Canso Investment Counsel Ltd.

For purposes of this brochure, “Canso,” “we,” “us” and “our” means Canso Investment Counsel Ltd., an Ontario corporation.

Advisory Firm Canso is an independent firm wholly owned by its current and former employees. It was founded and formed as an Ontario corporation in June 1997 as a corporate bond specialty manager, and its principal office is in Richmond Hill, Ontario. Canso is an investment adviser registered with the SEC. In Canada, Canso is registered as a portfolio manager and exempt market dealer in each province and territory. The principal owner of Canso is John Carswell (who holds shares through his personal holding company and family trust, Grip Investments Limited and Carswell Family Trust, respectively). The remaining shareholders, who are current and past employees of Canso, each own less than 20% of our firm.

Advisory Services We intend to provide investment advisory services across a range of fixed income strategies, including specialty bond and credit strategies, to U.S. clients that establish separately managed accounts with us (the “U.S. Clients”), and to pooled investment vehicles offered or sold to U.S. investors (the “Fund Clients” and together with the U.S. Clients, the “Advisory Clients”). Advisory Clients targeted by Canso in the U.S. will be primarily institutional investors. We do not currently provide investment advisory services to U.S. Advisory Clients; however, we may, in the future, provide such services to U.S. Clients and to Fund Clients that are offered or sold to U.S. investors. We also provide investment advisory services to clients that are not U.S. persons, including through pooled investment vehicles that are offered or sold solely to non-U.S. persons. Services will be provided to the U.S. Clients in accordance with an investment management agreement and on a continuing basis. This means that we may transact in securities on our U.S. Clients’ behalf or carry out other investment advisory services activities without obtaining consent or consulting with our U.S. Clients. When providing investment services to the U.S. Clients, we will generally tailor our advisory services to the individual needs of such clients, including any specific guidelines or restrictions such clients may request. Services will be provided to the Fund Clients in accordance with a separate investment management agreement. The investment objectives, including any investment restrictions of Fund Clients, are generally established in the offering document (i.e., offering memorandum or private placement memorandum) of the applicable Fund Client and/or the Fund Client’s investment management agreement. We do not participate in wrap fee programs.

Assets Under Management As of June 30, 2026, we manage a total of $46,645,743,893 of client assets, all of which are managed on a discretionary basis. Assets under management are provided in USD.

Investment Management Fees With respect to the U.S. Clients, we will charge an investment management fee comprised of an annual base fee consisting of a percentage of the market value of your portfolio. We, at our sole discretion, will offer a tiered investment management fee schedule, depending upon objective and subjective factors that include, for example: the amount of assets to be managed; portfolio composition; the scope and complexity of the engagement; related accounts; anticipated future additional assets; and/or a prior relationship with us and/or our representatives. Depending on a U.S. Client’s specific arrangement with us, we will calculate and accrue the investment management fee, in arrears, on a monthly or quarterly basis, and bill quarterly on the last business day of each quarter. This fee will be paid within the separately managed account. We do not have the ability to directly debit investment management fees from U.S. Clients’ accounts. U.S. Clients must instruct and approve the payment of an invoice by the U.S. Client’s custodian. We do not charge performance fees or operating expenses for separately managed accounts. U.S. Clients should refer to their investment management agreement for the precise amount of, and the manner and calculation of, the investment management fees. Fees are subject to taxes, as applicable. As compensation for investment services rendered to Fund Clients, we intend to receive from each such Fund Client an investment management fee typically calculated based on a percentage of the Fund Client’s net asset value. The precise amount of, and the manner and calculation of, the investment management fees for each Fund Client are set forth in such Fund Client’s offering documents and/or organizational documents.

Other Fees and Expenses Canso will only be compensated through investment management fees that it charges Advisory Clients. Advisory Clients will incur other fees and expenses unrelated to Canso. Such fees can include brokerage commissions or fees, and custodial charges related to the account. Custodial charges are separately negotiated between you and the custodian, without our involvement. When a broker is used in connection with an investment by an Advisory Client, such Advisory Client will incur brokerage charges which are embedded in the purchase and sale of fixed income securities. We do not earn any of the foregoing fees. For additional information regarding brokerage practices, please see Item 12 below.

