Fort Washington Investment Advisors, Inc.

Fort Washington Investment Advisors, Inc. (“Fort Washington,” “us,” “our,” or “we”) is a wholly owned subsidiary of The Western and Southern Life Insurance Company and the primary investment arm of Western & Southern Financial Group, Inc. (“W&SFG”) and its insurance affiliates. Fort Washington is comprised of three business units arranged by investment and/or client type: Institutional, Private Client Group, and Private Equity. We are registered with the SEC pursuant to Section 203 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). We are registered as both a cross-border investment advisory company (a “CB IAC”) and a discretionary investment management company (a “CB DIMC”) with the Financial Services Commission under the Financial Investment Services and Capital Markets Act of Korea. We were incorporated in 1990 under the laws of the State of Ohio. Our principal place of business is located in Cincinnati, Ohio. Due to temporary renovations at our offices, the firm is operating from multiple nearby facilities during a transitional period. During this time, client and visitor access to the firm is available primarily through the entrance located at 301 East Fourth Street, Suite 1200, Cincinnati, OH. Certain investment and trading personnel are temporarily operating from an additional nearby facility that is not held out to clients and is used solely for internal operational purposes. Limited working files may be maintained at these temporary locations; however, the firm’s required books and records are maintained electronically and subject to the firm’s centralized recordkeeping and supervisory policies. Upon completion of renovations, the firm intends to consolidate its personnel and operations into a single office occupying the 12th floor across two adjacent buildings, 303 Broadway and 301 East Fourth Street, with access available via both buildings. Throughout this transitional period, the firm’s principal office will remain located at 303 Broadway, Suite 1200, Cincinnati, Ohio. Listed below are our principal shareholders (i.e. those individuals and/or entities controlling 25% or more of Fort Washington): • Western & Southern Mutual Holding Company • Western & Southern Financial Group, Inc. • The Western and Southern Life Insurance Company

INSTITUTIONAL ADVISORY SERVICES Fort Washington offers a variety of strategies to the institutional market. The firm develops new business by cultivating relationships with consulting firms and prospective clients directly. Fort Washington is typically retained to provide one or more specific strategies within a stable of investments for institutional clients. Prospective clients are able to contact the firm directly for these services or a consultant may invite Fort Washington to participate in a search. In some cases, we respond to a formal Request for Proposal or Request for Information to participate in a search. Fort Washington also supplies information about the firm and its primary strategies to third party databases which serve as a repository for investment manager information. Our primary investment strategies offered to clients are: • Public Equity: Dividend Equity, Focused Equity; Large Cap Focused Equity; Small Company Equity

Fixed Income: Active Corporate Fixed Income, Bank Loans, Core Fixed Income, Core Plus Fixed Income, Emerging Markets Debt, High Yield Fixed Income; Intermediate Fixed Income; Municipal Fixed Income, Securitized Opportunities; Securitized Total Return; Short Duration Fixed Income; Strategic Income, Ultra Short Duration Multi-Strategy for Institutions (Comprised of various asset classes) Private Equity: Diversified Funds of Funds; Secondary Funds Private Client Group: Tailored portfolio management to meet the unique investment objectives of high-net-worth individuals, family offices and their clients, and smaller institutional clients.

Other investment strategies offered to clients are: • Cash Management • Private Equity: Regional Programs Many of the public equity, fixed income, and alternative asset strategies are available as a separate account and/or through commingled and affiliated mutual funds and exchange traded funds (“ETFs”). Typically, certain Fort Washington affiliates act as general partners or managing members of these funds, depending on whether they are organized as limited partnerships or limited liability companies, and as sub-advisors for affiliated mutual funds and ETFs. Certain Fort Washington employees have a direct or indirect investment interest in Fort Washington commingled and affiliated Funds. Fort Washington provides collateral management services to the Fort Washington CLO 20191, Ltd. and Fort Washington CLO 2021-2, Ltd. (“CLO”). Fort Washington will perform certain investment management, advisory, and administrative functions with respect to the assets within the CLO in accordance with the terms and conditions of the applicable collateral management agreement and other related documents. Fort Washington serves as investment manager to Collective Investment Trusts (“CITs”), sponsored by trust companies. We serve as the investment manager, pursuant to an investment management agreement, and receive a fee for managing the investment portfolios. The CITs have not been registered under federal or state securities laws and are subject to an exemption provided by Rule 3 (c) (11) of the Investment Company Act of 1940. The CITs are only available for investment by qualified retirement plans and are not for sale to the general public. Fort Washington serves as investment adviser to certain private funds formed for the purpose of investing and reinvesting cash collateral received in connection with a securities lending program administered by an authorized banking institution. These funds are available only to participants in the applicable securities lending program and are not offered to the general public. Fort Washington receives a management fee for providing investment advisory services to such funds. A complete list of composites and corresponding fee schedules are available from Fort Washington upon request. Please contact Joe Don Cole, Vice President & Director, Institutional Relationship Management, at 513.361.7672 or joedon.cole@fortwashington.com to obtain additional information regarding Fort Washington’s institutional composites.

PRIVATE CLIENT GROUP ADVISORY SERVICES Our Private Client Group provides wealth management, financial planning, and investment advisory services, targeting high net worth individuals, family offices, and smaller institutional clients. Our Private Client Group's services include allocation of assets among different investment categories, investment strategy development, portfolio risk management, financial planning, as well as security and/or manager selection. Once engaged, our Private Client Group reviews the client's financial position and whether or not the client’s current asset allocation plan and investment portfolio is sufficient to accomplish the client’s needs. We will evaluate whether the client's current allocation and investment portfolio are likely to meet the client's investment objectives, risk tolerances, and other client-specified criteria. Our Private Client Group bases its investment advice on many factors, including the client's investment objectives, risk tolerances, asset class preferences, time horizons, liquidity needs, anticipated returns, and overall financial position. In forming our advice, we consider the current economic and market views of our investment professionals and analysts, the views of independent investment firms, and other statistical measures. We generally seek to construct highly diversified portfolios with low correlation among asset classes, with the goal of generating maximum investment return or income, consistent with the client's investment objectives and risk tolerance. We often are asked to formulate an investment strategy, develop an investment policy statement, and periodically review the implementation of the strategy. These services include, but are not limited to: • Detailed comparisons of the client's portfolio against selected benchmarks • Analysis of the estimated annual income and current yield of the client's portfolio • Analysis of the client's realized and unrealized gains and losses • Evaluation of client’s tax position and liabilities • Analysis of financial and estate plans While executing the client's investment plan, our Private Client Group will have access to our full array of proprietary investment strategies, as well as access to outside, independent money managers. In our discretion, among other things, we decide whether or not to employ proprietary or outside investment products, active or passive strategies, and mutual funds or separate accounts, including strategies and products offered by our affiliates. We make these decisions solely on the basis of what is appropriate and in the client's best interest based on the facts as we know them and on the information provided by the client. Our Private Client Group relies upon many factors in recommending independent money managers or such investments as mutual funds and ETFs, including the following: absolute and relative performance, risk, cost efficiency, consistency of objectives and management, fund size, and tax efficiency. To assist our Private Client Group in serving our clients, we receive information from independent firms or independent money managers, including access to a large database of historic investment returns. These independent firms also provide us with information regarding managers’ performance track records, risk assessment, style fit and deviation, ownership, and firm statistics. We also use information obtained from rating and tracking organizations, business

publications, fund prospectuses, and other sources to assist our management of clients’ portfolios. When appropriate, based on a client’s request or unique circumstances, certain Fort Washington employees, who are also licensed as non-commissioned insurance agents of an affiliated insurance company, may sell suitable insurance products, including those of affiliates, to Private Client Group clients. These insurance services are separate from the services provided by Fort Washington. In some cases, a Fort Washington employee who is also a licensed non-commissioned insurance agent may recommend that a Private Client Group client have an affiliated insurance company design a retirement plan funded in whole or in part with life insurance products. In one type of plan, the affiliated company’s product must be used. In other plan types, affiliated or unaffiliated insurance products may be used. Certain plans can also be funded with an advisory account managed by Fort Washington. The affiliated insurance company does not charge for designing a retirement plan. It may, however, provide recordkeeping services, for a fee, though clients are not required to use those services. Fort Washington is not an insurance company. Neither Fort Washington nor its employees receive commissions or other compensation from the sale of insurance products. Any insurancerelated compensation is received solely by the affiliated insurance company. Nevertheless, this service creates conflicts of interest, which are discussed further in the Conflicts of Interest section under Item 10. Outside of insurance, Fort Washington may, at a client’s request, recommend professionals in other fields. Fort Washington does not receive any compensation for these recommendations. Implementation of financial plan recommendations is entirely at the client's discretion. Private Client Group clients meet and speak with their Fort Washington Portfolio Manager as often as they agree. We generally provide client reports on a quarterly basis. The client reports present aggregate information pertaining to individual client portfolio(s). Fort Washington has a complete list of composites that is available upon request. Please contact Tracey Stofa, Managing Director, Private Client Group, at 513.361.7694 or tracey.stofa@fortwashington.com to obtain additional information.

