GEODE CAPITAL MANAGEMENT, LLC

Description of Firm Geode Capital Management, LLC (“Geode”) was founded in 2001 as a subsidiary of Fidelity Investments. In 2003, Geode became independent from Fidelity Investments and registered as an investment advisor with the U.S. Securities & Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Geode is a limited liability company organized under the laws of the State of Delaware. In addition to being registered with the SEC, Geode is also registered with the U.S. Commodities and Futures Trading Commission (“CFTC”) as a Commodity Pool Operator (“CPO”) and Commodity Trading Adviser (“CTA”) and designated as a Swap Firm. Geode is also a member of the National Futures Association (“NFA”). Geode Capital Holdings LLC is the majority (99%) owner of beneficial ownership interests of Geode. As of December 31, 2025, Geode had discretionary assets under management of $1,736,523,234,533. These numbers reflect total assets under management across all of Geode’s advisory clients. Advisory Clients Geode is a systematic asset manager providing global investment solutions across multiple asset classes. Geode provides discretionary investment advisory and sub-advisory services for equity, commodity and options strategies for funds and client accounts. Geode provides discretionary portfolio management services to certain open-end investment companies (“Mutual Funds”) and exchange traded funds (“ETFs”) that are registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Geode provides investment advisory services for U.S. and non-U.S. taxable and tax-exempt institutional clients that invest through separately managed accounts (“Separate Accounts”) and pooled investment vehicles. Geode provides sub-advisory services to pooled investment vehicles domiciled in Canada under the regulatory framework for National Instruments 81-102 (“NI 81-102") and other Canadian pooled funds exempt from registration under NI 81-102, U.K Open-Ended Investment Company (“OEICs”), Irish Collective Asset Management Vehicle (“ICAVs”), and Luxembourg investment companies with variable capital (sociétés d’investissement à capital variable) (“SICAVs”) authorized under the regulatory framework for Undertakings for Collective Investment in Transferable Securities (together with the Mutual Funds and ETFs, the “Funds”). The Funds and Separate Accounts advised and sub-advised by Geode are collectively referred to herein as “Client Accounts.” Advisory Services Geode’s primary service is the design, implementation and management of portfolios that employ passive index investment strategies for equities and commodities, most frequently as sub-adviser for institutional clients. Passive index investment strategies are designed to track the performance of a specified market index (or “benchmark”). In managing passive index strategies, Geode does not seek to outperform an index or to make active investment decisions based on market forecasts, issuer-specific analysis, or economic trends. Instead, Geode seeks to achieve returns that correspond to the performance of the designated index. To implement a passive index strategy, Geode typically uses one of two methodologies: full replication or optimization (i.e. sampling). Under a full-replication method, Geode seeks to hold all securities in the index in approximately the same weightings as the index. Under an optimized-sampling method, Geode may hold a representative subset of securities that, in Geode’s judgment, is expected to closely match the index’s risk and return characteristics. The selection of methodology is determined in Geode’s sole

discretion and may depend on factors such as index size and liquidity, transaction costs, and operational considerations. In replicating an index for certain strategies, Geode may use statistical sampling techniques. Statistical sampling techniques attempt to match the investment characteristics of the index by taking into account such factors as capitalization, industry exposures, dividend yield, price-to-earnings (P/E) ratio, price-tobook (P/B) ratio, and earnings growth. Geode also manages index overlay strategies, for which Geode may buy and sell futures contracts, purchase or write put options, and/or purchase or write call options that provide investment exposure to the underlying index. Passive index strategies may not perfectly match the performance of the index. Differences may arise due to fees and expenses, transaction costs, cash holdings, corporate actions, tax considerations, timing of index rebalances, and other implementation factors. Additionally, Geode does not dictate index composition or methodology. Changes made by the index provider may limit Geode’s ability to match the performance of a particular index if those changes conflict with a client’s investment guidelines or applicable legal and regulatory requirements. In such instances, Geode may determine that it is necessary to modify its passive implementation methodology and rebalance or otherwise adjust the portfolio. Please see the below disclosure within Item 8 of this Brochure headed “Investment Strategy Risks” for more information about index-related risks. Geode provides investment advisory services for strategies based on numerous indexes provided by thirdparties, some of which include customized, non-proprietary indexes. Geode may, from time to time, add or discontinue certain index or investment strategies. Investment Selection Geode exercises full investment discretion and makes investment decisions in accordance with each client’s investment objectives and policies, applicable legal and regulatory requirements, and the oversight of the client’s Board of Trustees or Directors, where applicable. Geode maintains discretion over trading decisions to efficiently implement investment strategies. Types of Investments The type of investments transacted by Geode is contingent on the investment strategy employed. In general, Geode transacts in U.S. and non-U.S. common stocks, depositary receipts, real estate investment trusts, mutual funds, ETFs, currencies, index future contracts and option contracts, commodity-related derivatives, warrants, rights and fixed-income securities. Geode uses futures contracts for efficient portfolio management and to equitize cashflows and residual cash balances. In addition to using futures contracts, Geode uses various techniques, such as buying and selling ETFs, options contracts, and swaps, to increase or decrease exposure to changing security prices or other factors that affect security values, and conducts foreign currency transactions on a spot or forward basis.