Methods of Analysis and Investment Strategy INVESTMENT STRATEGIES Canso is a specialty corporate bond portfolio manager with a team of people across credit research, portfolio management and trading. Our mandates are primarily managed using one of three different fixed income strategies: Investment Grade, Broad Corporate, and Corporate Value. The Investment Grade mandate allows up to 100% in BBB rated issues and nothing below investment grade. The Broad Corporate mandate permits up to 100% in issues rated BBB and below with up to 30% rated below BBB. Both strategies are duration neutral. The Corporate Value mandate does not have a duration or quality constraint. It can be up to 100% in below BBB rated issues at our discretion. Our mandates do not focus on term or yield curve decisions, and our portfolios are built to maximize the credit spread and credit opportunity. We tend to invest in the term cohort where we believe the spread potential is the best to maximize yield at an acceptable level of credit risk. We typically hold positions until maturity or until we believe the security becomes overvalued or a better security is discovered.

INVESTMENT PHILOSOPHY Canso was founded on the principle that we conduct our own independent research and evaluation of each investment opportunity. Our fixed income approach concentrates on fundamental analysis and security selection. Traditional “core” bond management combines corporate bonds with government bonds in an “active” bond mandate. The corporate bonds usually selected are a limited number of higher investment grade issues, which form a portion of the overall bond portfolio at a weight that is typically higher than the corporate bond weight in the market index. Alternatively, a smaller portion of the bond portfolio is allocated to “high yield” management, which is exclusively invested in lower quality bonds. Our approach allocates a dedicated portion of a client’s bond portfolio to corporate bonds and manages these as its own universe. When permitted by a client’s mandate, the credit range of a portfolio may include all investment grade bonds (AAA to BBB) and below investment grade issues. We believe this latitude frees us from the necessity of trying to mimic index holdings and allows us to accept risks in the portfolios when we are appropriately compensated. Given the risk/return trade-off, we do not distinguish among bonds by credit rating, but rather on fundamentals. We are opportunistic in our process, moving between bonds as their valuations change; buying unpopular bonds cheaply and selling overvalued, highly sought after bonds into strength. We would rather buy an out-of-favour and cheap “A” bond than a highly sought after and overpriced junk bond. RESEARCH PROCESS Our investment process is focused on bottom up, fundamental research and security selection, and our primary focus is on our internal credit research. We generally do not rely on external research and credit rating agencies. We conduct research on issuers before making an investment and we continue to update our research on an ongoing basis for each issue in the portfolio. Our investment process begins with a fundamental review of the issuer of a security. An internal quality rating is then assigned to the issuer. At this point, the merits of the particular financial security are examined with particular regard to the legal structure and ranking of the security. The expected future cash flow stream is identified, and the risks associated with the investment are analyzed. Fundamental analysis is used to identify the credit risk of an issuer. In addition, the issuer is analyzed with respect to financial strength, management capability, and business environment, and the terms and conditions of the security (including covenant package, priority in a default, ability to incur additional debt and make dividend payments) are assessed. Following such analysis a risk/return profile is determined.

As part of our fundamental credit research process, we may consider environmental, social and governance ("ESG") factors where we believe such factors are financially material to an issuer's creditworthiness, cash flows, valuation or recovery prospects. ESG considerations are evaluated alongside other financial and credit factors and are not assigned a separate weighting in our investment process. The relevance and importance of ESG factors will vary by issuer and industry, and certain ESG factors may not be considered where they are not deemed financially material. We invest solely to achieve financial returns and do not pursue ESG-focused investment strategies or seek specific ESG-related outcomes. INVESTMENT OR DECISION-MAKING PROCESS As part of our overall investment process, a team meeting is held to consider an issue or issuer in which Canso is considering making an investment. After our initial review is completed, an internal credit rating is then assigned to the issuer, and a valuation is established by referring to other similar issuers and market pricing. In order to decide on the appropriate position size, we determine the potential downside of the security from its current market value using our proprietary Maximum Loss analysis. This analysis captures the potential return that will be available to the bondholders and creditors in an insolvency and workout situation, allowing us to better understand the intrinsic value of a security in a negative scenario. Issuers held in our portfolios are monitored on an ongoing basis and reviewed as required. If corporate development arises, the analyst responsible will present their analysis and recommendation to the other team members who provide peer review and input. After the development has been reviewed, the portfolio manager makes the investment decision. PORTFOLIO CONSTRUCTION Our portfolios reflect our “bottom up” research emphasis. Rather than identifying likely sectors for investment, we select individual securities with regard to their intrinsic risk and return trade-off. Our portfolios are constructed with little regard for the industry and geographic breakdowns of market indices but we maintain credit limits for individual holdings and ratings categories. Our “buy” or selection process focuses primarily on the absolute price of the issue given the fundamental credit quality of the issuer and the terms and conditions of the specific security. Then we determine the relative value of the prospective issue. If the yield spread is attractive both absolutely and relatively, we will establish a position. Our portfolios are constructed to maximize yield at an acceptable level of credit risk. When a security becomes overvalued on a peer or absolute basis, we look to sell it and will put the proceeds into Treasury bonds if no other attractive investment can be found at that time. If a security deteriorates from an operational or credit point of view, we will sell it on opportunity. Our strategy is “buy and hold,” although we will take advantage of market opportunity.