FINANCIAL PLANNING Our Private Client Group also generally provides a variety of financial planning and consulting services as part of the wealth management services provided to Private Client Group clients. Financial planning is a comprehensive evaluation of a client’s current and future financial state and needs by modeling and analyzing future cash flows, asset values, and withdrawal plans. The financial planning process seeks to consider the entire financial and lifespan situation of the client in order to devise a plan with the best prospects of enabling the client to achieve his or her personal financial goals and priorities. In general, the financial plan can address any or all of the following areas (including but not limited to): Compiling Net Worth statements, Cash Flow & Tax Planning, Investment Planning, Retirement Planning, Education Planning, Estate Planning and Charitable Planning, Family Planning.

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Our general policy is to charge fees in accordance with the fee schedule in effect at the time of the charge. However, all fees and account minimums are subject to negotiation. Some Fort Washington affiliates are subject to alternative fee arrangements. Please refer to “Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading” (Item 11) for additional

information. Fees may be debited from clients' custodial accounts, or clients may be billed directly. Clients elect the method by which they are billed. The specific manner in which we charge fees is set forth in a client’s written advisory agreement, but fees are generally assessed in accordance with the following schedules. Fees are structured with tiered rates that have the effect of applying different rates to different portions of the account’s assets, so that both the effective annual blended and actual fee rates decrease as assets in the account increase. Fort Washington is not a custodian, although we may be deemed to have custody of certain Private Client Group and pooled investment vehicle assets. Fees are deducted quarterly and are generally paid in arrears.

INSTITUTIONAL ADVISORY SERVICE FEE SCHEDULES A majority of client accounts are generally appraised quarterly for fee purposes. Expressed on an annual basis and assuming that securities will be held in custody with a third-party bank, trust company, or broker-dealer, the fee schedule is as follows. Fort Washington reserves the right to waive or reduce minimum account requirements at its discretion.

DIVIDEND E QUITY The minimum size for Dividend Equity separate accounts is $3,000,000. The fee schedule is as follows: Principal Amount

First $25,000,000

0.50%

Additional amounts over $25,000,000

0.30%

Clients may also invest in Dividend Equity - SRI. The minimum account size is $3,000,000, and the fee schedule is as follows: Principal Amount

First $25,000,000

0.50%

Additional amounts over $25,000,000

0.30%

Clients may also invest in Dividend Select Equity. The minimum account size is $3,000,000, and the fee schedule is as follows: Principal Amount

First $25,000,000

0.50%

Additional amounts over $25,000,000

0.30%

FOCUSED E QUITY The minimum size for Focused Equity separate accounts is $3,000,000. The fee schedule is as follows: Principal Amount

First $50,000,000

0.70%

Additional amounts over $50,000,000

0.65%

LARGE CAP FOCUSED EQUITY The minimum size for Large Cap Focused Equity separate accounts is $3,000,000. The fee schedule is as follows: Principal Amount

First $25,000,000

0.55%

Next $25,000,000

0.45%

Additional amounts over $50,000,000

0.40%

SMALL COMPANY E QUITY The minimum size for Small Company Equity separate accounts is $3,000,000. The fee schedule is as follows: Principal Amount

First $25,000,000

0.75%

Next $25,000,000

0.70%

Additional amounts over $50,000,000

0.65%

Clients, subject to certain investment requirements, may also invest in a collective investment trust (Small Company CIT) managed in this style. The minimum account sizes and fee schedules are as follows: Share Class

Minimum Amount

Annual Fee (Flat)

Class F

$15,000,000

0.50%

Class A

$3,000,000

0.60%

Class I

>$0

0.70%

ACTIVE CORPORATE FIXED INCOME The minimum size for Active Corporate Fixed Income separate accounts is $3,000,000. The fee schedule is as follows: Principal Amount

First $25,000,000

0.30%

Additional amounts over $25,000,000

0.25%

BANK LOANS The minimum size for Bank Loans separate accounts is $50,000,000. The fee schedule is as follows: Principal Amount

On the First $100,000,000

0.50%

On the Next $150,000,000

0.45%

Additional Amounts over $250,000,000

0.40%

CASH MANAGEMENT The minimum size for Cash Management separate accounts is $5,000,000. The fee schedule for Cash Management accounts is as follows: Principal Amount

First $25,000,000

0.15%

Additional amounts over $25,000,000

0.10%

CORE FIXED INCOME The minimum size for Core Fixed Income separate accounts is $5,000,000. The fee schedule is as follows: Principal Amount

First $25,000,000

0.30%

Additional amounts over $25,000,000

0.25%

CORE PLUS FIXED INCOME The minimum size for Core Plus Fixed Income separate accounts is $50,000,000. The fee schedule is as follows: Principal Amount

First $50,000,000

0.35%

Next $50,000,000

0.25%

Additional amounts over $100,000,000

0.20%

Clients, subject to certain investment requirements, may also invest in commingled funds (Fort Washington Core Plus Fixed Income LLC; Fort Washington Core Plus Fixed Income (ERISA) LLC) managed in this style. The minimum account size is generally $1,000,000 and the fee schedule is as follows: Principal Amount (Active Fund)

Flat

0.40%

Clients, subject to certain investment requirements, may also invest in a collective investment trust (Fort Washington Core Plus Fixed Income CIT) managed in this style. The minimum account sizes and fee schedules are as follows: Share Class

Minimum Amount

Annual Fee (Flat)

Class 1

$100,000,000

0.26%

Class 2

$50,000,000

0.30%

Class 3

>$0

0.32%

EMERGING MARKETS DEBT (“EMD”) The minimum size for Emerging Markets Debt separate accounts is $25,000,000. The fee schedule is as follows: Principal Amount

First $100,000,000

0.35%

Additional amounts over $100,000,000

0.30%

Clients, subject to certain investment requirements, may also invest in an Emerging Markets Debt commingled fund (Fort Washington Emerging Market Debt LLC) managed in this style. The minimum account size is $1,000,000 and the fee schedule is as follows: Principal Amount (Commingled Fund)

Flat

0.40%

HIGH YIELD FIXED INCOME The minimum size for High Yield Fixed Income separate accounts is $20,000,000. The fee schedule is as follows: Principal Amount

First $100,000,000

0.50%

Additional amounts over $100,000,000

0.45%

Clients, subject to certain investment thresholds, may also invest in High Yield Fixed Income commingled funds (Fort Washington High Yield Investors LLC; Fort Washington High Yield Investors II, LLC) managed in this style. The minimum account size for the commingled funds is generally $500,000 and the fee schedule is as follows: Principal Amount (Commingled Funds)

Flat

0.55%

INTERMEDIATE FIXED INCOME The minimum size for Intermediate Fixed Income separate accounts is $5,000,000. The fee schedule is as follows: Principal Amount

First $25,000,000

0.35%

Additional amounts over $25,000,000

0.30%

MUNICIPAL FIXED INCOME The minimum size for Municipal Fixed Income separate accounts is $3,000,000. The fee is as follows: Principal Amount

