First Eagle Investment Management, LLC

Firm Overview FEIM is a limited liability company organized under the laws of the State of Delaware and has been a registered investment adviser under the Advisers Act since 1995. It is a subsidiary of First Eagle Holdings, Inc., a Delaware holding company controlled by Genstar (defined below) (“FE Holdings”) and a part of First Eagle Investments (the brand name for FEIM, FE Holdings and their downstream affiliates, together “First Eagle”). Since August 15, 2025, a majority interest in FE Holdings has been owned by certain private investment funds managed by Genstar Capital, a private equity firm focused on investments in targeted segments of the financial services, software, healthcare and industrials industries. Genstar Capital is comprised of U.S. registered investment advisers Genstar Capital Management LLC and Genstar Capital Partners LLC (such entities, together with their affiliates, “Genstar”). Genstar’s interest in FEIM is held through GC Ferry Intermediate, Inc., a Delaware corporation that is the sole shareholder of FE Holdings; GC Ferry Holdings, Inc., a Delaware corporation that is the sole shareholder of GC Ferry Intermediate, Inc.; GC Ferry Parent, L.P., a Delaware limited partnership that is the sole shareholder of GC Ferry Holdings, Inc.; GC Ferry Parent GP, LLC, a Delaware limited liability company that is the general partner of GC Ferry Parent, L.P.; Genstar Capital Partners XI, L.P., a Delaware limited partnership and the sole indirect holder of more than 25% of FE Holding’s shares among the 12 limited partnerships managed by Genstar that are invested in FE Holdings. The general partner of Genstar Capital Partners XI, L.P. (together with its parallel investment vehicles) is Delaware limited partnership Genstar Capital XI, L.P.; Genstar XI GP LLC, a Delaware limited liability company, is the general partner of Genstar Capital XI, L.P.; and Genstar Capital Partners LLC is the manager of Genstar Capital Partners XI, L.P. (together with its parallel investment vehicles) and as such is entitled to receive management fees with respect thereto. Genstar Capital Partners LLC is owned by the five managing partners of Genstar (directly or indirectly via their estate planning vehicles): J. Ryan Clark, Jean-Pierre Louis Conte, Robert Stanley Rutledge, Anthony Jon Salewski and Eli Phillips Weiss. No individual owns 25% or more of FEIM. Genstar and its affiliates do not have any role in FEIM’s investment process related to the management of client assets. In performing fiduciary duties on behalf of clients, FEIM’s investment teams act independently, uninfluenced by Genstar personnel.

Investment Advisory Services FEIM provides investment advisory services primarily to mutual funds, exchange traded funds, private funds, collective investment trusts (“CITs”), Sociétés d’investissement à Capital Variable (or SICAV funds), Irish Collective Asset-Management Vehicles (or ICAV funds) and institutional separately managed accounts (“SMAs”), as well as to registered, closed-end interval funds and to a continuously offered closed-end management investment company that elects to be regulated as a business development company (“BDC”). FEIM is the investment adviser to the First Eagle Funds, First Eagle Variable Funds, First Eagle ETF Trust, First Eagle Real Estate Debt Fund, First Eagle Tactical Municipal Opportunities Fund and to the First Eagle Credit Opportunities Fund (collectively, the “Funds”), which are registered investment companies, as well as to the BDC, First Eagle Private Credit Fund, and FEIM serves as the investment adviser to the exchange-traded funds First Eagle Global Equity ETF, First Eagle Overseas Equity ETF, First Eagle US Equity ETF and First Eagle Mid Cap Equity ETF (the “ETFs”) which are sub-advised by Exchange Traded Concepts, LLC (the “SubAdviser”), which provides trading and execution services to the ETFs. Client accounts are generally managed by FEIM on a discretionary basis. Investment decisions are not tailored to the individual needs of clients but are based on the investment strategy chosen by the client, in line with any applicable client guidelines and/or restrictions. For SMAs, FEIM has agreed with clients to abide by certain restrictions, including but not limited to restrictions on issuers/securities and/or types of issuers/securities. In FEIM’s management of a client’s account, FEIM is not responsible for and does not consider any securities, cash or investments otherwise owned by the client or the client’s financial circumstances or investment objectives outside of the client’s investment with FEIM. The investment strategies offered by FEIM are as follows:

Global Value – This strategy seeks to deliver attractive real returns while avoiding the permanent impairment of capital over time by using a value approach to investing in global equity markets. The investment team follows a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability and that are

trading at what they believe are significant discounts to their “Intrinsic Values”.1 Additionally, the investment team has the flexibility to invest in non-equity securities, including cash and cash equivalents, corporate debt, short-term government bonds and gold.

International Value – This strategy seeks to deliver attractive real returns while avoiding the permanent impairment of capital over time by using a value approach to investing in non-U.S. equity markets. The investment team follows a bottomup, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability and that are trading at what they believe are significant discounts to their Intrinsic Values. Additionally, the investment team has the flexibility to invest in non-equity securities, including cash and cash equivalents, corporate debt, short-term government bonds and gold.

Global Balanced – This strategy seeks long-term growth of capital and current income generation by using a value approach to investing primarily in common stocks of U.S. and foreign companies that offer attractive dividend yields and a range of fixed income instruments, including high-yield, below investment grade instruments (junk bonds), investment grade instruments and sovereign debt, from markets in the United States and multiple countries around the world. The investment team follows a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability and that are trading at what they believe are significant discounts to their Intrinsic Values.

Global Equity – This strategy seeks capital appreciation using a value approach by investing primarily in US and non-US equity securities across developed and emerging markets. The investment team follows a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability and that are trading at what they believe are significant discounts to their Intrinsic Values.

Gold – This strategy seeks to deliver attractive real returns while avoiding the permanent impairment of capital over time by using a value approach to investing in securities directly related to gold or issuers principally engaged in the gold industry, including securities of gold mining finance companies as well as operating companies with long-, medium- or short-life mines. The investment team follows a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability and that are trading at what they believe are significant discounts to their Intrinsic Values.

US Small Cap – This strategy seeks long-term growth of capital by investing in equity securities of small- and micro-cap companies in an attempt to take advantage of what the investment team believes are opportunistic situations for undervalued securities. The investment team seeks to invest in companies that have become disconnected from their normalized valuations and have an identifiable catalyst for improvement.

U.S. Value – This strategy seeks to deliver attractive real returns while avoiding the permanent impairment of capital over time by using a value approach to investing in U.S. equity markets. The investment team follows a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability and that are trading at what they believe are significant discounts to their Intrinsic Values. Additionally, the investment team has the flexibility to invest in non-equity securities, including cash and cash equivalents, corporate debt, short-term government bonds, gold and, to a lesser extent, in securities of non-U.S. issuers.

International Equity – This strategy seeks capital appreciation using a value approach by investing primarily in non-US equity securities across developed and emerging markets. The investment team follows a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability and that are trading at what they believe are significant discounts to their Intrinsic Values.

US Dividend Equity – This strategy seeks capital appreciation and current income using a value approach by investing primarily in income-producing U.S. equity securities where the dividend is expected to increase over time and to a lesser extent in hybrid, option and debt securities. In selecting companies for investment, it seeks to identify what it considers to be high quality companies. While a company selected for investment may not meet all of these characteristics, FEIM considers a high-quality company to demonstrate some or all of the following: durable competitive advantage(s); conservative capital structure; prudent management; and attractive financial metrics.

FEIM’s Global Value investment team (the “Team”) defines “Intrinsic Value” as its estimate of what a knowledgeable buyer might pay in cash for an entire business. In creating such estimates, while the Team typically considers traditional valuation criteria such as price/earnings and price/book ratios, it generally places greater emphasis on cash flow valuation (enterprise value/EBIT) and on valuations that take the balance sheet into account (enterprise value/net asset value; enterprise value/asset replacement value), while also noting multiples paid in private market transactions (where possible and applicable).

Short Duration High Yield Municipal – This strategy seeks a high level of current income and will normally invest primarily in municipal bonds that pay interest that is exempt from regular federal personal income tax. Such municipal bonds may include obligations issued by U.S. states and their subdivisions, authorities, instrumentalities and corporations, as well as obligations issued by U.S. territories (such as Puerto Rico, the U.S. Virgin Islands and Guam) that pay interest that is exempt from regular federal personal income tax. The strategy may invest in all types of municipal bonds, including general obligation bonds, revenue bonds and participation interests in municipal leases, and may invest without limit in securities that generate income taxable to those shareholders subject to the federal alternative minimum tax. While the strategy may invest in securities with any time to maturity, under normal market conditions, it will generally maintain an investment portfolio with a weighted average effective duration of less than 5 years.

US Smid Cap – This strategy seeks long-term growth of capital by investing in equity securities of small- and mid-cap companies in an attempt to take advantage of what the investment team believes are opportunistic situations for undervalued securities. The investment team seeks to invest in small and midcap companies that have become disconnected from their normalized valuations and have an identifiable catalyst for improvement and positions the investment team to capture the evolution of quality businesses as they grow.

Mid Cap – This strategy seeks long-term growth of capital by primarily investing in equity securities of mid-cap companies in an attempt to take advantage of what the investment team believes are opportunistic situations for undervalued securities. Potential investments that the investment team considers to be opportunistic can include situations involving company turnarounds (e.g., a company that may be experiencing periods of poor financial or stock performance but may be exhibiting potential for financial recovery), emerging growth companies with interrupted earnings patterns (e.g., companies without a long or consistent history of earnings but that the investment team believes have the potential for earnings growth), companies with unrecognized asset values, or undervalued growth companies (e.g., companies that have low multiples of price-to-book or price-to-sales ratios, or companies with securities that are trading at a price below what the investment team believes the security is worth). FEIM defines mid-cap companies as those that have at the time of investment a market capitalization of not greater than that of the largest company in the Russell Mid Cap Index.

