GOLDMAN SACHS ASSET MANAGEMENT, L.P.

This Brochure relates to GSAMLP, GSAMI, GSAMC, GSAMHK and GSAMS.1 The Registrants are part of The Goldman Sachs Group, Inc. (“GS Group”), a public company that is a bank holding company and financial holding company under the Bank holding Company Act of 1956, as amended (“BHCA”) and a world-wide, fullservice financial services organization. GS Group and its subsidiaries (“Goldman Sachs”) deliver a broad range of financial services to a large and diversified client base that includes corporations, financial institutions, governments and individuals. For business and regulatory reasons, Goldman Sachs has established certain information barriers and other policies designed to address information sharing between different businesses within Goldman Sachs (including within GSAM), as discussed throughout this Brochure. The Registrants, together with various affiliates as described in this Brochure, comprise the asset management business of Goldman Sachs Asset & Wealth Management (“Asset & Wealth Management”). As used in this Brochure, “GSAM” refers to the various business units (also referred to as teams) that perform investment advisory services on behalf of the asset management business of Asset & Wealth Management. The disclosure contained in this Brochure applies to each Registrant, except where a specific Registrant is identified or where the context clearly indicates that such disclosure applies to fewer than all Registrants. This Brochure also describes the investment advisory services provided by GSAM to clients of the Private Wealth Management (“PWM”) unit of Goldman Sachs & Co. LLC (“GS&Co.”).

Principal Owners and Operating History of Registrants GSAMLP is wholly-owned by GSAM Holdings LLC, a wholly-owned subsidiary of GS Group. GSAM Holdings LLC is also the general partner of GSAMLP. GSAMLP has been providing financial solutions for investors since 1988. GSAMI is wholly-owned by Goldman Sachs Asset Management International Holdings Limited, an indirect wholly-owned subsidiary of GS Group. GSAMI, which is regulated by the Financial Conduct Authority (“FCA”), as well as the SEC, has been providing financial solutions for investors since 1990. GSAMC is wholly-owned by Goldman Sachs Asset Management International Holdings LLC (“GSAMIH”), an indirect whollyowned subsidiary of GS Group. GSAMC, which is regulated by the Financial Services Agency, the Kanto Financial Bureau, the Ministry of Land, Infrastructure, Transport and Tourism, the Securities and Exchange Surveillance Commission, the Tokyo Metropolitan Government and the SEC, has been providing financial solutions for investors since 1990. GSAMHK is a Hong Kong company and is an indirect wholly-owned subsidiary of GS Group. The sole shareholder of GSAMHK is GSAMIH. GSAMHK is regulated by the Securities and Futures Commission of Hong Kong and the SEC.

Each of GSAMI, GSAMC, GSAMHK and GSAMS has its principal office and place of business outside the United States. This Brochure is provided to their U.S. clients in connection with their advisory services to U.S. clients and U.S. investors. The Investment Advisers Act of 1940, as amended (the “Advisers Act”) and other U.S. federal securities laws generally will not apply to a foreign registered investment adviser’s relationship with its non-U.S. clients outside of the United States. Accordingly, the provisions of such U.S. laws and underlying regulations, which may include various mechanisms designed to protect investors, will not be applicable to a non-U.S. client’s relationship with GSAMI, GSAMC, GSAMHK, or GSAMS, and GSAM makes no representation that such protective mechanisms will be available. Page | 5

GSAMS is a Singapore company and is an indirect wholly-owned subsidiary of GS Group. The sole shareholder of GSAMS is GSAMIH. GSAMS is regulated by the Monetary Authority of Singapore and the SEC.

GSAM’s Advisory Services GSAM’s advisory services are offered through a variety of investment products and arrangements, depending on the strategy. These include separately managed accounts (either directly or through wrap fee programs) and pooled investment vehicles such as mutual funds and private investment funds. Depending on the strategy, investment advice to clients is provided on a discretionary or non-discretionary basis. GSAM also advises individual and institutional investors with regard to alternative investments, including hedge funds, private equity funds, funds of funds, co-investments and other opportunities. Depending on the investment strategy employed on behalf of a particular client and the investment team managing a particular client’s assets, GSAM’s advisory services include, but are not limited to, portfolio construction, portfolio evaluation, portfolio rebalancing, asset allocation, risk assessment, risk management, liquidity management, diversification solutions, customized hedging, tactical investments, credit analysis, review of investment and co-investment opportunities, investment structuring, reporting and accounting services, and the review, selection, and oversight of third-party managers. GSAM also provides retirement plan consulting services, as well as solutions unique to life, health, property, and casualty reinsurers and reinsurance clients, and the negotiation and administration of Stable Value Contracts. GSAM also offers goal and risk-based financial planning and portfolio management services (such services are referred to herein as “Managed Account Services”). Managed Account Services provided by GSAM are generally delivered to accounts (“Enrolled Participant Accounts”) for enrolled plan participants or retail investors (“Enrolled Participants”) through an automated software platform (the “Software Platform”) developed by GSAM. For certain investment strategies, GSAM provides model portfolios to investment advisers that are affiliated with Goldman Sachs (“Affiliated Advisers”), as well as investment advisers that are unaffiliated with Goldman Sachs, including (i) investment advisers that are not controlled by Goldman Sachs but in which certain Advisory Accounts hold equity, profits or other interests, (ii) investment advisers, including registered investment advisers, with which Goldman Sachs has business relationships (collectively, “Unaffiliated Advisers” and, together with Affiliated Advisers, “Advisers”), and (iii) brokerdealers, technology providers, turnkey asset management providers, and other financial intermediaries that are unaffiliated with Goldman Sachs, in each case that use such model portfolios to assist in developing their own investment recommendations and managing their client accounts. In addition, as further described in Item 12, Brokerage Practices, GSAM also executes portfolio transactions at the direction of certain Advisory Accounts. Goldman Sachs can invest in, and currently maintains a minority investment in certain of these financial intermediaries. In addition, GSAM provides services incidental to managing Advisory Account assets, including hedging interest rate or currency risk for Advisory Accounts and related cash management, disposing of assets distributed in kind by Advisers, trade order transmission and execution services, and providing Advisory Accounts with access to due diligence reports and other information with respect to one or more Underlying Funds and Unaffiliated Advisers (“Diligence Reports”). Incidental services may also include entering into and negotiating the terms and conditions of agreements related to the management of client assets for discretionary accounts, providing publications and reports to clients on a variety of topics, providing nonpersonalized investment-related plan implementation and educational services, assisting clients in the review, search and selection of a variety of service providers for their programs, and providing searches for, or evaluations of, retirement income or annuity-based products. GSAM also provides model asset allocation portfolios and analysis of third party Page | 6

manager fees, comparative analysis of fees and expenses, and analysis of components of fees and expenses. GSAM may also use artificial intelligence to support its provision of investment advisory services. For information about GSAM’s strategies and solutions, please see Item 8, Methods of Analysis, Investment Strategies and Risk of Loss.

INVESTMENT RESTRICTIONS Clients have the option to impose reasonable restrictions on the management of their separate accounts, including restricting particular securities or types of investments, provided that GSAM accepts such restrictions. Any such restrictions will be reflected in the investment guidelines or other documentation applicable to the Advisory Account. GSAM may, in its discretion, hold the amount that would have been invested in the restricted security in cash or money market funds, invest in substitute securities, or invest it across the other securities in the strategy that are not restricted. Absent specific instructions to the contrary, certain types of account limitations requested by clients, for example prohibiting investments in particular industries or limiting investments to those in certain socially responsible categories, may be defined or identified by reference to information provided by a third-party service provider selected by GSAM. GSAM will generally apply such restrictions based on GSAM’s internal policies and procedures or methodologies and the policies and methodologies of the service provider. The methodology used by GSAM or these service providers to analyze companies may change without notice to clients. There can be no assurance that the information provided by any such service provider is complete or accurate. See also Item 8, General Risks—Environmental, Social Impact, and Governance Considerations. Unaffiliated Advisers appointed by GSAM on behalf of clients or Manager of Manager Accounts are responsible for making investment decisions consistent with the investment guidelines and restrictions developed by GSAM. Where GSAM is the investment adviser to a pooled investment vehicle, investment objectives, guidelines and any investment restrictions are not tailored to the needs of individual investors in those vehicles, but rather apply to the vehicle and are described in the prospectus or other relevant offering document for the vehicle. When an XIG Program Fund invests in a third-party managed Underlying Fund, investment objectives, guidelines and any investment restrictions of the third-party managed Underlying Fund are described in the prospectus or other relevant offering document for the third-party managed Underlying Fund. As part of Goldman Sachs, a global financial services organization that is subject to a number of legal and regulatory requirements, GSAM is subject to, and has itself adopted, internal guidelines restrictions and policies that restrict investment decisions and activities on behalf of Advisory Accounts under certain circumstances. See Item 11, Code of Ethics, Participation or Interest in Client Transactions and Personal Trading—Participation or Interest in Client Accounts— Firm Policies, Regulatory Restrictions, and Certain Other Factors Affecting Advisory Accounts.