All management fees charged by Geode are subject to negotiation. For Funds and certain other accounts, Geode charges a fixed fee or an asset-based fee determined by the investment strategy utilized and based on the Fund’s or other account’s average net assets. In most

circumstances, the management fee is accrued on a daily basis and collected monthly or quarterly. The annualized management fee rates generally range from 0.01% to 0.20% for equity index portfolios and 0.10% to 0.75% for commodity and options portfolios, based on investment strategy, and may be on a tiered fee structure by net asset levels. Some of these fee arrangements aggregate net assets across multiple client accounts and may include a minimum annual fee. Geode may also enter into agreements to waive a portion of management fees based on certain net asset levels. Geode’s compensation for Separate Accounts is generally based on an annual percentage of assets under management and is typically calculated and payable monthly, in arrears, based on the total market value of the account (including cash, cash equivalents and accrued interest). These fee arrangements may aggregate net assets across multiple client accounts and may include a minimum annual fee. Generally, investment management agreements (“IMAs”) can be terminated by either party upon 60 days written notice without the imposition of any penalty. Under certain circumstances, clients may terminate a contract upon written notice. Where advisory fees are payable in arrears, no refund of advisory fees will typically be necessary. Where Geode and the client determine to make fees payable in advance, upon termination of the advisory contracts, Geode will refund the pro-rata, unearned portion of the prepaid advisory fees. Geode has advisory contracts with terms that vary from the terms described above. The specific manner in which fees are charged by Geode is established in a client’s written agreement with Geode. Geode will generally bill its fees on a monthly or quarterly basis. Clients may elect to be billed in advance or arrears. Clients may also elect to be billed directly for fees. Management fees shall be prorated for each capital contribution and withdrawal made during the applicable billing period (with the exception of de minimis contributions and withdrawals). Client Accounts initiated or terminated during a calendar quarter will also be charged a prorated fee. Upon termination of an account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Geode’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which are typically incurred by the client. Clients will incur certain charges imposed by custodians, brokers, and other third parties which include, but are not limited to, fees charged by advisers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. (See Item 12 of this Brochure for more information on brokerage practices.) Mutual Funds and ETFs sometimes charge internal fees, which are disclosed in a fund’s prospectus or offering document. Such charges, fees and commissions are exclusive of and in addition to Geode’s advisory fee, and Geode does not receive any of the foregoing commissions, fees, or costs.

In managing discretionary client accounts, Geode uses a variety of investment strategies and methods of analysis implemented by the investment teams. This Item 8 describes these methods of analysis and investment strategies, along with the primary risks associated with them. However, it is not possible to identify all risks related to investing, and the specific risks applicable to any client account will depend on the nature of the account, its investment strategy or strategies, and the types of securities it holds. Equity Index Geode offers a range of equity index investment strategies spanning all major market-capitalization components, style and sector specific strategies, developed and emerging market indexes, as well as targeted single-country strategies. Geode manages its equity index strategies with the objective of delivering broad equity market exposure while seeking to minimize tracking error relative to the designated benchmarks. Client accounts may not always hold all the same securities as the designated benchmarks. Geode may use statistical sampling techniques to attempt to replicate the returns of the benchmark. Statistical sampling techniques attempt to match the investment characteristics of the benchmark by taking into account such factors as capitalization, industry exposures, dividend yield, priceto-earnings (P/E) ratio, price-to-book (P/B) ratio, and earnings growth. Commodity Index Geode offers commodity Index strategies that provide diversified exposure to the global commodities market through a systematic process to gain exposure to commodity sectors across energy, metals, and agricultural sectors, serving as a potential hedge against inflation, a source of diversification, and a return driver independent of traditional equity and fixed‑income markets. Commodity index strategies