First $25,000,000

0.35%

Additional amounts over $25,000,000

0.30%

SECURITIZED OPPORTUNITIES The minimum size for Securitized Opportunities separate accounts is $25,000,000. The fee schedule is as follows: Principal Amount

Flat

0.35%

SECURITIZED TOTAL RETURN The minimum size for Securitized Total Return separate accounts is $15,000,000. The fee schedule is as follows: Principal Amount

First $25,000,000

0.30%

Additional amounts over $25,000,000

0.25%

SHORT DURATION FIXED INCOME The minimum size for Short Duration Fixed Income separate accounts is $3,000,000. The fee schedule for Short Duration accounts is as follows: Principal Amount

First $25,000,000

0.25%

Additional amounts over $25,000,000

0.20%

STRATEGIC INCOME The minimum size for Strategic Income separate accounts is $100,000,000. The fee schedule is as follows: Principal Amount

Flat

0.40%

Clients, subject to certain investment requirements, may also invest in a commingled fund (Fort Washington Strategic Income LLC) managed in this style. The minimum account size is $1,000,000 and the fee schedule is as follows: Principal Amount (Commingled Fund)

Flat

0.45%

ULTRA-SHORT DURATION The minimum size for Ultra-Short Duration separate accounts is $15,000,000. schedule is as follows: Principal Amount

Flat

0.15%

The fee

MULTI -STRATEGY SEPARATE ACCOUNTS (COMPRISED OF INVESTMENT VEHICLES REPRESENTING MULTIPLE ASSET CLASSES ) The minimum size for Multi-Strategy Separate Accounts is $5,000,000. Fees for MultiStrategy accounts invested in strategies managed by Fort Washington and third-party subadvisors include a flat 30bps advisory fee, payable to Fort Washington for asset allocation, monitoring, and oversight of sub-adviser(s) in addition to the fee(s) to be paid to the subadviser(s). Fees will be paid to the sub-adviser as outlined in the investment advisory agreement and client Sub-Adviser Acknowledgement Form. When suitable, Fort Washington recommends to its clients shares of Touchstone ETFs and Touchstone Funds, including those funds and ETFs for which Fort Washington serves as SubAdviser and receives a sub-advisory fee. Fort Washington waives the Multi-Strategy investment advisory fees on that portion of the client's assets invested in such affiliated mutual funds and affiliated ETFs.

PRIVATE CLIENT GROUP The minimum size for High-Net-Worth Individual and Family accounts is $500,000. Client accounts are generally appraised for fee purposes quarterly. Expressed on an annual basis and assuming that securities will be held in custody with a third-party bank, trust company, or brokerdealer, the fee schedule for discretionary accounts is as follows: Principal Amount (Discretionary Account)

First $1,000,000

1.00%

Next $4,000,000

0.75%

Additional amounts over $5,000,000

0.50%

In applying the breakpoints, Fort Washington will typically aggregate related client accounts. The fees described above are negotiable. Non-discretionary Private Client Group accounts are generally charged $500 annually and are billed quarterly in advance, but these fees may vary depending on client circumstance.

PRIVATE EQUITY FUNDS From time to time, Fort Washington forms and offers partnership interests in closed-end private equity funds, typically diversified private equity funds of funds (“Funds of Funds”) and secondary funds (“Secondary Funds”).

For Funds of Funds, management fees are typically based on committed capital and generally range from 0.50% - 1.25% during approximately the first 10 years of the fund, after which they are reduced by 10% per year thereafter. Carried Interest of 5% - 7.5% is charged on profits after a return of contributed capital and a 6% - 7% preferred return, for certain Funds of Funds. There is also a fee structure implemented for prior funds. For Secondary Funds, management fees are typically charged a rate between 0.85% 1.25% annually, during the investment period, based on committed capital. After the investment period, management fees are generally reduced by 10% annually. Carried Interest of 15% is charged on profits after a return of contributed capital and an 8% preferred return. There is also a fee structure implemented for prior funds. For certain qualified investors that make a large commitment or are affiliated with or under a common consultant relationship with other investors, the level of the asset-based management fee may be reduced. If Carried Interest applies, investors generally pay a percentage of profits after a return of contributed capital and a preferred return. Certain Funds of Funds do not charge Carried Interest. See “Performance-Based Fees and Side-By-Side Management” (Item 6) below for further information about performance-based fees. Fort Washington also manages and advises on legacy funds and customized private equity partnerships no longer open to new investors. These partnerships charge different fees and/or Carried Interest from those we would charge on newly formed partnerships. Closed funds may be subject to alternative fee schedules. Additional information regarding fees can be found in each fund’s private placement memorandum and Limited Partnership Agreement.

FINANCIAL PLANNING Fort Washington considers its Financial Planning division to serve as an extension and integral part of Fort Washington Private Client Group in the wealth management services it provides to its clients. As such, Fort Washington will generally waive any related financial planning fees and expenses for those clients of its Private Client Group. Fort Washington will also occasionally provide financial planning advisory services to its associates and to W&SFG associates at a discounted rate. When the financial planning services are not connected to the wealth management provided to our Private Client Group clients, Fort Washington typically collects its fee upon completion of the Financial Planning Agreement. In such instances, financial planning-only clients are typically charged on a per-plan (i.e., flat) or hourly basis, depending on the degree of complexity of the plan and according to applicable contract provisions.

FAMILY OFFICE SERVICES Fees for Family Office Services are negotiable and are generally based on the scope and complexity of the services to be provided, the anticipated time commitment, and other relevant considerations. Family Office Services fees may be structured as fixed fees, project-based fees, hourly fees, retainer fees, or other fee arrangements as agreed with the client. The specific fee arrangement, billing terms, and scope of services will be set forth in the applicable Family Office Services Agreement. Fees for Family Office Services are generally billed monthly

in arrears, although alternative billing arrangements may be utilized depending on the nature of the engagement. Family Office Services fees are separate from and in addition to any fees charged for investment advisory, investment management, financial planning, or other services provided by Fort Washington pursuant to separate agreements.

GENERAL INFORMATION TERMINATION OF THE A DVISORY RELATIONSHIP A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days’ written notice, or as indicated in the Advisory Agreement. As disclosed above, fees are generally paid in arrears of services provided. However, upon termination of an account where fees are paid in advance, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period.

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The methods of analysis Fort Washington use in formulating investment advice and/or managing client assets include but are not limited to: Fundamental Analysis. For public securities, we attempt to assess the value of a security by evaluating economic and financial factors specific to the particular security and, in addition, conditions in the relevant sector and the overall economy. For private investments, we attempt to measure the fair market value using the same factors that we consider in assessing public securities, while also incorporating a value judgment based upon the illiquid nature of private securities in general. Fundamental analysis attempts to incorporate all the relevant securityspecific attributes and the many macro-driven factors that may affect the security in order to arrive at a solid assessment of the current value of a security. Since securities prices may change in conjunction with overall market movements, securities identified by fundamental analysis as having good prospects may decline in value. Even if this occurs, however, our fundamental analysis may enable us to select securities that will perform better on a relative basis, regardless of the overall market’s direction. Technical Analysis. For certain public securities, we may analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns and to predict future price movement. Technical analysis does not consider the underlying financial condition or fundamental value of a security. Accordingly, there is a risk that securities of poorly managed or financially unsound companies may look attractive on a technical basis but perform poorly long-term or relative to the market. There is, however, no guarantee that past performance or trends which serve as the basis for technical analysis will continue in the future. Quantitative Analysis. For certain public securities, we use mathematical models to obtain an objective measure of the quality of a company’s business model and compare the results of that assessment to the market’s perception of that company using valuation and price-related factors. A risk in using quantitative analysis is that the models may be more backward looking in nature and may be based on assumptions that prove to be incorrect or that the quantitative model may not capture all relevant or current information necessary to determine a company’s value.