RISK MANAGEMENT Our firm defines risk in terms of absolute capital loss. In our bond portfolios, we use a proprietary system of default risk for our bond holdings called Maximum Loss. Compared to commercial credit ratings, our Maximum Loss methodology estimates the maximum potential loss on a position given its trading value. This limits exposure to bonds trading expensively compared to their potential losses and encourages purchase of bonds trading near or below their workout values. This limits the portfolio’s downside risk and creates more upside potential than by using traditional credit rating methodology. The Maximum Loss methodology limits each position according to its potential impact on a portfolio’s long term value-added. Each position is analyzed independently. The higher the trading price of a security compared to its downside potential, the smaller the position allowed. The risk assessment allows the security’s specific features that modify its downside risk to be considered. This includes the priority of the security and nature of the issuer. Portfolios are diversified by issuer type and industry sector. Positions are then limited individually by the determination of the Maximum Loss potential of each issue. In addition, portfolio weightings in credit cohorts are established by investment policy statement constraints which reflect client risk tolerances.

Material Risks of Significant Investment Strategies Investing in securities involves a substantial degree of risk. An Advisory Client may lose all or a substantial portion of its investments, and investors must be prepared to bear the risk of a complete loss of their investments. In addition, material risks relating to the investment strategies and methods of analysis described above, and to the types of securities typically purchased by or for the Advisory Clients, include the following: Recent Financial Market Fluctuations. Various sectors of the U.S. and global financial markets and the broader current financial environment have been, and continue to be, characterized by uncertainty, volatility and instability. The financial services industry generally and investment activities are affected by general economic and market conditions, including interest rates, availability of credit, lack of price transparency, inflation rates, economic uncertainty, changes in tax and other applicable laws and regulations, trade barriers, national and international and environmental and socioeconomic circumstances. These financial market fluctuations have the tendency to reduce the availability of attractive investment opportunities for an Advisory Client and may affect the Advisory Client’s ability to make investments and the value of the investments held by an account. Instability in the securities markets and economic conditions generally may also increase the risks inherent in an Advisory Client’s investments. The public securities markets have seen increased volatility and the ability of companies to obtain financing for ongoing operations or expansions may be severely hampered by the tightening of the credit markets and the ongoing financial turmoil. It is unclear what the repercussions of this market

turmoil may be. Moreover, it remains unknown whether governmental measures undertaken in response to such turmoil (whether regulatory or financial in nature) will have a positive or negative effect on market conditions. There can be no assurance that the market will, in the future, become more liquid than it is at present, and it may well continue to be volatile for the foreseeable future. Derivatives Risk. An account’s investments may include derivative instruments and Canso may engage in various hedging and other investment strategies in an effort to hedge various market risks (such as interest rates, currency exchange rates, and broad or specific equity market movements) or to manage the effective maturity or duration of fixed-income securities or the account’s exposure to various securities markets. These hedging and other investment strategies involve certain risks, including the possible default of the other party to the transaction, the lack of liquidity, the imperfect nature of the hedge or the ineffectiveness of the strategy in a particular situation, and the possible accentuation of losses or reductions in gains of the underlying portfolio securities. Currency/ Foreign Exchange Risk. Currency risk is the risk that fluctuations in exchange rates between the U.S. dollar and foreign currencies may cause the value of foreign currency investments to decline significantly. If the value of the U.S. dollar has increased relative to the foreign currency, the return on the foreign security may be reduced, eliminated or made negative. The opposite can also occur, where the return on the foreign security may benefit from an increase in the value of the foreign currency relative to the U.S. dollar. In addition, movements in the exchange rate between the U.S. dollar and the foreign currency could increase or reduce the value of foreign securities valued in such foreign currency when translated to U.S. dollars. Credit or Company Specific Risk. Credit risk is the risk that an Advisory Client could lose money if an issuer or guarantor of a debt instrument becomes unwilling or unable to make timely principal and/or interest payments, or to otherwise meet its obligations. An Advisory Client’s investment in a debt instrument could decline because of concerns about the issuer’s credit quality or perceived financial condition. Fixed income securities are subject to varying degrees of credit risk, which are sometimes reflected in credit ratings. High-Yield Risk. An Advisory Client’s investments in high-yield securities and unrated securities of similar credit quality (commonly known as junk bonds or below investment grade debt) may be subject to greater levels of interest rate, credit and illiquid investment risk than vehicles that do not invest in such securities. These securities are considered predominately speculative with respect to the issuer’s continuing ability to make principal and interest payments. An economic downturn or period of rising interest rates could adversely affect the market for these securities and reduce Canso’s ability to sell these securities (illiquid investment risk). If the issuer of a security is in default with respect to interest or principal payments, an Advisory Client may lose its entire investment. Issuer Risk. Changes in the financial condition of an issuer of or counterparty to a debt security, changes