are managed to replicate the risk/return characteristics of the underlying index while maintaining disciplined portfolio construction, efficient implementation, and risk‑controlled tracking. Option Index The Options index overlay strategies employ a systematic, rules-based portfolio construction process that combines a put spread index options overlay with a passive equity index exposure. The strategies seek to generate premium income from writing fully collateralized exchange listed out-of-the-money put spread options across multiple strikes and maturities while providing equity exposure. These strategies have three components: short put positions, long put positions, and an underlying equity position intended to provide market exposure. The option overlay component is implemented using exchange traded listed index options, including both weekly and monthly expirations. The strategies do not invest in single stock options. Investment Strategy Risks All investment strategies involve risk of loss. Clients should be prepared to bear such losses in connection with investments. Clients may lose money. Client Accounts that pursue strategies that concentrate in particular industries or are otherwise subject to particular segments of the market may be significantly impacted by events affecting those industries or markets. Additionally, investments are subject to operational risks, which can include risks of loss arising from failures in internal processes, people, or systems, such as routine processing errors or major systems failures, or from external events impacting service providers or other financial institutions. Geode offers multiple investment strategies to satisfy a wide variety of institutional clients and risk profiles. In general, the portfolios managed by Geode are subject to one or more of the investment risks discussed below. All strategies are ultimately affected by impacts on the individual investments, such as changes in an issuer’s profitability and credit quality, or changes in tax, regulatory, market or economic developments. Bond Risk: In general, the bond market is volatile, and fixed-income securities carry interest rate risk. As interest rates rise, bond prices usually fall, and vice versa. Lower quality bonds can be more volatile and have greater risk of default than higher-quality bonds. The ability of an issuer of a bond to repay principal prior to a security’s maturity can cause greater price volatility if interest rates change, and, if a bond is prepaid, a bond fund may have to invest the proceeds in securities with lower yields. Fixed-income securities also carry inflation risk and credit and default risks for both issuers and counterparties. In addition, investments in certain bond structures will be less liquid than other investments, and therefore will be more difficult to trade effectively. Cash and Forward Trading Risk: Trading of cash and forward contracts, such as non-U.S. currencies, may be entered into with banks and market makers. There is no limitation on daily price movements of cash or forward contracts. At times, prices can be quoted with unusually wide spreads. Commodity-Related Investment Risk: Commodity markets are typically subject to greater volatility than investments in securities. The value of commodities and commodity-related investments are affected by the performance of the overall commodities markets as well as weather, political, tax, and other regulatory and market developments. Additionally, the value of commodity linked derivatives are generally influenced by factors such as supply and demand relationships, governmental programs and policies, political and economic events, and changes in interest rates. Margin deposits generally are

required in commodity futures trading, and leverage may be used by a pooled investment vehicle engaging in commodity futures trading. Concentration Risk: When investments are concentrated in a particular asset class, country, geographical region, industry, or sector, performance may be more susceptible to loss due to adverse impacts affecting that asset class, country, geographical region, industry or sector. Counterparty Risk: Counterparty risk is the risk to each party of a contract that the counterparty will not, or is unable to, honor its contractual obligations. Client Accounts could potentially incur losses as a result of counterparty credit exposure if the counterparty fails to fulfill its obligations. Credit Risk: Changes in the financial condition of an issuer or counterparty, and changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security’s or instrument’s credit quality or value. Currency Risk: Currency risk is the risk that currency exchange rates will negatively affect securities denominated in non-base currencies. The liquidity and value of non-base currencies could be affected by global economic factors, such as inflation, interest rate levels, and trade balances among countries, as well as the actions of governments and central banks. Changes in currency exchange rates may create losses in a Client Account. Derivative Instrument Risk: Certain derivative instruments are subject to various types of risks, including market risk, leverage risk, liquidity risk, operational risk, legal risk, the risk of non-performance by the counterparty, including risks relating to the financial soundness and creditworthiness of the counterparty. Certain derivatives traded over-the-counter (“OTC”) do not have an authoritative source of valuation and the models used to value such derivatives are subject to change. Special risks may apply in the future that cannot be determined at this time with respect to derivative instruments that are not presently contemplated for use or that are currently not available. The regulatory and tax environment for derivative instruments is continuing to evolve, and changes in the regulation or taxation of such securities can have a material adverse effect on investments in derivatives. ETF Risk: ETFs are pooled investment vehicles whose shares are traded on a securities exchange. ETFs may seek to track an index, commodity, or other basket of assets, or may be actively managed. ETF shares may trade at a premium or discount to net asset value (“NAV”) and are often affected by the market fluctuations of their underlying investments. They will also have unique risks depending on their structure and underlying investments. Equity Securities Risk: Equity securities fluctuate in value in response to many factors, including the financial results and financial condition of companies; competition; market conditions; interest rates; and economic environments. Futures Risks: Futures prices may be volatile. Price movements in a futures contract price will affect a portfolio. Purchase or sale of a futures contract may result in losses in excess of the amount invested. Futures have “daily price fluctuation limits” or “daily limits.” During a single trading day, no trades can be executed at prices beyond the daily limit. This could prevent the timely liquidation of positions and subject a Client Account to substantial losses.