Asset Allocation. Where requested by the client, in addition to focusing on security selection, we attempt to identify and invest the account in an appropriate mix of different asset classes (stock, bonds, cash, etc.) or investment strategies based on client’s objectives and assessment of their risk tolerance. The purpose of asset allocation is to seek to improve overall portfolio performance and/or reduce volatility by diversifying the client's investments consistent with the client's investment objectives and risk tolerance. A risk of asset allocation is that the client’s ability to participate in sharp increases in a particular security, industry, or market sector is limited because portfolio diversification necessarily limits the portion of the client's account invested in a single security, industry, or market sector. Another risk is that the ratio of securities allocated to specific asset classes or investment strategies typically changes over time due to market movements and, if not corrected, will no longer be appropriate for the client’s goals. To seek to mitigate this risk, we monitor the allocation among asset types as valuations fluctuate in the market and periodically readjust the allocations to the intended levels. This monitoring and adjustment process is typically called portfolio rebalancing. Third-Party Investment Manager Analysis. Where we advise clients with regard to investment with third party investment managers, we examine their experience, expertise, investment philosophies, and past performance to attempt to determine if that manager has demonstrated an ability to invest successfully over a period of time and in different economic conditions. We monitor the managers, which typically includes evaluating the underlying holdings, strategies, concentrations, terms, and performing reference checks as part of our initial and/or periodic risk assessment. Additionally, we will typically survey the manager’s compliance, business enterprise risks/alignment, and terms. A risk of investing with a third-party manager who has been successful in the past is that the third-party manager may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager will deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. While we do not control a third-party manager’s daily business, compliance, or operations, we seek to mitigate the business, regulatory, and reputational risks arising from this. We periodically receive and review reports from third-party managers and service providers to determine alignment with their stated philosophy. Environmental, Social and Corporate Governance (“ESG”) Analysis. Senior management has Responsible Investment (“RI”) oversight responsibilities as part of a firm-wide RI Committee. The Portfolio Manager and Investment Analysts are required to use ESG data as a portfolio monitoring tool as determined by the RI Committee. In conjunction with the Compliance Department, it is also the responsibility of the Portfolio Manager to ensure socially responsible mandates are followed. Our firm has several formalized processes and groups empowered to manage risk. First, there is a formal Risk Management Committee chaired by the W&SFG Chief Risk Officer and Fort Washington Chief Financial Officer. The members of this committee represent all senior leaders of Fort Washington. That committee's charter identifies specific business, operational, reputational, regulatory, and performance risks to track and mitigate. ESG governance is specifically and regularly addressed by the Committee. The Committee meets at least quarterly to review activity and mitigation of previously identified risks and serves as the forum to identify

new risks. At least annually, the Committee re-establishes the risk paradigm under which it will operate for the following year. There is separate risk management infrastructure dedicated solely to investment management risk, which is included in the Performance Measurement and Risk function. This group works directly with the W&SFG CRO and Fort Washington CFO to provide regular topdown risk assessment on each of the firm's portfolios and strategies on IPS restrictions, violations to internal guidelines, correlation metrics, relative performance analysis, and the implementation of other proprietary models. Regular internal reporting is provided to investment teams and all variances require explanation on a monthly basis.

INVESTMENT STRATEGIES Fort Washington uses the following practices in managing client accounts, provided that such practices are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities for certain strategies and composites with the idea of holding them in the client's account for longer than a year. Typically, we employ this strategy when: • We believe the securities to be currently undervalued • We may desire to have exposure to a particular asset class over time as a core holding within a portfolio • The security’s liquidity or transaction cost does not lend itself to active trading such as in the case of private equity or debt • We believe the underlying fundamentals and/or market share for a security are superior to its competitors Short-term purchases. For certain strategies and composites, we purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a favorable price swing. Shortterm purchases may involve higher brokerage and other transaction costs than other investment strategies. Short sales. Short sales occur when an investor sells borrowed securities in anticipation of a price decline and is required to return an equal number of shares at some point in the future. We primarily engage in short sales of securities in the Fort Washington Core Plus Fixed Income LLC and affiliated accounts. We also use short futures positions in Touchstone Active Bond, Touchstone TVST Bond, Touchstone Balanced, Touchstone Strategic Income Fund, Touchstone Strategic Income ETF, Fort Washington Strategic Income LLC, Fort Washington Core Plus Fixed Income (ERISA) LLC, Fort Washington Core Plus Fixed Income CIT, and Fort Washington Emerging Market Debt LLC. Fort Washington works with the relevant parties to ensure securities are delivered promptly. Options. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. When suitable, we use options as part of an investment strategy. The two types of options are calls and puts:

A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we believe that the price of the security will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we believe that the price of the security will fall substantially before the option expires.

We may use options to “hedge” a security; in other words, we will use an option purchase or sale in an attempt to offset or limit the impact of an underlying security’s price movement in a client’s portfolio in exchange for paying or receiving the option price. We use “covered calls,” in which we sell an option on a security our clients own. In this strategy, our client receives a fee or premium for selling the option, and the person purchasing the option has the right to buy the security from our client at an agreed-upon price for a specified period of time. We use a “spreading strategy,” in which we purchase two or more option contracts for the same underlying security. This effectively puts our client on both sides of the market, but with the ability to vary price, time, and other factors. International Fixed Income and Equities. For certain strategies and composites, we purchase securities of companies domiciled outside of the U.S. We do this in an attempt to take advantage of our perception of the attractiveness of certain international markets. Derivatives. For certain accounts, we use derivatives with a goal of producing absolute return or to hedge risk and generally do so in affiliated accounts. Derivatives may be combined with cash or other derivatives to attempt to profit from mispricing (i.e., arbitrage). Each derivative trade will have a limit on risk, as expressed in dollar terms. There are certain risks associated with investments in derivative products, similar to owning any other security type. Because investments of this type typically involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Private Equity Investments. These investments are generally made with the objective for longterm appreciation with limited liquidity. Investors in private equity partnerships may have a portion of their investment held for up to fifteen years or more. When we invest in private equity partnerships or securities not managed by the firm, we have limited control over the management of such investments. Additional information regarding private equity investment composites and strategies can be found in “Fees and Compensation” (Item 5).

RISK OF LOSS Investment returns are not guaranteed, and our clients may lose money on their investments. We ask that our clients work with the Portfolio Manager to help understand the clients' tolerance for risk. Our securities analysis and investment strategy methods rely, where possible and as appropriate, on internal fundamental research, external research, credit ratings prepared by independent rating agencies and on financial statements audited by independent public auditors. We assume that rating agencies and auditors are in fact independent and that they perform their services in accordance with applicable legal and professional standards. In addition, we rely on

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Fort Washington provides advisory services to various types of clients, including the following: • Banking / Thrift institutions / Registered Investment Advisers / Broker-Dealers • Charitable institutions • Corporations or other businesses not listed above • Corporate pension and profit-sharing plans (other than plan participants) • Defined Contribution Investment Only (“DCIO”) • Family Offices • Foundations and endowments • High-net-worth individuals and their families • Insurance companies • Investment companies (including mutual funds)

ETFs Other pooled investment vehicles Private investment funds State or municipal government entities Taft-Hartley plans

As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature of the service(s) being provided. For a more detailed description of those requirements, please review the disclosures provided for each applicable service.

As discussed in Item 5 above, Fort Washington private funds may charge a performance fee to qualified clients as set forth in the applicable limited partnership agreement. Fort Washington will structure any performance or incentive fee arrangement subject to Section 205(a)(1) of the Advisers Act in accordance with the exemptions made available under its provisions, including the exemption set forth in Rule 205-3. In measuring clients’ assets for the calculation of performance-based fees, Fort Washington shall include realized and unrealized capital gains and losses. Please refer to “Fees and Compensation” (Item 5) above for additional performancebased fee information. For some institutional accounts, along with a base fee rate, Fort Washington will charge clients a negotiated performance fee. Any performance fees charged by Fort Washington will comply with the requirements of Section 205(a) (1) of the Advisers Act and the applicable rules thereunder. The receipt of performance-based fees creates conflicts of interest. Performance-based fee arrangements create an incentive for Fort Washington to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. In order to reduce potential conflicts of interest, Fort Washington does not show preferential treatment to accounts under a performance-based fee arrangement. We have procedures designed and implemented to treat all clients fairly, and to prevent this potential conflict from influencing our selection of investments for accounts with performance- based fee arrangement or the allocation of investment opportunities among clients. See Item 12 below, "Allocation of Investment Opportunities and Orders".