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As described in Item 4 above, we are a corporate bond specialty manager, based in Ontario, Canada. In Canada, we provide investment advisory services to major corporations, pension plans, endowments, foundations, and private clients. We also provide investment advisory services to pooled investment vehicles that are offered or sold solely to non-U.S. investors and are either managed by an affiliate of Canso, or a third-party manager. For more information on our affiliates, please refer to Item 10 below. In the U.S., we intend to focus on providing investment advisory services to U.S. Clients, who are primarily institutional investors. We may in the future also offer investment advisory services to Fund Clients. We may in the future offer investment advisory services to other clients, pooled investment vehicles, or in respect of other investment products. With respect to Advisory Clients, we will generally impose a minimum investment amount to open an account. However, we may waive any such requirements at our discretion.

As described in Item 5 above, for Advisory Clients, we will typically only charge an investment management fee. We currently charge a performance-based fee for pooled investment vehicles that are offered or sold solely to non-U.S. persons as established in the fund’s offering document and investment management agreement with us.

Canso is a registered portfolio manager and exempt market dealer in all provinces and territories of Canada. As of April 30, 2025, Canso has five Canadian-based related entities registered under applicable Canadian securities legislation, each with a separate and distinct regulated line of business and non-U.S. client segment: Canso Fund Management Ltd. (“CFM”), Lysander Funds Limited (“Lysander”), PBY Capital Ltd. (“PBY”), Portfolio HiWay Inc. (“PHW”) and Jesselton Capital Management Inc. (“Jesselton”). •

CFM is registered as an investment fund manager in the provinces of Ontario, Quebec, and Newfoundland and Labrador, Canada. CFM is the institutional pooled fund management arm within the Canso group as the fund manager of investment funds and other collective/ pooled investment vehicles offered under prospectus exemptions to non-U.S. investors (the “Canso Funds”) and is a wholly-owned subsidiary of Canso.

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Lysander is registered as an investment fund manager in the provinces of Ontario, Quebec, and Newfoundland and Labrador, and as portfolio manager and exempt market dealer in the province of Ontario, Canada. Lysander is the retail fund management arm within the Canso group as the fund manager of investment funds offered under prospectus to non-U.S. investors (the “LysanderCanso Funds”) and is an affiliate of Canso under common control.

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PBY is registered as an investment fund manager in the provinces of Ontario, Quebec, and Newfoundland and Labrador, and as a portfolio manager and exempt market dealer across all Canadian provinces. PBY distributes the Canso Funds and the Lysander-Canso Funds to non-U.S. clients of family offices and multi-family offices as well as non-U.S. institutional clients and is also the fund manager of investment funds offered under prospectus exemptions to non-U.S. investors and is an affiliate of Canso under common control.

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PHW is registered as an investment dealer and is a member of the Canadian Investment Regulatory Organization in each province and territory in Canada and is an affiliate of Canso under common control.

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Jesselton is registered as an investment fund manager, portfolio manager and exempt market dealer in Ontario, Canada, and is an affiliate of Canso under common control.