Index Tracking Risk: No assurances can be made that an investment strategy tracking the performance of a specified market index will be able to match the returns, volatility or other results of the applicable Index. Results may deviate from the index due to: (i) fees and expenses associated with the investment strategy; (ii) transaction costs and risks associated with buying and selling securities; (iii) the investment strategy not always holding all of the same securities as the index and not in the exact proportions as the Index; (iv) timing differences associated with additions to and deletions from the index; (v) regulatory restrictions; (vi) investment restrictions or limitations detailed in the governing documents for the investment strategy; and/or (vii) not being able to purchase or sell securities included in the index. Indexes are unmanaged, and it is not possible to invest directly in an index. Geode may seek to make indirect investments, such as using futures or derivative instruments, on behalf of Client Accounts to receive exposure to certain securities in excess of the applicable ownership restrictions and limitations where permitted under applicable laws, regulations, and investment guidelines. There may be limited availability of derivatives that provide indirect exposure to an impacted security or index and the use of such instruments may affect the strategy’s ability to achieve close correlation with its index. Interest Rate Risk: Fixed income securities are generally sensitive to interest rate risk. When interest rates rise, the price of fixed income securities typically decrease. Fixed income securities with longer maturities are more susceptible to interest rate risks. Issuer Risk: The value of an individual security or particular type of security can be more volatile than the market as a whole. If the financial condition or credit ratings of an issuer deteriorate, the value of its securities will most likely decline. Liquidity Risk: Under certain market conditions, the liquidity of portfolio positions is reduced. Under these circumstances, Geode may be forced to dispose of securities at reduced prices, thereby adversely affecting its performance. If other investors are seeking to dispose of the same securities at the same time, Geode may be unable to sell or prevent losses. Money Market Fund Risk: An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. It is possible for a money market fund to lose money. Non-Diversified Risk: Non-diversified Funds invest a large percentage of assets in a relatively small number of issuers. A non-diversified fund’s performance may be concentrated and therefore may be more susceptible to loss. Non-U.S. Markets Risk: Non-U.S. securities are subject to interest rate, currency exchange rate, economic, regulatory, and political risks, all of which may be greater in emerging markets. Such risks include, but are not limited to: the risk of nationalization of assets; taxation; social, economic and political instability; illiquid markets; currency exchange rate risk; hyper-inflation; controls on non-U.S. investment; governmental involvement in the economy; differences in financial standards; less regulatory oversight; different settlement periods; difficulty in enforcing contractual obligations; lack of modern technology and less available information than is generally the case in the United States. These risks are particularly significant for Client Accounts that focus on emerging markets. Non-U.S. markets may be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Non-U.S. exchange rates can also be extremely volatile.

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Geode provides portfolio management investment advisory services on a discretionary basis to a wide range of institutional clients including, but not limited to, Mutual Funds, ETFs, banks, corporations, trusts, registered investment advisers, Separate Accounts, and other pooled investment vehicles. Geode requires different minimum investment amounts based on investment strategy and type of Client Account. Geode, in its discretion, may lower the minimum investment amounts due to a number of considerations, including pre-existing relationships with the client or its affiliate or consultant, as well as for growth potential, for example.

Geode does not currently charge performance-based fees. Geode’s portfolio managers are often responsible for managing one or more client accounts, including Separate Accounts and Funds. Some portfolio managers may provide investment advisory duties to portfolios with similar investment objectives and strategies or with the side-by-side management of multiple Client Accounts and accounts advised by Geode’s affiliates (if applicable). A portfolio manager may also manage client accounts that may have materially higher or lower fee arrangements. The sideGEODE CAPITAL MANAGEMENT, LLC

by-side management of these accounts raises potential conflicts of interest relating to the allocation of investment opportunities, cross-trading, and the aggregation and allocation of trades. The portfolio managers have a fiduciary responsibility to manage all client accounts in a fair and equitable manner. Geode has adopted policies and procedures designed to treat all Client Accounts fairly and equally, and to mitigate actual and potential conflicts of interest due to side-by-side management of client accounts. These procedures include order allocation policies and controls designed to treat all clients fairly in the aggregation and allocation of trade orders in a manner consistent with Geode’s fiduciary duty and obligation to seek best execution.

Geode is registered with the CFTC as a CPO and CTA and designated as a Swap Firm. Geode is also a member of the NFA. Certain Geode employees are registered as principals and associated persons of the CPO. Geode also is a signatory to the Principles for Responsible Investing. Geode provides investment advisory or sub advisory services to registered investment companies and other pooled investment vehicles. In providing such services, Geode does not control, and is not under common control with, these entities. Geode’s advisory or sub-advisory relationships with these entities do not give rise to material conflicts of interest. Geode is under common control with Geode Capital Management Trust Company, LLC (“GCMTC”). GCMTC is a trust company established and chartered under the laws of the State of New Hampshire, with its principal place of business in Boston, Massachusetts. GCMTC is regulated by the New Hampshire Banking Department and is an approved foreign fiduciary by the Commonwealth of Massachusetts Division of Banks. GCMTC has established and serves as trustee of the Spartan Group Trust for Employee Benefit Plans (“Group Trust”), and provides trust, investment management, fiduciary and related services for the commingled pools established under the Group Trust. The executive officers listed in Schedule A of Form ADV Part 1 and certain other of Geode's personnel provide various administrative, ministerial, technology, consulting, management, support, trading,

compliance and other services to GCMTC pursuant to a Support and Services Agreement between GCMTC and Geode. Conflicts of interest can arise from Geode’s various investment advisory services and the services provided by Geode to GCMTC. Geode seeks to mitigate such conflicts through its compliance program.