Fort Washington has relationships or arrangements that are material to its advisory business and its clients with related persons (i.e., affiliates) as described below.

BROKER-DEALERS Fort Washington is affiliated with the following broker-dealers: • Touchstone Securities, LLC • W&S Brokerage Services, Inc. Fort Washington does not execute securities transactions with W&S Brokerage Services, Inc. Please refer to the “Conflicts of Interest” section below for important conflict of interest disclosures.

INVESTMENT COMPANIES Fort Washington previously disclosed in “Advisory Business” (Item 4) and “Fees and Compensation” (Item 5) of this Brochure that our firm is a sub-adviser to Touchstone Advisors, Inc. (“Touchstone”) on several mutual funds, as well as Variable Series Trusts which Touchstone advises. Please refer to these items for a detailed explanation of these relationships and important conflict of interest disclosures. Please refer to the “Conflicts of Interest” section below for important conflict of interest disclosures.

OTHER POOLED INVESTMENT VEHICLES As disclosed in Section 7.A. on Schedule D of Form ADV, Part I, Fort Washington owns or controls a number of limited liability companies (collectively, the “Managing Entities”) which each serve as the managing member or general partner of a pooled investment vehicle formed for investment purposes (collectively, the “Pooled Vehicles” or “Funds”). In addition, Fort Washington generally serves as the investment adviser to each of the Managing Entities. Fort Washington personnel spend as much time as deemed necessary on activities relating to the Managing Entities and the Pooled Vehicles. Each of the Pooled Vehicles and their respective Managing Entity are listed below:

Pooled Vehicles

Managing Entities

Fort Washington Core Plus Fixed Income LLC

Fort Washington Fixed Income, LLC

Fort Washington Core Plus Fixed Income (ERISA) LLC

Fort Washington Fixed Income, LLC

Fort Washington Emerging Market Debt LLC

Fort Washington Fixed Income, LLC

Fort Washington High Yield Investors LLC

Fort Washington Capital Partners, LLC

Fort Washington High Yield Investors II, LLC

Fort Washington Investment Advisors, Inc.

Fort Washington Strategic Income LLC

Fort Washington Fixed Income, LLC

Fort Washington Private Equity Investors III, L.P.

Fort Washington Capital Partners, LLC

Fort Washington Private Equity Investors IV, L.P.

Fort Washington Capital Partners, LLC

Fort Washington Private Equity Investors V, L.P.

FWPEI V GP, LLC

Fort Washington Private Equity Investors V-B, L.P.

FWPEI V GP, LLC

Fort Washington Private Equity Investors V-VC, L.P.

FWPEI V GP, LLC

Fort Washington Private Equity Investors VI, L.P.

FWPEI VI GP, LLC

Fort Washington Private Equity Investors VII, L.P.

FWPEI VII GP, LLC

Fort Washington Private Equity Investors VIII, L.P.

FWPEI VIII GP, LLC

Fort Washington Private Equity Investors VIII-B, L.P.

FWPEI VIII GP, LLC

Fort Washington Private Equity Investors IX, L.P.

FWPEI IX GP, LLC

Fort Washington Private Equity Investors IX-B, L.P.

FWPEI IX GP, LLC

Fort Washington Private Equity Investors IX-K, L.P.

FWPEI IX GP, LLC

Fort Washington Private Equity Investors X, L.P.

FWPEI X GP, LLC

Fort Washington Private Equity Small Market Investors X-S, L.P.

FWPEI X GP, LLC

Fort Washington Private Equity Investors X-B, L.P.

FWPEI X GP, LLC

Fort Washington Private Equity Investors XI, L.P.

FWPEI XI GP, LLC

Fort Washington Private Equity Investors XI-B, L.P.

FWPEI XI GP, LLC

Fort Washington Private Equity Investors XI-K, L.P.

FWPEI XI GP, LLC

Fort Washington Private Equity Small Market Investors II, L.P.

FWPEI Small Market II GP, LLC

Fort Washington Private Equity Small Market Investors II-B, L.P.

FWPEI Small Market II GP, LLC

Fort Washington Private Equity Small Market Investors II-K, L.P.

FWPEI Small Market II GP, LLC

Fort Washington Private Equity Small Market Investors III, L.P.

FWPEI Small Market III GP, LLC

Fort Washington Private Equity Small Market Investors III-B, L.P.

FWPEI Small Market III GP, LLC

Fort Washington Private Equity Small Market Investors III-K, L.P.

FWPEI Small Market III GP, LLC

Fort Washington Private Equity Opportunities Fund II, L.P.

FWPEO II GP, LLC

Fort Washington Private Equity Opportunities Fund III, L.P.

FWPEO III GP, LLC

Fort Washington Private Equity Opportunities Fund III-B, L.P.

FWPEO III GP, LLC

Fort Washington Private Equity Opportunities Fund IV, L.P.

FWPEO IV GP, LLC

Fort Washington Private Equity Opportunities Fund IV-B, L.P.

FWPEO IV GP, LLC

Fort Washington Private Equity Opportunities Fund IV-K, L.P.

FWPEO IV GP, LLC

Fort Washington Private Equity Opportunities Fund IV-Feeder, LLC

FWPEO IV GP, LLC

Fort Washington Private Equity Opportunities Fund V, L.P.

FWPEO V GP, LLC

Fort Washington Private Equity Opportunities Fund V-B, L.P.

FWPEO V GP, LLC

Fort Washington Private Equity Opportunities Fund V-K, L.P.

FWPEO V GP, LLC

NEO Capital Fund, L.P.

BVP NEO, LLC

The Ohio Capital Fund LLC

Buckeye Venture Partners, LLC

Mauna Kea Taft-Hartley Partners (ERISA), L.P.

FWPEI Mauna Kea GP, LLC

Securities Lending Fund, LLC

Fort Washington Securities Lending Fixed Income LLC

Securities Lending Fund-B, LLC

Fort Washington Securities Lending Fixed Income LLC

As appropriate, our advisory clients are presented with the possibility to invest in one or more of the Pooled Vehicles. However, because investment in these types of entities involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated

investment objectives, tolerance for risk, liquidity, and suitability. Those clients interested in investing in a particular Pooled Vehicle will be provided with a private placement memorandum or equivalent document for their review which will contain detailed information and risk factors specific to the Pooled Vehicle. Each Managing Entity collects management fees from investors of the Pooled Vehicles and, in some cases, a performance fee on profits from such Pooled Vehicles in the form of Carried Interest. As a result, if a client were to invest in a Pooled Vehicle, Fort Washington may be entitled to receive additional compensation from such client as a result of these fees and payments. Therefore, clients should be aware that this potential for additional compensation to Fort Washington creates a potential conflict of interest that may impair the objectivity of our firm when making advisory recommendations. In addition, from time to time, Fort Washington or one of our related persons makes a proprietary investment in a Pooled Vehicle. We or our related persons will receive proportional returns associated with the investment, in addition to our receipt of management fees and Carried Interest. Pooled investment vehicles typically include additional regulatory expenses, including, without limitation: expenses related to preparing and making regulatory and compliance filings associated with the vehicle and its investment activities; software and related systems; consultants utilized in connection with the preparation and making of such filings; organizational expenses; expenses incurred in connection with the offering and sale of the Interests (including expenses incurred in accordance with domestic or foreign law), and other similar expenses related to the vehicle. Fort Washington has created an allocation policy that describes the procedures and decisionmaking processes to allow for the equitable allocation of investment opportunities, relative to portfolios within the partnerships and other portfolios that may be invested concurrently, in accordance at all times with the best interests of each account or investment vehicle. Please refer to the “Conflicts of Interest” section below for important conflict of interest disclosures.

OTHER INVESTMENT ADVISERS As disclosed in Section 7.A. on Schedule D of Form ADV, Part I, Fort Washington is affiliated with the following registered investment advisers: • Touchstone Advisors, Inc. • Eagle Realty Capital Partners, LLC • W&S Brokerage Services, Inc. • W&S Advisory Services, LLC Please refer to the “Conflicts of Interest” section below for important conflict of interest disclosures.