Canso is affiliated through common ownership and control with several Canadian regulated entities, including CFM, Lysander, PBY, PHW. and Jesselton. These entities conduct separate regulated businesses in Canada and are subject to Canadian securities regulation. Certain directors, officers and employees of Canso may also serve as directors, officers or registered individuals of one or more affiliated entities, subject to applicable regulatory requirements and internal conflict management procedures. As of the date of this brochure, Canso does not provide investment advisory services to any U.S. clients and does not currently recommend, invest client assets in, or otherwise utilize affiliated investment products or services in connection with U.S. advisory activities. If Canso were in the future to provide advisory services to U.S. clients and recommend or utilize affiliated products or services, the resulting conflicts of interest would be managed in accordance with Canso's policies and procedures and disclosed to affected clients as appropriate.

Code of Ethics Canso has adopted a Code of Ethics (the “Code”) that governs our standard of business conduct as a fiduciary to our clients and includes policies such as Personal Trading, Gifts and Entertainment, Conflicts of Interest & Outside Activities, Compensation, and Insider Trading. Advisory Clients may obtain a copy of the Code upon written request to: clientservice@cansofunds.com.

Conflicts of Interest Canso and its related entities engage in a broad range of activities. In the ordinary course of conducting its activities, the interests of an Advisory Client will, from time to time, conflict with our interests, the interests of other Advisory Clients or their respective affiliates. We seek to ensure that Advisory Clients are treated fairly in the management of their account and in the execution of trades. A conflict of interest

is considered material if, depending on the circumstances, it is likely to affect the decision-making process of either party. Certain of these conflicts of interest, as well as a description of how we address such conflicts of interest, can be found below.

Allocation of Investment Opportunities Among Clients In connection with our investment activities, we may encounter situations in which we must determine how to allocate investment opportunities among various clients and other persons, which may include, but are not limited to, Advisory Clients. We maintain policies and procedures that address the potential conflict of interest in such situations. When allocating securities that have been aggregated for the purposes of trading or settlement efficiencies (bulk, block or bunched trades), care is taken to equitably share trading opportunities and expenses between client accounts. If pro-rata distribution is not practical due to security availability or costs, allocation is done based on an established methodology. If trade orders are filled at different times, these partial fills are allocated to client accounts as equitably as possible, taking into account trading costs, commissions and account size. If a pro-rata distribution would result in such a small allocation being made to an account such that it would not affect account performance, such accounts may be excluded from the allocation so that other accounts can benefit from a reasonable allocation. If a trading program continues over a longer period, we review the trading program to ensure that the allocations are fair and not biased towards large or small accounts. Partial fills are allocated to ensure that all account sizes have reasonably uniform positions over time. New issues are allocated to avoid preference to any account over time.

Cross Trades Trades between client accounts, or cross trades, may give rise to conflicts of interest because we are responsible for determining the terms of the trade, including the price, for both accounts. The terms of the trade may benefit one account to the detriment of the other account. This conflict is addressed in several ways, including by ensuring fair and independent pricing of the security being exchanged has been obtained by a reputable and unbiased third party pricing source, such as a broker-dealer or custodian, ensuring the sale or acquisition of the security is in the best interest of the Clients involved and

consistent with their investment objectives, ensuring that neither the Firm nor its related persons receive commissions or other form of compensation related to the cross trade , and that the trade is allocated in accordance with the policy on Allocation of Trades and Investment Opportunities.

Personal Trading To mitigate potential conflicts of interest, our personal trading policy requires our access persons and certain of their family members (“related persons”) to report to the Firm securities accounts and holdings, both upon first becoming an access person/related person of the Firm and on an ongoing basis. Accounts that cannot hold anything other than mutual funds and accounts the Firm determines are discretionary accounts managed by a third party over which the access person or related person does not exercise direct

or indirect influence or control are exempted from the reporting requirement. Access persons and related persons are also required to seek pre-clearance from Compliance prior to securities trading in personal accounts, except for certain types of securities, such as mutual funds, exchange traded funds, money market securities, certain index funds, government of Canada bonds and U.S. Treasury securities, bankers’ acceptance and commercial paper, guaranteed investment certificates and variable and fixed annuities. Access Persons are also prohibited from trading cryptocurrencies, cryptocurrencies ETFs, or any other digital assets, whether directly or by way of derivatives with the exception of selling grandfathered positions held prior to joining Canso, which can be sold without pre-clearance. Related persons are not subject to this restriction.