Global Real Assets – This strategy seeks long-term capital growth, by investing in a variety of assets believed to represent interests in ‘‘real assets’’ or ‘‘real asset’’ industries. The strategy primarily invests in equity securities. ‘‘Real assets’’ in which the strategy invests include physical assets and assets that are otherwise recognized as stores of value, such as gold bullion or other precious metals, certain commodities and inflation-linked fixed income securities. While the strategy has no current intention to make direct investments in real estate, land or equipment, it targets the industries of companies that are related to these assets.

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The specific way fees are charged by FEIM is established in each client’s written agreement. For SMAs, FEIM typically charges an annual fee based on a percentage of assets under management. FEIM’s current basic annual fee schedule for SMAs is as follows:

Global Value – 75 basis points;

International Value – 75 basis points;

Global Income Builder – 75 basis points;

Global Equity – 65 basis points up to $100mm; 60 basis points on the next $100mm; 50 basis points over the next $150mm; and 45 basis points thereafter;

Gold – 75 basis points;

US Small Cap – 85 basis points up to $75mm; then 75 basis points on the next $75mm; then 70 basis points on the next $300mm; and 65 basis points over $450mm;

U.S. Value – 75 basis points;

International Equity – 65 basis points up to $100mm; 60 basis points on the next $100mm; 50 basis points over the next $150mm; and 45 basis points thereafter;

US Dividend Equity – 50 basis points;

Short Duration High Yield Municipal – 45 basis points;

US Smid Cap – 75 basis points;

Mid Cap – 75 basis points;

Global Real Assets – 65 basis points; and

High Yield Municipal – 45 basis points up to $50mm; 40 basis points on the next $200mm; and 35 basis points thereafter.

The basic fees listed above can vary depending on certain factors including but not limited to the total value of client assets under management with FEIM and the application of a performance fee. Unless a different arrangement is made with a client, FEIM generally bills its management fees on a quarterly basis in arrears based on the average month-end assets during the quarter. Clients generally elect to be billed directly for fees. Management fees are typically prorated for partial periods. For the Funds and for the private funds advised by FEIM, fees are described in the relevant prospectus or offering document. More information on the fees and expenses borne by the First Eagle Funds is contained in the prospectus, available at www.firsteagle.com/individual-investors/overview. With respect to the private funds, the applicable fees and expenses are set forth in each private fund’s respective investment management agreement, limited partnership agreement or operating agreement, as the case may be, and/or other governing documents, or the private fund’s offering memorandum (together with any supplements thereto, the “OM”), if the private fund has issued an OM. FEIM also has performance-based fee arrangements with certain clients. Generally, incentive compensation agreements provide for a performance fee that is a percentage of the profits or a percentage of the increase in net asset value, or a percentage of the profits in excess of a predetermined benchmark. The period over which the performance-based fee is calculated and the designation of any benchmark or hurdle is negotiated with each client. In the case of private funds, the amount of any performance fee is described in the fund’s OM. Contracts with clients typically include a provision for indemnification to FEIM under certain circumstances. FEF Distributors, LLC (“FEF Distributors”), a limited purpose broker-dealer and wholly owned subsidiary of FEIM, is the principal underwriter and distributor of the Funds, of registered, closed-end interval funds and of the BDC and is the wholesale placement agent of private funds advised by FEIM. FEF Distributors receives compensation for the sale of securities, including asset-based

sales charges, service fees and contingent deferred sales charges from the sale of the Funds. These fees and charges are not applied to offset advisory fees. Certain of FEIM’s employees who are also FEF Distributors representatives typically receive compensation for the sale of investments (including investments in the Funds, private funds and to SMAs). All such compensation is paid by FEIM from revenue attributable to such investments. In addition, FEIM has adopted incentive plans and has entered into agreements that provide for compensation to its employees who develop and refer new business. These arrangements present a conflict of interest and give FEIM and its employees/ FEF Distributors representatives an incentive to recommend investment products based on the compensation received, rather than on a client’s needs. To help prevent FEIM and its employees from acting in such a way, FEIM has adopted a Code of Ethics and a Code of Business Conduct requiring all FEIM employees to place the interests of clients first and to refrain from taking inappropriate advantage of their positions. Certain of FEIM’s investment products are also available for purchase through other agents or brokers that are not affiliated with FEIM. Certain investors in GC Ferry Parent, L.P. and/or non-employee directors of GC Ferry Parent GP, LLC have financial interests in entities that receive compensation for the sale of investments (including investments in the Funds, private funds and potentially to SMAs). Any such compensation would generally be paid by FEIM from revenue attributable to its management of such investments. Fees paid to FEIM for investment advisory services are separate from the fees and expenses that the Funds charge to their shareholders. Each Fund's fees and expenses are described in the Fund's prospectus, and generally include a management fee and other fund expenses and may include initial and contingent sales charges, asset-based sales charges, service fees and/or distribution fees ("Rule 12b-1 fees"). Rule 12b-1 fees are paid by a Fund to compensate for providing distribution-related, administrative and other services, and are automatically deducted directly from the Fund's assets. Some Fund complexes offer multiple share classes of the same Fund, and some share classes have higher expenses, which may include Rule 12b-1 fees, while other share classes of the same Fund have lower expenses, with or without Rule 12b-1 fees. Higher expenses adversely affect performance; therefore, an investment in a higher-expense share class will earn lower returns than an investment in a lowerexpense share class of the same Fund. In certain circumstances, fees and account minimums are negotiable. FEIM is generally permitted to waive or rebate a portion of the fees charged to investors in investment funds it manages. FEIM may change its fee structure at any time. FEIM’s wholly owned subsidiary, First Eagle Alternative Credit, LLC (a Delaware limited liability company and U.S. registered investment adviser formerly named THL Credit Advisors LLC; together with its affiliates, as the context requires, “FEAC”) and certain of FEAC’s clients and/or its portfolio investments are engaged in the loan origination and/or servicing businesses. In connection with FEAC’s lending activities, FEAC and/or its affiliates, including FEF Distributors, from time to time receive certain fees, including origination, closing, commitment, documentation, structuring, restructuring, facility, syndication, underwriting, placement, amendment, administrative agent, loan servicing and/or other transaction fees. Certain of such fees are charged on a costreimbursement or on a cost-plus basis. Clients or the issuers of financial instruments held by clients may acquire loans originated, structured, placed and/or arranged by FEAC and in respect of which FEAC receives fees. Certain categories of such fees (such as arrangement, origination, closing, commitment, documentation, structuring, restructuring, facility, syndication, underwriting, placement, amendment, administrative agent, loan servicing and similar fees) are not always offset against management fees, or such categories of fees are offset for certain clients and not others in accordance with the applicable client agreements. To the extent such fees are not borne by clients, they are borne by the issuers of financial instruments held by clients.

Other Fees and Expenses In addition to fees paid to FEIM for investment advisory services by the Funds, private funds, ETFs, UCITS funds, CITs or other clients it advises, FEIM also performs or arranges for certain administrative, legal, operations, compliance and accounting services. Certain FEIM clients pay an administrative fee and/or reimburse FEIM for costs (including personnel, overhead, rent and other expenses and costs) related to those services, and certain clients incur redemption fees, as well. Clients also generally incur certain transaction fees and other expenses including charges imposed by custodians, brokers, and other third parties such as fees charged by managers, custodial fees, brokerage commissions, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Through brokerage transactions, FEIM’s clients invested in portfolios holding equity securities also generally bear the cost of eligible services under Section 28(e) of the Securities Exchange Act of 1934, as amended, as brokerage commissions for the purchase and sale of equity securities by FEIM’s client accounts generally include “soft dollar” payments for investment research sold by brokers and/or other third-party research providers, whether such payments (in the form of higher commissions) are made directly to brokers or are paid through commission sharing arrangements. For more information with respect to brokerage commissions, see Item 12 – Brokerage Practices, below. Funds, private funds and other clients bear other expenses, in addition to the fees and expenses described above, among which, depending on the Fund, private fund or other client, include: (1) costs and expenses with respect to any workout, restructuring, recapitalization, amendment, waiver or consent with respect to certain investments and the protection or

enforcement of rights thereunder; (2) costs and expenses in connection with the acquisition of director and officer insurance; (3) legal, custodial, accounting and related costs and expenses; (4) costs and expenses in connection with the off-market acquisition and/or sale of block positions, including related investment banking, legal and accounting fees; (5) pricing service costs incurred in valuing investments; (6) expenses incurred in obtaining credit ratings on investments; (7) all taxes imposed on a client and all litigation expenses (and any judgments or settlements paid in connection therewith) and other extraordinary expenses; (8) the costs of forming and maintaining any alternative investment vehicle and (at the discretion of the general partner or manager of a client) the costs of maintaining any other pooled investment vehicle through which to invest; (9) insurance costs; (10) interest and commitment fees payable in connection with credit facilities made available to a client; (11) fees of outside auditors and tax preparers and the costs of preparation of the books and records and tax returns of a client, including periodic reports to limited partners, and fund administration service provider expenses; (12) costs of liquidation and termination of a client; (13) all other costs incurred in connection with the administration of a client account; (14) any other expenses actually incurred on behalf of a client and paid by FEIM in connection with the management of certain investments; (15) fees and expenses related to portfolio exposure and performance management systems, risk management services and software to trade reconciliation, valuation quotation systems (e.g., Bloomberg terminals, historical and live financial data and other similar services and data feeds) and trade order management systems; (16) compliance and reporting expenses, liquidity risk management expenses and expenses attributable to regulatory filings that are made with respect to certain funds or assets of certain funds (including Section 13 filings, Section 16 filings, Form D, Form PF, FATCA, anti-money laundering compliance, state securities filings, general regulatory compliance and non-U.S. position reporting filings, if applicable, and non-U.S. filings, if any); (17) fees paid to proxy and securities class action advisory firms; (18) expenses relating to the offer and sale of certain units and redemptions and transfers thereof, including the costs of producing, updating and distributing offering memoranda and other marketing materials and the costs of printing and distributing periodic and annual reports and statements; (19) other reasonable expenses related to the purchase, sale, preservation or transmittal of certain funds’ assets and (20) certain other fees and expenses authorized under a fund’s governing documents or account documents.