INSURANCE COMPANIES Fort Washington is affiliated with the following insurance companies and serves as an investment adviser to each of them: • The Western and Southern Life Insurance Company • Western-Southern Life Assurance Company • Integrity Life Insurance Company • National Integrity Life Insurance Company • Columbus Life Insurance Company • The Lafayette Life Insurance Company • Gerber Life Insurance Company Please refer to the “Conflicts of Interest” section below for important conflict of interest disclosures.

SYNDICATOR OF LIMITED PARTNERSHIPS Fort Washington has established and will likely continue to establish a number of limited partnership investment vehicles for investment purposes. Please refer to the “Other Pooled Investment Vehicles” and “Conflicts of Interest” sections for a detailed explanation of these relationships and important conflict of interest disclosures.

CONFLICTS OF INTEREST As described above, Fort Washington is part of W&SFG, which includes insurance companies, broker-dealers, other investment advisers, and other financial services companies. Members of the W&SFG provide a wide range of insurance, investment, and other financial service products. Some officers or directors of Fort Washington also serve as officers or directors of affiliated companies. Some employees of Fort Washington also serve as employees of affiliated companies. As a result, the businesses and interests of Fort Washington and its affiliates give rise to potential conflicts of interest of which potential clients should be aware and that could disadvantage advisory accounts. Fort Washington provides investment advisory services to advisory affiliates and their clients. Similarly, some of our investment professionals and other employees who are officers of advisory affiliates provide other services to those affiliates and their clients. Certain Fort Washington employees are licensed as non-commissioned agents with an affiliated insurance company to sell life insurance products, including those of affiliates, to individuals who are typically Private Client Group clients. Sales of affiliated products create a conflict of interest because they benefit affiliates of Fort Washington. When a Fort Washington employee recommends a retirement plan that may be funded with insurance products and/or a Fort Washington advisory account, different compensation structures apply at the entity level. The affiliated insurance company may receive commissions on insurance products, while Fort Washington may receive ongoing advisory fees on managed accounts. These differences create a conflict, as Fort Washington and its affiliates may have an incentive to recommend one product or structure over another. Insurance services provided by Fort Washington employees in their capacity as licensed insurance agents are strictly those of the affiliated insurance company, not Fort Washington. Neither Fort Washington nor its employees receive commissions or other

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Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct. Fort Washington and our personnel owe a duty of loyalty, fairness, and good faith towards our clients and have a fiduciary obligation to adhere not only to the specific provisions of the Code of Ethics, but to the general principles that guide the Code of Ethics. Our Code of Ethics defines personnel as either a Supervised Person or an Access Person: • Supervised Persons are directors, officers, general partners, and advisory personnel of Fort Washington.

Access Persons have access to non-public information regarding any client's purchase or sale of securities and/or portfolio holdings, are involved in the making or have access to securities recommendations to clients, or are an employee of Fort Washington.

Supervised Persons must take the following steps when making personal securities transactions: • Report initial holdings [including in our affiliated or sub-advised mutual fund(s)] • Certify all holdings on a quarterly and annual basis • Pre-clear certain transactions Access Persons must take the following steps when making personal securities transactions: • Report initial holdings [including in our affiliated or sub-advised mutual fund(s)] • Certify all holdings on a quarterly and annual basis • Pre-clear certain transactions • Three-Day Blackout Period on certain transactions • 30-Day Holding Period on certain transactions Other procedures regarding other potential Conflicts of Interest include: • Confidentiality Our firm prohibits the use of material non-public information. Where we have access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity and is subject to our Insider Trading Policy.

Gifts Typically gifts of nominal value may be offered or received. Gifts in excess of $100, whether individual or in aggregate must be pre-cleared and pre-approved by the President & CEO and the Compliance department. Fort Washington’s Political Contributions Policy, which aims to ensure compliance with SEC Rule 206(4), however, places significant restrictions on the ability of Fort Washington, its employees, officers, directors, and other affiliated entities to make political contributions. Please refer to the “Governmental Client Referrals” section in Item 14 below for additional information.

Outside Business Activities Any outside business activity involving a non-affiliated company must be pre-approved.

Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm have the ability to buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, a certain security or securities may also be recommended to a client even when a related person has an interest or position in the same security or securities. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics. This ensures our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest:

No director, officer, or employee of our firm will put his or her own interest above the interest of an advisory client No director, officer, or employee of our firm will buy or sell securities for their personal portfolio(s) where their decision derives from information received as a result of his or her employment unless the information is also available to the investing public Our firm requires prior approval for any initial public offering or private placement investments by related persons of the firm We maintain a list of all reportable securities holdings for our firm and anyone associated with this advisory practice that has access to advisory recommendations; these holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or his/her designee We have established procedures for the maintenance of all required books and records All of our directors, officers, and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices We require delivery and acknowledgement of the Code of Ethics by each Supervised Person of our firm We have established policies requiring that Code of Ethics violations be reported to Fort Washington’s senior management and Board of Directors Any individual who violates any of the above restrictions may be subject to penalties up to and including termination

A complete copy of our Code of Ethics is available to our advisory and prospective clients. A copy may be requested by contacting Scott Henry, Chief Compliance Officer, by phone at 513.361.7934, or by email at scott.henry@fortwashington.com.

PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS Fort Washington or related persons (including affiliates) may buy securities for the firm or for themselves from our advisory clients. In addition, Fort Washington or related persons (including affiliates) may sell securities owned by the firm or the individual(s) to our advisory clients. We will ensure, however, that such transactions are conducted in compliance with all the provisions under Section 206(3) of the Advisers Act governing principal transactions to advisory clients. Fort Washington is prohibited from engaging in agency cross-transactions. Fort Washington manages assets for its affiliated insurance companies, including these companies’ general accounts. Typically, third-party and affiliated clients invest in the same assets. In connection with its Private Funds, Fort Washington owns or controls the following subsidiaries which serve as general partners or managers to their respective Pooled Vehicles:

Fort Washington Fixed Income, LLC Fort Washington Investment Advisors, Inc. Buckeye Venture Partners, LLC BVP NEO, LLC Fort Washington Capital Partners, LLC FWPEI V GP, LLC FWPEI VI GP, LLC FWPEI VII GP, LLC

FWPEI VIII GP, LLC FWPEI IX GP, LLC FWPEI X GP, LLC FWPEI XI GP, LLC FWPEI Small Market II GP, LLC FWPEI Small Market III GP, LLC FWPEO II GP, LLC FWPEO III GP, LLC FWPEO IV GP, LLC FWPEO V GP, LLC FWPEI Mauna Kea GP, LLC Fort Washington Securities Lending Fixed Income LLC

Each General Partner has designated Fort Washington primary responsibility for investment management and administrative matters, such as accounting, tax, and periodic reporting pertaining to each Pooled Vehicle. Fort Washington and our directors, officers, and employees will devote to the Funds as much time as necessary and appropriately manage each Pooled Vehicle. Fort Washington and our subsidiaries are not restricted from forming additional investment funds, entering into other investment advisory relationships, or engaging in other business activities, even though such activities could be in competition with the Funds and/or involve substantial time and resources of our firm and our subsidiaries. Potentially, such activities could be viewed as creating a conflict of interest in that the time and effort of our management personnel and employees will not be devoted exclusively to the Funds. Investments in the Funds are recommended to advisory clients for whom a partnership investment is more suitable than a separate advisory account managed by our firm. Clients who invest in the Funds are not charged any additional advisory fees other than the advisory fee allocated to the limited partners of the Fund. The Funds are not required to register as an investment company under the Investment Company Act of 1940 in reliance upon one or more exemptions available to funds whose securities are not publicly offered. Fort Washington manages the Funds on a discretionary basis in accordance with the terms and conditions of the Fund's offering and organizational documents. As previously disclosed in this brochure, Fort Washington is the investment adviser to affiliated mutual funds. Please refer to “Advisory Business” (Item 4) and “Fees and Compensation” (Item 5) for a detailed explanation of this relationship and important conflict of interest disclosures. For a detailed explanation of these relationships, please refer to “Other Financial Industry Activities and Affiliations” (Item 10).

