for functions that are not research or brokerage related. In such cases, the research or brokerage service or product has a mixed use. Where a product

or service has a mixed use, Calamos will make a reasonable allocation of the cost of the product or service according to its use, and will pay for the non-research and brokerage function at its own expense (not using client commissions). We will use various methodologies to determine this allocation including but not limited to the percentage of time the product or service is used for investment decision-making or the percentage of the function that is investment decision-making or research-oriented, as the case may be, but under all circumstances, the mixed use allocation will be made in good faith and documented consistent with our Brokerage Practices Policy and Section 28(e) of the Exchange Act. Calamos participates in client commission arrangements (“CCAs”) under which we effect transactions through a broker-dealer and request that the broker-dealer allocate a portion of the commissions or commission credits to another firm that aggregates these client monies and, with our oversight and approval, pays service providers of qualified research and brokerage. Calamos believes the CCAs, as well as the research provided in connection with such arrangements, comply with Section 28(e) of the Exchange Act, as interpreted by the SEC. Further, Calamos believes participating in a CCA enables us to efficiently consolidate payments for qualified research and brokerage services through one or more channels. Using the accumulated client commissions (credits from transactions executed through multiple broker-dealers and electronic communication networks (“ECN”)), Calamos can then obtain qualified research and brokerage services provided by firms and vendors of its choice. Such arrangements also help to provide us with the continued receipt of research services while facilitating best execution in the trading process. In all cases, we believe such research and brokerage services are important to our investment decision-making. When Calamos uses client brokerage commissions to obtain research and brokerage services, we receive benefits because we do not have to produce such products internally and we do not have to compensate third-party providers of the research using Calamos money. Therefore, such use of client brokerage commissions results in a conflict of interest because we have an incentive to direct client brokerage to those brokers who provide research and services we utilize, even if these brokers do not offer the best price or commission rates for our clients. Calamos has in place controls designed to mitigate or manage the conflicts described above, including:

Brokerage Practices Committee review and approval of soft dollar arrangements; Periodic review of commission rates; Periodic review of our soft dollar process to determine in good faith that commissions used to acquire research products and services were reasonable relative to the value of the research and services received; Monitoring execution of transactions in our client’s portfolios, including reviewing trades for best execution; and Periodic review of mixed price allocations.

CLIENT DIRECTED BROKERAGE Clients may request “directed brokerage” by instructing Calamos to send their trades to a specific broker. For example, certain institutional clients may direct Calamos to place all or a portion of their brokerage with brokers who provide the client with certain services, such as performance monitoring and commission recapture. Where the client directs Calamos to use a specific broker, the client should understand that: (i) Calamos will not negotiate commissions on the client’s behalf and that, as a result, the client may pay materially different commissions than paid by other clients depending on the client’s commission arrangement with such broker; (ii) these accounts may not have their trades included in Calamos aggregated orders intended to reduce transactions costs or to otherwise negotiate commissions and, therefore, the client may pay a different brokerage commission than other clients of Calamos participating in such aggregated orders and may receive less favorable prices and execution; (iii) the client’s transactions may not be executed until after Calamos executes transactions for accounts that do not direct

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Calamos does not receive an economic benefit from anyone other than its clients. Calamos and its affiliates may enter into Referral Agreements with a promoter such as a broker-dealer or an investment adviser. Calamos or its affiliates generally pay the promoter a percentage of the management fee and/or performance-based fee collected from the client. Regardless of how it is calculated, any such referral fee will be paid solely from Calamos’ investment management fee and will not result in any additional charge to the client. See Item 5 for additional information on advisory fees. Calamos has entered into arrangements with unaffiliated third parties for their assistance in referring business to Calamos or providing advice to Calamos with respect to the expansion of the firm’s distribution of products or services in various U.S. and non-U.S. markets and distribution channels. Calamos may pay cash compensation under these arrangements based on a monthly flat fee as well as, in the sole discretion of the firm, a bonus at the conclusion of the arrangements. The fees paid to the unaffiliated third party are not passed on to any introduced clients, but the presence of these arrangements may affect Calamos’ willingness to negotiate below its standard investment advisory fees and, therefore, may affect the overall fees paid by referred clients. Calamos has in place a promoter agreement with its affiliated, limited purpose broker-dealer, CFS. The referral fees paid typically equal an estimate of the expenses incurred by the promoter to obtain such business. CFS, in turn, may engage third party selling agents to market interests in private funds managed by Calamos. Calamos will structure these arrangements in accordance with its obligations under the SEC Marketing Rule.

We are required to disclose any legal or disciplinary events that are material to your evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose.

Our investment team regularly monitors client accounts for consistency with client objectives and restrictions. Our Portfolio Administrators perform a periodic review of each client account. In these reviews, positions in client accounts are compared to the weights in the appropriate investment strategy model. Calamos issues periodic written reports to its investment advisory clients. These written reports generally contain a list of assets, investment results, and statistical data related to the client’s account. We urge clients to carefully review these reports on a timely basis and compare the statements that they receive from their independent qualified custodian to the reports that we provide. The information in our reports may vary from custodial statements based on accounting procedures, reporting dates or valuation methodologies of certain securities. We encourage you to follow up with us, as well as the custodian for your account, to understand any differences. Because Calamos, not the custodian, calculates the amount of the advisory fees for your assets under management with us, it is important you carefully review your custodial statements to verify the accuracy of the calculation, among other things. Clients should contact Calamos directly if they believe that there may be an error in the calculation of their fees.