The following are broad descriptions of the methods of analysis and strategies employed by FEIM.

Global Value FEIM’s Global Value Strategy seeks long-term growth of capital by investing in a range of asset classes from markets in the United States and throughout the world. In seeking to achieve this objective, the Global Value Strategy will normally invest primarily in common stocks (and securities convertible into common stocks) of U.S. and foreign companies. However, the strategy is generally permitted to invest a portion of its assets in other investments, including short-term debt instruments, gold and other precious metals, and futures contracts related to precious metals, and fixed-income securities of domestic or foreign issuers which, in addition to the income they may provide, appear to offer potential for long-term growth of capital. Under normal circumstances, the Global Value Strategy anticipates it will allocate a substantial amount of its assets to foreign investments. That generally means that approximately 40% or more of the strategy’s net assets (plus any borrowings for investment purposes) will be allocated to foreign investments (unless market conditions are not deemed favorable by the strategy, in which case it expects to invest at least 30% of its net assets, plus any borrowings for investment purposes, in foreign investments).

International Value FEIM’s International Value Strategy seeks long-term growth of capital by investing primarily in equities issued by non-U.S. corporations. In seeking to achieve this objective, the International Value Strategy invests primarily in equity securities of non-U.S. companies, the majority of which are traded in mature markets, and may invest in emerging markets, fixed-income instruments, short-term debt instruments, gold and other precious metals, and futures contracts related to precious metals. Under normal market conditions, the International Value Strategy invests primarily in foreign securities.

Global Income Builder FEIM’s Global Income Builder Strategy seeks current income generation and long-term growth of capital by investing in a range of asset classes including dividend-paying equities and corporate and other fixed income instruments, including high-yield debt, investment grade instruments and sovereign debt, from markets in the United States and multiple countries around the world. To pursue its investment objective, the Global Income Builder Strategy will normally invest primarily in income-producing securities.

Global Equity FEIM’s Global Equity Strategy seeks capital appreciation using a value approach by investing primarily in US and non-US equity securities across developed and emerging markets. The Global Equity Strategy’s assets may be concentrated in a particular security, sector, or geographic area. However, the strategy will not invest more than 25% of its assets in securities of companies in any one industry or, typically, more than 5% of its assets in securities of one company (in both cases, other than U.S. government securities or money market vehicles). The strategy may invest in companies of any market capitalization. Under normal market conditions, the strategy is permitted to hold no more than 8% of its net assets in cash and cash equivalents.

Gold FEIM’s Gold Strategy seeks to provide investors the opportunity to participate in the investment characteristics of gold (and to a limited extent other precious metals) for a portion of their overall investment portfolio. Many investors believe that, historically, a limited exposure to gold-related investments has provided some protection against loss of purchasing power during periods of extensive price inflation and/or following periods of extensive credit expansion. Under normal circumstances, the strategy will be invested primarily in gold and/or securities (which may include both equity and, to a limited extent, debt instruments) directly related to gold or issuers principally engaged in the gold industry, including securities of gold mining finance companies as well as operating companies with long, medium or short-life mines. The Gold Strategy may also invest in debt and equity instruments unrelated to the gold industry, other precious metals and futures contracts related to precious metals.

US Small Cap FEIM’s US Small Cap Strategy seeks long-term growth of capital by investing in equity securities of small- and micro-cap companies, aiming to take advantage of what the team believes are opportunistic situations for undervalued securities. Potential investments that the team considers to be opportunistic may include situations involving company turnarounds (e.g., a company that may be experiencing periods of poor financial or stock performance but may be exhibiting potential for financial recovery), emerging growth companies with interrupted earnings patterns (e.g., companies without a long or consistent history of earnings but that the team believes have the potential for earnings growth), companies with unrecognized asset values, or undervalued growth companies (e.g., companies that have low multiples of price-to-book or price-to-sales ratios, or companies with securities that are trading at a price below what the team believes the security is worth).

U.S. Value FEIM’s U.S. Value Strategy seeks long-term growth of capital by investing, under normal market conditions, primarily in domestic equity and debt securities. The U.S. Value Strategy may also invest in gold and other precious metals, and in futures contracts related to precious metals.

International Equity FEIM’s International Equity Strategy seeks capital appreciation using a value approach by investing primarily in non-US equity securities across developed and emerging markets. The International Equity Strategy’s assets may be concentrated in a particular security, sector, or geographic area. However, the strategy will not invest more than 25% of its assets in securities of companies in any one industry or, typically, more than 5% of its assets in securities of one company (in both cases, other than U.S. government securities or money market vehicles). The strategy may invest in companies of any market capitalization. Under normal market conditions, the strategy is permitted to hold no more than 8% of its net assets in cash and cash equivalents.

US Dividend Equity FEIM’s US Dividend Equity Strategy seeks capital appreciation and current income by investing primarily in domestic stocks and, to a lesser extent, debt and foreign equity instruments. Normally, the strategy’s assets will be invested primarily in domestic equity and debt instruments. Such investments include common stock, hybrid instruments such as preferred stock and convertible securities, warrants, corporate bonds, repurchase agreements, real estate investment trusts and derivatives. At least 65% of the strategy’s net assets will be income-producing, including equity, hybrid, option and debt securities.

Short Duration High Yield Municipal This strategy seeks a high level of current income and will normally invest primarily in municipal bonds that pay interest that is exempt from regular federal personal income tax. Such municipal bonds may include obligations issued by U.S. states and their subdivisions, authorities, instrumentalities and corporations, as well as obligations issued by U.S. territories (such as Puerto Rico, the U.S. Virgin Islands and Guam) that pay interest that is exempt from regular federal personal income tax. The strategy may invest in all types of municipal bonds, including general obligation bonds, revenue bonds and participation interests in municipal leases, and may invest without limit in securities that generate income taxable to those shareholders subject to the federal alternative minimum tax. While the strategy may invest in securities with any time to maturity, under normal market conditions, it will generally maintain an investment portfolio with a weighted average effective duration of less than 5 years.

US Smid Cap FEIM’s US Smid Cap Strategy seeks long-term growth of capital by investing in equity securities of small- and midcap companies, aiming to take advantage of what the investment team believes are opportunistic situations for undervalued securities. Normally, the strategy invests primarily in the equity securities (e.g., common stocks, warrants, rights and preferred stocks) of U.S. smid cap companies. FEIM defines smid cap companies as those that have at the time of investment a market capitalization not greater than that of the largest company in the Russell 2500TM Index. Potential investments that the investment team considers to be opportunistic may include situations involving company turnarounds (e.g., a company that may be experiencing periods of poor financial or stock performance but may be exhibiting potential for financial recovery), emerging growth companies with interrupted earnings patterns (e.g., companies without a long or consistent history of earnings but that the team believes have the potential for earnings growth), companies with unrecognized asset values, or undervalued growth companies (e.g., companies that have low multiples of price-to-book or price-to-sales ratios, or companies with securities that are trading at a price below what the team believes the security is worth).

Mid Cap FEIM’s Mid-Cap Strategy seeks long-term growth of capital by primarily investing in equity securities of mid-cap companies in an attempt to take advantage of what the investment team believes are opportunistic situations for undervalued securities. Potential investments that the investment team considers to be opportunistic can include situations involving company turnarounds (e.g., a company that may be experiencing periods of poor financial or stock performance but may be exhibiting potential for financial recovery), emerging growth companies with interrupted earnings patterns (e.g., companies without a long or consistent history of earnings but that the investment team believes have the potential for earnings growth), companies with unrecognized asset values, or undervalued growth companies (e.g., companies that have low multiples of price-to-book or price-to-sales ratios, or companies with securities that are trading at a price below what the investment team believes the security is worth). FEIM defines mid-cap companies as those that have at the time of investment a market capitalization of not greater than that of the largest company in the Russell Mid Cap Index.

Global Real Assets To achieve its objective of long-term capital growth, the Global Real Assets Strategy normally invests primarily in a variety of assets believed by FEIM to represent interests in ‘‘real assets’’ or ‘‘real asset’’ industries. The strategy primarily invests in equity securities (including convertible securities) of U.S. and foreign companies, with the balance invested in precious metals and related securities, cash and cash equivalents (such as Treasury bills), fixed income securities including inflation-linked fixed income securities (such as Treasury Inflation-Protected Securities or ‘‘TIPS’’) and debt instruments that are below investment grade, commonly known as ‘‘high yield’’ or ‘‘junk’’ bonds. ‘‘Real assets’’ in which the strategy invests include physical assets and assets that are otherwise recognized as stores of value, such as gold bullion or other precious metals, certain commodities and inflation-linked fixed income securities. While the strategy has no current intention to make direct investments in real estate, land or equipment, it targets companies in industries that are related to these assets (e.g., real estate investment trusts, developers and construction businesses, real estate finance companies, real estate brokerages and other related businesses, such as home improvement and home furnishings retailers). Specifically, ‘‘real asset’’ industries are those that relate to ownership or production of such assets or products or services otherwise supporting such assets. These industries may include basic materials, industrials, chemicals, energy, infrastructure, real estate, and utilities, as well as related suppliers and similarly connected businesses such as businesses within the telecommunications, healthcare, automobile and consumer staples sectors or industries. The strategy may invest in any size company, including large, medium and smaller companies.