Additional Investment Restrictions Applicable to GSAM Stable Value Advisory Accounts For retirement plans and other Advisory Accounts that have a “stable value” or similar investment objective, providers of wrap, separate account or other benefit responsive agreements (“Stable Value Contracts”) typically require that the Advisory Account be managed within specified guidelines as a part of their underwriting and contract process. These guidelines are generally in addition to those imposed by the Advisory Account, and limit the scope or types of investments that GSAM might otherwise include within an Advisory Account’s portfolio, which could result in a lower return to investors. These restrictions typically also apply to Unaffiliated Advisers or Underlying Funds that are included within an Page | 7

Advisory Account’s portfolio and, with respect to Underlying Funds, could affect investors who would not otherwise be subject to these limitations (e.g., investors that do not have “stable value” or a similar objective).

Read the rest in the brochure

Separately Managed Accounts Clients generally pay advisory fees for separate account management based on a percentage of assets (generally of the net asset value of the assets, or, with respect to certain Advisory Accounts, the book value or the levered or notional value of the assets) in their Advisory Accounts. Certain clients also pay advisory fees for separate account management based on other criteria, including, for example, based on the amount of assets a client determines to allocate to investments recommended by GSAM in respect of a non-discretionary Advisory Account. In addition, certain clients pay a flat fee for certain types of advisory services, such as asset allocation advice and the provision of model portfolios. The actual fees, minimum fees and minimum account sizes for GSAM may be negotiated, and a client could pay more or less than the fees set forth in this Brochure, or more or less than similar clients or clients invested in similar strategies. Amounts may vary as a Page | 12

result of negotiations, discussions and/or factors such as the particular circumstances of the client, the size and scope of the overall client relationship, client customization of the investment guidelines, additional or differing levels of servicing, or as may be otherwise agreed with specific clients. Servicing arrangements such as reporting also varies among clients. In some cases, clients with multiple Advisory Accounts may be able to aggregate accounts managed by GSAM within each product or across Advisory Accounts, for purposes of applying lower fee rates at higher asset levels (referred to herein as “breakpoints”) or reduced fee schedules. Registrants, in their discretion, with respect to certain clients, agree to lower fees, waive minimums on fees, provide lowest available fee arrangements, or allow credits or offsets relating to certain types or specified amounts of expenses. Clients that negotiate fees with differing breakpoints, including flat fees and performancebased fees, may pay a higher fee than the fees set forth in this Brochure as a result of fluctuations in the amount of the client’s assets under management and account performance. Please see Appendix A for the fee schedules generally attributable to separately managed accounts advised by each of GSAMLP, GSAMI, GSAMC, GSAMHK and GSAMS. For certain separately managed accounts, GSAMLP does not maintain a standard fee schedule. Actual fees are individually negotiated with each Advisory Account client, vary depending on a number of factors, including those described above, and are set forth in the governing documents for the applicable Advisory Account. In certain cases, GSAM is also compensated for performing diligence on, and advising clients whether or not to participate in, potential investment opportunities for such clients’ Advisory Accounts that are not otherwise made available to other Advisory Accounts or in which other Advisory Accounts do not otherwise participate. The compensation that GSAM receives in respect of such diligence and advice will vary, and may be dependent on the clients’ determination to participate in the potential investment opportunities. Pooled Investment Vehicle Fees GSAM acts as investment adviser to pooled investment vehicles such as mutual funds, collective investment trusts, private investment funds, and other pooled investment vehicles (e.g., hedge funds, private equity funds, funds of funds, private credit funds, real estate funds and business development companies). GSAM’s fees for such services are based on each investment vehicle’s particular structure, investment process, and other factors. GSAM generally receives a management fee for management of non-private investment funds and a management fee and an incentive fee or allocation (which, in certain cases, takes the form of a carried interest and which, in certain cases, is received by an affiliate of GSAM) from private investment funds (other than certain categories of private investment funds, including but not limited to certain XIG Program Funds and long-only funds), business development companies, and certain registered investment companies. The amount and structure of the management fee, incentive fee and/or allocation varies from fund to fund (and may vary significantly depending on the investment fund) and is set forth in the prospectus or other relevant offering document for each fund. In certain cases, investors receive fee reductions of all or a portion of the management fee (and/or incentive fee or allocation) attributable to that investor’s interest in the pooled investment vehicle, or invest fee free in pooled investment vehicles and pay negotiated fees outside of the pooled investment vehicle, which may be based on a separate fee schedule agreed upon by GSAM and/or its affiliates and the applicable investor. Certain of GSAM’s fee structures create an incentive for GSAM to cause the pooled investment vehicles to make investments earlier in the life of such vehicle than otherwise would have been the case, redeploy investment proceeds in order to receive ongoing asset-based fees, or defer the disposition of a poorly performing investment in order to defer any potential clawback obligation, continue to receive asset-based management fees, or possibly receive a larger carried

Page | 13

interest and/or incentive allocation if the value of the investment increases in the future. GSAM receives similar fees from other types of vehicles (e.g., securitization vehicles) in respect of the advisory services GSAM provides to such vehicles. Under the governing documents of an Advisory Account, GSAM may offset some of, or all of, certain fees it receives from portfolio companies or Advisory Accounts against management fees otherwise payable by Advisory Accounts. If GSAM provides services and receives fees that could be characterized as more than one type of fee, GSAM will be incentivized to characterize those fees in a way that minimizes the management fee offset. In addition, from time to time determinations are made regarding the characterization of proceeds received by Accounts relating to an investment (including those proceeds distributed as capital to investors in the Accounts). Such determinations could include, but are not limited to, characterizing such proceeds as an amortization, distribution, prepayment of loan principal, and/or dividend recapitalization. It is possible that the characterization determined to apply could result in GSAM receiving greater management fees than would be the case under another characterization, and/or result in GSAM or an affiliate receiving performance-based compensation earlier than would be the case under another characterization. GSAM can, but is under no obligation to, rely on a determination by a third-party servicer with respect to any such characterization of proceeds. Furthermore, GSAM generally treats costs directly related to acquiring an asset (e.g., transaction fees and/or deal fees) as part of the total invested capital, rather than as expenses. To the extent management fees are calculated based on invested capital, this practice increases the basis on which management fees are calculated and results in greater management fees owed to GSAM. This conflict is exacerbated when the capitalized fees are paid to Goldman Sachs because in such cases Goldman Sachs receives both the transaction and/or deal fees and the management fee. Certain investors that are invested in pooled investment vehicles pay higher or lower fees and/or are subject to higher or lower carried interest and/or incentive allocations than similarly situated investors that are invested in the same pooled investment vehicle. Amounts, rates, breakpoints, hurdles or similar calculation methodologies vary as a result of negotiations, discussions and/or factors such as the particular circumstances of the investor, the size and scope of the overall relationship, whether the investor has a multi-strategy, multi-asset class or multi-product investment program with Goldman Sachs or GSAM, or as may be otherwise agreed with specific investors. Fees and allocations charged to investors may differ depending on the class of shares or other interests purchased. Master-feeder funds (i.e., structures in which investors invest in entities commonly referred to as feeder funds, which then invest their assets in other entities commonly referred to as master funds), XIG Program Funds, and certain other funds are subject to multiple levels of expenses and, in certain cases, are subject to multiple levels of fees. Certain pooled investment vehicles are also subject to subscription and/or redemption/withdrawal fees, including in connection with early redemption penalties, described in the relevant offering and governing documentation. Notwithstanding the foregoing, in certain cases, GSAM provides investment advisory services to funds without receiving any fee for such services. In these cases, Goldman Sachs may receive placement fees or compensation for other noninvestment advisory services from the funds, the investors in the funds (including Advisory Accounts), or from the companies or Underlying Funds in which the Goldman Sachs-managed funds invest. The terms of any such arrangements are disclosed in the governing documents or disclosure documents relating to the Goldman Sachs-managed funds. Management fees and incentive fees or allocations are generally not payable by funds raised for the benefit of Goldman Sachs employees.