Calamos serves as General Partner and investment adviser to Calamos Global Opportunities Fund Limited Partnership, and Ares Quant Fund I, LP, As such, we are deemed to have custody of the assets invested in these funds. The funds’ financials are audited by an independent public accounting firm and are issued to investors within 120 days of the fiscal year end. (As noted above, the Ares Quant Fund I, LP are not currently offered to investors.) Calamos does not maintain physical custody of its clients’ assets. Rather, as discussed previously, you must establish a custody account with an unaffiliated custodian. You should receive quarterly or monthly account statements from the broker-dealer, bank or financial services firm that serves as qualified custodian to your account. Clients should carefully review these statements. Clients who do not receive such account statements are encouraged to follow up directly with their custodian and request such statements. To the extent a client receives additional reports from Calamos, they are urged to compare these reports to the account statements they receive from the qualified custodian. Calamos’ reports may vary from custodial statements based on accounting procedures, reporting dates, valuation methodologies and other factors. Calamos’ reports are not intended to be a substitute for account statements provided by a qualified custodian and should not be used for official purposes.

As noted in Item 4, Calamos accepts discretionary authority, via the Investment Management Agreement or other Power of Attorney, to manage the assets in the client’s account. Calamos endeavors to follow reasonable directions, investment guidelines and limitations. This discretionary authority will remain in full force and effect until we receive written notice from you of its termination or until we receive actual notice of your death or adjudged incompetency.

Proxy Voting Proxies are voted solely in the best interests of Calamos clients; namely, the Calamos Funds, separate account clients, and where employee benefit plan assets are involved, in the interests of the plan participants and beneficiaries (collectively, "Advisory Clients") that have properly delegated such responsibility to Calamos. Voting proxies on behalf of our clients is established by Calamos advisory contracts or comparable documents, and our proxy voting guidelines have been tailored to reflect these specific contractual obligations. Calamos has assigned its administrative duties with respect to the proxy analysis and voting decisions to the “Proxy Group” (the Investment Team – research analysts and portfolio management), and administrative processing to its Corporate Actions Group within the Operations Department. Calamos utilizes two vendors which provide distinct services relevant to Calamos’ proxy duties: Glass Lewis and Broadridge. Glass Lewis facilitates the voting decision of each proxy in accordance with Calamos’ proxy voting policies (“custom policies”). Calamos’ custom policies include instances where a proposal must be presented to the Proxy Group for vote direction due to the unique nature of the transaction or proposal (“case by case” items). Corporate Actions uses Broadridge’s Proxy Edge to monitor and manage the proxy processes. Proxy Edge receives the voting decisions from Glass Lewis with which it uses to vote the ballots at the account/custodian level. Proxy Edge provides the record keeping, systematic voting, account administration and reporting for Calamos. Calamos will generally follow its custom policies unless it determines that the client’s interests are best served by voting otherwise or unless otherwise directed by the client.

Proxy Edge systematically votes shares based on Calamos’ custom policies that are maintained within Glass Lewis. Any ballot that includes one or more “case by case” items will not be systematically voted. All items on this type of ballot are manually voted. Case by case items are sent to the Proxy Group along with the written guidance and other relevant information produced by Glass Lewis to assist with the Proxy Group’s analysis. Based on the instruction provided by the Proxy Group, the Corporate Actions Group will process the Calamos votes on Proxy Edge which will then vote each proxy accordingly. Directors and employees of Calamos including the Proxy Group are sensitive to the possibility that their interests may conflict with the interests of Advisory Clients. Even while a proxy may involve an entity with which a relationship exists, generally the matters put to vote do not cause a conflict of interest between Calamos and the client. Potential conflicts of interest are identified based upon analyses of client, broker and vendor lists, information periodically gathered from directors and officers, and information derived from other sources, including public filings relative to the matters for which the Company is seeking shareholder approval. Calamos will generally apply its custom policies to proxy matters regardless if a conflict has been identified. However, in these situations, Corporate Actions will refer the matter, along with the recommended course of action by Calamos (based on its custom policies), if any, to its Proxy Review Committee, comprised of the representatives from the Proxy Group, Operations, Legal and Compliance departments, for evaluation. The Proxy Review Committee will independently review proxies, determine the appropriate action to be taken, which in limited circumstances includes sending the proxy directly to the relevant client with a recommendation regarding the vote for approval. To the extent the shares have been systematically voted and the Proxy Committee decides to vote differently than its custom policies, Corporate Actions will manually change the vote within Proxy Edge, if time permits. It should be noted for the following strategies: Global Sustainable Equities, International Sustainable Equities and U.S. Sustainable Equities, there is a separate proxy policy in place. These ballots do not systematically vote. There may be some instances when Calamos believes its client’s best interest is served by abstaining or not voting certain proxies. Additional information is provided in the procedures. Clients may obtain a copy of our procedures by contacting us at caminfo@calamos.com, or by calling us at 800-582-6959. You, the client, reserve the right to vote the proxies on your account(s) and you may do so by sending your custodian and Calamos a written request to update the proxy instructions on your account. Calamos will not advise and will not act on a client’s behalf in legal proceedings involving companies whose securities you hold in your account(s). This includes the filing of "Proofs of Claim" in class action settlements. Clients may direct us to transmit copies of class action notices to them or to a third party. We will make commercially reasonable efforts to forward such notices in a timely manner. Calamos is not responsible for voting proxies we do not receive. However, we will make reasonable efforts to obtain missing proxies. Clients may request information on how proxies for his/her shares were voted by writing us at caminfo@calamos.com.

Calamos has no known financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients. In addition, we have never been the subject of a bankruptcy proceeding.