and Personal Trading Geode has adopted a Code of Ethics for Personal Investing, Insider Trading and Conflicts of Interest Policy (the “Code of Ethics”) pursuant to Rule 204A-1 of the Advisers Act. The Code of Ethics is based on the principle that persons related to Geode, including officers, directors and employees, temporary employees and certain contractors (together, “Advisory Personnel”) owe a fiduciary duty to Geode’s clients and investors in the Funds and must place the interests of Geode’s clients and investors in the Funds above their own. All directors and Advisory Personnel must comply with federal securities laws and report violations of the Code of Ethics or federal securities laws to Geode’s Compliance Department. Geode maintains a comprehensive compliance program designed to identify, escalate, mitigate, and monitor potential conflicts of interest. The program operates through adherence to established policies and procedures, a structured governance and oversight framework, and ongoing employee training. Geode is not a broker-dealer and does not act as principal or broker in connection with client transactions. The Code of Ethics sets forth procedures that govern the personal securities transactions in accounts beneficially owned by Advisory Personnel. Advisory Personnel may buy, sell, or have a financial interest in securities recommended to clients. Such persons may buy, sell, or have a financial interest in such securities by investing directly in the Funds, or otherwise through independent transactions in personal accounts. Personal trading by Advisory Personnel may create a conflict when they are trading the same securities as Geode trades on behalf of its clients. Potential conflicts of interest in connection with such transactions and the controls designed to mitigate such conflicts are generally disclosed to clients herein. Advisory Personnel also must acknowledge their understanding and acceptance of the Code of Ethics. Rules for Advisory Personnel The Code of Ethics establishes personal securities transaction requirements for all Advisory Personnel and their covered persons. These requirements generally include, but are not limited to the following provisions: (i) pre-clearance of transactions in covered securities, subject to limited exceptions, (ii) prohibitions on purchases of securities in initial public offerings unless an exception has been granted (iii) restrictions on creating or maintaining short positions, (iv) requirements to surrender profits from “shortswing” trading (purchase and sale of the same security within a 60-day period), subject to certain limited exceptions, (v) pre-clearance of private placement transactions, (vi) restrictions on trading in securities deemed restricted by Geode Compliance, (vii) compliance with applicable trading limits, and (viii) prohibitions on the use of derivatives to circumvent requirements as outlined in the Code. In addition to the requirements described above, investment professionals with responsibility for making investment decisions for a client account are prohibited from (1) trading in their personal accounts within seven days of a client account for which such person is involved in the day-to-day management, subject to certain exceptions, and (2) intentionally failing to recommend or trade a suitable security or commodity

interest for a client account in order to avoid an actual or apparent conflict of interest with a transaction in that security or commodity interest in a personal securities account. Reporting Requirements The Code of Ethics outlines certain reporting requirements for all Advisory Personnel and their covered persons. These requirements generally include the following Code provisions: (i) disclose all personal securities accounts and holdings of covered securities at the time of hire and annually thereafter (ii) reporting of transactions in covered securities on a quarterly basis, (iii) attest to the accuracy of all personal securities accounts on file with Geode on a quarterly basis, (iv) attest to having read and understood responsibilities and requirements as outlined in the Code on an annual basis. Non-access directors of Geode who are not involved in the day-to-day operations of either Geode or any of its clients’ portfolios and who do not generally have access to nonpublic information regarding trading activities or portfolio holdings of Geode’s clients or investment recommendations or decisions of Geode are not subject to the foregoing requirements. A non-access director must report personal securities transactions only in certain limited circumstances where the director obtains access to certain nonpublic information regarding trading activities in a client’s portfolio. The Code of Ethics establishes sanctions if its requirements are violated, up to and including dismissal from employment. The foregoing is only a summary of the provisions of the Code and is qualified in its entirety by the detailed provisions appearing in the full text of the Code, a copy of which is available upon request.

When placing transactions in Client Accounts, Geode seeks to achieve best execution for its clients. Geode’s duty to seek best execution typically requires that Geode obtain the best available terms for its clients by taking into consideration various factors that are relevant to a particular transaction, given prevailing market conditions. In selecting a counterparty to execute transactions, the price of the security or instrument and the cost to transact are some of the important factors for determining whether a transaction represents best execution. However, Geode will consider a range of quantitative and qualitative factors when seeking to achieve best execution. For example, such factors may include the following: Counterparty Considerations • Trading expertise • Reputation and integrity • Size and type of transaction • Access to liquidity • Execution efficiency • Capital utilization • Clearance and settlement capabilities • Reasonableness of commission rate or spread • Financial strength • Fairness in resolving disputes • Credit rating

Market Considerations • Size and type of transaction • Characteristics of the market(s) in which the security is traded • Nature of post-trade settlement, custody and non-U.S. exchanges For transactions in over-the-counter markets, achievement of best execution typically includes an analysis of counterparty creditworthiness, counterparty diversification, and existing counterparty exposure, as well as other counterparty and market factors as described above. Geode’s best execution policy applies to all transactions in all instruments, regardless of the fund or account. Best Execution Monitoring and Trade Cost Analysis Geode utilizes independent third-party vendors and systems to assist in the evaluation of trading costs for equities, futures, and FX transactions processed by Geode’s trading desk. The evaluation process occurs for trades across all Client Accounts and may include an assessment of trading slippage (e.g. the difference between benchmark costs and actual trading cost), as well as an examination of trading efficiency, whereby costs are examined on a trade-by-trade basis. In addition to third-party trading cost analysis, Geode has proprietary tools that allow traders to check for reasonableness of the trading costs. The traders review trading cost analysis on a regular basis. For certain OTC transactions, best execution and transaction cost analysis are evaluated by traders based on selecting the best available bid or offer. This selection process involves reviewing multiple published bids and offers to reach a conclusion as to available execution for specific securities, or actively engaging market makers to provide bids and offers to Geode on specific securities. In cases where securities trade in less liquid markets, seeking multiple quotations may not be in the client’s best interest and best execution is often achieved by negotiating with a market maker through exclusive or working instructions. Best Execution Oversight Geode’s investment team and Operations Committee regularly review trading costs and best execution. Portfolio managers and traders continuously monitor Geode’s trading practices, including reviewing relevant information and evaluating capabilities provided by the broker-dealers. At least quarterly, Geode Compliance confirms that the various provisions of this policy are upheld by reviewing trade cost analyses (including designated execution levels, if any) and records for both exchange and OTC transaction activity. Brokerage and Research Services Geode may execute portfolio transactions with broker-dealers that, in connection with the execution of such transactions, provide brokerage or research services, consistent with Section 28(e) of the Securities Exchange Act of 1934. Currently, Geode does not enter into traditional soft dollar arrangements in which it uses client brokerage to obtain research or other services from broker-dealers where there is an explicit target or ratio linked to Geode’s commission business with such broker-dealers. Geode may receive and consume market research, risk monitoring services and algorithmic trading services as part of execution only transactions with these broker-dealers, but only where such benefits are incidental and there is no formalized arrangement with an explicit target or ratio linked to Geode’s commission business with such broker-dealers. Geode does not pay for this incidental research and services or select broker-dealers on the basis of research it may receive.

Transactions Among Clients Geode has the ability to execute interfund trades (cross trades across client accounts) in circumstances where certain conditions are met and will follow its cross-trading policies and procedures in connection with such trades in accordance with Rule 17a-7 under the Investment Company Act. Trade Allocation Policies Geode recognizes that aggregating trade orders for execution may be advantageous in reducing transaction costs and avoiding inequities that can arise when placing orders independently. When feasible and consistent with Geode’s duties to each client and permitted by applicable laws and regulations, advisory contracts and investment objectives, Geode will seek, but is not required, to place orders for the same security and execution criteria through a blocked trade order. Any aggregation and allocation of trade orders must be performed in accordance with Geode’s established allocation methodologies. Trades are executed by the trading desk based on orders received from portfolio manager(s). Allocations are typically done electronically, in most cases without any manual intervention, unless lot sizes or other aspects of the allocation require manual adjustment. Each client participating in the blocked trade order will receive the same average price and shall be charged the same commission rate. Fair and equitable treatment of client accounts over time is the principle underlying Geode’s allocation procedures. All trade allocations will be executed in a manner consistent with Geode’s fiduciary duty and its obligation to provide best execution in accordance with applicable federal securities laws, while taking into account all relevant factors. When, in Geode’s opinion, the supply/demand of a security or instrument is insufficient under the circumstances to satisfy all outstanding orders (i.e. a partial fill), Geode’s standard allocation methodology is that the executed portion of the order be allocated on a pro-rata basis amongst the participating client accounts in proportion to the size of the original order placed for each client account. Geode’s trade allocation policies identify circumstances under which it is appropriate to modify or deviate from the general allocation criteria and describe the alternative procedures. For example, if a standard allocation would result in a Client Account, or an account advised by its affiliates (if applicable), receiving a very small allocation (e.g., on account of small asset size), the account may receive an increased allocation to achieve a more meaningful allocation, or the account may receive no allocation. To identify and mitigate potential conflicts of interest, Geode monitors trading of Client Accounts across all strategies to ensure that trading is conducted in a fair and equitable manner. Geode's portfolio managers may purchase equity securities in initial or secondary public offerings when such securities become available and are consistent with the investment objectives of eligible accounts. When initial or secondary purchase orders exceed available supply, allocations will be made on a pro-rata basis amongst the participating client accounts in proportion to the size of the original order placed for each client account. Any exceptions to Geode’s trade allocation policies (i.e., special allocations) must be approved by senior investment or trading personnel and reviewed and documented by Geode Compliance.

Geode principally provides investment advisory or sub advisory services to registered investment companies and other pooled investment vehicles and receives compensation based on a percentage of assets under management and fixed fees. While Geode maintains solicitation arrangements with brokerdealers (the “Solicitors”), these agreements are not actively used for solicitating registered investment companies, pooled investment vehicles and other institutional clients.

Geode has no information applicable to this Item.

On a continuous basis, portfolio managers manage, monitor, and review their assigned Client Accounts. Portfolio managers are responsible for the suitability and appropriateness of holdings and transactions in light of the Client Account’s specific investment objective and strategy, guidelines, restrictions and regulatory requirements, as applicable. Client Accounts are also routinely reviewed by investment oversight personnel for compliance with investment guidelines, restrictions, and applicable regulatory requirements. The Chief Investment Officer oversees the respective portfolio managers and their Client Accounts, including the number of accounts assigned to each portfolio manager. The boards of the Funds periodically review the activities of the applicable Fund for which they are required to oversee. Geode also provides investment advisory services to other entities, or clients of other entities, related or unrelated to Geode. These entities, or their clients, may similarly review and conduct oversight of the activities within their accounts. Geode communicates regularly with its clients to discuss all aspects of the portfolios to which Geode provides investment advisory services. In some cases, Geode provides periodic written account reports to its clients. In some cases, these reports include, among other information, securities purchased and sold, portfolios and brokerage commissions paid, portfolio composition, performance and market information. Some clients also receive periodic written compliance certifications and compliance reports from Geode.

Geode is not currently deemed to have custody over any Client Accounts as defined under Rule 206(4)-2 of the Advisers Act (the “Custody Rule”).

Geode’s fiduciary duty requires it to give investment advice that is suitable and appropriate to a particular client, and to have an adequate basis in fact for its investment recommendations. Geode is required to provide a certain amount of individualized treatment to its clients. Geode’s discretionary authority is limited to the purchase and sale of investments, selection of brokers, negotiation of commission rates, and its client investment objectives and investment policy restrictions. The portfolio composition within the same investment objectives and strategies may, at any given time, differ as to securities invested,

security and industry weightings, and cash levels. As a result, the performance of a Client Account within a particular investment strategy may differ from other Client Accounts, or other accounts advised by Geode’s affiliates, with similar or identical investment objectives and strategies. Clients should not expect that the performance of their portfolios will be identical to the performance of such other portfolios with similar investment objectives and strategies. Geode, in its role as investment adviser, has investment management and trading discretion for certain Client Accounts and provides advice and trade execution services for certain other Client Accounts. Geode recognizes that it has a fiduciary duty to all Client Accounts it provides investment management services. Geode further recognizes that this duty requires fair, equitable and ethical treatment of all of the Client Accounts so that they share in the expertise and benefits of collective management and trading while providing full consideration of the individual investment objectives, policies, limitations and other requirements of each Client Account. Geode and its affiliates employ policies to provide guidance to its investment professionals as to the fulfillment of Geode’s fiduciary duties and to establish procedural safeguards for the management and resolution of actual or potential conflicts of interest among Client Accounts and between Client Accounts and accounts advised by Geode’s affiliates. When selecting securities and determining amounts, Geode observes the investment policies, limitations and restrictions of the specific Client Account for which it provides investment management services. For the Funds, Geode’s authority to trade securities is also limited by certain federal securities and tax laws that require diversification of investments. Client investment guidelines and restrictions must be provided to Geode in writing. Geode reviews each advisory contract to ensure that it complies with applicable law. Geode also is responsible for ensuring that the advisory contract is not inconsistent with disclosures in its Form ADV. Prior to opening a managed account for a client and at least annually thereafter, Geode will determine whether the client appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the U.S. Department of Treasury in consultation with the federal regulators.

As an investment adviser, Geode holds discretionary voting authority over most of its client accounts. Geode understands its obligations with respect to voting for clients and will apply a voting methodology for clients in a manner that Geode believes represents the best interests of its clients. Except in cases where clients have dictated separate voting guidelines, Geode’s voting methodology is applied in a unified manner across all clients consistent with established proxy voting policies (“Voting Policies”), which seek to ensure that proxies are voted in the clients’ best interests and that Geode’s proxy voting activities comply with applicable rules and regulations. Geode’s Voting Policies are designed to (1) establish a framework for Geode’s decision-making with respect to proxy voting in client accounts and (2) set forth operational procedures for the oversight and execution of Geode’s proxy voting responsibilities. In certain limited instances, Geode clients may request that client-approved proxy voting guidelines are required to be followed. In these rare instances, a third-party proxy provider is engaged to vote proxies in accordance with such client-approved guidelines rather than the Voting Policies

Third-Party Proxy Advisory Firms Geode has engaged a third-party proxy advisory firm (“Proxy Agent”) to act as Geode’s proxy voting agent (“Proxy Agent”) providing Geode with vote execution and administration services including, operational, recordkeeping and reporting services. Geode also uses research and analysis relating to general corporate governance issues and specific proxy items from proxy advisory firms. Geode performs oversight of the Proxy Agent’s implementation and execution of the Voting Policies. This oversight typically includes a review of the Proxy Agent’s application of the Voting Policies and an assessment of the adequacy and quality of the Proxy Agent’s internal controls and policies and procedures, including those related to potential conflicts of interest. Proxy Voting Process Except in cases where clients have dictated separate voting guidelines, Geode retains the responsibility for voting proxy ballot items in accordance with the Voting Policies and does not otherwise reference the Proxy Agent’s voting policies. To help facilitate the vote execution process, the Proxy Agent prepares a written analysis and recommendation of each proxy ballot item based on the Proxy Agent’s application of Geode’s Voting Policies. The Proxy Agent generally pre-populate and submit votes for proxy ballot items in accordance with the Voting Policies. If the Proxy Agent or Geode becomes aware that an issuer has filed, or will file, additional proxy solicitation materials sufficiently in advance of the voting deadline, the Proxy Agent and Geode will generally endeavor to consider such information where such information is viewed as material in Geode’s discretion when casting votes on behalf of client accounts. In certain instances, this may result in an override, or a revised recommendation issued by the Proxy Agent. In circumstances where the Voting Policies do not address the specific matter or where the Proxy Agent has operational limitations on applying the Voting Policies, the Proxy Agent will refer the ballot back to Geode for vote review and processing. Geode aims to vote all shareholder meetings; however, when deemed appropriate, Geode reserves the right to refrain from voting certain meetings, for example in cases where: • Power of attorney documentation is required. • Issuer-specific beneficial owner documentation or certifications are required. • Voting is not permissible due to sanctions affecting the company. • Voting occurs in certain share blocking markets where shares are subject to lockup periods during shareholder meeting dates. Securities Lending While Geode typically does not recall securities on loan for voting purposes because it views the revenue of the loan to be greater than the potential long-term financial value from the vote itself, Geode, in acting as a fiduciary for its clients, may determine on a case-by-case basis that the potential value of the vote outweighs the revenue from the loan and recall securities accordingly. Conflicts of Interest Due to its focused business model and the number of investments that Geode will make for its clients (particularly pursuant to its indexing strategy), Geode does not anticipate that actual or potential conflicts of interest are likely to occur in the ordinary course of its business. However, Geode believes it is essential to avoid having conflicts of interest affect its objective of voting in the best interests of its clients. Therefore, in the event that Geode, the Proxy Agent, or any other person involved in the analysis or voting of proxies has knowledge of, or has reason to believe there may exist, any potential relationship, business

or otherwise, between the portfolio company subject to the proxy vote and Geode (or any affiliate of Geode) or their respective directors, officers, shareholders, employees or agents, such person shall notify the Chief Compliance Officer or his or her designee. Proxy Voting Policies Geode has adopted and implemented written Proxy Voting Policies that are reasonably designed to ensure that proxies are voted, consistent with its fiduciary obligations, in the long-term economic interests of its clients, which it believes will be furthered through (1) accountability of a company’s management and directors to its shareholders, (2) alignment of the interests of management with those of shareholders (including through compensation, benefit and equity ownership programs), and (3) increased disclosure of a company’s business and operations. Geode reserves the right to override any of the Voting Policies with respect to a particular shareholder vote when such an override is, in Geode’s best judgment, consistent with the overall principle of voting proxies in the best long-term economic interests of Geode’s clients. All proxy votes shall be considered and made in a manner consistent with the best interests of Geode’s clients (as well as shareholders of mutual fund clients) without regard to any other relationship, business or otherwise, between the portfolio company subject to the proxy vote and Geode or its affiliates. Geode will vote with management’s recommendation on shareholder proposals concerning environmental or social issues, as Geode believes management and the board are ordinarily in the best position to address these matters, unless Geode believes the proposals meet the following conditions (i) request disclosure of new or additional information that is material to investors, and increase or preserve shareholder value by improving transparency into the company’s processes and governance relating to the topic of the proposal, and (ii) would not be impractical or overly burdensome for the company to comply with. Geode may take action against the re-election of board members if there are serious concerns over an issuer’s approach to environmental or social issues. For ballots related to proxy contests, mergers, acquisitions and other organizational transactions, Geode may determine it is appropriate to conduct a company specific evaluation. Corporate governance standards, legal or regulatory requirements and disclosure practices in foreign countries can differ from those in the United States. When voting the securities of non-US issuers, Geode will evaluate proposals in accordance with the Voting Policies to the greatest extent possible but will also take local market standards and best practices into consideration. In the event local market standards and best practices in a non-US jurisdiction differs with (or are not specifically covered by) the Voting Policies, Geode will generally vote in accordance with such local market standards and best practices. A copy of Geode’s Voting Policies, as most recently updated in February 2026, is available on Geode’s website at the following link: https://www.geodecapital.com/info. A client can contact Geode directly for information on how proxies were voted on such client’s behalf.

Geode has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.