Page | 14

Workplace Managed Account Services Fees For Workplace Managed Account Services, fees are generally paid to GSAM for its advisory services (“Workplace Managed Account Fees”), unless such fees are waived by GSAM. The Workplace Managed Account Fees are generally calculated based on the Enrolled Participant Account’s average daily balance and begin accruing on the date that an Enrolled Participant’s enrollment is processed, unless such fees are prorated for partial periods during which the Enrolled Participant was enrolled in the Workplace Managed Account Services. Assets held within the Enrolled Participant Account that are not managed by GSAM are excluded from the account balance for fee calculation purposes. Unless otherwise agreed to with the firm that engaged GSAM to provide Workplace Managed Account Services to Enrolled Participant Accounts (a “WMA Institution”) or Plan Sponsor, an authorized service provider retained by the WMA Institution or Plan Sponsor (e.g., a recordkeeper) will collect the Workplace Managed Account Fees on a quarterly or monthly basis, unless otherwise specified in writing, and remit the portion of such Workplace Managed Account Fees owed to GSAM for its advisory services, unless such fees are waived by GSAM. If investment funds that pay an investment advisory fee to GSAM or its affiliate are selected by a WMA Institution, Plan Sponsor or other third-party fiduciary for the plan’s investment menu and are used in the Workplace Managed Account Services, then the investment advisory fees received by GSAM or its affiliate for the investment funds generally will be excluded from or credited on a pro rata basis against the Workplace Managed Account Fees charged by GSAM, unless such fees are waived by GSAM. Retail Managed Account Services Fees For Retail Managed Account Services, the WMA Institution sets the advisory fee (“WMA Institutional Fee”) charged to Enrolled Participants, which is based on a percentage of an Enrolled Participant’s assets under management. The WMA Institutional Fee includes the advisory fees of GSAM and the WMA Institution, and brokerage commissions, taxes, charges and other costs related to the purchase and sale of ETFs and other investment vehicles, custody fees, portfolio accounting fees, and reporting fees. GSAM and the WMA Institution will negotiate the portion of the WMA Institutional Fee that is to be allocated to GSAM for the Retail Managed Account Services. The WMA Institutional Fee generally begins accruing on the date that an Enrolled Participant’s enrollment is processed and is deducted from the Enrolled Participant’s account quarterly in arrears, unless otherwise specified in writing. The WMA Institutional Fee does not cover certain charges associated with securities transactions, including: (i) dealer markups, markdowns or spreads charged on transactions in over-the-counter securities; (ii) costs relating to trading in certain foreign securities; (iii) the internal charges and fees that are imposed by any investment products, including, but not limited to, mutual funds, CITs, or ETFs, such as operating expenses, management fees, redemption fees, 12b-1 fees and other fees and expenses, including regulatory fees; (iv) brokerage commissions or other charges imposed by broker-dealers or entities other than the Enrolled Participant Account’s custodian if and when trades are cleared by another broker-dealer; (v) the charge to carry tax lot information on transferred interests in mutual funds, CITs, or ETFs, postage and handling charges, returned check charges, transfer taxes; and (vi) stock exchange fees or other fees mandated by law. Details regarding WMA Institutional Fees are described in the Enrolled Participant Account agreement and/or applicable WMA Institution’s brochure. Certain WMA Institutions will require an Enrolled Participant’s account to be minimally funded before being implemented.

Page | 15

Read the rest in the brochure

GSAM and its investment teams offer a broad range of products across asset classes, regions and the risk spectrum. These investment teams are described below. GSAM’s investment teams use a variety of proprietary and non-proprietary analysis and data to evaluate investment options and formulate investment advice for Advisory Accounts. The methods of analysis and particular account

Page | 38

characteristics will vary depending on the particular investment strategy offered, but may include fundamental or quantitative (including asset allocation models) analysis as well as ESG and impact strategies. Additional sources of research information include other general information and analysis as may be appropriate under the circumstances. Advisory Accounts differ from portfolio management group to portfolio management group, and guidelines, strategies and substrategies differ among Advisory Accounts. The investment processes used by GSAM’s investment teams consider a wide range of factors, indicators, and/or risks, and no one factor or other consideration is determinative. For certain strategies, as part of the applicable team’s investment process, the investment team may integrate ESG factors with traditional fundamental factors. The identification of a risk related to an ESG factor will not necessarily exclude a particular security and/or sector that, in the applicable investment team’s view, is otherwise suitable and attractively priced for investment, and certain teams may invest in a security or sector without integrating ESG factors or considerations into their fundamental investment processes. The relevance of specific traditional fundamental factors and ESG factors to the fundamental investment process varies across asset classes, sectors and strategies. Investment teams may utilize data sources provided by third-party vendors and/or engage directly with issuers when assessing the above factors. Advisory Account clients and investors in pooled investment vehicles should understand that all investment strategies and the investments made pursuant to such strategies involve risk of loss, including the potential loss of the entire investment, which clients and investors should be prepared to bear. The investment performance and the success of any investment strategy or particular investment can never be predicted or guaranteed, and the value of a client’s or an investor’s investments will fluctuate due to market conditions and other factors. The investment decisions made and the actions taken for Advisory Accounts will be subject to various market, liquidity, currency, economic, political and other risks, and investments may lose value. Please see this Item 8, Methods of Analysis, Investment Strategies and Risk of Loss—Material Risks for Significant Investment Strategies and Particular Types of Securities for information about the risks associated with security types and investment techniques used by GSAM. Fundamental Equity The Fundamental Equity team conducts bottom-up fundamental research across a broad range of country-specific and multi-regional portfolios in choosing securities for an Advisory Account. The team also uses macro analysis of numerous economic and valuation variables to anticipate changes in company earnings and the overall investment climate. The team is able to draw on the research and market expertise of securities dealers, including affiliates of GSAM. The team currently manages strategies across a broad range of capitalizations and styles, spanning U.S., global-developed, growth and emerging markets. The team’s Advisory Accounts generally invest in common stocks, preferred stocks, interests in real estate investment trusts (“REITs”), convertible debt obligations, and convertible preferred stocks. Other Advisory Account investments include equity interests in trusts, partnerships, joint ventures, SPACs, limited liability companies and similar enterprises, Master Limited Partnerships (“MLPs”), warrants and stock purchase rights and synthetic and derivative instruments that have economic characteristics related to equity securities. Global Fixed Income and Liquidity Management The Global Fixed Income team seeks to capitalize on fixed income investment opportunities across countries, currencies, sectors and issuers utilizing a dynamic fundamental investment process. The team offers single-sector, multi-sector, short duration and government and municipal/tax-free strategies and uses independent specialist teams for bottom-up and topdown analyses, and to generate strategies within their areas of expertise. The team generally establishes a “risk budget” or Page | 39

range that a particular Advisory Account may deviate from its applicable benchmarks with respect to sector allocations, country allocations, securities selection and, to a lesser extent, duration. Following analysis of risk and return objectives, the team allocates the overall risk budget to each component strategy to seek to optimize potential return and builds a diversified portfolio of individual securities consistent with each client’s overall risk and return objectives. When managing Advisory Accounts, portfolio managers dynamically adjust the mix of top-down and bottom-up strategies and strategy teams adjust strategies and security selections in seeking to optimize performance within their specialty areas. The Global Liquidity Management team within Global Fixed Income helps clients to construct liquidity management solutions that encompass commercial and government securities as well as multicurrency options using a dynamic fundamental investment process. The Global Liquidity Management team uses a combination of active duration management, term structure, and sector and security selection decisions. Duration and term structure decisions reflect the team’s view on the timing and direction of monetary policy, as well as an Advisory Account’s immediate and near-term cash requirements. Sector and individual security selection decisions also depend on Advisory Account guidelines, as well as on fundamental and quantitative sector research that seeks to optimize the risk/return profile of the portfolio. Security selection is restricted to issuers that meet certain credit standards. Insurance Asset Management The Insurance Asset Management team, which includes dedicated fixed-income portfolio managers and insurance-focused sector specialists that are integrated into the Global Fixed Income team, offers a broad range of investment solutions to life, health, property and casualty insurers, and reinsurance clients. The team develops investment solutions within customized capital and risk management frameworks, including assisting clients in assessing financial risk. The team also incorporates specialized insurance strategy, risk management, reporting and accounting services, unique to the needs of insurers. The team focuses on educating and assisting insurers in areas such as strategic asset allocation, asset liability management, capital management, peer analysis, capital and tax-efficient investment strategies. In providing this education and assistance, a team of professionals with experience in the insurance industry and quantitative analysis use risk and capital modeling optimization and stress testing capabilities based on Goldman Sachs’ proprietary optimization systems. As agreed with Advisory Accounts, the team’s fixed-income investment approach takes into account regulatory, capital, accounting and other client-specific requirements. The fixed-income investment strategies employed to manage assets may include: (i) modified total return strategies that are typically managed to total return objectives; and/or (ii) income/buy and hold strategies that are typically managed to specific, client-defined income, yield or spread targets. Where appropriate, the team also leverages the resources of other GSAM investment teams across asset classes with the goal of providing clients with diverse sources of risk-adjusted returns. Quantitative Strategies The Quantitative Strategies teams pursue a disciplined and systematic application of quantitative techniques (“Quantitative Strategies”) in the investment management process. These Quantitative Strategies are offered primarily through two separate channels: (i) the Quantitative Investment Strategies (“QIS”) team and (ii) the Quantitative Equity Solutions (“QES”) team. In implementing the Quantitative Strategies, the QIS and QES teams may rely on resources such as sophisticated risk modeling capabilities, algorithmic trading, transaction cost modeling and optimization-based portfolio construction. Each team will monitor and, from time to time, may make changes to the selection or weight of individual or groups of securities, currencies, or markets in which Advisory Accounts invest. Such modifications may result from changes in the quantitative Page | 40