High Yield Municipal This strategy seeks a high level of current income and will normally invest primarily in municipal bonds that pay interest that is exempt from regular federal personal income tax. Such municipal bonds may include obligations issued by U.S. states and their subdivisions, authorities, instrumentalities and corporations, as well as obligations issued by U.S. territories (such as Puerto Rico, the U.S. Virgin Islands and Guam) that pay interest that is exempt from regular federal personal income tax. The strategy may invest in all types of municipal bonds, including general obligation bonds, revenue bonds and participation interests in municipal leases, and may invest without limit in securities that generate income taxable to those shareholders subject to the federal alternative minimum tax. While the strategy may invest in securities with any time to maturity, it is a long-term bond strategy and, as such, will generally maintain, under normal market conditions, an investment portfolio with an overall weighted average maturity of greater than 10 years.

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FEIM provides portfolio management services to corporate pension and profit-sharing plans, Taft-Hartley plans, municipal pension plans, mutual funds, ETFs, ICAV funds, CITs and other trusts, private funds, registered, closed-end interval funds, a BDC, sovereign funds, non-U.S. funds, and other U.S. and non-U.S. institutions. FEIM generally requires minimum account sizes, which are based on mandate and type. FEIM reserves the right, in its sole discretion, to waive or change investment minimums in certain circumstances. By strategy, FEIM’s minimum account sizes are generally as follows:

Global Value – $100mm

International Value – $100mm

Global Income Builder – $100mm

Global Equity – $100mm

Gold – $100mm

US Small Cap – $25mm

U.S. Value – $100mm

International Equity – $100mm

US Dividend Equity – $50mm

Short Duration High Yield Municipal – $50mm

US Smid Cap – $25mm

Mid Cap – $25mm

Global Real Assets – $50mm

High Yield Municipal – $50mm

As noted above, in addition to the accounts FEIM manages for asset-based fees, FEIM also charges certain accounts performancebased fees – that is, fees based on a share of capital gain or capital appreciation of the account assets. There are potential conflicts of interest that arise due to the side-by-side management of fixed-fee accounts with performance-fee accounts as there is an incentive to favor higher-fee-paying accounts in the allocation of investment opportunities. Moreover, performance-based fee arrangements create an incentive for FEIM to make investments which are riskier or more speculative than those which would be made under a different fee arrangement. A similar conflict exists to favor higher-fee-paying accounts when managing client accounts paying higher asset-based fees compared to other accounts; likewise when FEIM manages accounts containing assets owned by FEIM itself, its employees or its owners, side-by-side with other accounts. FEIM, its affiliates and their respective personnel have differing investment, compensatory and other pecuniary interests that could serve to influence such persons to favor one client over another – including in circumstances where personnel are in position to influence investment or other decisions that impact clients. To address conflicts related to performance fees and pecuniary interests, FEIM has adopted and implemented written policies and procedures, including trade aggregation and allocation procedures, reasonably designed to ensure that all clients are treated fairly and equitably over time, and to prevent these conflicts from influencing the allocation of investment opportunities among clients. FEIM typically aggregates trades in the same security when execution is intended to be completed within the same time frame. Generally, FEIM allocates its clients’ aggregated trades on a pro-rata basis among eligible accounts, regardless of advisory fees paid to FEIM or of other pecuniary interests of FEIM or its personnel. Eligible accounts include those handled by FEIM’s trading desk for which there are no guidelines or restrictions that are inconsistent with the proposed trade and for which there is available cash to enter into the transaction. Certain considerations, including cash flow, tax status, specialized account status, odd lots/de minimis status and threshold amounts can cause FEIM to deviate from pro-rata allocation and vary the portfolio composition, timing, and/or relative size of purchases and sales among types of accounts if, under the circumstances, such other method of allocation is reasonable, done in good faith and does not result in an improper disadvantage to any account. FEIM periodically reviews performance dispersion among all similar accounts, including accounts subject to a performance fee, to identify whether any account appears to have been consistently favored relative to other similar accounts over time. Further details on allocation policies and procedures are provided in Item 12 – Brokerage Practices, below.

FEF Distributors serves as the distributor to the Funds and as a wholesale placement agent for FEIM’s private funds and is registered as a limited purpose broker-dealer. FEF Distributors receives compensation in connection with the distribution of these investment products, which is generally based on asset levels or sales of such products. As a result, FEIM and its affiliates have an economic interest in the distribution and growth of these products, which presents a conflict of interest. For additional information regarding these compensation arrangements and related conflicts, see Item 5.

Genstar Certain private funds, including Genstar Capital Partners XI, L.P., that are managed by affiliates of Genstar, indirectly own a controlling interest in or have the power to direct First Eagle. Genstar Capital Partners LLC, a U.S. registered investment adviser, is the investment adviser to the investment vehicles invested in FEIM. Genstar owns and/or controls other investment advisers, broker-dealers and sponsors of investment funds and limited partnerships, and other financial industry companies. Following Genstar’s August 2025 acquisition of First Eagle, FE Holdings remains the managing member of FEIM; however, oversight of First Eagle and its subsidiaries is exercised through the board of directors of GC Ferry Parent GP, LLC, which replaced the prior board structure. Certain FEIM employees have interests in or are affiliated with other investment advisers or financial services firms, including members of FEIM’s investment teams who are also providing investment advisory services to FESAM (defined below). Additionally, certain investors in GC Ferry Parent, L.P. and/or non-employee directors of the board of GC Ferry Parent GP, LLC have financial interests in entities that receive compensation for the sale of investments (including investments in the Funds, private funds and potentially to SMAs). Certain directors of GC Ferry Parent GP, LLC have industry affiliations with other financial firms, including firms affiliated with Genstar and broker-dealers or investment adviser firms that do business with FEIM and its clients, including in certain portfolio companies of Genstar that sell products sponsored by First Eagle. From time to time, various potential and actual conflicts of interest arise from the overall advisory, investment and other activities of Genstar, its affiliates and personnel. The following summarizes certain material conflicts of interest but does not purport to describe every potential conflict that may arise. Certain of these conflicts may arise even where Genstar or its affiliates are not deemed to be “management persons” or “affiliated persons” of FEIM for purposes of the Advisers Act. On behalf of its advisory clients, FEIM may enter into agreements, transactions, loans, brokerage, underwriting or other arrangements with Genstar affiliates and portfolio companies, including transactions involving the securities of such companies. On behalf of itself, including for years prior to Genstar’s acquisition of First Eagle, FEIM has engaged a Genstar portfolio company to provide regulatory and compliance advisory services. Although FEIM believes such services have been of appropriate quality, the continued use of an affiliate presents a conflict of interest. From time to time, employees of Genstar may serve as directors or advisory board members of certain issuers of clients’ investments or other entities. It is expected that FEIM’s investments in such issuers, if any, would not have a material impact on such compensation.

Information Barriers and Genstar By virtue of its ownership interests in and control of First Eagle, Genstar may have access to information that is not available to FEIM’s clients or to investors in the Funds and in its private funds. Genstar is entitled to receive information regarding FEIM and its activities, including, without limitation, information about FEIM’s clients (together with information about the Funds, ETFs, ICAV funds, CITs, SMAs and the private funds’ portfolios, subscriptions, withdrawals and other information relating to FEIM’s clients), as well as confidential, proprietary information about First Eagle. FEIM has adopted policies and procedures to address potential conflicts with Genstar and support compliance with applicable legal, regulatory and contractual requirements, including the use of information barriers designed to limit the flow of certain information and to address conflicts of interest with portfolio companies. These measures may limit investment opportunities for client accounts. FEIM maintains a restricted list of companies whose securities are subject to trading prohibitions due to the business activities of Genstar. A client’s account could be prohibited from buying or selling securities on the restricted list until the restriction is lifted, which could disadvantage the client.

Genstar may represent creditors or debtors in proceedings under Chapter 11 of the Bankruptcy Code or prior to such filings. From time to time Genstar may serve as advisor to creditor or equity committees. While FEIM has adopted policies and procedures, including information barriers, to address potential conflicts and reduce the risk that FEIM would face restrictions under these circumstances, the participation of Genstar in any such activities could potentially limit or preclude the flexibility that FEIM’s clients may otherwise have to participate in restructurings. Alternatively, FEIM could be required to liquidate any existing client positions of the applicable portfolio entity. The inability to transact in any security, derivative or loan held by a client may adversely affect a client’s investment flexibility and, in certain circumstances, result in losses.

Trading Process Separation with First Eagle Separate Account Management, LLC First Eagle Separate Account Management, LLC (“FESAM”), a wholly owned subsidiary of FEIM, and a registered investment adviser, acts as investment adviser to a retail separately managed account or “wrap fee” business. The strategies FESAM currently offers for its separate account business are executed by substantially the same investment teams that provide investment advisory services to FEIM’s Global Equity/Value, International Equity/Value, U.S. Small Cap, U.S. Dividend Equity and Muni Strategy clients, but differ in important ways, potentially including differences in the types of securities purchased, in management and brokerage fees, in minimum account size and in trade execution. Since its creation in 2020, FESAM has expanded to offer more strategies that mirror other FEIM strategies and will likely continue to do so. Because FESAM’s clients’ trades will be executed in largely the same portfolio companies as those held by FEIM’s clients, under some circumstances, FESAM’s trading may affect the timing or pricing of trades on behalf of FEIM’s clients. While FEIM and FESAM operate their portfolio management functions together, with the exception of certain separate accounts managed for FESAM by FEIM’s High Yield Municipal Investment Team which handles all trading for those accounts (and which trades are subject to FEIM’s policies and procedures), they maintain largely separate trading processes due to limitations related to differences in clients and/or investment strategies and business structures. The separate trading processes are designed to limit the sharing of detailed trading information regarding timing and execution of a particular trade made in the other process. FESAM maintains policies and procedures under which it may determine that certain trades be traded away from the Sponsor or Designated Broker and may route such trades to FEIM’s trading desk, in which case those trades would be subject to FEIM’s trading policies and procedures. It is possible that the process separation procedures may not fully achieve their intended objectives of addressing potential conflicts of interest and avoiding any actual or perceived misuse of trading information, which in turn could have adverse effects on clients and on the reputation of FEIM. See Item 12 – Brokerage Practices for more information about the separate trading processes of FEIM and FESAM, and other policies and procedures established relating thereto.