Fort Washington does not maintain custody of your assets on which we advise, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15 Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We are independently owned and

operated and not affiliated with any qualified custodian. Custodians will hold your assets in a brokerage account and buy and sell securities when instructed. Fort Washington allows multiple custodians to be used as custodian/broker, and for each one, you will decide whether to open your account by entering into an account agreement directly with them. We do not open the account for you. Our clients use a variety of custodians, and each client decides which custodian to use independently of Fort Washington. Each client also decides whether to use directed brokerage or non-directed brokerage. Even if your non-directed brokerage account is maintained at a particular custodian, we can still use other brokers to execute trades for your account, as described in the next paragraph.

BROKERAGE DISCRETION AND BEST EXECUTION Fort Washington requires written authority from its clients giving our firm discretion to select broker-dealers and to negotiate commission costs. It is Fort Washington’s policy to seek best trade execution with respect to each transaction, in light of the overall quality of brokerage and research services provided to it or its clients, and Fort Washington has a Best Execution/Soft Dollar Committee that oversees the firm’s compliance with these objectives. For equity transactions, traders consider many factors when seeking best execution, such as: order size relative to the average daily volume (% of ADV), availability of contra orders in the marketplace, Portfolio Manager instructions for participation levels, urgency of order completion and settlement, and the use of brokerage firm resources that contribute significant value to the investment process. Broker selection is, therefore, a critical part of the best execution process, and includes utilizing traditional brokers and/or the strategic use of electronic execution tools (algorithms). The lowest possible commission, while important, is part of but not the principal factor in choosing a broker within the best execution process. Fixed Income Portfolio Managers typically execute their own trades with approved brokers who provide closely monitored inventories of fixed income securities on a regular basis. Fort Washington has controls in place for monitoring execution in our clients’ portfolio transactions, including periodically reviewing trades for best execution. Due to the nature of the transactions, Fort Washington does not monitor best execution for private placement or private equity transactions. Fort Washington may recommend or select a broker who provides useful research and securities transaction services even if a lower commission is charged by a broker who offers no research services and minimal securities transaction assistance. Research services are typically useful in servicing many of our clients, even though it may not be useful for the account for which the particular transaction was made.

YOUR CUSTODY AND BROKERAGE COSTS For our clients’ accounts, some custodians charge a fee for custody services, while other custodians do not charge a separate fee for custody services, but are instead compensated by charging you commissions or other fees on trades executed or settled in your account. Certain custodians’ commission rates applicable to our client accounts were negotiated based on our commitment to maintain a specified level of our clients’ assets in accounts at that custodian. This commitment benefits you because the overall commission rates you pay are lower than they would be if we had not made the commitment. In addition to commissions, certain custodians charge you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your custodial account. These fees are in addition to

the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have your custodian execute most trades for your account.

PRODUCTS AND SERVICES AVAILABLE TO US FROM CUSTODIANS Certain custodians provide us and our clients with access to institutional brokerage – this includes trading, custody, reporting, and other related services – many of which are not typically available to retail customers of those custodians. Certain custodians also make available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Here is a more detailed description of these support services: Services that Benefit You. Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment from our clients. The services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You. Certain custodians also make available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both from the custodian itself and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at that custodian. In addition to investment research, the custodians also make available software and other technology that:

Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts Provide pricing and other market data Facilitate payment of our fees from our clients’ accounts Assist with back-office functions, recordkeeping, and client reporting

Services that Generally Benefit Only Us. Certain custodians also offer other services intended to help us manage and further develop our business enterprise. These services include access to:

Educational conferences and events Technology and business consulting Publications and conferences on practice management

A custodian may provide some of these services itself. In other cases, it will arrange for thirdparty vendors to provide the services to us. These custodians may also discount or waive their fees for some of these services or pay all or a part of a third party’s fees.

SOFT DOLLARS Consistent with obtaining best execution for clients, Fort Washington directs certain brokerage transactions for clients' portfolios to brokers who provide research and execution services to Fort

Washington and, indirectly, to our clients. These services are based on the safe harbor requirements of Section 28(e) of the Securities Exchange Act of 1934 and are designed to augment our own internal research and investment strategy capabilities. Fort Washington uses soft dollars for equity research and does not use it for fixed income. Certain research services obtained through the use of soft dollars or Commission Sharing Arrangements (“CSAs”) are developed by brokers to whom brokerage is directed or by third-parties which are compensated by the broker. Selected brokers are typically paid commissions for executing client transactions that exceed the commissions other brokers would have charged for the same transactions, provided that Fort Washington determines in good faith that the commissions are reasonable in relation to the value of the brokerage and/or research services provided for our clients. Generally, we do not enter into agreements or understandings with brokers regarding the placement of securities transactions in light of the research they provide. We have an internal procedure for allocating transactions in a manner consistent with our execution policy to brokers who we believe add value by providing research or execution services that particularly benefit clients. Our Best Execution/Soft Dollar Committee regularly considers whether a given service provides lawful and appropriate assistance to our investment advisory services, and whether the cost of the services is reasonable in relation to the benefit to our clients. We make every effort in tracking soft dollar allocations to unbundle commission charges in order to show the execution and soft dollar components of our trading practices. Fort Washington does not attempt to allocate the relative costs or benefits of those services among clients, since the services typically benefit multiple clients and assist us in fulfilling our duty to our clients collectively. We have obtained products and services on a soft-dollar basis in the form of: • Written and oral reports on individual companies and industries, general economic conditions, relevant legal developments, and changes in accounting practices • Statistical collations • Appraisals and analyses relating to markets, companies, and industries • Various methods and mediums of communication regarding business and economic factors, market trends affecting portfolio companies, portfolio strategy, as well as trading insight and intelligence • Quotation, trading, and information gathering equipment Fort Washington uses the information furnished through soft dollar arrangements to carry out investment management responsibilities for all of our clients. As a result, we will use those services in managing accounts that paid little or no commission to the broker that provided the service or those that do not generate commissions resulting in soft dollar services. When Fort Washington uses client brokerage commissions to obtain research or brokerage services, we receive an unpaid benefit equal to the cost of such services. Therefore, use of client brokerage commissions could present a conflict with our duty of best execution, because of an incentive to direct client brokerage to those brokers who provide research and services we utilize. We seek to obtain “best execution” on all trades considering many components of the trade including execution price, research obtained, and commissions charged. In addition, as described above, we have adopted procedures to ensure that our soft dollar usage complies with legal requirements and that the cost is reasonable in light of the benefits to our clients as a result of our receipt of soft dollar research and brokerage services.

Certain soft dollar eligible items are not used exclusively for either execution or research services. The cost of such “mixed-use” products or services will be fairly allocated and Fort Washington makes a good-faith effort to determine the percentage of such products or services which are considered as research or brokerage services. The portions of the costs attributable to non-research usage of such products or services are paid by our firm in accordance with the provisions of Section 28(e) of the Securities Exchange Act of 1934. Selected services provided by broker-dealers to Fort Washington could have administrative marketing or other uses which do not constitute research or brokerage services within the meaning of Section 28(e) of the Securities and Exchange Act. Such services are generally known as “mixed-use” services. Fort Washington evaluates the use within the firm of any “mixed-use” services, allocating the cost of such services between research/brokerage and nonresearch/brokerage uses based on the number of people, the purpose used, or the time that different functions utilize the service. In making such an allocation, a conflict of interest may arise in determining the cost allocation of mixed-use items between research and non-research portions of the products. W&SFG, our parent company, has directed us to use commissions from trades executed on its behalf to pay for certain equipment, investment services, and investment information for the collective benefit of Fort Washington’s clients.

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Our firm pays referral fees to affiliated and independent persons or firms ("Promoters") for introducing certain clients to us. Whenever we pay a referral fee to a third party, we require that the prospective client be provided with a copy of our Firm Brochure and a separate disclosure statement that includes the following information: • the Promoter's name and relationship with our firm • the fact that the Promoter is being paid a referral fee • the amount of the Promoter fee • Whether the client will pay an increased fee in order to compensate the Promoter As a matter of firm practice, clients do not pay an increased fee for promoter arrangements. Our firm receives an economic benefit from certain custodians in the form of support products and services made available to us and other independent investment advisers when clients maintain accounts at those custodians. These products and services, how they benefit us, and

the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability to us of these products and services is not based on us giving particular investment advice, such as buying particular securities for our clients.