methodology, changes in the manner of applying the quantitative methodology, changes in trading procedure, or adjustments to the outputs of the model in the qualitative or quantitative judgment of the team. Quantitative Investment Strategies The QIS team uses quantitative methodologies to manage portfolios across a wide variety of equity alpha, alternative risk premia, and rules-based factor investing strategies. The QIS team members focused on equity alpha strategies attempt to forecast expected returns on a global universe of stocks on a daily basis using proprietary models based on certain investment themes including, among others, fundamental mispricings, high quality business models, overall market sentiment and market themes and trends. Within these models, the QIS team may utilize artificial intelligence techniques, such as natural language processing and machine learning, to, among other things, help extract information from various textual or audio datasets. The QIS team members focused on alternative risk premia strategies create portfolios comprising liquid hedge fund beta and alternative risk premia strategies, including volatility and trend strategies. The methods and techniques that are utilized in the team’s investment processes include a customizable solution for implementing a hedge fund beta program as well as practical tools for analyzing and attributing an existing hedge fund portfolio; construction, risk-management, and implementation of long/short alternative risk premia portfolios across asset classes; and customized options-based overlay solutions for equity portfolios. The QIS team members focused on rules-based factor investing strategies design rules-based equity portfolios that seek exposure to common investment factors. The methods and techniques that are utilized in the team’s investment processes include ActiveBeta™ equity portfolios that employ a transparent, rules-based and patented methodology for constructing benchmark-aware factor portfolios that aim to achieve efficient exposure to a diverse set of investment factors. The team also offers customized multi-asset class allocations, risk management strategies, tactical investments and investment advisory solutions. As described above, for certain strategies, the multi-factor models used by QIS assess a wide range of indicators, which may include certain ESG indicators. These ESG indicators may include, but are not limited to, emission intensity, labor satisfaction, reputational concerns, governance and management incentives. QIS also may also seek to address certain environmental risks, such as climate transition risk by weighting stocks based, in part, on certain proprietary emissions metrics. The relevance and weightings of specific ESG indicators to or within the investment process vary across asset classes, sectors and strategies and no one indicator is determinative. QIS in its sole discretion may periodically update the indicators used in the investment decision-making process. The indicators applied by QIS are assessed in reliance on one or a number of third-party vendors, including third-party ESG vendors. QIS, in its sole discretion, retains the right to disapply data and/or ratings provided by third-party vendors where it deems the data and/or ratings to be inappropriate. Quantitative Equity Solutions The QES team designs and builds personalized portfolios and investment solutions tailored to the investment goals and objectives of both individual and institutional investors. The QES team strategies seek to deliver on a range of client goals, including tax-managed, factor-based, income-oriented, value-aligned, and environmental and socially responsible portfolios.

Page | 41

Read the rest in the brochure

GSAM provides investment solutions to a range of individual and institutional investors worldwide. GSAM’s clients include individuals, families and family entities, banks and thrift institutions, pooled investment vehicles, pension and profit sharing plans, trusts, estates, charitable organizations, insurance companies, corporations, and other business entities. In addition to those types of clients, GSAM provides investment advice to U.S. and non-U.S. government entities, sovereign wealth funds, local authorities and public international bodies, as well as mutual funds, closed end funds (including business development companies), exchange traded funds, interval funds, collective trusts, long-only pooled investment vehicles (direct and Manager of Manager Accounts that are pooled investment vehicles), hedge funds (direct and funds-of-funds), private equity funds, real estate funds, securitization vehicles and other private investment vehicles (e.g., XIG Program Funds). GSAM also has client and other relationships with other entities, including special purpose acquisition vehicles, operating companies, and commodity ETFs. GSAM provides various services to these entities, including management and other services in relation to their business strategies and operations. GSAM (or an affiliate of GSAM) receives compensation in exchange for these services, which may include asset and/or performance-based compensation or other forms of compensation (e.g., equity interests in such entities). GSAM does not provide services to these entities pursuant to investment advisory contracts and GSAM’s relationships with these clients are not investment advisory relationships. As a result, investors in such entities generally do not have the protections of the substantive provisions of the Advisers Act and may not have the protections of the substantive provisions of certain other laws and regulations. However, GSAM in its discretion may, and in many cases does, operate such entities in accordance with, and take such entities into account for purposes of, certain of the policies and procedures described herein. In particular, such entities generally receive allocations of opportunities from GSAM, and generally are included in GSAM’s allocation procedures, as described above in Item 6, Performance Based Fees and Side-By-Side Management—Side-By-Side Management of Advisory Accounts; Page | 37

Allocation of Opportunities. In addition, GSAM’s activities on behalf of such entities in certain situations creates conflicts of interest between such entities, on the one hand, and Advisory Accounts, on the other hand, that are the same as or similar to the conflicts that arise between Advisory Accounts, or between an Advisory Account, on the one hand, and an Account, on the other hand, as described in Item 6, Performance Based Fees and Side-By-Side Management and Item 11, Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. ACCOUNT REQUIREMENTS Except as described below with respect to Retail Managed Account Services Enrolled Participant Accounts, GSAM does not generally impose a minimum dollar value of assets in order to open or maintain an account. However, GSAM does consider the minimum annual fee an account is expected to generate when determining whether to open or maintain an account. GSAM may take into account the dollar value of assets expected to be managed in an account, as well as the type of investment strategy to be employed, in determining whether to open or maintain a separately managed account. Retail Managed Account Services Enrolled Participant Accounts are subject to a minimum account size of $5,000, unless such minimum is waived by GSAM in its sole discretion. In the case of consulting or Wrap Programs sponsored by certain broker-dealers, GSAM generally requires clients to have minimum assets under management of $100,000. The minimum account size applicable to GSAM clients with “dual contract,” “single contract” or sub-advisory managed account arrangements may differ from that applicable to GSAM clients participating in consulting or Wrap Programs. To open or maintain an Advisory Account with GSAM, clients are required to sign an investment advisory agreement that, among other things, describes the nature of the investment advisory authority given to GSAM. Under delegated authority from one or more of its affiliates, GSAM also manages certain accounts of its affiliates’ clients and receives a portion of the fee or other compensation paid by the client from the affiliate for such services. In such cases, the client will have entered into an investment advisory agreement with Goldman Sachs or with GSAM’s affiliate and not GSAM. In the case of certain separately managed accounts and private investment funds, U.S. investors must generally be “accredited investors” as defined in Rule 501(a) of Regulation D under the U.S. Securities Act of 1933, as amended (the “1933 Act”), “qualified purchasers” as defined in Section 2(a)(51)(A) of the Investment Company Act and “qualified eligible persons” under Rule 4.7 of the U.S. Commodity Exchange Act, as amended. The minimum amount investors must invest in such GSAM-managed funds and accounts is set forth in each such fund’s prospectus or other relevant offering document and varies from fund to fund depending on the particular investment product. Such minimum amount is typically between $500,000 and $25,000,000, although may be lower (as is the case for GSAM Employee Funds) or higher, and may be waived in the discretion of a fund’s general partner, managing member, board of directors, or other managing body.

Certain Advisory Accounts are subject to performance-based compensation (and in certain cases also include an assetbased compensation component). Performance-based compensation includes carried interest, override, incentive allocation, performance fees and other similar forms of performance-based compensation. Performance-based compensation arrangements for Advisory Accounts varies among clients and investment strategies. Certain Advisory Accounts are subject to performance-based compensation calculated by reference to the relevant high water marks for such Advisory Accounts, while other Advisory Accounts are subject to performance-based compensation that is paid only after a specified return has been achieved (a “preferred return”), the thresholds of which vary across Advisory Accounts. For example, Advisory Accounts (including hedge funds) that invest in readily marketable securities often provide for an asset-based fee based on the market value of the investments in the account at specified month or quarter ends and/or performance-based compensation calculated based on the applicable high water mark. Other Advisory Accounts, such as Advisory Accounts (including private equity funds) that invest in assets which lack a readily available market value, provide for an asset-based fee based on the investor’s capital commitment to the account or based on the amount of such commitment that is invested and performance-based compensation, typically in the form of a carried interest, that is subject to a preferred return. These different types of performance-based compensation result in certain Advisory Accounts paying higher or lower performance-based fees than other Advisory Accounts. Advisory Accounts that bear performance-based compensation reward GSAM for positive performance in those Advisory Accounts. Performance-based compensation arrangements provide a heightened incentive for portfolio managers to make investments that may present a greater potential for return but also a greater risk of loss, or that may be more speculative than would exist if only asset-based fees were applied. The simultaneous management of Advisory Accounts that bear performance-based compensation and Advisory Accounts that only bear an asset-based fee, or that bear performance-based compensation that is calculated in a different manner, creates a conflict of interest as the portfolio manager has an incentive to favor Advisory Accounts with the potential to bear greater fees when allocating resources, services, functions or investment opportunities among Advisory Accounts. For example, a portfolio manager will be faced with a conflict of interest when allocating scarce investment opportunities, given the possibly greater compensation from Advisory Accounts that bear performance-based compensation, as opposed to Advisory Accounts that bear no performance-based compensation. In addition, in cases where a particular Advisory