Information Barriers with FEAC and Napier Park First Eagle Alternative Credit, LLC is a registered investment adviser, and serves as general partner, collateral manager, subadviser and investment manager for both direct lending and broadly syndicated investments through registered funds, private funds, collateralized loan obligations, SMAs, a business development company, an interval fund and co-mingled funds (such entities collectively, “FEAC”). FEAC’s Direct Lending platform provides debt and equity capital to middle-market companies. In particular, direct lending clients provide financing primarily in the form of directly originated first lien and second lien secured loans, including through unitranche investments. In certain instances, direct lending clients make subordinated debt investments, which sometimes include an associated equity component such as warrants, preferred stock or similar securities, and direct equity co-investments. FEAC also offers a Tradable Credit platform. The Tradable Credit Strategy offers discretionary and non-discretionary investment management services to clients in below investment grade investment opportunities in bank loans, high yield debt, collateralized loan obligations (“CLOs”), including CLO debt or equity mandates, and other securities. FEAC’s Tradable Credit clients include: registered funds, separate accounts, private funds and structured products, including CLOs. On August 1, 2022, FEIM acquired 100% of the interests in Napier Park Global Capital LLC, a Delaware limited liability company. Napier Park Global Capital LLC is the parent of (i) Napier Park Global Capital (US) LP, a Delaware limited partnership, which is registered as an investment adviser with the SEC and (ii) Napier Park Global Capital Ltd., a private limited company formed in the United Kingdom, which is registered as an investment adviser with the SEC and is authorized and regulated by the Financial Conduct Authority in the United Kingdom (collectively, “Napier Park”). Napier Park operates as an autonomous, wholly owned unit of FEIM. Napier Park also owns a de minimis interest in Regatta Loan Management LLC, a Delaware limited liability company, which is a private investment company and collateral manager to securitized asset vehicles that is registered as an investment adviser with the SEC. Napier Park provides management and/or advisory services to private investment companies such as hedge funds, private equity funds, securitized asset vehicles, an interval fund and infrastructure funds, and institutional investors, pension plans, state and

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FEIM has adopted a Code of Ethics (the “Code”) to address its fiduciary duties to its clients and to set forth general ethical principles and a standard of conduct that FEIM requires of its employees. The Code establishes policies regarding personal trading by employees and their immediate family members (as defined in the Code), to address actual and potential conflicts of interest. Generally, the Code prohibits personal trading in any security (subject to exceptions set forth in the Code) while a client order in that security is pending. FEIM has implemented procedures to monitor compliance with the provisions of the Code, including pre-approval of personal securities transactions and post-trade monitoring, as well as quarterly personal transaction certifications and annual compliance confirmations and holdings report certifications. The Code contains prohibitions on purchases of initial public offerings of equity securities and pre-clearance procedures with respect to private placements. For employees and, under certain circumstances, their immediate families, personal securities transactions must be pre-cleared and are subject to short-term trading bans and blackout periods, unless they meet certain exemptions. Personal securities transactions are monitored for compliance with the Code. Any employee who violates the Code is subject to disciplinary action, up to and including termination of employment. Employees are required to provide written certifications of their compliance with the Code upon the commencement of their employment and annually thereafter. In addition, in accordance with FEIM’s Code of Business Conduct and inside information procedures, FEIM prohibits the use of MNPI and maintains a restricted list of securities that may not be purchased by its employees for their own accounts or for client accounts because of the possession of inside information. The Code of Business Conduct addresses areas of conduct regarding conflicts of interest, including but not limited to the acceptance and provision of gifts and business entertainment, outside business activities, political contributions, charitable contributions and privacy. On a quarterly basis, employees must disclose all gifts and business entertainment in excess of certain de minimis thresholds, and employees must pre-clear giving/receiving gifts or providing/receiving entertainment if above certain thresholds or, in any amount, if made to government/public fund officials, union representatives, plan fiduciaries or foreign officials. Pre-approval requirements also apply to participation in outside business activities and for service on a board of directors (or other governing body) of any unaffiliated organization. The Code of Business Conduct requires that such activities not be approved unless FEIM’s Legal, Compliance and Enterprise Risk Department determines that the activities would not create a real or perceived conflict of interest to FEIM’s clients or to FEIM, itself. Likewise, personal relationships presenting potential conflicts for FEIM and its clients are required to be reported to FEIM and are then logged and monitored by FEIM’s Legal, Compliance and Enterprise Risk Department, together with any approved outside business activities or board participation. Copies of FEIM’s Code of Ethics and Code of Business Conduct are available to all clients and prospective clients upon request.

Participation or Interest in Personal Trading – Client Trading From time to time, FEIM’s employees, in their personal securities accounts, purchase, sell, or otherwise enter into transactions in securities and other instruments. Prior to, simultaneously with or after such transactions, FEIM occasionally will, for its clients, purchase, sell, or otherwise enter into transactions involving any of these same securities or other instruments, or in related securities or instruments (including securities issued by the same issuer, options on such securities or instruments, and instruments convertible into such securities or instruments). In addition, while FEIM generally does not enter into principal transactions, it is permitted to cause its advisory clients to enter into principal transactions with related persons in accordance with policies and procedures adopted under Section 206(3) of the Advisers Act. To address related potential conflicts, employees deemed to be “Access Persons” under the Code are required to report brokerage and trading accounts to FEIM upon hire, at the time a new account is opened and annually thereafter. Access Persons’ personal securities transactions are also subject to limitations regarding the type and timing of transactions, including certain trading prohibitions, and pre-approval and monitoring by FEIM’s Legal, Compliance and Enterprise Risk Department.

Subject to the restrictions described above, FEIM’s employees personally are permitted at any time to hold, acquire, increase, decrease, dispose of or otherwise deal in investments in which a client account also has an interest. FEIM has no obligation to acquire the same securities for different clients, or to acquire the same securities for clients that employees have acquired for their personal accounts. Likewise, client accounts do not have first refusal, co-investment or other rights in respect of any such investment.

Participation or Interest in Personal Trading While the Code is designed to address potential conflicts of interest and improprieties, including even the appearance of impropriety in employees’ personal actions, it is not designed to eliminate such issues. FEIM and its affiliates and their related persons and employees are permitted to buy or sell securities that are also purchased and sold on behalf of client accounts. This often occurs where FEIM acts as general partner, investment adviser or managing member to private funds and Funds in which clients are solicited to invest. FEIM has taken positions for advisory clients (including private investment funds) and affiliates of FEIM have taken positions for their own accounts in securities contrary to the positions held in the same securities (e.g., short versus long positions) by clients of FEIM. It is possible that FEIM or its affiliates may, from time to time, cause short sales for a client to be executed following long transactions for other clients (including proprietary accounts) in the same security. There is a possibility that employees might benefit from market activity by a client in a security held by an employee. The nature and/or timing of actions taken by one or more of FEIM’s employees or by one or more of FEIM’s affiliates, either for their own accounts or for the accounts of clients, will often differ from the nature and timing of actions taken by FEIM for client accounts. Because the Code of Ethics places restrictions on when employees can trade certain securities, the price received by FEIM’s clients in a securities transaction will most likely be different than the price received by FEIM’s employees. FEIM and its affiliates perform investment management and investment advisory services for various clients, including SMAs and wrap programs, many of which have differing investment objectives, guidelines, and restrictions. As a result, FEIM or an affiliate from time to time will give advice and take action in the performance of its duties for a particular client that differs from the advice given, or the timing or nature of action taken, with respect to other clients. In some cases, FEIM or an affiliate may cause one or more accounts to buy or sell a security from or to a broker-dealer, and soon thereafter may engage in the opposite transaction for one or more other accounts from that or another broker-dealer. This practice may result in certain accounts receiving less favorable prices. FEIM and its affiliates have adopted procedures that they believe are reasonably designed to obtain the most favorable price and execution for the transactions by each account under the circumstances applicable to each account, including any relevant account restrictions and investment guidelines.