Gifts and Entertainment To mitigate potential conflicts of interest, our gifts and entertainment policy is intended to ensure that the practice of giving and accepting gifts or entertainment is not abused and does not compromise the integrity, objectivity or fiduciary responsibilities of the Firm or its supervised persons, create an appearance of impropriety or raise potential conflicts of interest. Compliance pre-approval is required for attendance at business events hosted by our business partners and any gifts received by employees are to be notified to the CCO and recorded by Compliance. Only gifts of modest value are permitted and we forbid our supervised persons to offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity. Cash and cash equivalents (such as gift cards) are prohibited regardless of amount. The cumulative annual permitted expenditure on each person employed by a Business Partner is not to exceed CAD$1,000 (before taxes), except for employees of FINRA-regulated broker-dealers where the limit is CAD$300, unless the CCO gives prior written approval. No gift or entertainment must ever be accepted with the expectation of any quid pro quo from the Firm or any supervised person. Supervised persons are prohibited from giving, and must tactfully refuse, any gift of cash, gift certificate or cash equivalents. Supervised persons may not give or accept any gift or entertainment from any third party that is inappropriate under the circumstances, or inconsistent with applicable law or regulation.

Compensation and Incentive Practices Sales incentives for investment services, and internal sales and revenue targets, are an inherent conflict of interest because they can influence the registered individual to put their own interests ahead of their clients. Canso prohibits sales incentives for investment services, internal sales and revenue targets, and commission-based compensation models to avoid competitive behaviours and selling practices. Registered individuals, including the CCO, are compensated based on their individual contribution to Canso. Furthermore, a compensation committee comprising of members of senior management reviews compensation and bonus awards for all Canso employees.

Management of the Accounts

We intend to manage a number of accounts that have investment objectives similar to each other. We expect that we or our personnel will in the future establish one or more additional separately managed accounts or pooled investment vehicles with investment objectives substantially similar to, or different (and potentially conflicting) from, other Advisory Client accounts. We may give advice or take actions with respect to the investments of one or more Advisory Client accounts that may not be given or taken with respect to other Advisory Client accounts with similar investment programs, objectives or strategies. As a result, Advisory Client accounts with similar strategies will not hold the same securities or achieve the same performance. In addition, it is expected that our personnel responsible for managing a particular Advisory Client account will have responsibilities with respect to other Advisory Client accounts managed by us. Potential conflicts of interest can arise in allocating time, services or functions of these personnel. Personnel have an incentive to allocate more time, services or functions to Advisory Client accounts from which such personnel derive a higher economic benefit and/or better-performing accounts. As described above under Compensation and Incentives Practices, we address this potential conflict of interest by adopting certain anti-competitive compensation and incentive practices. We may from time to time, consider, and reject an investment opportunity on behalf of one Advisory Client account and subsequently determine to have another Advisory Client account make an investment in the same company. A conflict of interest arises because one Advisory Client will, in such circumstances, benefit from the initial evaluation, investigation and due diligence undertaken by us on behalf of the original Advisory Client account considering the investment. In such circumstances, the benefiting Advisory Client will not be required to reimburse the original Advisory Client account for expenses incurred in connection with researching such investment.

Selection of Brokers and Dealers For each of the Advisory Clients, we have sole discretion over the purchase and sale of investments (including the size of such transactions) and the broker or dealer, if any, to be used to effect transactions. In placing each transaction for an Advisory Client involving a broker-dealer, we will seek “best execution” of the transaction. “Best execution” means a duty to use reasonable efforts to execute securities transactions so that a client's total costs or proceeds in each transaction are the most favorable under the circumstances. Best execution is not limited solely to the consideration of the best available commission rate. In determining whether a particular broker or dealer is likely to provide best execution in a particular transaction, we take into account all factors that we deem relevant to the broker’s or dealer’s execution capability, including, by way of illustration, price, the size of the transaction, the nature of the market for

the security, the amount of the commission, the timing of the transaction taking into account market prices and trends, the reputation, experience and financial stability of the broker or dealer, and the quality of service rendered by the broker or dealer in other transactions. When purchasing or selling over-thecounter securities with market makers, we generally seek to select market makers we believe to be actively and effectively trading the security being purchased or sold. We continuously monitor trade execution offered at different trading venues and maintain a list of approved brokers who are selected for their trade execution quality. In order to monitor best execution, Best Execution Committee meets to review our list of approved broker-dealers and determine whether all of the broker-dealers listed continue to demonstrate the ability and commitment to provide best execution. We do not receive “soft dollars” in connection with any use of broker-dealers.