Page | 27

Account invests alongside other Advisory Accounts in the same investment opportunity, GSAM will have an incentive to manage certain investment or disposition decisions for such Advisory Accounts in a manner that maximizes the amount of aggregate performance compensation payable to GSAM, including not disposing of investments when it would otherwise be to the financial advantage of the particular Advisory Account, which could result in adverse consequences for the particular Advisory Account. To address these types of conflicts, GSAM has adopted policies and procedures under which allocation decisions may not be influenced by compensation arrangements and investment opportunities will be allocated in a manner that GSAM believes is consistent with its obligations and fiduciary duties as an investment adviser. GSAM’s policies and procedures relating to allocation of investment opportunities are described further below. Investment groups within GSAM are subject to these and/or other similar policies and procedures that are consistent with GSAM’s obligations and fiduciary duties as an investment adviser and that address circumstances that may be unique to their businesses. No assurance can be made that these policies and procedures will have their desired effect. Notwithstanding GSAM’s allocation policies, the availability, amount, timing, structuring or terms of investments available to particular Advisory Accounts, including Advisory Accounts engaging in the same or similar strategies, differ in certain cases. SIDE-BY-SIDE MANAGEMENT OF ADVISORY ACCOUNTS; ALLOCATION OF OPPORTUNITIES GSAM manages or advises multiple Advisory Accounts (including Advisory Accounts in which Goldman Sachs and personnel of Goldman Sachs have an interest) that have investment objectives that are the same or similar and that seek to make or sell investments in the same securities or other instruments, sectors or strategies. This creates potential conflicts, particularly in circumstances where the availability or liquidity of investment opportunities is limited. Areas in which such limited opportunities may exist include, without limitation, in local and emerging markets, high yield securities, fixedincome securities, direct loan originations, regulated industries, real estate assets, primary investments and secondary interests in private investment funds, direct or indirect investments in and co-investments alongside private investment funds, investments in MLPs in the oil and gas industry, IPOs/New Issues and privately-issued debt securities. Opportunities also exist where Advisers limit the number of investors in (or the size of) their Underlying Funds, or the amount of assets in accounts that they manage. For example, limited availability may exist with certain Advisers or with respect to certain classes of interests issued by an Underlying Fund that have better terms than other classes or where GSAM has negotiated different investment terms (including, without limitation, lower fees or more frequent liquidity than other investors) with an Adviser for itself and its clients but the Adviser limits the size of the investment by Goldman Sachs and its clients that will be subject to such terms. If GSAM wishes to transfer an existing investment that would be subject to the different terms or fee arrangements depending upon the Advisory Accounts to which it is transferred, GSAM faces potential conflicts in connection with the allocation of such investments among Advisory Accounts. To address these potential conflicts, GSAM has developed allocation policies and procedures that provide that GSAM Personnel making portfolio decisions for Advisory Accounts will make investment decisions for, and allocate investment opportunities among, Advisory Accounts consistent with GSAM’s fiduciary obligations. These policies and procedures could result in the pro rata allocation (on a basis determined by GSAM) of limited opportunities across eligible Advisory Accounts managed by a particular portfolio management team, but in other cases such allocation may not be pro rata. Furthermore, certain investment opportunities sourced by GSAM, or Goldman Sachs businesses or divisions outside of GSAM, may be allocated to Goldman Sachs for its own account or investment vehicles organized to facilitate investment by its current or former directors, partners, trustees, managers, members, officers, employees, and their families and related entities, including employee benefit plans in which they participate, and current consultants (“GSAM Employee Funds”), and not to Page | 28

client accounts. See Item 11, Code of Ethics, Participation or Interest in Client Transactions and Personal Trading, Participation or Interest in Client Transactions—Certain Effects of the Activities of Goldman Sachs and Advisory Accounts. Allocation-related decisions for Advisory Accounts are made by reference to one or more factors and suitability considerations. Factors may include:

Date of inception of the Advisory Account;

Advisory Account investment horizons and objectives (including with respect to portfolio construction and targeted returns);

Different levels of exposure to certain strategies, including sector oriented, concentrated new opportunities or other strategies;

Risk profile of the investment;

Client-specific investment guidelines, restrictions and instructions, including, without limitation, the ability to utilize leverage or hedge through short sales or other techniques;

Whether Advisory Accounts give GSAM discretion or request client approval for investments;

Whether the timing of the Advisory Account’s execution of the transaction has an adverse effect on other Advisory Accounts or GSAM potentially participating in the investment opportunity;

Current and expected future capacity of applicable Advisory Accounts;

Limits on GSAM’s brokerage discretion, including client directed brokerage arrangements;

Tax sensitivity and objectives of Advisory Accounts;

Cash and liquidity needs and other considerations, including, without limitation, availability of cash for investment (e.g., purchase orders for a Wrap Program account are generally only executed to the extent of available cash);

Relative sizes and expected future sizes of applicable Advisory Accounts and eligible capital;

Anticipated magnitude of the overall investment program for the then current year and any changes in the rate at which the program is carried out;

Expected future capacity of the applicable Adviser and/or Underlying Fund and limitations set by the applicable Adviser and/or Underlying Fund or other relevant parties;

Availability (or lack thereof) of other appropriate or substantially similar investment opportunities;

Whether an opportunity exists to invest in different layers in the capital structure of a company;

Legal and regulatory restrictions affecting certain Advisory Accounts or affecting holdings across Advisory Accounts, which may result in adjusting existing or future positions across Advisory Accounts and may consequently open up capacity for new Advisory Accounts or Advisory Account cash-flows;

Minimum denomination, minimum increments, de minimis threshold, maximum position sizes, and round lot considerations;

Limitations set by relevant parties (e.g., Unaffiliated Advisers) and any relevant contractual provisions;

Page | 29

Differences in benchmark factors and hedging strategies among Advisory Accounts;

Current investments held by Advisory Accounts similar to the applicable investment opportunity;

Whether an investment opportunity constitutes a follow-on investment with respect to a particular asset held in certain Advisory Accounts;

The relationship of Advisory Accounts with particular issuers, Unaffiliated Advisers or investment opportunities, or sourcing or other investment-related activities of Advisory Accounts or the GSAM teams managing such Advisory Accounts;

Reputational matters and other such considerations;

Suitability requirements and the nature of the investment opportunity;

GSAM’s perception of a potential co-investment party’s interest; and

The source of the investment opportunity.

Suitability considerations may include:

Relative attractiveness of an investment to different Advisory Accounts;

Concentration of industry sector, sub-strategy, or positions in an Advisory Account;

Appropriateness of a security for the applicable benchmark, if any, and benchmark sensitivity of an Advisory Account;

An Advisory Account’s risk tolerance, risk parameters and strategy allocations;

Use of the opportunity as a replacement for an opportunity that GSAM believes to be attractive for an Advisory Account but is otherwise unavailable to the Advisory Account (including for legal or regulatory reasons); and/or

Considerations relating to hedging a position in a pair trade.

Non-proportional allocations may occur across Advisory Accounts, including, without limitation, in fixed-income securities due to the availability of multiple appropriate or substantially similar investments in fixed-income strategies, as well as due to differences in benchmark factors, hedging strategies, or other reasons. In addition, the fact that certain personnel of Goldman Sachs are dedicated to one or more Advisory Accounts or clients is in certain cases a factor in determining the allocation of opportunities (including private equity opportunities and IPOs/New Issues) sourced by such personnel. Investment opportunities sourced by one portfolio management team may not be made available to Advisory Accounts managed by other portfolio management teams. In addition, certain portfolio management teams transact with Goldman Sachs on behalf of Advisory Accounts, whereas other portfolio management teams, including teams utilizing the same investment strategy, do not. As a result, certain Advisory Accounts receive allocations of certain investment opportunities, including IPO/New Issues and other profitable investments, that are not available to Advisory Accounts managed by portfolio management teams that do not transact with Goldman Sachs. GSAM, from time to time, develops and implements new trading strategies or seeks to participate in new trading strategies and investment opportunities. These strategies and opportunities are not employed in all Advisory Accounts or employed pro rata among Advisory Accounts where they are used, even if the strategy or opportunity is consistent with the objectives of such accounts. Page | 30

Read the rest in the brochure

GS&Co. is a registered broker-dealer. Certain of GSAM’s management persons are registered representatives of GS&Co. and act in such capacities if necessary or appropriate to perform their responsibilities.