Generally, FEIM receives full discretion from its clients to choose broker-dealers through whom transactions may be executed. This means that FEIM has discretion to select broker-dealers and negotiate the transaction costs, including commissions or spreads, in the execution of client portfolio transactions. When exercising discretion over client brokerage, it is FEIM’s policy to seek to obtain the best execution available for its clients’ securities transactions or the most favorable results under the circumstances. FEIM’s determination of best execution doesn’t necessarily mean that a client is paying the lowest possible commission rate or spread, as there are several additional important factors to consider when evaluating best execution in client brokerage. In selecting brokers for its clients, FEIM considers the full range and quality of a broker’s services, including execution capability, commission rates (or markup or markdown) and volume discounts, the nature of the applicable market, market liquidity, financial responsibility, confidentiality, as well as the value and availability of research services, and general responsiveness. In addition to executing trades via traditional exchanges, FEIM has access to several electronic communication networks (commonly referred to as “ECNs”). For Muni Strategy clients, FEIM expects to utilize electronic fixed income trading platforms or other execution venues as part of its efforts to access liquidity, seek price discovery, and facilitate the execution of municipal securities transactions, with clients generally incurring markups, markdowns, spreads, platform fees, transaction charges, custody-related charges, taxes, or other costs in connection with fixed income transactions. Certain costs, including fees charged by electronic trading platforms or other execution venues, ordinarily will be reflected in the price paid or received for a security rather than shown as a separate charge. These costs are paid by Muni Strategy clients in addition to FEIM’s advisory fee. In light of all relevant factors, FEIM’s portfolio managers and traders will select the market mechanism which they believe offers the best overall execution for client transactions and reduces other transaction costs. Furthermore, FEIM has banned the provision of order flow to broker-dealers in exchange for the distribution of shares of the registered investment companies that FEIM sponsors.

Soft Dollars In placing orders for portfolio securities or futures, FEIM seeks to obtain best execution or the most favorable execution under the circumstances and in accordance with FEIM’s best execution policy and applicable law. Within this framework, FEIM will consider the research and investment services provided by brokers, dealers or futures commission merchants who effect transactions for a client account or who are parties to portfolio transactions with a client account, FEIM or FEIM’s other clients. Such research and investment services are those which brokerage houses customarily provide to institutional investors and include, but are not limited to, statistical and economic data research reports on particular companies and industries, and meetings with corporate executives (sometimes referred to as “corporate access”). Brokers, dealers or futures commission merchants furnishing such services may be selected for the execution of transactions of other client accounts, whose aggregate assets could be significantly smaller or larger than those of other client accounts (historically, a portfolio of the First Eagle Funds generally has been the largest client account within each investment strategy offered by FEIM), and the services furnished by such brokers, dealers or futures commission merchants used by FEIM in providing investment management services to certain of FEIM’s client accounts, as well as certain client accounts of FEIM’s wholly owned subsidiary, FESAM, which shares FEIM’s investment management personnel, and manages investment strategies that mirror a subset of FEIM’s investment strategies. Commission rates are based on the quality and quantity of execution services provided by the executing party and reflect generally prevailing rates. In addition, FEIM may pay higher commissions on brokerage transactions through its client accounts to brokers, consistent with its obligations to seek best execution and in accordance with applicable law, in order to secure the research and investment services described above (sometimes referred to as “paying up”). The use of commissions on brokerage transactions paid by any of FEIM’s client accounts to pay for research and the investment services described above is sometimes referred to as “soft dollars”. Accordingly, FEIM need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not FEIM’s practice to negotiate “execution only” commission rates. Thus, a client account may be deemed to be paying for research, brokerage or other services provided by the broker that are included in the commission rate. To engage in soft dollar transactions, the investment team must complete FEIM’s Soft Dollar/CSA Service Request Form, have the relevant portfolio manager and trader sign it, and provide it to the Legal, Compliance and Enterprise Risk Department for review and approval. Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an investment adviser to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision-making process. The use of commissions to obtain other services would be outside the parameters of Section 28(e). Since Section 28(e) generally relates only to the use of commissions on equity transactions, the use of commissions or other transaction costs paid on transactions in instruments other than equity securities typically would also be outside the parameters of Section 28(e). The payment for eligible services under Section 28(e) by FEIM’s clients’ accounts through soft dollars using client assets benefits FEIM because FEIM does not need to produce or pay for such research services and, as a result, the receipt of research in exchange for soft dollars creates a conflict of interest between FEIM and its clients, as well as between any particular FEIM client and the other clients of the Firm. Research or other services obtained in this manner may be used in servicing any or all of FEIM’s clients as well as the clients of FESAM and the ETFs, including in connection with accounts other than those that pay commissions to the broker relating to the research or other service arrangements. The client accounts of FESAM and the ETFs sub-advised by Exchange Traded Concepts, LLC, because they trade separately from FEIM’s other clients, holding issuers that generally overlap with the issuers held by many of FEIM’s clients and which common issuers are the subject of the research of FEIM’s investment teams, generally benefit from the soft dollars spent by FEIM’s client accounts to pay for FEIM’s research of such issuers without having to pay for the research themselves. Additionally, such products and services may disproportionately benefit some FEIM clients’ investment accounts relative to others based on the amount of brokerage commissions paid by some clients relative to such other client accounts. For example, research or other services that are paid for through one client’s commissions may not be used in managing that client’s portfolio. In addition, other client accounts may receive the benefit, including disproportionate benefits, of economies of scale or price discounts in connection with products and services that may be provided to larger client accounts and to such other smaller investment accounts. Certain clients, including the FEIM’s larger client accounts (particularly the First Eagle Funds), could bear more of the cost of soft dollar arrangements than other investment accounts. Moreover, FEIM may be incentivized to select or recommend a broker-dealer based on FEIM’s interest in receiving research services, among the other factors that FEIM considers, consistent with best execution. Where appropriate, FEIM may allocate mixed-use research services as payable in cash by FEIM (to the extent not utilized by FEIM as brokerage or research) or through commission costs (to the extent utilized by FEIM as brokerage or research). In allocating brokerage commissions from mixed-use items, FEIM would make a good faith determination as to the product or service’s relation to the investment decision-making process. The receipt of mixed-use products and services and the determination of the appropriate allocation could create a potential conflict of interest between FEIM and its clients.

Research and brokerage services obtained by the use of commissions arising from a client’s portfolio transactions may be used by FEIM in its other investment activities and thus, a client whose brokerage pays in part for certain research services may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided. Independent third-party research is a component of FEIM’s investment selection process and is generally paid for via its clients’ brokerage commissions that bundle research costs either directly with the trade execution clearing and/or settlement services provided by a particular broker-dealer, or through step-out transactions with other broker-dealers. FEIM’s receipt of research on this basis benefits it because FEIM does not need to produce or pay for such research services and, as a result, the receipt of research in exchange for soft dollars creates a conflict of interest. Effectively, through “soft dollars”, broker-dealer produced/arranged research is paid for by client commissions that also pay for the execution, clearing and settlement services provided by the broker-dealer, and are not paid by FEIM, itself. FEIM may also receive research that is either paid for directly by it (sometimes referred to as “hard dollar” arrangements) or, as described below in greater detail, obtained utilizing soft dollars, through a commission sharing arrangement (“CSA”). FEIM has entered into CSAs under which it may execute transactions through, and obtain research from, a broker-dealer. Under a CSA, FEIM may request that the broker-dealer allocate a portion of the commissions paid by FEIM’s clients to another firm that provides research to FEIM. To the extent that FEIM continues to engage in CSAs, many of the same conflicts related to traditional soft dollar arrangements exist. Although FEIM will make a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to commission rates for execution only will generally result in higher transaction costs than would otherwise be obtainable. The receipt of such products or services and the determination of the appropriate allocation in the case of “mixed use” products or services create conflicts of interest between FEIM and its clients. Soft dollars may not be used to correct trade errors or to pay for advisory client account referrals.

Commission Sharing Arrangements Independent research is a component of FEIM’s investment selection process and is either paid for directly by FEIM (referred to as “hard dollar” arrangements), or by utilizing “soft dollars” as described above or through a CSA. FEIM has entered into CSAs under which it executes transactions through, and obtains research services from, one or more CSA broker-dealers. Under its CSAs, FEIM’s Head Trader will typically instruct a CSA broker-dealer to pay a portion of a commission amount to another firm that provides research to FEIM and cannot accept cash payment directly from FEIM for its research services. The broker (not FEIM or its accounts) must be obligated to pay for soft dollar research, and FEIM may not promise in advance to direct brokerage to any particular broker under a soft dollar agreement or commitment, although FEIM may agree to a nonbinding expectation of future commissions. If a soft dollar broker or research provider requests a written agreement, the contract is reviewed by FEIM’s Legal, Compliance and Enterprise Risk Department before it is signed. Additionally, as with soft dollar arrangements described above, prior to paying for any new research service through the CSA, the investment team must complete the Soft Dollar/CSA Service Request Form, have the relevant portfolio manager and trader sign it, and provide it to the Legal, Compliance and Enterprise Risk Department for review and approval. To the extent that FEIM engages in a commission sharing arrangement, many of the same conflicts related to traditional soft dollar arrangements exist.

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FEIM has adopted incentive plans and enters into agreements from time to time that provide for cash payments to its employees who develop and refer new business. In addition, FEIM’s affiliated entities may enter into arrangements with third-party “introducers”, solicitors or placement agents (collectively, “Promoters”) to identify and introduce prospective non-U.S. investors to certain non-U.S. registered investment funds managed by FEIM. Currently, a non-U.S. affiliate of FEIM has engaged one such Promoter to introduce potential investors domiciled in Europe to the FEIM affiliate for investment in one or more of the sub-funds of First Eagle Funds (Ireland) ICAV, an Irish UCITS. Under this arrangement, the FEIM affiliate compensates the Promoter for these services. This compensation typically consists of a fixed retainer and a percentage of the management fees earned by FEIM or its affiliates on the amount of the introduced investor’s investment. The use of Promoters creates a conflict of interest, as the Promoter has a financial incentive to recommend FEIM’s funds based on the compensation received rather than solely on the investor's best interests. Prospective investors are notified of these arrangements as required by applicable law. FEIM ensures that each employee, affiliate, or future third-party solicitor or placement agent complies with the applicable requirements in Rule 206(4)-1 under the Advisers Act. Such requirements may include, depending on the circumstances, maintenance of a written agreement between FEIM and the Promoter, and delivery by the Promoter of certain disclosures to prospective clients or prospective private fund investors setting forth the nature of the relationship between the Promoter and FEIM, any fees to be paid to the Promoter, and related conflicts of interest. Investors or prospective investors should be aware that these incentive plans or arrangements create a conflict of interest between an investor and FEIM, as well as FEIM’s relevant employees, placement agents, introducers and others. This conflict continues after an investment is made to the extent that payments under these plans or arrangements are made over a period of years by reference to the amount of the investment maintained with FEIM over time. Such plans or agreements include those FEIM has with its own employees who develop and refer new business. There are also certain investors in and/or non-employee directors of GC Ferry Parent GP, LLC who have financial interests in broker-dealers or investment adviser firms which do business with FEIM and its clients, including sales of investment products sponsored by First Eagle.

FEIM has no reportable material legal or disciplinary events.

Portfolio Managers review performance, transactions and holdings for clients’ accounts on an ongoing basis and select investments for clients in accordance with each client’s investment objectives, as stated in their respective investment management agreements, and consistent with the investment philosophy of FEIM. Generally, each SMA client receives periodic, written performance and holdings reports per the contractual requirements of the client’s investment management agreement. FEIM maintains systems for guideline surveillance that check pre-trade security transactions and post-trade account holdings against client account guidelines.

The SEC deems investment advisers, including FEIM, to have “custody” of client funds or securities within the meaning of Rule 206(4)-2 under the Advisers Act if they have access to or authority over client accounts for purposes other than, among other things, issuing trading instructions, as is commonly the case for the general partners of limited partnerships sponsored by investment advisers. When FEIM is deemed to have custody of a limited partnership’s assets, the client’s administrator is directed to send the client’s limited partners periodic account statements indicating the amounts of any funds or securities in the limited partner’s account as of the end of the statement period and any transactions in the account during the statement period. Limited partners for whom FEIM is deemed to have custody should receive monthly statements from the administrator of the limited partnership in which they are invested. Limited partners are advised to carefully review these statements and to notify FEIM promptly if account statements are not received from their respective account’s administrator on at least a monthly basis. Because FEIM serves as general partner of certain private funds that are limited partnerships, FEIM is deemed to have “custody” over these private funds within the meaning of Rule 206(4)-2 under the Advisers Act. To comply with this Rule, each private fund administrator provides each investor in such private funds with audited financial statements within 120 days following the private

fund’s fiscal year end. Limited partners who have invested in these private funds and have not received audited financial statements on a timely basis should contact FEIM without delay.

Generally, clients retain FEIM on a discretionary basis to provide continuous investment advice pursuant to an investment management agreement that describes the services to be provided. Consistent with the client’s investment objectives, FEIM typically will be granted full investment decision making authority over the types of investments and brokerage for the client’s account. Within the respective investable scope of each of FEIM’s investment strategies, FEIM has customarily agreed with its separately managed account clients to implement certain client-specific restrictions on the investments that FEIM may execute for their account. When selecting securities and determining transaction quantities, FEIM seeks to follow the investment policies, limitations and restrictions of its clients. While none of FEIM’s current clients direct that FEIM use certain broker-dealers to execute their account’s transactions, in the past, FEIM has agreed to certain directed brokerage arrangements. As described in Item 12 – Brokerage Practices, FEIM generally retains the authority to select broker-dealers and to determine the commissions to be paid.

Proxy Voting FEIM has adopted proxy-voting policies and procedures (the “Policies”) designed to ensure that where clients have delegated proxyvoting authority to FEIM, proxy-voting decisions are made solely in the best interest of clients and in a manner consistent with enhancing the economic value of the underlying portfolio securities held in its clients’ accounts. When a client retains FEIM, the client will instruct, in its investment management agreement, whether FEIM is authorized to vote proxies on its behalf. FEIM has retained Institutional Shareholder Services (“ISS”), a third-party proxy voting service, for recommendations as to voting on particular issues, for technical assistance in tracking instances in which clients have the opportunity to vote and in transmitting voting instructions to the relevant corporate issuer or its proxy tabulation agents. FEIM utilizes ISS as a resource to enable it to make better-informed proxy voting decisions and to limit the potential for conflicts in the proxy voting process. FEIM has analyzed and determined the relevant ISS proxy guidelines to be largely consistent with FEIM’s views on various types of proxy proposals, which typically seek to be consistent with the best interests of the client and with enhancing the economic value of the underlying portfolio securities. While other services or recommendations may be considered from time to time, including Glass, Lewis & Co., LLC, FEIM principally utilizes the proxy voting services provided by ISS. As a practical matter, in most cases, FEIM votes client proxies in a manner consistent with the voting recommendation of the third-party services. However, FEIM evaluates individual proxies in accordance with the Policies and may determine to depart from the recommendation of its proxy voting service provider in voting a proxy. Under FEIM’s proxy-voting policies, each proxy voted by FEIM must be instructed in accordance with the recommendations provided under the applicable ISS guidelines (ordinarily, ISS’s “Benchmark Guidelines”), unless FEIM’s relevant investment professionals believe that it is in the best interest of the client(s) and/or that it will enhance the economic value of portfolio securities to override those recommendations. Factors that FEIM’s Global Value investment team will consider in determining whether to override include, but are not limited to: (i) director independence initiatives at family and founder controlled companies where the founding family has substantial economic ownership and is aligned with First Eagle’s view of long-term value creation; (ii) executive compensation programs, in light of our assessment of the value created by an issuer’s management over the long term, measured in terms of market share gains and capital discipline compared to peer companies; and (iii) shareholder proposals attempting to direct business strategies and proposals asking for greater disclosure, in view of the robustness of a company’s existing disclosures and legal requirements, and any associated financial costs and competitive issues raised by such proposals. In those cases in which FEIM’s investment personnel believe a proxy should be voted in a manner contrary to applicable ISS recommendations, the investment personnel must complete a form describing the reasons for departing from the ISS recommendation and disclosing facts that might suggest a conflict, if any. In the event the applicable ISS guidelines do not address how a proxy should be voted or state that the vote is to be determined on a “case-by-case” basis, the proxy will be voted in accordance with the investment team’s recommendation, as approved in advance by FEIM’s Legal, Compliance and Enterprise Risk Department. A client may request in writing that FEIM vote proxies for its account in accordance with a set of guidelines which differs from ISS’s Benchmark Guidelines, which FEIM will otherwise generally apply by default. For example, a client may wish to have proxies voted for its account in accordance with the ISS’s Taft-Hartley, Sustainability or Board-Aligned proxy voting guidelines. In such a case,

FEIM will vote the shares held by such client accounts in accordance with their direction, which may be different from the vote cast for shares held on behalf of other client accounts that vote in accordance with the Benchmark Guidelines. For any material conflict of interest that arises between FEIM’s interests and a client’s interests, votes will only be cast in the best interest of the client and to enhance the economic value of the underlying portfolio securities held in the client’s accounts, regardless of the situation. FEIM occasionally refrains from voting proxies for its clients’ accounts, taking into account its obligation to act in the best interest of clients and enhance the economic value of the underlying portfolio securities. Potential circumstances for not voting include but are not limited to the following:

When the economic effect on shareholders’ interests or the value of the portfolio holding would not reasonably be expected to be material;

When the voting of proxies is subject to “share-blocking” restrictions;

When voting the proxy would unduly impair the investment management process;

When the client’s custodian has not notified FEIM of the vote on a timely basis;

When client securities in a securities lending program are out on loan;

Due to timing issues related to the opening and closing of accounts; or

When the cost of voting the proxies outweighs the benefits or is otherwise impractical.

As part of its ongoing monitoring efforts, FEIM will determine whether ISS has the capacity and competency to adequately analyze the matters for which FEIM is responsible for voting. FEIM will consider in making its determination such factors as it deems appropriate and applicable, which may include, among other things: (i) the adequacy and quality of ISS’s staffing, personnel, and technology; (ii) the adequacy of ISS’s process for seeking timely input from issuers and its clients; (iii) the adequacy of ISS’s disclosure to FEIM of its methodologies in formulating voting recommendations; (iv) the nature of any third-party information sources that ISS uses as a basis for its voting recommendations; and (v) the adequacy of ISS’s policies and procedures regarding how it identifies and addresses conflicts of interest. Any factual errors or methodological weaknesses of ISS as may be identified by the FEIM investment teams also will be considered. As ISS also is providing proxy administration and vote tabulation and submission services, FEIM’s monitoring addresses those services in addition to its research and recommendation services. It should be noted that FEIM and its subsidiary investment advisers operate with independent investment teams and may utilize different proxy voting policies or third-party research providers or may otherwise decide to vote proxies differently from one another. Consequently, FEIM may cast a vote for its clients that differs from the vote cast by an affiliated adviser for its own clients on the same proxy matter. Similarly, the individual investment teams within FEIM itself may likewise decide to vote differently for their respective client accounts. In such instances, each adviser will have determined that its respective vote is in the best interest of its specific clients, notwithstanding the divergent positions taken within the broader firm. FEIM may change or amend its proxy voting policies and procedures at any time, without prior notice, if it determines that doing so is consistent with its fiduciary duty and in the best interests of its client accounts. Clients may obtain a copy of FEIM’s proxy voting policies and procedures or obtain information on how their account’s securities were voted by submitting their request in writing to: First Eagle Investment Management, LLC, Attention: Legal, Compliance and Enterprise Risk Department, 1345 Avenue of the Americas, New York, NY 10105 or by calling 212-698-3300. Legal Proceedings FEIM does not file claims or make decisions on behalf of separately managed account clients in legal proceedings (including bankruptcies and class actions) relating to securities held or formerly held in a separately managed account or, generally, notify clients of any such proceedings. Clients who wish to make an election to opt in or opt out of a class action should instruct their custodians to forward applicable class action notifications to them. FEIM does not give legal advice, including advice concerning participation in class actions. Institutional separate account clients’ custodians will ordinarily receive all documents relating to class actions, bankruptcies, or other litigation matters because the client’s securities are held in the client’s name at its custodian. Accordingly, such clients should direct their custodian and/or legal counsel as to the manner in which such matters should be handled.

FEIM does not require or solicit prepayment of its fees. FEIM is not aware of any financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients.

Privacy Notice for First Eagle’s U.S. Clients and Shareholders This Privacy Notice is provided by the following entities (collectively “FEIM or “we”): First Eagle Investments; First Eagle Global Fund, First Eagle Overseas Fund, First Eagle U.S. Fund, First Eagle Gold Fund, First Eagle Global Income Builder Fund, First Eagle High Yield Municipal Fund (formerly named First Eagle High Income Fund), First Eagle Short Duration High Yield Municipal Fund, First Eagle Core Plus Municipal Fund, First Eagle Rising Dividend Fund (formerly named First Eagle Fund of America), First Eagle Small Cap Opportunity Fund, First Eagle Global Real Assets Fund and First Eagle U.S. Smid Cap Opportunity Fund, separate portfolios of First Eagle Funds, an open-end investment management company; four exchange-traded funds: First Eagle Global Equity ETF, First Eagle Overseas Equity ETF, First Eagle US Equity ETF and First Eagle Mid Cap Equity ETF; three closed-end interval funds: First Eagle Credit Opportunities Fund, First Eagle Real Estate Debt Fund and First Eagle Tactical Municipal Opportunities Fund; First Eagle Small Cap Opportunity CIT and First Eagle Global Equity CIT, each a collective investment trust; First Eagle Funds (Ireland) ICAV; First Eagle Amundi Sub-Funds (Luxembourg) SICAV; as well as a continuously offered closed-end management investment company that elects to be regulated as a business development company, First Eagle Private Credit Fund, (each a “Trust” and, combined, the “Trusts” and each of the preceding funds a “Fund” and combined the “Funds”), together with any additional portfolios that may be added to the Trusts from time to time, as well as First Eagle Investment Management, LLC, First Eagle Investment Management, Ltd, First Eagle Investment Management GmbH, First Eagle Separate Account Management, LLC, Diamond Hill Capital Management, LLC, First Eagle Alternative Credit, LLC, Napier Park Global Capital (US) LP, Napier Park Global Capital Ltd., Napier Park Global Capital GmBH and Regatta Loan Management LLC, First Eagle Holdings, Inc., FEF Distributors, LLC and First Eagle Investments Sarl. FEIM is providing you with this privacy notice to inform you of how we handle your personal information that we collect and may disclose to our affiliates and nonaffiliates. If FEIM’s information practices change, we will provide you with notice of any material changes. This privacy policy supersedes any of our previous policies relating to the information you disclose to us. If you are a natural person, this Privacy Notice will be relevant to you directly. If you are a non-natural person that provides us with personal information of individuals connected to you for any reason in relation to your investment with us, such as your investors or employees, this Privacy Notice will be relevant for those individuals, and you should transmit this document to such individuals or otherwise advise them of its content.

Why this Privacy Notice Applies to You You obtained a financial product or service from or through us for personal, family or household purposes when you opened an account with FEIM and are therefore covered by this privacy notice.

Sources and Types of Personal Information We Collect As part of providing you with FEIM’s products and services, we may obtain nonpublic personal information about you from the following sources:

Information we receive from your (or your employer’s, financial intermediary’s and/or designated representative’s) correspondence, interactions and transactions with us, our affiliates or others, including by letter, email, telephone, and our websites, and through information provided on subscription applications or other forms, such as your name, address, email address, telephone number, Social Security number, occupation, assets and income;

Information about your transactions with us, our affiliates, or unaffiliated third parties, such as your account balances, payment history and account activity;

Information we receive from consumer reporting agencies, our service providers or other sources we may engage in connection with conducting due diligence, know-your-customer, anti-money laundering, and other checks required to be performed in relation to admitting new investors;

Information from public records we may access in the ordinary course of business; and

Information collected from you online, such as your IP address and data gathered from your browsing activity and location.

We may also collect information that is considered “sensitive” under some data protection laws, such as your account log-in information if you log into our portal, sensitive identifiers like social security numbers and some financial information. When we do so, we use such information only for lawful purposes in compliance with the applicable data protection laws, such as to perform the services requested by you and to resist malicious, deceptive, fraudulent, or illegal actions. Where required by applicable law, we will obtain your consent prior to processing such information.

Why We Have and How We Use Your Personal Information We use your personal information for a number of reasons, including:

To provide you with FEIM’s products and services, including to process your subscription application and/other forms; provide information you have requested; create, manage and administer your shares, interests or account; maintain registers; and communicate with you about your investments;

To comply with our legal and regulatory obligations including but not limited to applicable know-your-customer requirements, tax, anti-money laundering, fraud, sanctions and counter-terrorist-financing legislation. Personal information (including financial information) may be shared with applicable regulators, government bodies and relevant tax authorities. They in turn may exchange information (including personal information and financial information) with foreign tax authorities (including foreign tax authorities located outside the European Economic Area);

To operate and facilitate our business and services to you; undertake business management, planning, statistical analysis, market research and marketing activities; administer and maintain our core records; protect FEIM’s rights and interests; ensure the security of our assets, systems and networks; prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services; and enforce our terms and conditions;

Where necessary for the establishment, exercise or defense of legal claims; and

For any other specific purposes where you have given specific consent.

We will keep your data for as long as you are a client or shareholder and afterwards in accordance with our legal and regulatory obligations.

Categories of Affiliates to Whom We May Disclose Personal Information We may share personal information about you with affiliates. Our affiliates do business under names that include but are not limited to First Eagle Investments; First Eagle Global Fund, First Eagle Overseas Fund, First Eagle U.S. Fund, First Eagle Gold Fund, First Eagle Global Income Builder Fund, First Eagle High Yield Municipal Fund (formerly named First Eagle High Income Fund), First Eagle Short Duration High Yield Municipal Fund, First Eagle Core Plus Municipal Fund, First Eagle Rising Dividend Fund (formerly named First Eagle Fund of America), First Eagle Small Cap Opportunity Fund, First Eagle Global Real Assets Fund and First Eagle U.S. Smid Cap Opportunity Fund, separate portfolios of First Eagle Funds, an open-end investment management company; four exchangetraded funds: First Eagle Global Equity ETF, First Eagle Overseas Equity ETF, First Eagle US Equity ETF and First Eagle Mid Cap Equity ETF; three closed-end interval funds: First Eagle Credit Opportunities Fund, First Eagle Real Estate Debt Fund and First Eagle Tactical Municipal Opportunities Fund; First Eagle Small Cap Opportunity CIT and First Eagle Global Equity CIT, each a collective investment trust; First Eagle Funds (Ireland) ICAV; First Eagle Amundi Sub-Funds (Luxembourg) SICAV; the Diamond Hill Funds; as well as a continuously offered closed-end management investment company that elects to be regulated as a business development company, First Eagle Private Credit Fund, (each a “Trust” and, combined, the “Trusts” and each of the preceding funds a “Fund” and combined the “Funds”), together with any additional portfolios that may be added to the Trusts from time to time, as well as First Eagle Investment Management, LLC, First Eagle Investment Management, Ltd, First Eagle Investment Management GmbH, First Eagle Separate Account Management, LLC, Diamond Hill Capital Management, LLC, First Eagle Alternative Credit, LLC, Napier Park Global Capital (US) LP, Napier Park Global Capital Ltd., Napier Park Global Capital GmBH and Regatta Loan Management LLC, First Eagle Holdings, Inc., FEF Distributors, LLC and First Eagle Investments Sarl.

You May Limit Marketing Solicitations by Choosing to Opt Out We offer you the right to opt out from many types of marketing by our affiliates based on your personal information that we collect and share in accordance with this privacy policy. To limit those marketing solicitations, investors in the Funds may call 800-3342143, indicating the desire not to receive marketing from our affiliates. Investors in private funds or separate accounts managed by FEIM may call 800-800-9006. Should you choose to opt out, your choice will remain in our records until you notify us otherwise, although we may choose to contact you in the future to modify your preference.

When We May Disclose Your Personal Information to Unaffiliated Third Parties We may share your personal information collected, as described above, with unaffiliated third parties, including:

At your request;

When you authorize us to process or service a transaction or product (unaffiliated third parties in this instance may include service providers such as brokers and custodians, the Funds’ distributors, registrars and transfer agents for shareholder transactions, and other parties providing individual shareholder servicing, accounting and recordkeeping services);

With companies that perform sales and marketing services on our behalf with whom we have agreements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them;

In connection with a corporate transaction such as a merger, joint venture, financing, reorganizing, or sale of company assets, for example, if one or more of the Funds are sold or transferred to a third party, or if there is a change in any advisor to a Fund, we may disclose your information to those third parties; or

When required by law to disclose such information to appropriate authorities.

We do not otherwise provide information about you to outside firms, organizations or individuals, except to our attorneys, accountants and auditors, and as permitted by law.

What We Do to Protect Your Personal Information We maintain physical, electronic and procedural safeguards intended to protect consumer information. We permit only authorized individuals, who are trained in the proper handling of individual personal information and need to access this information to do their job, to have access to this information. Despite the security measures that we have put in place, no such measures can guarantee security or protect against unauthorized activity.

What We do with Personal Information about Our Former Customers If you decide to discontinue doing business with us, FEIM will continue to adhere to this privacy policy with respect to the information we have in our possession about you and your account following the termination of our relationship.

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