GOVERNMENTAL CLIENT REFERRALS In accordance with SEC adopted Rule 206(4)-5 under the Advisers Act, Fort Washington prohibits third-party solicitation of advisory business from any government entity on behalf of Fort Washington, unless the third parties are registered broker-dealers or registered investment advisers subject to pay-to-play restrictions. This prohibition is part of Fort Washington’s Political Contributions Policy, which aims to ensure compliance with SEC Rule 206(4) by placing significant restrictions on the ability of Fort Washington, its employees, officers, directors, and other affiliated persons to make political contributions.

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

While the underlying securities within Institutional accounts are continually monitored, these accounts are reviewed at least annually by senior management. Accounts are reviewed in the context of each client's stated investment objectives and guidelines as outlined in each client’s investment policy statement. In addition, we generally review the following items: turnover rate, commissions, adherence to portfolio mandates, brokerage relationships, advisory contract(s) and corresponding paperwork, fees paid, and performance. More frequent reviews are triggered by material changes in variables such as the client's individual circumstances or the market, political, or economic environment. These accounts are reviewed by the: President and Chief Executive Officer, Chief Compliance Officer or their designee, and responsible parties from Portfolio Management and Operations. In addition to the statements and confirmations of transactions that clients receive from their custodian, we provide reports summarizing account performance, balances, and holdings on a monthly or quarterly basis depending on the client’s preference.

SUB-ADVISORY P ORTFOLIO MANAGEMENT While the underlying securities within accounts are continually monitored, these accounts are reviewed annually by senior management. Accounts are reviewed in the context of stated investment objectives and guidelines. More frequent reviews are triggered by material changes in variables such as individual circumstances or the market, political, or economic environment. These accounts are reviewed by the: President and Chief Executive Officer, Chief Investment Officer, Chief Compliance Officer or their designee, and responsible parties from Portfolio Management and Operations. Unless stipulated differently in the sub-advisory agreement, Fort Washington provides the adviser or their clients with reports summarizing account performance, balances, and holdings on a monthly or quarterly basis depending on the adviser’s or their client’s preference.

MUTUAL FUND P ORTFOLIO MANAGEMENT Fort Washington continually reviews and monitors mutual fund holdings in accordance with the investment objectives as detailed in the fund prospectus and/or Statement of Additional Information (“SAI”). As a sub-adviser, Fort Washington provides regular reports to the adviser as reasonably requested or required.

MODEL P ORTFOLIO MANAGEMENT While the underlying securities within Model Portfolio Management accounts are continually monitored, typically no formal reviews will be conducted for these clients unless otherwise contracted. Model Portfolio clients will not typically receive reports due to the nature of the service.

PRIVATE EQUITY On-going monitoring of existing investments is handled by the Private Equity Investment, Finance and Accounting, and Operations Teams. Fort Washington provides its Private Equity investors with audited financial statements annually. Quarterly reports, capital calls and distribution notices, capital account statements, and Schedules K-1 and K-3 are also available to investors online or through an alternative method of delivery chosen by the investor.

PRIVATE CLIENT GROUP While the underlying securities within our clients' accounts are continually monitored, these accounts are reviewed at least annually by Portfolio Managers. Accounts are reviewed in the context of each client's stated investment objectives and guidelines as outlined in each client’s investment policy statement. In addition, we generally review the following items: turnover rate, commissions, adherence to portfolio mandates, brokerage relationships, advisory contracts and corresponding paperwork, review of fees paid, and performance. More frequent reviews are triggered by material changes in variables such as the client's individual circumstances or the market, political, or economic environment. In addition to the statements and confirmations of transactions that clients receive from their custodian, we generally provide reports summarizing account performance, balances, and holdings on a monthly or quarterly basis depending on the client’s preference.

SELECTION AND MONITORING OF THIRD -PARTY VENDORS FOR PRIVATE CLIENT GROUP Periodically, PCG will leverage the investment-related research and due diligence of an affiliated company in addition to its own research. PCG and the affiliated company receive no special benefits as a result of this relationship.

FINANCIAL PLANNING Reviews may occur at different stages depending on the nature and terms of the specific engagement.

As described in the "Fees and Compensation" section (Item 5) of this Brochure, our firm both debits advisory fees from client accounts and bills clients directly. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from the client's account. On at least a quarterly basis, the custodian is required to send a statement to the client showing all transactions made within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation and other information provided. Clients should contact their custodians if they have questions regarding their custodial statement. In addition to the periodic statements that clients receive directly from their custodians, we also send account statements/appraisals directly to our clients on a monthly or quarterly basis depending on the client’s preference. We urge our clients to carefully compare the information provided in these reports to ensure that all account transactions, holdings, and values are correct and current. In the case of pooled investment vehicles, Fort Washington has retained the services of an independent public accountant to conduct an annual audit. We send quarterly account statements to the limited partners and annual audited financial statements within 120 days of the Fund’s fiscal year end, or in the case of Funds of Funds, within 180 days of the Fund’s fiscal year end. Fort Washington has retained the services of an independent public accountant to conduct an annual surprise examination of the Private Client accounts where we have been deemed to have custody. If requested by our clients, we will provide them with a copy of Form ADV-E, which is filed with the SEC by the public accountant with the results of the examination.

Certain clients hire us to provide discretionary asset management services, in which case we make investment decisions and place trades in a client's account without prior consultation with the client. Our discretionary authority includes the ability to do the following without contacting the client:

Determine the security to buy or sell Determine the amount of the security to buy or sell Exchange or convert securities, including money market instruments Determine the timing of securities transactions Select a broker to effect securities transactions Determine the terms of the transaction, including commission amounts (if any)

Clients give us discretionary authority when they sign a discretionary agreement with our firm, and have the ability to limit this authority through written instructions or based on their investment policy statements. Clients may also change/amend such limitations by once again providing us with written instructions or by revising their investment policy statements. We seek to manage portfolios with similar instructions or guidelines in the same way. Accordingly, in some instances, accounts with restrictive guidelines are unable to participate in aggregated orders and can be disadvantaged by the market impact of trading for other accounts. In non-discretionary accounts, we make periodic recommendations to clients regarding the securities to be purchased or sold and the size of those transactions.

Fort Washington has adopted and implemented procedures that we believe are reasonably designed to ensure that proxies are voted in the best interests of clients, in accordance with our fiduciary duties and policies and procedures established by the firm. Our authority to vote proxies on behalf of our clients is established by our advisory contract or by written instructions from our clients. Our firm will retain all proxy voting books and records for the period of time required by law, including a copy of any document created by us that was material to making proxy voting decisions, our proxy policies and procedures, and a copy of each written client request for information on how Fort Washington voted proxies. Our clients always have the right to vote proxies themselves. Clients can exercise this right by instructing us in writing not to vote proxies on their account. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting Eric Walzer, Vice President, Investment Operations, at eric.walzer@fortwashington.com or at 513.361.7951. Clients may also request, in writing, information on how proxies were voted. If any client requests a copy of our complete proxy policies and procedures or how we voted proxies for their account(s), we will promptly provide such information to the client. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. To direct us to vote a proxy in a particular manner, clients should contact Eric Walzer at eric.walzer@fortwashington.com or at 513.361.7951. We vote proxies for some, but not all of our clients. For accounts where we do not vote proxies, clients maintain exclusive responsibility for voting proxies. Clients are responsible for instructing their custodian to forward copies of all proxies and shareholder communications to the client. Fort Washington will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s) including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct us or

their custodian, in writing, to transmit copies of class action notices to the client or a third party. Upon such direction, we will make every reasonable effort to forward such notices in a timely manner.

Fort Washington has no additional financial circumstances to report. Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement with this brochure. Fort Washington has not been the subject of any bankruptcy petition.