Page | 89

COMMODITY POOL OPERATOR, COMMODITY TRADING ADVISOR, FUTURES COMMISSION MERCHANT REGISTRATION Each of GSAMLP, GS&Co. and GSAMI is registered with the CFTC as a commodity pool operator (“CPO”) and a commodity trading advisor (“CTA”), and GSAMS is registered with the CFTC as a CTA. GS&Co. is also registered with the CFTC as a futures commission merchant. Each of GSAMLP, GSAMI and GSAMS is a registered swap firm with the National Futures Association. In addition, certain of GSAM’s management persons are registered as associated persons and swap associated persons, and act in such capacities to the extent necessary or appropriate to perform their responsibilities. OTHER MATERIAL RELATIONSHIPS WITH AFFILIATED ENTITIES In certain cases, GSAM uses, suggests and recommends its own services and those of affiliated Goldman Sachs entities and business units. Fees paid in connection with such services, while believed to be customary compensation for relevant activities, is not always negotiated and, from time to time, could be more or less than what a comparable third party might charge. GSAM manages Advisory Accounts on behalf of certain affiliated Goldman Sachs entities, which creates potential conflicts of interest related to GSAM’s determination to use, suggest or recommend the services of such entities or business units. The particular services involved depends on the types of services offered by the affiliate or business unit. The arrangements may involve sharing or joint compensation, or separate compensation, subject to the requirements of applicable law. GSAM shares resources with or delegates certain of its trading, advisory and other activities for Advisory Accounts to other businesses within Goldman Sachs and/or to GSAM’s affiliates and portfolio management functions may be shared or moved between affiliated advisers. Particular relationships include, but are not limited to, those discussed below. Goldman Sachs’ affiliates will retain any compensation when providing investment services to, or in connection with investment activities of, Advisory Accounts, subject to applicable law. Compensation may take the form of referral payments, commissions, markups, markdowns, service fees or other commission equivalents. Advisory Accounts are not entitled to any such compensation retained by Goldman Sachs’ affiliates. Broker-Dealer; Derivatives Dealer Subject to applicable law and client consent, in some circumstances GSAM uses, or suggests or recommends that advisory clients use, the securities, futures execution, clearing, custody or other services offered by GSAM’s broker-dealer and other affiliates. These affiliates include (but are not limited to) GS&Co., Goldman Sachs International (“GSI”), Goldman Sachs (Asia) Securities Limited, Goldman Sachs Japan Co., Ltd., and Goldman Sachs Saudi Arabia. Clients pay for broker-dealer or other services performed by GSAM’s affiliates in addition to the advisory fee paid to GSAM. For accounts offered through PWM but managed by GSAM, transactions are executed according to GSAM’s policies and procedures regarding execution of trades. In addition, the broker-dealer affiliates that provide custodial services may benefit from the use of free credit balances (i.e., cash) in advisory clients’ accounts, subject to the limitation set forth in SEC Rule 15c3-3 under the U.S. Securities Exchange Act of 1934, as amended (the “1934 Act”). Free credit balances are payable to clients on demand. If negative interest rates apply, clients will be charged a fee in connection with such free credit balances. GSAM receives record keeping, administrative and support services from its broker-dealer affiliates. GSAM also obtains research ideas, analyses, reports and other services (including distribution services) from broker-dealer affiliates. As described in Item 12, Brokerage Practices, GSAM pays affiliates for brokerage and research services that assist GSAM in the investment decision-making process with “soft” or commission dollars in certain circumstances. As permitted by applicable

Page | 90

law, GSAM may receive these services in lieu of the affiliates reducing the commissions or fees they charge an Advisory Account, and these services may or may not be used to benefit the Advisory Account. Subject to client consent to the extent required by applicable law, in certain circumstances GSAM enters into principal transactions, including over-the-counter derivatives transactions, for clients with its affiliates, including GS&Co., GSI and other affiliates of GSAM. GSAM’s affiliates will earn mark-ups, mark-downs, spreads, financing fees and other charges that may be embedded in the cost of the derivative. Clients will pay these charges in addition to the advisory fee paid to GSAM. GSAM and its affiliates will likely share all or a portion of their charges and fees with each other and with their affiliates and employees, including, in the case of PWM clients, with the client’s Private Wealth Advisor, which could create an incentive to make execution decisions based on their interest in receiving a share of such charges and fees. For additional information about principal trading, please see Item 11, Code of Ethics, Participation or Interest in Client Transactions and Personal Trading—Participation or Interest in Client Accounts—Firm Policies, Regulatory Restrictions, and Certain Other Factors Affecting Advisory Accounts. In addition, Goldman Sachs has ownership interests in trading networks, securities or derivatives indices, trading tools and settlement systems. In addition, Goldman Sachs holds ownership interests in, and Goldman Sachs personnel sit on the boards of directors of, centralized exchanges and trading platforms, electronic communication networks, alternative trading systems and other similar execution or trading systems or venues (collectively, “ECNs/Trading Venues”). Goldman Sachs may be deemed to control one or more of such ECNs/Trading Venues based on its levels of ownership and its representation on the board of directors of such ECNs/Trading Venues. As of the date hereof, Goldman Sachs held ownership interests in the following ECNs/Trading Venues: (i) Members Exchange (MEMX), (ii) Members Exchange Options (MEMX Options), (iii) PureStream, (iv) GS Sigma X2, and (v) Marquee (GSCO). Goldman Sachs may acquire ownership interests in other ECNs/Trading Venues (or increase ownership in the ECNs/Trading Venues listed above) in the future. Information regarding the ECNs/Trading Venues in which Goldman Sachs has an ownership interest, as well as the ECNs/Trading Venues used by GSAM, is updated from time to time and is available at https://www.goldmansachs.com/disclosures/ecns-disclosure.html. Consistent with its duty to seek best execution for the Advisory Accounts, GSAM, from time to time, directly or indirectly through a broker-dealer, effects trades for Advisory Accounts through such ECNs/Trading Venues. In such cases, Goldman Sachs receives an indirect economic benefit based upon its ownership interests in ECNs/Trading Venues. In addition, Goldman Sachs receives fees, cash credits, rebates, discounts or other benefits from ECNs/Trading Venues to which it, as broker, routes order flow based on the aggregate trading volume generated by Goldman Sachs (including volume not associated with client orders) and the type of order flow routed and certain ECNs/Trading Venues, such as many exchanges, provide rebates or charge fees based on whether routed orders contribute to, or extract liquidity from, the ECN/Trading Venue. Discounts or rebates received by Goldman Sachs from an ECN/Trading Venue during any time period could differ and could exceed the fees paid by Goldman Sachs to the ECN/Trading Venue during that time period. The amount of such discounts or rebates varies. Further, the U.S. listed options exchanges sponsor marketing fee programs through which registered market-makers receive payments from the exchanges based upon their market making status and/or as a result of their designation as a “preferenced” market maker by an exchange member with respect to certain options orders. GS&Co. may receive payments from “preferenced” registered market makers related to these exchange-sponsored marketing fee programs. The amount of such payments varies. GSAM will effect trades for an Advisory Account through such ECNs/Trading Venues only if GSAM (or the broker-dealer through which GSAM is accessing the ECN/Trading Venue) reasonably believes that such trades are in the best interest of the Advisory Account and that the requirements of Page | 91

applicable law have been satisfied. As discussed in further detail in Item 12, Brokerage Practices, GSAM executes transactions with Goldman Sachs or unaffiliated broker-dealers in accordance with its best execution policies and procedures. In the event assets of an Advisory Account are treated as “plan assets” subject to the U.S. Employee Retirement Income Security Act of 1974 (“ERISA”), the use of ECNs/Trading Venues to execute trades on behalf of such Advisory Account may, absent an exemption, be treated as a prohibited transaction under ERISA. However, GSAM effects trades through ECNs/Trading Venues provided that such trades are executed in accordance with the exemption under Section 408(b)(16) of ERISA. In addition, GSAM is required to obtain authorization from any Advisory Account whose assets are treated as “plan assets” in order to execute transactions on behalf of such Advisory Account using an ECN/Trading Venue in which Goldman Sachs has an ownership interest. Furthermore, there may be limitations or restrictions placed on the use of ECNs/Trading Venues (including, without limitation, for purposes of complying with law and otherwise). Through GSAM’s trading on or membership to various trading platforms or venues, or interactions with certain service providers (including depositaries and messaging platforms), GSAM and its affiliates, in certain cases, receive interests, shares, or other economic benefits from such service providers. Investment Companies and Other Pooled Investment Vehicles GSAM and certain of its affiliates act in an advisory or sub-advisory capacity with respect to separately managed accounts and private investment funds and in other capacities, including as trustee, managing member, adviser, administrator and/or distributor, to a variety of U.S. and non-U.S. investment companies (including separate accounts underlying variable life insurance policies and variable annuity contracts that are structured as registered investment companies) as well as other pooled investment vehicles including collective trusts, exchange-traded funds, closed-end funds, business development companies and private investment funds. Such advisory, sub-advisory, or other relationships may be with affiliated entities or with institutions that are not part of Goldman Sachs. Certain GSAM Personnel are also directors, trustees and/or officers of these investment companies and other pooled investment vehicles. GSAM and its affiliates, in their capacities as advisers or sub-advisers to these entities, will receive management or advisory fees. Although such fees are generally paid by the entities, the costs are ultimately borne by their investors. These fees will be in addition to any advisory fees or other fees agreed between the investors in their capacities as clients and GSAM and its affiliates for investment advisory, brokerage or other services. Business Development Companies and Registered Investment Companies As further described above in Item 6, Performance-Based Fees and Side-By-Side Management—Co-Investment Opportunities—Co-Investments by Certain Advisory Accounts, GSAM has formed, and expects to form, one or more additional GS RICs that co-invest with other Advisory Accounts. The relationship between the GS RICs and other Advisory Accounts creates certain conflicts of interest. For example, the GS RICs will invest alongside certain Advisory Accounts in certain investments, which will reduce the portion of each investment that would otherwise have been allocated to such Advisory Accounts. In addition, the GS RICs are subject to certain regulatory and other considerations that constrain their operations. In turn, this could have an impact on Advisory Accounts that co-invest alongside the GS RICs, including with respect to the structuring, terms, consummation and disposition of Advisory Account investments. Furthermore, coinvestments alongside GS RICs will be subject to relevant provisions of the Investment Company Act. GSAM has obtained exemptive relief from certain of these provisions via an exemptive order that permits certain GS RICs to engage in certain types of co-investments with affiliates, including certain Advisory Accounts. On May 21, 2025, the SEC granted an Page | 92