Aggregation of Trades We may aggregate (or bunch) the orders of more than one Advisory Client for the purchase or sale of the same publicly traded or over-the-counter security. We often employ this practice because larger transactions may enable us to obtain better overall prices, including lower commission costs or mark-ups or mark-downs. We may combine orders on behalf of Advisory Clients with orders for other Advisory Clients for which we have trading authority, or in which we have an economic interest. In such cases, we generally aggregate trade orders for publicly traded or over-the-counter securities so that each participating Advisory Client will receive the average price for each execution of a transaction. If an order for more than one Advisory Client for a publicly traded or over-the-counter security cannot be fully executed, allocation shall be made based upon our procedures for allocation of investment opportunities, as described in Item 11 above.

We do not currently have any solicitation or referral arrangements and do not pay cash and/or other payments for client referrals, directly or indirectly; nor do we receive any monetary or non-monetary benefit from third parties for referring or recommending business.

Canso and our management personnel have no reportable disciplinary events to disclose.

We will review the portfolio investments of each Advisory Client regularly (typically on a daily basis) with a view to evaluating, among other things, economic developments, industry outlook and other issues related to the portfolio investments. Compliance with an Advisory Client’s investment policies and investment constraints is a two-part process. Each Advisory Client’s portfolio investments are reviewed by teams consisting of our investment professionals. These teams monitor overall performance, portfolio composition, credit events in the underlying portfolios, risk factors, financial performance and compliance with the investment guidelines of the relevant Advisory Clients. Reviews also consider, and may be triggered by, market, legal or regulatory developments. Trades are discussed regularly. We also utilize computer-generated exception reports from our portfolio management system that will flag any non-compliance with investment constraints and restrictions as outlined in the investment management agreement for each respective Advisory Client. The compliance module in our portfolio

management system evaluates portfolio compliance with the compliance rules assigned to each account. When we take on a new client, investment constraints are codified in our portfolio management system as part of our account opening process and are updated as needed. Where a client has a specific investment restriction or constraint in their portfolio, the teams are made aware of the constraint during the account opening process. Our general practice is to notify clients of any breach to their constraints as soon as it is reasonably possible. There are instances where breaches can occur because of events outside of our control such as market movements and ratings downgrades. In these instances, if we feel it is in the best interests of our clients, we will request permission to continue to hold the security. Otherwise, we will advise clients of the breach and the corrective action taken. Subject to the provisions of the investment management agreement, we will typically provide the Advisory Clients with written quarterly portfolio statement that will list their holdings, the market value, and the position of their investments and transactions. In addition to the information typically provided to all Advisory Clients, at an Advisory Client’s request, we may in certain circumstances provide certain Advisory Clients with additional information.

We are not a broker-dealer and do not take possession of client assets. Advisory Clients house their assets at qualified custodians at their discretion, and the custodian will issue trade confirmations and monthly account statements directly to clients. Advisory Clients are strongly urged to compare the information in their quarterly account statements provided by us with the statements provided by their custodian.

We have discretionary authority to manage accounts on behalf of the Advisory Clients. Services are provided to the Advisory Clients in accordance with written investment management agreements with the U.S. Clients and the Fund Clients, as applicable. With respect to Advisory Clients, our authority is limited to selecting, and determining the quantity of, securities or financial instruments to be bought or sold to satisfy the account objectives for each respective account. We may also accept any reasonable limitation or restriction to such authority placed by Advisory Clients, subject to it being provided to us in writing.

We have established written policies and procedures setting forth the principles and procedures by which

we vote or give consent with respect to securities owned by the Advisory Client accounts. The guiding principle by which we vote all votes is to vote in the best interests the Advisory Clients. The Firm makes proxy voting decisions considering long- and short-term impact to our Advisory Clients. For non-routine corporate matters or under circumstances when the Firm believes that company management’s proposal will not maximize value for the Clients, the Firm may vote against company management, on a case-by-case basis and will keep a record of such decision. Only portfolio managers are authorized to vote proxies or make proxy-voting decisions. The Corporate Action Team coordinates the proxy voting based on what the portfolio manager has decided. In the unlikely event a proxy vote presents a conflict of interest with an Advisory Client, the portfolio managers will inform Compliance.

We do not require or solicit prepayment of fees. Further, we are currently not in, and have never been in, a financially precarious situation, or the subject to a bankruptcy petition.

ITEM 19 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS