Foresight Group

Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). Foresight is an investment manager in real assets and capital for growth based in London, United Kingdom. Established in 1984, Foresight has three operational divisions: Real Assets, Private Equity and Capital Management1. The Real Assets strategy is focused on energy transition which includes renewable generation, grid infrastructure and natural capital, social, transport and digital infrastructure. The Private Equity division is focused on private equity, venture capital and private credit investment principally in the UK to small and medium sized enterprises in a wide range of sectors including telecommunications, media and technology (TMT), healthcare and business services. The Capital Management division is focused on investing in listed securities within the infrastructure, renewable energy, energy transition, real estate, natural capital and sustainable equity sectors. Foresight and its affiliates provide discretionary investment advisory services to their clients, which consist of private investment funds and institutional investors. Foresight serves as investment adviser for, and provides discretionary investment advisory services to, (i) pooled investment vehicles operating as private investment funds, including open-ended funds, closed-ended funds, and funds in which affiliates or employees of Foresight invest alongside such other private investment funds and (ii) investment funds registered or authorized in foreign jurisdictions for retail investors on a wholesale basis (collectively, the “Funds”). Foresight also provides sub-advisory portfolio management services to a private fund and a mutual fund. In addition, Foresight provides nondiscretionary investment advisory services to individually managed accounts (the “Managed Accounts”) for institutional investors. Foresight generally serves as investment manager for Managed Accounts or arrangements formed to offer investment solutions for institutional investors. The Funds and the third-party investors in or owners of the Managed Accounts shall be referred to herein as the “Clients”. For the avoidance of doubt, in the United States, Foresight only provides advisory services to “qualifying private funds” (as that term is defined in Section 203(m) of the Investment Advisers Act of 1940 (the “Advisers Act”) and managed accounts for qualified clients (as that term is defined in Rule 205(a)(1) of the Advisers Act). Foresight is 100% owned by Foresight Holdco 2 Limited, an English limited company, which is 100% owned by Foresight Group CI Limited, a Guernsey-based limited company. Foresight Group CI Limited is 100% owned by Foresight Group Holdings Limited, a Guernsey-based limited company. Foresight Group Holdings Limited is listed on the London Stock Exchange and its largest shareholder is Beau Port Investments Limited, a Guernsey-

1 Foresight Group Holdings Limited, ultimate parent company of Foresight Group LLP, announced to the London Stock Exchange

on 11 June that it has entered an agreement to sell its public markets investment division, Foresight Capital Management to Guinness Global Investors with completion expected in the third quarter of 2026. Link: https://www.londonstockexchange.com/news-article/FSG/sale-of-public-markets-division-to-ggi/17634004

based limited company holding 28.13% of its shares2, of which Bernard Fairman is the beneficial owner and founder of the company. No other shareholder holds more than 10% holdings in Foresight Group Holdings Limited as of June 25th, 2026. For more information on the ownership information of Foresight, please see Foresight’s Form ADV Part 1, Schedule A and B. On 11 June 2026, Foresight Group Holdings Limited, the ultimate parent company of Foresight, announced to the London Stock Exchange that it had entered into an agreement to sell its public markets investment division, Foresight Capital Management, to Guinness Global Investors. Completion is anticipated in the third quarter of 2026, and upon completion the funds managed by the Foresight Capital Management division, including the Cromwell Foresight Global Infrastructure Fund (the “Mutual Fund”), are expected to transfer to Guinness Global Investors. Following completion of the transaction, Foresight will cease to manage the public markets funds, including the Mutual Fund, and the disclosures in this Brochure relating to the Foresight Capital Management division and the Mutual Fund will be updated by way of an other-than-annual amendment to reflect the change. The descriptions of Foresight’s public markets business and the Mutual Fund set out in this Brochure reflect Foresight’s business as conducted as of the date of this Brochure, prior to completion of the transaction. B. Describe the types of advisory services you offer. If you hold yourself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. Foresight operates two lines of business – private markets and public markets. Foresight’s private markets business provides discretionary and non-discretionary investment advisory services with respect to investments in private companies (“private equity”) and infrastructure investments to Clients. Foresight’s investment advisory services to Clients consist of identifying and evaluating investment opportunities, recommending and negotiating the terms of purchase and sale of private equity and infrastructure investments. Investments are made globally. Foresight’s public markets business consists of providing discretionary investment advice to Clients related to investments in securities of public traded infrastructure and real assets companies. C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. Investment objectives for all Clients are described in the private placement memorandum, limited partnership agreement, investment management/ advisory agreement, operating

agreement, subscription agreement, side letter agreements and other governing documents (collectively, “Governing Documents”). Foresight allows Managed Account Clients to customize their investments, upon their request, by imposing reasonable investment restrictions on certain industries or sectors. In these cases, the Client will provide Foresight with written instructions. These requests are typically received at account inception and memorialized in the negotiated investment advisory agreement. Relationships with Managed Account Clients are on an advisory basis whereby investment decisions are principally made by the Client itself. Foresight does not tailor its advisory services to the individual needs of investors in Funds.

2 Issued share capital as of 31 March 2026.

D. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Foresight does not participate in wrap fee programs. E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a nondiscretionary basis. Disclose the date “as of” which you calculated the amounts. As of 31 March 2026, the Firm managed approximately $10,061,148,450 in regulatory assets under management, where $8,334,248,113 are managed on a discretionary basis and $1,726,900,337 on a non-discretionary basis3.

Describe how you are compensated for your advisory services. Provide your fee schedule. Disclose whether the fees are negotiable. Foresight is compensated for its advisory services with a management fee (the “Management Fee”) and a performance based carried interest allocation (“Carried Interest”).

3 These numbers reflect adjustments for investments of the Cromwell fund in other Foresight products.

Management Fees For its investment advisory services provided to Funds, Foresight and/or an affiliated entity, such as a Fund’s general partner, typically receive a management fee4 calculated either as a percentage of the net assets or invested capital pursuant to the Offering and/or Governing Documents, which are provided to prospective investors. For its investment advisory services provided to Managed Accounts, Foresight typically receives a management fee calculated either as a percentage of the net assets or invested capital as disclosed in the relevant investment management agreement to which the investing entity/person is a party. For the Cromwell Foresight Global Infrastructure Fund5, with respect to sub- advisory services provided to investment companies, the firm receives a percentage of the management fee outlined under the Fees and Expenses of the Fund section in the prospectus. Offering and/or governing documents, including the investment management agreement (or such other agreement that govern Managed Account arrangements) in the case of a Managed Account, when applicable, will be referred to herein as the “Offering and/or Governing Documents”. Notwithstanding Item 5 and Item 6 below, a Client’s Offering and/or Governing Documents may provide for a fee structure pursuant to which Foresight is compensated on the basis of entirely different criteria, metrics, or circumstances than those described. While Foresight’s policy is that its fees are not negotiable, Foresight reserves the right to waive or reduce its fees for certain investors or Clients. As different Fund governing documents may provide a different level of Management Fee, the existence of differing Management Fees for Clients investing side-by-side may create a conflict of interest for Foresight and its affiliates with respect to the allocation of investment opportunities. Foresight’s investment allocation policy (see Item 16 – Investment Discretion) addresses this potential conflict of interest.

4 For certain funds, the Fund general partner receives a Priority Profit Share from the Fund and Foresight invoices

the general partner for a management fee of an equal amount. 5 Formerly Cromwell Foresight Global Sustainable Infrastructure Fund

Management Fee Offset Generally, the management fee payable by a Client to Foresight will be reduced by all or a portion (as disclosed in the Offering and/or Governing Documents of the relevant Client) of such Client’s allocable share of any origination or other transaction fees (including commitment, closing, amendment, waiver, directors’, topping, organizational, break-up, monitoring, exit or other disposal fees, or other similar fees in respect of such Client’s purchase, monitoring or disposal of an investment or prospective investment by such Client (collectively, “Other Fees”)) received by Foresight for transactions effected for such Client’s account. B. Describe whether you deduct fees from clients’ assets or bill clients for fees incurred. If clients may select either method, disclose this fact. Explain how often you bill clients or deduct your fees. Management Fees generally are payable monthly or quarterly in advance subject to the applicable Offering and/or Governing Documents. Foresight may elect to defer payment of all or part of the management fee payable by a Client. Management Fees payable by a Client are generally deducted from the Fund’s assets and may be deducted from the Client’s assets as/ if permitted by the applicable Offering and/or Governing Documents. Where that’s not the case, Clients will be invoiced for such Management Fees. C. Describe any other types of fees or expenses clients may pay in connection with your advisory services, such as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage and other transaction costs, and direct clients to the section(s) of your Brochure that discuss brokerage. Subject to the applicable Offering and/or Governing Documents, each Client will generally be responsible for the organizational expenses, including, without limitation, legal, accounting, director’s fees, filing, capital raising, marketing, advertising, secretarial and wholesaling and other organizational expenses of the Client, as well as organizational expenses of any related investment vehicles and any parallel funds. The Offering and/or Governing Documents of each Client provide a description of any additional fees and expenses for which such Client may be responsible in addition to the Management Fees and any performance-based allocations or fees (see Item 6 – Performance-Based Fees and Side-By-Side Management below). Portfolio Company Remuneration Foresight and its affiliates may perform management, advisory, transaction-related, financial advisory and other services for, and receive transaction and monitoring fees from,

affiliates and portfolio companies to the extent that it is described in more detail in each Fund’s Governing Documents. In consideration for such services, Foresight may receive directors’ fees and arrangement fees monitoring fees and breakup fees, as mentioned above. These fees are in addition to the Management Fees. Subject to the Fund’s Governing Documents, Foresight can reduce the amount of Management Fees paid in connection with the receipt of such fees in the manner as set forth in the Offering and/or Governing Documents. Additionally, as mentioned above, a portfolio company will, on occasion, reimburse Foresight for expenses (including without limitation travel expenses) incurred by Foresight in connection with its performance of services for such portfolio company, and such reimbursements are not subject to the offset against Management Fees. Client Account Expenses In addition to the Management Fee, Clients pay all other costs, expenses and obligations relating to such Fund’s or Managed Account’s activities, investments and business (to the extent not borne or reimbursed by a portfolio company and which expenses differ across Client accounts), including without limitation: (i) all costs, expenses, liabilities and obligations attributable to acquiring, holding and disposing of investments and short term investments (including, without limitation, interest on money borrowed); (ii) legal, accounting, auditing, insurance, travel, litigation and indemnification costs and expenses, judgments and settlements, consulting, finders’, financing, appraisal, filing and similar fees and expenses (including, without limitation, expenses associated with the preparation of the financial statements including the cost of any third party administrator thereto, tax returns and Schedule K-1s); (iii) expenses of any advisory committee; (iv) all out-of-pocket fees and expenses incurred by the Funds or Managed Accounts, Foresight or any other management person relating to investment and disposition opportunities for the Funds or Managed Accounts not consummated (including, without limitation, legal, accounting, auditing, insurance, travel, consulting, finders’, financing, appraisal, filing, printing, real estate title and similar fees and expenses); (v) all out-of-pocket fees and expenses incurred by the Funds or the Managed Accounts, Foresight or any other management person in connection with any conference or meeting with investor(s); (vi) the Management Fee; (vii) any taxes, fees and other governmental charges levied against the Client; (viii) costs and expenses that are classified as extraordinary expenses under UK GAAP; and (ix) any organizational expenses, including any costs and expenses of placement agents or other finders, but not including (A) excess organizational expenses, (B) placement fees and (C) any costs or expenses incurred in the registration of Foresight as an investment adviser under Advisers Act. Third-Party Professional Expenses Foresight often requires portfolio companies, at their expense, to engage and retain advisers, consultants and other professional service providers who are not employees or affiliates of Foresight and who, from time to time, receive payments from,

or fee allocations with respect to, portfolio companies and/or other entities. These professionals also incur expenses while working with Foresight portfolio companies, and such expenses are paid by the relevant portfolio company or the relevant Client (generally in the case of a deal that is not consummated). Similarly, these professionals are often appointed to sit on a Foresight portfolio company board of directors and are reimbursed for the cost of their travel to and from such portfolio company board meetings and for other portfolio company business; such expenses are generally borne by the relevant portfolio company which the third-party professional is advising but may also be paid by the relevant Client (generally in the case of a deal that is not consummated). In such circumstances, such amounts will not be deemed paid to or received by Foresight. In the event a third-party professional provides work for a portfolio company in addition to board service, any such fees are paid by the portfolio company and are not offset against Management Fees. Co-Investment Expenses Foresight may form investment vehicles to facilitate investments alongside a Client in connection with the consummation of a Client transaction (“Co-Investment Funds”). In the event a Co-Investment Fund is created, Foresight reserves the right to charge investors in such Co-Investment Fund with all expenses related to the Co-Investment Fund’s organization and formation and other expenses incurred in relation to the co- investment opportunity. Foresight also reserves the right to charge the Co-Investment Fund’s investors with the pro-rata portion of expenses incurred in making (or in the case of an aborted or failed investment, not making) an investment. Allocation of Fees and Expenses In good faith and in its fair and reasonable discretion, Foresight determines on a case-bycase basis whether an expense should be borne by Foresight, a Client, multiple Clients, a Co-Investment Fund or an investment. To the extent that the Governing Documents do not expressly provide for a method of allocation or to the extent that, in infrequent circumstances that an invoice does not relate to a specific Client, Foresight will typically allocate common expenses among multiple Clients on a pro rata basis unless another method is more equitable. Where one or more Clients to which an expense would otherwise be allocable are not permitted to be so allocated based on the applicable Governing Documents, the portion of the expense attributable to such Client(s) will be borne by Foresight. Additional Fees and Expenses Clients will pay certain out-of-pocket fees and expenses pursuant to such Client’s Offering and/or Governing Documents, including brokerage fees, brokerage commissions and all other brokerage transaction costs, stock borrowing and lending fees, interest on cash balances, custodial fees, reasonable transaction legal expenses, regulatory fees or taxes

payable in respect of the applicable Account, professional expenses (including fees in connection with the use of proxy voting services) and any other fees and expenses related to the trading and investment activity of the applicable Client account or Fund as determined by Foresight. Please see Item 12 – Brokerage Practices for more information. D. If your clients either may or must pay your fees in advance, disclose this fact. Explain how a client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period. Explain how you will determine the amount of the refund. Foresight receives its Management Fees in advance. In the event a Client has pre-paid Foresight’s advisory fees and, pursuant to the Client’s Offering and/or Governing Documents, is due a refund Foresight will return the fees on a pro-rata basis and subject to any notice period. If Foresight is terminated as manager for misconduct, all advance paid fees will be returned. For the majority of its Clients, investment is made on a no redemption basis, and the transfer of management away from Foresight is restricted within the governing documents of the Fund. Therefore, the likelihood of termination and thereby a fee refund, is very low. E. If you or any of your supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact and respond to Items 5.E.1, 5.E.2, 5.E.3 and 5.E.4. Neither Foresight nor any employee of Foresight accepts, or otherwise directly receives, any compensation for the sale of securities or other investment products.

Describe the methods of analysis and investment strategies you use in formulating investment advice or managing assets.

Foresight uses a range of methods to identify, analyze and assess potential and existing investment opportunities. Generally, analytical methods used by the investment teams can include gain/loss forecast models, cash-flow models, other financial modeling and simulation, risk sensitivity analysis, fundamental, technical, and cyclical analyses. Foresight often employs specialist consultants to evaluate resource forecasts, management teams and commercial relationships as part of its due diligence for each new investment. Principal Investment Strategies for Cromwell Foresight Global Infrastructure Fund (Mutual Fund): Under normal circumstances, the Mutual Fund invests at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of sustainable infrastructure

companies. The Mutual Fund will invest directly in the shares of companies (including listed investment trusts, real estate investment trusts (“REITs”), ETFs or units of master limited partnerships (“MLPs”) that, in each case, invest in infrastructure companies and are publiclytraded (listed) on stock exchanges in developed markets, meaning North America, Western Europe and Asia Pacific (specifically Australia, New Zealand, Singapore, Japan, Hong Kong); and that own and operate real infrastructure or sustainable assets anywhere in the world. Such companies’ revenue streams are typically directly or indirectly supported by long-term government or public sector contracts and government supported initiatives. B.

For each significant investment strategy or method of analysis you use, explain the material risks involved. If the method of analysis or strategy involves significant or unusual risks, discuss these risks in detail. If your primary strategy involves frequent trading of securities, explain how frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes.

General and Private Investment Risks As with any type of investing, a certain degree of risk can be associated with private investments. As a result, Clients should be prepared to bear the following potential risks: •

Because of the nature of investment opportunities on which Foresight advises, the anticipated or targeted returns cannot be guaranteed.

•

There can be no assurance that the Clients’ investment objectives will be achieved. The possibility of partial or total loss of capital will exist and Clients and their investors must be prepared to bear capital losses that could result from investments.

•

Potential investors in a Fund Client should carefully consider the risks of Fund Clients’ investments disclosed in the applicable Offering and/or Governing documents.

Other risks of investing with Foresight include, but are not limited to, the following: No Assurance of Investment Return Foresight cannot provide assurance that it will be able to choose, make, and realize anticipated or targeted returns in any investment opportunity. Foresight uses extensive research, forecasting analyses and modeling to identify in advance and mitigate any potential performance risks; however, the returns can be unpredictable and ultimately there can be no assurance that Foresight’s investment recommendations will be able to generate returns or that the returns will be commensurate with the risks of investing. During due diligence, Foresight will analyze the track records and historical performance of potential investments, as well as the underlying assumptions and key drivers of

success to maximize Clients’ and their investors’ probability of achieving targeted returns. Reliance on Foresight Foresight has exclusive responsibility for Clients’ activities, and, other than as may be set forth herein and in the Offering and/or Governing documents of Clients, investors are not able to make investment or any other decisions concerning the management of a Client’s account. Investors in a Fund generally have no rights or powers to take part in the business and affairs of such Fund or make investment decisions and, other than what is provided in the investor reports, will not receive all the financial information that is generally available to Foresight with respect to the companies, assets, projects, and/or businesses in which a Fund invests. Additionally, Foresight may be restricted from disclosing or may determine it is appropriate not to disclose to investors in a Fund material non-public information regarding one or more specific investments, including certain investments in which a Fund may participate alongside other Funds, which may result in such investors not receiving certain material non-public information regarding a Fund and/or one or more of its investments under certain circumstances. Furthermore, in the event certain Foresight investment professionals acquire confidential or material, non-public information concerning an entity in which a Fund has invested in or proposes to invest in, the possession of such information may limit the ability of the applicable Fund to buy or sell particular securities of such entity on behalf of such Client, thereby limiting the investment opportunities or exit strategies available thereto. Foresight will generally have sole discretion in structuring, negotiating and purchasing, financing and eventually divesting investments on behalf of Clients (subject to specified exceptions). Accordingly, no person should invest unless such person is willing to entrust all aspects of the management to Foresight. Asset Illiquidity and Valuations – Private Markets Investments in unlisted companies may be difficult or impossible to realise. In general, a Fund’s private markets investments will be illiquid unless and until they are sold or become publicly listed, and the ability of the Client to realise capital gains from such investments will therefore be subject to any number of uncontrollable and unpredictable factors. It may be difficult from time to time for that Fund to realise, sell or dispose of an investment at an attractive price or at the appropriate time or in response to changing market conditions, or the Fund may otherwise be unable to complete a favourable exit strategy. Although the Fund’s investments may generate some current income, the return of capital and the realisation of gains, if any, will generally occur only upon the partial or complete disposal of an investment. Certain investments held by a Fund may be in securities that are or become publicly traded. Such investments may involve economic, political, interest rate and other risks, any of which could result in an adverse change in the market price. In addition, in some cases

the Fund may be prohibited by contract or other limitations from selling such securities for a period of time so that the Fund is unable to take advantage of favourable market prices. As most of a Fund’s investments are highly illiquid2 and most likely not be publicly-traded or readily marketable, Foresight will therefore not have access to readily ascertainable market prices when establishing valuations of the investments and Foresight and the Fund can provide no assurance that any given investment could be sold at the fair value ascribed to such investment in connection with the valuation thereof. Actual realized returns will depend on various factors, including future operating results, the value of the assets and market conditions at the time of disposition, any related transaction costs and the timing and manner of sale. Investing in Private Companies Investments in unlisted, private companies are intrinsically riskier than investments in listed companies, as private companies may be smaller, more vulnerable to changes in markets, technology and circumstances and be dependent on the skills and commitment of a small management team. Private companies are not subject to the same disclosure and reporting requirements that are generally applicable to public companies. There can be no guarantee that the small number of individuals on which a private company relies will continue to be employed by such company once a Fund has invested in it. Although Foresight will monitor the performance of each investment, the Fund will necessarily rely on the management teams of the individual portfolio companies in which the Fund invests for day-to-day management. Highly Competitive Market for Investment Opportunities The activity of identifying, completing and realizing attractive investments to be pursued as part of a Client’s investment program is highly competitive and involves a high degree of uncertainty. The availability of investment opportunities is generally subject to market conditions, as well as the prevailing regulatory and political climate. In particular, in light of changes in such conditions, including changes in the availability and cost of debt financing, certain types of investment opportunities may not be available to Clients on terms that are as attractive as the terms on which opportunities were available previously to Foresight. Clients compete for investment opportunities with a significant number of other investors, including, without limitation, other investment partnerships and corporations, business development companies, sovereign wealth funds, domestic and international public pension plans, the public debt and equity markets, individuals, financial institutions and other financial investors investing directly or through affiliates. Furthermore, over the past several years, an ever-increasing number of tactical opportunity, special situations and related investment funds have been formed and many

This is only applicable to the private markets business strategy.

such existing funds have grown substantially in size, including private equity funds investing in stressed, distressed, special situations, private equity and similar strategies, resulting in an unprecedented amount of capital available for private equity investment. Additional funds with similar objectives will likely be formed in the future by other unrelated parties. Some of these competitors may have more relevant experience, greater financial, technical, marketing and other resources, more personnel, higher risk tolerances, different risk assessments, lower return thresholds, lower cost of capital, synergistic cost savings and access to funding sources unavailable to Foresight and Foresight’s Clients. Consequently, competition for appropriate investment opportunities has increased, and it is possible that competition for appropriate investment opportunities may continue to increase, thus reducing the number of investment opportunities available to Clients and adversely affecting the terms, including without limitation, pricing, upon which investments can be made. There can be no assurance that Clients will be able to locate, consummate and exit investments that satisfy Clients’ target equity size range, rate of return objectives or realize upon their values or that they will be able to invest fully their committed capital. To the extent that Clients encounter competition for investments, returns to investors may decrease. In addition, Foresight’s investment strategies in certain sectors may depend on its ability to enter into satisfactory relationships with joint venture partners, operating executives or senior advisors. There can be no assurance that Foresight’s current relationship with any such partner, operating executive or senior advisor will continue (whether on currently applicable terms or otherwise) with respect to Clients or that any relationship with other such persons will be able to be established in the future as desired with respect to any sector or geographic market and on terms favorable to Clients. Legal and Regulatory Risks Legal and regulatory changes could occur during the time of Clients’ investment with Foresight that may adversely affect the Client, its portfolio investments or its partners. For example, a Client expects to make investments in a number of different sectors, some of which are or may become subject to regulation by one or more countries regulatory authorities, U.S. federal agencies and/or by various agencies of the states, localities and counties in which they operate. New and existing regulations, changing regulatory schemes and the costs and burdens of regulatory compliance all may have a material, negative impact on the performance of investments that operate in these industries. Foresight cannot predict whether new legislation, regulation or regulatory interpretations governing those industries will be enacted or adopted by legislative bodies or governmental agencies, nor can Foresight predict what effect such legislation, regulation or regulatory interpretation might have. There can be no assurance that new legislation, regulation or regulatory interpretation, including changes to existing laws, regulations and regulatory interpretations, will not have a

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Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. In the United States, Foresight’s advisory services are limited to providing investment advice to “qualifying private funds” as that term is defined in Section 203(m) of the Advisers Act, subadvisory services to mutual funds, Managed Accounts, accredited investors and qualified purchasers. The Clients and investors in Foresight’s Funds and Managed Accounts are mainly institutional investors and high-net worth individual investors capable of understanding the risks of their investments, including the following types of persons: • • • • •

Banks and other financial institutions Insurance companies Investment companies Public and private retirement and pension plans Public and private profit sharing plans

• • • • • • • •

Trusts and estates Charitable organizations State and municipal government agencies Sovereign wealth funds Hedge funds and funds of funds High net worth individuals Corporations Business entities other than those listed above

Foresight (a) must have a reasonable belief that potential investors invited to participate in Funds or other products meet certain eligibility requirements and (b) in each case must satisfy certain compliance procedures (including anti-money laundering procedures), prior to accepting any subscription or investment amount. In addition, any separate maintenance or other investment-related provisions (e.g., minimum account sizes, minimum fee amounts, etc.) will be provided in the Offering and/or Governing Documents of each Fund or Managed Account, which are made available to each potential investor prior to investment. Foresight provides investment advisory services to investment vehicles, including but not limited to, Open Ended Investment Companies (“OEICs”), Venture Capital Trusts (“VCTs”), Enterprise Investment Schemes (“EIS”) and other UK government sanctioned inheritance and business property tax relief funds. These investment vehicles are not offered or generally sold by Foresight directly to investors but may be offered and sold to retail investors through appropriately qualified financial intermediaries. It also provides investment advisory and/or management services to pooled investment funds in limited partnership structures to institutional clients and UK investment trusts.

If you or any of your supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client (such as a Client that is a hedge fund or other pooled investment vehicle) – disclose this fact. If you or any of your supervised persons manage both accounts that are charged a performance- based fee and accounts that are charged another type of fee, such as an hourly or flat fee or an asset-based fee, disclose this fact. Explain the conflicts of interest that you or your supervised persons face by managing these accounts at the same time, including that you or your supervised persons have an incentive to favor accounts for which you or your supervised persons receive a performance-based fee, and describe generally how you address these conflicts. In addition to the Management Fees and other fees described in Item 5 – Fees and Compensation above, Foresight, in accordance with the relevant Offering and/or Governing

Documents of each Client, may receive a performance-based allocation or fee, subject in certain, but not all, cases to a loss carry forward provision or claw-back provision. Performancebased allocations or fees may be based on either realized or unrealized profits attributable to a Client. All performance-based compensation arrangements are more fully disclosed in the relevant Offering and/or Governing Documents of each Client. The existence of a performance-based allocation or fee may incentivize Foresight to manage a Client’s assets in a manner that is more aggressive than it would in the absence of such allocation or fee. Further, the existence of differing performance-based allocations or fees for Clients investing side-by-side could create an incentive to favour client accounts where Foresight receives a performance-fee over client accounts that do not pay a performance fee and client accounts that pay a higher performance fee over client accounts that pay a lower performance fee. Key conflicts of interest are disclosed to Clients in each Client’s Offering and/or Governing Documents to ensure Clients and investors are aware of Foresight’s investment activities and related with such activities. Foresight also has an investment allocation policy (see Item 16 – Investment Discretion) within each business division, that addresses the conflict of interest related to allocation of investment opportunities amongst Clients. In addition, Foresight and/or its affiliates make monetary commitments to each of the Foresight Funds effectively investing alongside investors and aligning Foresight’s interests with Fund investors. Finally, Foresight has designed and implemented a Remuneration Policy designed to promote sound and effective risk management.

If you or any of your management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, disclose this fact. Neither Foresight nor any of its management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. B. If you or any of your management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities, disclose this fact. Neither Foresight nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing. C. Describe any relationship or arrangement that is material to your advisory business or to your clients that you or any of your management persons have with

any related person listed below. Identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how you address it. 1. Broker-dealer, municipal securities dealer, or government securities dealer or broker 2. Investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) 3. Other investment adviser or financial planner 4. Futures commission merchant, commodity pool operator, or commodity trading advisor 5. Banking or thrift institution 6. Accountant or accounting firm 7. Lawyer or law firm 8. Insurance company or agency 9. Pension consultant 10. Real estate broker or dealer 11. Sponsor or syndicator of limited partnerships. Foresight is affiliated with multiple legal entities set up primarily for legal, accounting and regulatory purposes. Foresight provides personnel and other services to these and other Foresight entities. For additional information on the financial industry affiliations see Item 7.A of Form ADV Part 1. Foresight, either directly or through its one or more affiliates, may act as general partner or managing member or investment manager for one or more entities formed in connection with specific investments. In such capacity, Foresight may be entitled to certain contractual economic, governance, reporting and other rights. For example, Foresight (directly or through such affiliates) may receive a portion of the fees and distributions (including "carry") payable to such general partner. The interests of these general partner or managing member relationships may conflict with the interest of Clients. The partners or employees of Foresight serve on the boards of directors of portfolio companies in which their clients invest. Serving in such capacity could give rise to conflicts to the extent that an employee’s fiduciary duties to a portfolio company as a director conflicts with the interest of the Client. In certain circumstances, for example in situations involving bankruptcy or near-insolvency of a portfolio company, actions that would be in the best interest of the portfolio company may not be in the best interests of a Client (or Clients) and vice versa. Accordingly, in these situations, there will be conflicts of interest between such individual’s duties as an officer or employee of Foresight and such individual’s duties as a director of the portfolio company. Conflicts can also arise in cases

where a Client makes an investment in a different class of securities relative to any other Client that has an interest in the same portfolio company. The officers, directors, members, managers, and employees of Foresight can trade in securities for their own accounts, subject to restrictions and reporting requirements as required by law or otherwise determined from time to time by Foresight. To the extent officers, directors, members, managers, and employees of Foresight invest in the same securities as a Client, such transactions introduce a potential conflict of interest between the interests of such Client and the interests of Foresight or its related persons. For example, a potential conflict of interest could arise in that the interested related person could benefit from such a purchase or sale of the applicable securities by such Client. From time to time, Foresight receives training, information, promotional material, meals, gifts, entertainment or prize drawings from vendors and others with whom it does business or to whom it makes referrals. At no time will Foresight accept any benefits, gifts, entertainment or other arrangements that are conditioned on directing individual client transactions to a specific security, product or provider. Foresight has strict internal procedures around the acceptance and giving of gifts, and the provision of entertainment which involved disclosure of the activity and provider/recipient. Similarly, Foresight employees have in the past, and expect in the future, to speak at or attend conferences and programs for potential investors interested in investing in private funds and other events that are sponsored by various investment bankers, broker-dealers or others through such capital introduction and other events, prospective investors have the opportunity to meet with Foresight. D. If you recommend or select other investment advisers for your clients and you receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or if you have other business relationships with those advisers that create a material conflict of interest, describe these practices and discuss the material conflicts of interest these practices create and how you address them. Neither Foresight nor any of its management persons recommend or select other investment advisers for Clients. Foresight may select or recommend financial advisors to advise in various capacities. Foresight does not receive compensation from such appointments/recommendations, and selections are made based on various factors including inter alia each firm's professional qualifications to undertake such engagements. If Foresight were to encounter a circumstance in which it believed a potential or actual conflict of interest existed when making such decisions, Foresight would disclose it to the Clients in advance of proceeding with the engagement.

Trading

A. If you are an SEC-registered adviser, briefly describe your Code of Ethics adopted pursuant to SEC Rule 204A-1 or similar state rules. Explain that you will provide a copy of your Code of Ethics to any client or prospective client upon request. As fiduciaries, Foresight and its employees are required to conduct personal securities transactions in a manner that prioritize clients’ interest in client eligible investments. Foresight has adopted a Code of Ethics pursuant to Rule 204A-1 of the Advisers Act which sets forth standards of conduct that are expected of Foresight’s principals and supervised persons and addresses conflicts that can arise from personal trading. The Code of Ethics requires all supervised persons to place Client interests ahead of Foresight’s interests, to avoid taking advantage of his or her position and to maintain full compliance with the federal securities laws. Because of the nature of Foresight’s private investments, Foresight expects there to be only limited instances of employees having access to material non-public information with respect to its Private Equity and Real Assets Business. There are certain instances where an investment team, including the Foresight Capital Management team that manage the Mutual Fund are exposed to material non-public information as a result of a market sounding. The Firm maintains an Anti-Market Abuse Policy and a specific Foresight Capital Management gatekeeping process is in place to ensure that appropriate restrictions are in place to prevent trading on that information. Regardless, Foresight’s Code of Ethics requires all supervised persons to report their personal securities transactions and comply with the policies and procedures reasonably designed to prevent the misuse of, or trading upon, material non-public information. At least once a year, each Foresight supervised person is required to acknowledge the Code of Ethics and agree to be bound by it. Supervised persons of Foresight who violate the Code of Ethics will be subject to disciplinary actions, including, but not limited to, censure, suspension or dismissal. Supervised persons are also required to promptly report any violations of the Code of Ethics of which they become aware. Foresight will provide a copy of its Code of Ethics to any existing Client upon request to Jonathan Parsons, the Chief Compliance Officer, at +44 (0)20 3667 8100 or by email to jparsons@foresightgroup.eu. B. If you or a related person recommends to clients, or buys or sells for client accounts, securities in which you or a related person has a material financial interest, describe your practice and discuss the conflicts of interest it presents. Describe generally how you address conflicts that arise. Participation or Interest in Client Transactions Principals and employees of Foresight and its affiliates are permitted to directly or indirectly

own an interest in one or more Funds, including certain co-invest vehicles. The extent to which Principals and employees are permitted to participate in co-investment vehicles depends on potential conflicts of interest considerations and their seniority at Foresight. The Governing Documents of a Fund may also require it. To the extent that co-invest vehicles exist, such vehicles must invest in the same projects and portfolio companies as a Client. Co-invest opportunities may also be presented to certain affiliates of Foresight, as well as third party investors and other persons, and such co-investments may be effected through co-invest vehicles or directly in a particular project or portfolio company. C. If you or a related person invests in the same securities (or related securities, e.g., warrants, options or futures) that you or a related person recommends to clients, describe your practice and discuss the conflicts of interest this presents and generally how you address the conflicts that arise in connection with personal trading. Personal Trading The personal trading policy for all Foresight supervised persons is set forth in Foresight’s Personal Account Dealing Policy and is acknowledged as received and understood by each supervised person. Foresight’s personal trading policy is designed to ensure that no Client is disadvantaged by the transactions executed by any supervised person and that supervised persons in no respect misappropriate any benefit properly belonging to a Client. Foresight supervised persons are prohibited from trading, either personally or on behalf of others, in securities while in possession of material non-public information regarding these securities or communicating material non-public information to others. The Code of Ethics and Personal Account Dealing Policy establishes guidelines for personal trading requirements, insider trading and reporting of personal securities transactions, including certain pre-clearance and reporting obligations. Foresight maintains a restricted list regarding issuers about which it has material non-public information. Pre-clearance is required by supervised persons for certain personal securities transactions, including transactions in securities Foresight has an interest in, has (or may have) a business relationship with, restricted list securities, initial public offerings and certain limited offerings. In addition, Foresight requires all transactions to be pre-cleared as outlined within the Foresight’s personal trading policy. Supervised persons are required to file certain reports and submit their brokerage account statements to the Chief Compliance Officer for review. D. If you or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for your own (or the related person’s own) account, describe your practice and discuss the conflicts of interest it presents. Describe generally how you address conflicts that arise.

Because of the private nature of its investments, Foresight does not typically face a situation where a supervised person buys or sells a security for his or her own account at or about the same time that Foresight is also buying or selling the same securities for a Client (or Clients). In the event this were to occur, the supervised person would be required to seek pre-approval from the Chief Compliance Officer for such transaction.

Describe the factors that you consider in selecting or recommending brokerdealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Foresight’s principal investment focus is on the securities transactions of private companies, generally through the purchase and sale of interests in such companies through privately negotiated transactions. In pursuing privately negotiated transactions, Foresight will, on occasion, engage the services of a broker-dealer or investment banker in connection with the purchase or sale of a portfolio investment. In such privately negotiated transactions, best execution is met by the consummation of the deal with the best possible terms for the Client(s). Whether for private or public securities transactions, Foresight selects a broker- dealer or investment banker with the overall aim of maximizing returns for Clients and will adhere to the requirements of the Advisers Act of 1940. Selection of a broker-dealer or investment banker is based on Foresight’s judgment regarding a variety of factors which will not be limited solely to ultimate deal price, including but not limited to: Foresight’s prior experience in working with the broker-dealer or investment banker; the broker-dealer or investment banker’s execution capability, financial responsibility, reputation and expertise within the industry; the broker-dealer or investment banker’s responsiveness to Foresight; the broker-dealer or investment banker’s expertise in dealing with investments that are restrictive or illiquid in nature; and the commissions charged, among other factors. When Foresight selects a broker-dealer for its Foresight Capital Management listed securities activities, it considers a variety of factors including the broker’s order execution arrangements and policies, financial strength, perceived financial stability, creditworthiness and reputation, ability to offer the best price or liquidity, ability to settle trades in a timely manner, ability to settle the size of the trade required, access to markets and quality of service, counterparty risk, competitiveness of costs and charges. The Foresight Capital Management team conducts ongoing reviews of its brokers to ensure that these factors are reconsidered on a periodic basis. Although Foresight generally seeks competitive commission rates, it will not necessarily pay the lowest commission or commission equivalent, especially in private securities transactions that rely heavily on the specialty services or experience of a broker-dealer that operates outside of

a competitive bidding environment. Transactions that involve such specialized services on the part of the broker-dealer or investment banker can thereby entail higher commissions or their equivalents than would be the case with other transactions requiring more routine services. 1. Research and Other Soft Dollar Benefits. Foresight does not receive research or other benefits paid for with soft dollars. Foresight pays for all research and execution services on its own. 2. Brokerage for Client Referrals. Foresight does not receive client referrals in connection with selecting or recommending broker- dealers for Clients. 3. Directed Brokerage. The Firm does not recommend, request or require that a Client direct the Firm to execute transactions through a specified broker. B. Discuss whether and under what conditions you aggregate the purchase or sale of securities for various client accounts. If you do not aggregate orders when you have the opportunity to do so, explain your practice and describe the costs to clients of not aggregating.

Foresight will only aggregate a Client’s order with those of one or more other Client if it is unlikely that the aggregation will be to the disadvantage of any of the Clients concerned. In the event Foresight aggregates the purchase or sale of public securities, it will do so on a pro rata basis. After execution, the aggregated order will be promptly allocated. Allocation will be at the price paid, which may be volume weighted, and will be for discretionary transactions - to the account of the Client, for which the Firm has decided to deal. Allocations may be revised where an error in either the intended basis or actual allocation is identified, or if a partial allocation results in an uneconomic allocation.

If someone who is not a client provides an economic benefit to you for providing investment advice or other advisory services to your clients, generally describe the arrangement, explain the conflicts of interest, and describe how you address the conflicts of interest. For purposes of this Item, economic benefits include any sales awards or other prizes. As described in Item 5 above, Foresight receives directors’ fees, transaction fees, monitoring fees, breakup fees and reimbursements from some portfolio companies or prospective portfolio companies held by Clients. These fees are paid pursuant to separate agreements entered into with the portfolio companies to provide certain consulting services that Foresight believes will ultimately enhance the value of the companies and benefit Clients and their investors. These types of arrangements present potential conflicts of interest and provide Foresight with an incentive to recommend investments based on compensation received rather than the best interests of Clients. To help mitigate this potential conflict, an allocable portion of such benefits received by Foresight or its employees in connection with services rendered to portfolio companies are often offset in part against Management Fees. B. If you or a related person directly or indirectly compensates any person who is not your supervised person for client referrals, describe the arrangement and the compensation. Foresight does not make cash payments to third parties for solicitation of clients for separately managed accounts. From time to time, Foresight reserves the right to enter into solicitation arrangements pursuant to which it compensates third parties for referrals that result in a potential investor becoming a limited partner in a Fund. In a typical distribution/placement arrangement, Foresight may agree to pay a third party for referring investors in certain Funds. Typically, the third party will receive a portion of the management fee and/or performance fee payable to Foresight (although other payment arrangements could exist). A prospective investor solicited by a third party engaged by Foresight will be informed of (and may be asked to acknowledge

in writing its understanding of) any such arrangement. All fees for such solicitation services will be borne by Foresight, and investors in such Fund will not bear any increased or additional fees or charges. If they are used, placement agents engaged to solicit investors in the U.S. will be registered as broker-dealers with the SEC. Third party solicitors outside the U.S. may be registered with a non-U.S. regulatory body to the extent such registration is required.

If there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation of your advisory business or the integrity of your management, disclose all material facts regarding those events. Foresight is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client’s evaluation of Foresight or the integrity of Foresight’s management. Foresight and its management persons have not been subject to any material legal or disciplinary events applicable to this Item.

Indicate whether you periodically review client accounts or financial plans. If you do, describe the frequency and nature of the review, and the titles of the supervised persons who conduct the review. The investments made by Clients are generally private, illiquid and long-term in nature. Accordingly, the investment review process is not directed toward a short-term decision

to dispose of securities. Decisions as to when to purchase or sell an investment are made by Foresight’s Private Equity, Real Assets Investment Committees for the private equity and infrastructure strategies. The FCM Investment Committee, makes decisions with respect to the portfolio weightings of funds managed by the Foresight Capital Management team. Foresight’s team of investment professionals closely monitors the operations of investments and maintains ongoing oversight. These reviews include, without limitation, asset performance efficiency, review of sales trends, margins, profitability, debt to equity ratios, disposal opportunities, material business developments, competitive landscape and management. The team conducting such reviews are generally accountants, specialist analysts and other investment professionals including Foresight appointed directors sitting on the board of portfolio companies. Certain funds are also monitored by a depositary whose duties include monitoring of fund cash flows, acting as custodian and verification of fund ownership of investment interests and ensuring valuations are conducted in line with law. B. If you review client accounts on other than a periodic basis, describe the factors that trigger a review. The Chief Compliance Officer reviews the accounts of Clients on a regular basis. The Firm and/or the Chief Compliance Officer would perform additional reviews in the event that an investment needed subsequent financing, in the event of a potential acquisition or liquidity event, or if there were a serious performance issue. C. Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. State whether these reports are written. Subject to the Governing Documents of the Fund, Foresight will generally provide to its investors on behalf of its Funds the following written reports: (i) audited financial statements annually prepared in accordance with internationally recognised accounting principles (either UK GAAP or IFRS), accompanied by the report of the independent auditor, within a maximum of 120 days of year end, commencing with the first year in which the Fund either is in operation for at least six months or makes an investment; (ii) unaudited financial statements for each quarter of each financial year; and (iii) descriptive investment information for each portfolio company quarterly. Reports are typically sent to investors electronically. Prospective Clients and investors are advised to review the applicable Offering and/or Governing Documents for a more extensive description of the applicable reporting content and obligations. In the course of conducting due diligence or throughout the term of their investment(s),

Clients periodically request information pertaining to their investments. Foresight responds to these requests, and in answering these requests provides information that is not generally made available to other Clients who have not requested such information. While Foresight does not have an obligation to update any such information provided, the Firm endeavors to provide the information requested in the most current form available. Additionally, upon request, certain Clients receive additional information and reporting that other Clients do not receive. Foresight is of the view that the provision of this further information does not put any Clients at an advantage to other Clients.

If you have custody of client funds or securities and a qualified custodian sends quarterly, or more frequent, account statements directly to your clients, explain that clients will receive account statements from the broker-dealer, bank or other qualified custodian and that clients should carefully review those statements. If your clients also receive account statements from you, your explanation must include a statement urging clients to compare the account statements they receive from the qualified custodian with those they receive from you. In connection with the management of investments for certain Clients, Foresight has, or is deemed to have, custody of certain funds or securities belonging to its Clients. Rule 206(4)-2 (the “Custody Rule”) of the Advisers Act defines custody as holding client securities or funds or having any authority to obtain possession of them, including the authority to withdraw funds or securities from a client’s accounts or ownership of or access to client funds or securities (such as through fee deductions). The Funds are generally subject to a year-end audit by a major accounting firm that is a member of, and examined by, the UK Financial Reporting Council (“FRC”). Foresight provides the audited financial statements to the investors as part of its regular reporting, in accordance with the governing documents of the Fund. Subject to the governing documents of the Fund, Foresight may maintain certain Client assets with qualified custodians, such as banks, registered broker-dealers, and certain foreign financial institutions.

If you accept discretionary authority to manage securities accounts on behalf of clients, disclose this fact and describe any limitations clients may (or customarily do) place on this authority. Describe the procedures you follow before you assume this authority (e.g., execution of a power of attorney). Except in circumstances noted throughout this Form ADV Part 2A (e.g. for Managed Accounts), Foresight is retained on a fully discretionary basis and is authorized to determine and direct execution of portfolio transactions pursuant to the terms of each Client’s Offering

and/or Governing Documents. Investment advice is provided directly to Clients and not to investors in any Fund individually. The terms upon which Foresight serves as investment manager are established at the time each Client retains Foresight as their investment manager. To become a Client, a Client must execute at minimum an investment management agreement. To become an investor in a Fund, an investor must execute, among other documents, a subscription agreement with such Fund. Such Offering and/or Governing Documents generally sets out the Foresight, or its affiliate’s powers, which includes powers related to the orderly administration of the affairs of the Client. Generally, Foresight’s only restrictions with respect to managing a Client account, such as (but not limited to) the type of securities in which a which a Client invests, will be contained in the relevant Client’s Offering and/or Governing Documents. However, Clients and investors in Funds may impose limitations on Foresight’s authority through the investment management agreement or a side letter agreement. Foresight may choose to accept reasonable limitations or restrictions at its discretion. All limitations and restrictions placed upon a Client’s or investor’s investments must be presented to Foresight in writing and agreed to by Foresight and such Client or investor. Other investors meeting certain commitment thresholds are often provided with notification provisions regarding such side letter agreements but are not provided with consent rights over such agreements.

If you have, or will accept, authority to vote client securities, briefly describe your voting policies and procedures, including those adopted pursuant to SEC Rule 206(4)-6. Describe whether (and, if so, how) your clients can direct your vote in a particular solicitation. Describe how you address conflicts of interest between you and your clients with respect to voting their securities. Describe how clients may obtain information from you about how you voted their securities. Explain to clients that they may obtain a copy of your proxy voting policies and procedures upon request. As a fiduciary, an investment adviser with proxy voting authority has a duty to monitor corporate events and to vote proxies on behalf of its clients, as well as a duty to cast such votes in the best interests of its clients and to not subrogate client interests to its own. Rule 206(4)-6 under the Advisers Act (the “Proxy Voting Rule”) places specific requirements on registered investment advisers with proxy voting authority. The vast majority of Foresight’s investments are in unlisted private equity and infrastructure assets. As owners of these types of investments, Foresight exercises shareholder rights through board participation. However, the funds managed by Foresight Capital Management division invest in shares of companies that are listed on regulated markets.

To meet its obligations under this rule, Foresight has adopted a written Stewardship Framework (the “Policy”), which is available upon request. This policy is reasonably designed and implemented in a manner to confirm that Foresight votes proxies in the best interests of its Clients to support change and drive improvement. The Policy requires Foresight to take all reasonable steps to avoid conflicts of interest and, when they cannot be avoided, manage, monitor and disclose those conflicts of interest in order to prevent them from adversely affecting the interests of any Client and its investors, and ensure that all funds are fairly treated. Clients may request a copy of Foresight’s Stewardship Framework and the proxy voting record by contacting Foresight at the address or telephone number on the cover of this Brochure. The Foresight Capital Management division’s proxy voting record and stewardship activities are publicly available in its annual Stewardship Report.

In accordance with what has been agreed in the governing documents, Foresight’s Clients may make prepayments of more than $1,200 in fees, six months or more in advance. There are no financial conditions that are reasonably likely to impair Foresight’s ability to meet contractual commitments to Clients, Funds or Fund investors. Foresight has not been the subject of a bankruptcy petition.