Read the rest in the brochure

GSAM has adopted a Code of Ethics (the “Code”) under Rule 204A-1 of the Advisers Act designed to provide that GSAM Personnel, and certain additional personnel of Goldman Sachs who support GSAM, comply with applicable federal securities laws and place the interests of clients first in conducting personal securities transactions. The Code imposes certain restrictions on securities transactions in the personal accounts of covered persons to help avoid conflicts of interest. Subject to the limitations of the Code, covered persons buy and sell securities or other investments for their personal accounts, including investments in pooled investment vehicles that are sponsored, managed or advised by Goldman Sachs, and also take positions that are the same as, different from, or made at different times than, positions taken (directly or indirectly) for Advisory Accounts. GSAM will provide a copy of the Code to clients or prospective clients upon request. Additionally, all personnel of Goldman Sachs, including GSAM Personnel, are subject to firm-wide policies and procedures regarding confidential and proprietary information, information barriers, private investments, outside business activities and personal trading. GSAM requires pre-clearance of personal securities transactions, both public and private, by GSAM Personnel and GSAM can deny any such transaction in its discretion. In order to address potential conflicts of interest with the Advisory Accounts and other legal and regulatory restrictions (such as when GSAM has confidential information about a Page | 111

portfolio company), Goldman Sachs maintains a list of securities in which GSAM Personnel cannot trade. Additionally, GSAM generally does not allow its personnel to purchase securities of single-name public issuers, other than registered investment companies and government securities. In addition, GSAM prohibits its employees from accepting gifts and entertainment that could influence, or appear to influence, their business judgment. This generally includes gifts of more than $300 or meals and other business-related entertainment that may be considered lavish or extraordinary and therefore raise a question or appearance of impropriety. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS Goldman Sachs is a worldwide, full-service investment banking, broker-dealer, asset management and financial services organization and a major participant in global financial markets. As such, it provides a wide range of financial services to a substantial and diversified client base that includes corporations, financial institutions, governments and individuals. Goldman Sachs acts as broker-dealer, investment adviser, investment banker, underwriter, research provider, administrator, financier, adviser, market maker, trader, prime broker, derivatives dealer, clearing agent, lender, custodian, counterparty, agent, principal, distributor, investor or in other commercial capacities for accounts or companies (including Advisory Account portfolio companies) or affiliated or unaffiliated Underlying Funds. In those and other capacities, Goldman Sachs advises and deals with clients and third parties in all markets and transactions and purchases, sells, holds and recommends a broad array of investments, including securities, derivatives, loans, commodities, currencies, credit default swaps, indices, baskets and other financial instruments and products for its own account and for the accounts of clients and of its personnel. In addition, Goldman Sachs has direct and indirect interests in the global fixed-income, currency, commodity, equities, bank loan and other markets. In certain cases, Goldman Sachs causes Advisory Accounts to invest in products and strategies sponsored, managed or advised by Goldman Sachs or in which Goldman Sachs has an interest, either directly or indirectly, or otherwise restricts Advisory Accounts from making such investments, as further described herein. In this regard, there are instances when Goldman Sachs’ activities and dealings with other clients and third parties affect Advisory Accounts in ways that disadvantage Advisory Accounts and/or benefit Goldman Sachs or other Accounts (including Advisory Accounts). Additionally, as described below, GSAM faces conflicts of interest arising out of Goldman Sachs’ relationships and business dealings in connection with decisions to take or refrain from taking certain actions on behalf of Advisory Accounts when doing so would be adverse to Goldman Sachs’ relationships or other business dealings with such parties. See Item 11, Code of Ethics, Participation or Interest in Client Transactions and Personal Trading—Participation or Interest in Client Transactions—Certain Effects of the Activities of Goldman Sachs and Advisory Accounts. In addition, as described above in Item 7, Types of Clients, GSAM’s activities on behalf of certain other entities that are not investment advisory clients of GSAM create conflicts of interest between such entities, on the one hand, and Advisory Accounts, on the other hand, that are the same as or similar to the conflicts that arise between Advisory Accounts, or between an Advisory Account on the one hand, and an Account on the other hand, as described in this Item 11, Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. In managing conflicts of interest that arise as a result of the foregoing, GSAM generally will be subject to fiduciary requirements. The following are descriptions of certain conflicts of interest and potential conflicts of interest that are associated with the financial or other interests that GSAM and Goldman Sachs have in advising or dealing with clients (including Advisory Accounts) or third parties acting on their own behalf. The conflicts herein do not purport to be a complete list or explanation of the conflicts associated with the financial or other interests GSAM or Goldman Sachs may have now or in the future. Prior to making an investment in an Advisory Account that is a pooled investment vehicle, prospective investors are encouraged to read the offering materials relating to such Advisory Account.

Page | 112

Principal Trading and Cross/Agency Cross Transactions with Advisory Accounts When permitted by applicable law and GSAM policy, GSAM, acting on behalf of certain Advisory Accounts (for example, those employing taxable fixed income, municipal bond fixed income and structured investment strategies), may (but is under no obligation or other duty to) enter into transactions in securities and other instruments with or through Goldman Sachs or in Affiliated Products and cause Advisory Accounts to engage in principal transactions, cross transactions and agency cross transactions. Principal transactions occur if GSAM, on behalf of Advisory Accounts, engages in a transaction in securities or other instruments with Goldman Sachs or in Affiliated Products acting as principal. In certain cases, Goldman Sachs earns compensation (such as a spread or mark-up) in connection with these transactions. Cross transactions occur if GSAM causes an Advisory Account to buy securities or other instruments from, or sell securities or other instruments to, another Advisory Account of GSAM or an Affiliated Adviser. An agency cross transaction occurs if Goldman Sachs acts as broker for an Advisory Account on one side of the transaction and a brokerage account on the other side of the transaction in connection with the purchase or sale of securities by the Advisory Account. Goldman Sachs receives a commission from such agency cross transactions. There are potential conflicts of interest, regulatory considerations or restrictions identified in GSAM’s internal policies relating to these transactions which could limit GSAM’s determination and/or ability to engage in these transactions for Advisory Accounts. In certain circumstances such as when Goldman Sachs is the only or one of a few participants in a particular market or is one of the largest such participants, such limitations will eliminate or reduce the availability of certain investment opportunities to Advisory Accounts or impact the price or terms on which transactions relating to such investment opportunities may be effected. GSAM may (but is under no obligation or other duty to) cause Advisory Accounts to engage in cross transactions involving interests in hedge funds, private equity funds, real estate funds and other private or non-private funds. For example, HFS may cause HFS Advisory Accounts to buy or sell interests in an Underlying Fund, including such interests that are illiquid or difficult-to-value, from or to another Advisory Account or other Account (including an Account advised by another area of Goldman Sachs for its clients). This will typically occur when one Advisory Account determines to sell an interest in an Underlying Fund at the same time that another Advisory Account wishes to purchase an interest in the same Underlying Fund. Transactions in respect of illiquid or difficult-to-value assets may be effected at a discount to the net asset value of the illiquid assets provided by the applicable Adviser. Another example of cross transactions involving Underlying Funds occurs when XIG private equity and real estate Advisory Accounts rebalance their interests in Underlying Funds over the course of a stated period of time (such as the period of time during which investors may invest in XIG closed-ended private equity and real estate funds). Cross transactions may also occur in connection with the offering of Co-Investment Opportunities to an Advisory Account following the acquisition of an investment by another Advisory Account. In these cases, the Advisory Account that is offered the Co-Investment Opportunity generally purchases a portion of the investment acquired by another Advisory Account. The price at which an Advisory Account acquires an investment in connection with a Co-Investment Opportunity may be based upon cost and may or may not include an interest component or may reflect adjustments to the value of the investment following acquisition by the selling Advisory Account. In addition, cross transactions may occur where GSAM causes an Advisory Account to acquire all or a portion of the interests in one or more portfolio companies from another Advisory Account (including situations where a new Advisory Account is organized by GSAM solely for this purpose) or merge an existing portfolio company of the Advisory Account with a portfolio company of another Advisory Account. Such

Page | 113

Read the rest in the brochure

Page | 139

Counterparty Credit Requirements An Advisory Account will be required to establish business relationships with its counterparties based on its own credit standing. Goldman Sachs, including GSAM, will not have any obligation or other duty to allow its credit to be used in connection with an Advisory Account’s establishment of its business relationships, nor is it expected that an Advisory Account’s counterparties will rely on the credit of Goldman Sachs in evaluating the Advisory Account’s creditworthiness. Broker-Dealer Selection Considerations Relating to the Allocation of Assets to Underlying Funds or Advisers If GSAM allocates assets to an Adviser through a separately managed account or similar structure, the Adviser will generally have the authority to select prime brokers and other trading counterparties, clearing members and service providers (including, subject to applicable law, affiliates of GSAM) through which to clear transactions, subject to a set of objective criteria established by GSAM. GSAM generally allows these Advisers to select executing brokers as long as the relevant clearing member or prime broker, as applicable, can accommodate and properly clear and report such transactions. Advisers generally are expected to seek best execution considering price, commissions and commission equivalents, other transaction costs, quality of brokerage services, financing arrangements, creditworthiness and financial stability, financial responsibility and strength and clearance and settlement capability. Subject to the Advisers’ best execution obligations, and to the extent permitted by applicable law and their internal policies, Advisers may select entities within Goldman Sachs to act as a broker, clearing member or dealer with respect to the accounts of their clients. RESEARCH AND OTHER SOFT DOLLAR BENEFITS Subject to applicable law, GSAM often selects U.S. and non-U.S. broker-dealers (including GSAM’s affiliates) that furnish GSAM, Advisory Accounts, GSAM affiliates and personnel involved in decision-making for Advisory Accounts with proprietary or third-party brokerage and research services (collectively, “brokerage and research services”) that provide, in GSAM’s view, appropriate assistance to GSAM in the investment decision-making process. These brokerage and research services could be bundled with the trade execution, clearing, or settlement services provided by a particular broker-dealer and, subject to applicable law, GSAM may pay for such brokerage and research services with client commissions (or “soft dollars”). The types of brokerage and research services that GSAM acquired with client brokerage commissions within GSAM’s last fiscal year, which may vary among Registrants including as a result of applicable law, included: research reports on companies, industries, and securities (including proprietary research from affiliated and unaffiliated broker-dealers, as well as independent research providers); economic, market and financial data; access to broker-dealer analysts, corporate executives and industry experts; attendance at trade industry seminars and broker organized conferences; and services related to effecting securities transactions and functions incident thereto (such as clearance and settlement). When GSAM uses client commissions to obtain brokerage and research services, GSAM receives a benefit because GSAM does not have to produce or pay for the brokerage and research services itself. As a result, GSAM will have an incentive to select or recommend a broker-dealer based on GSAM’s interest in receiving the brokerage and research services from that broker-dealer, rather than solely on its clients’ interest in receiving the best price or commission. In addition, where GSAM uses client commissions to obtain proprietary research services from an affiliate, GSAM will have an incentive to allocate more “soft” or commission dollars to pay for those services. However, when selecting broker-dealers that provide brokerage and research services, including its affiliates, GSAM is obligated to determine in good faith that the “commissions” (as broadly defined by the SEC to include a mark-up, mark-down, commission equivalent or other fee in certain circumstances) to be paid to broker-dealers are reasonable in relation to the value of the brokerage and research services they provide to GSAM. The reasonableness of these commissions will be viewed in terms of the particular Page | 140

transactions or GSAM’s overall responsibilities to Advisory Accounts over which it exercises investment discretion, even though that broker-dealer itself, or another broker-dealer, might be willing to execute the transactions at a lower commission. Accordingly, transactions will not always be executed at the most favorable available price or commission and GSAM in certain cases causes clients to pay commissions higher than those charged by other broker-dealers as a result of the soft dollar benefits received by GSAM. GSAM’s evaluation of the brokerage and research services provided by a broker-dealer is in certain cases a significant factor in selecting a broker-dealer to effect transactions. For this purpose, GSAM has established a voting process in which certain portfolio management teams participate pursuant to which personnel rate broker-dealers that supply them with brokerage and research services. Subject to GSAM’s duty to seek best execution and applicable laws and regulations, GSAM allocates Advisory Account trading among broker-dealers in accordance with the outcome of the voting process. Arrangements under which GSAM receives brokerage and research services vary by product, strategy, account or applicable law in the jurisdictions in which GSAM conducts business. Subject to applicable law, GSAM participates in so-called “commission sharing arrangements” and “client commission arrangements” under which GSAM executes transactions through a broker-dealer, including an affiliate, and requests that the broker-dealer allocate a portion of the commissions or commission credits to another firm, including an affiliate, that provides research to GSAM. Participating in commission sharing and client commission arrangements may enable GSAM to consolidate payments for brokerage and research services through one or more channels using accumulated client commissions or credits from transactions executed through a particular broker-dealer to obtain brokerage and research services provided by other firms. Such arrangements also help to ensure the continued receipt of brokerage and research services while facilitating GSAM’s ability to seek best execution in the trading process. GSAM believes such arrangements are useful in its investment decision-making process by, among other things, ensuring access to a variety of high quality research, access to individual analysts and availability of resources that GSAM might not be provided access to absent such arrangements. Commission sharing and client commission arrangements may be subject to different legal requirements or restrictions in different jurisdictions. Generally, GSAM excludes from use under these arrangements those products and services that are not eligible under applicable regulatory interpretations, even where a portion would be eligible if accounted for separately. Advisory Accounts differ with regard to whether and to what extent they pay for research and brokerage services through commissions and, subject to applicable law, brokerage and research services may be used to service any or all Advisory Accounts throughout GSAM, including Advisory Accounts that do not pay commissions to the broker-dealer relating to the brokerage and research service arrangements. As a result, brokerage and research services (including soft dollar benefits) may disproportionately benefit some Advisory Accounts relative to other Advisory Accounts based on the relative amount of commissions paid by the Advisory Accounts and in particular those Advisory Accounts that do not pay for research and brokerage services or do so to a lesser extent, including in connection with the establishment of maximum budgets for research costs (and switching to execution-only pricing when maximums are met), as described below. For example, research that is paid for through one client’s commissions may not be used in managing that client’s account, but may be used in managing other Advisory Accounts within GSAM. In connection with these practices, subject to applicable law and GSAM’s policies and procedures, brokerage and research services obtained through commissions paid by a client or clients whose accounts are managed by a particular portfolio management team within GSAM are shared with, and used partially or exclusively by, other portfolio management personnel within GSAM, including portfolio management personnel of the same or a different Registrant, or portfolio Page | 141

management personnel of GSAM’s affiliates. Except as required by applicable law, GSAM does not attempt to allocate soft dollar benefits proportionately among clients or to track the benefits of brokerage and research services to the commissions associated with a particular Account or group of Accounts. In connection with receiving brokerage and research services from broker-dealers, GSAM may receive “mixed use” services where a portion of the service assists GSAM in its investment decision-making process and a portion is used for other purposes. Where a service has a mixed use, GSAM will make a reasonable allocation of its cost according to its use and will use client commissions to pay only for the portion of the product or service that assists GSAM in its investment decisionmaking process. GSAM has an incentive to underestimate the extent of any “mixed use” or allocate the costs to uses that assist GSAM in its investment decision-making process because GSAM may pay for such costs with client commissions rather than GSAM’s own resources. Although, as described above, GSAM may pay for such brokerage and research services with client commissions, there are instances or situations in which such practices are subject to restrictions under applicable law. The European Union’s Markets in Financial Instruments Directive II (“MiFID II”) restricts European Union domiciled investment advisers from receiving research and other materials that do not qualify as “acceptable minor non-monetary benefits” from brokerdealers unless the research or materials are paid for by the investment advisers from their own resources or from research payment accounts funded by and with the agreement of their clients. GSAMI is subject to MiFID II and pays for the research and other materials (other than “acceptable minor non-monetary benefits”) that such entity or its European investment advisory affiliates, as applicable, uses from its own resources to the extent required by MiFID II. GSAM is not directly subject to MiFID II but has agreed with GSAMI, with reference to Advisory Accounts delegated to GSAM by GSAMI, to implement certain controls and arrangements designed to secure, to GSAMI’s satisfaction in its oversight of GSAM’s delegate functions, substantively equivalent outcomes (i.e., equivalent to those outcomes which MiFID II is designed to achieve and to which GSAMI is directly subject). This consists primarily of the introduction of a process for establishing maximum budgets for research costs (and switching to execution-only pricing when maximums are met), enhancements to the process for valuing research inputs, and excluding the provision of research as a significant factor (taken as a whole) in order routing and/or the selection of brokers. While GSAM will seek to estimate its research costs in good faith and in accordance with its policies and procedures, the actual costs of such research may be higher or lower than estimated, and GSAM faces conflicts of interest in estimating such costs. In the context of Manager of Manager Accounts and the Underlying Funds in which XIG Program Funds invest, the Advisers to the Underlying Funds and separately managed accounts may also engage in client commission sharing and similar arrangements and those arrangements may be broader and may raise conflicts other than those described above. GSAM also receives benefits from the custodian for its Retail Managed Account Services Enrolled Participants, although trades for such Enrolled Participants executed through the custodian are not subject to commission, transaction charges, or prime brokerage fees. See Item 5, Fees and Compensation—Other Fees and Expenses—Retail Managed Account Services Fees for additional information regarding fees and expenses charged to Retail Managed Account Services Enrolled Participants. Such benefits include trading tools and access to a third-party trade order execution management system. Access to this system allows GSAM use of certain algorithmic trading and direct market access systems, and also provides GSAM with the ability to route and execute Enrolled Participant trade orders through other broker-dealers. These benefits reduce the administrative costs of GSAM. Page | 142

Read the rest in the brochure

General From time to time, the Registrants may make payments for client referrals to affiliated and unaffiliated persons in accordance with applicable laws. Referrals by Affiliates In certain circumstances, and in accordance with applicable laws, a particular Registrant (or a particular business unit within a Registrant) or an affiliate of the Registrants will refer clients to another Registrant (or another business unit within the same or a different Registrant). Payment for any such referrals may take the form of cash or non-cash compensation (including a reduction of management fees or performance-based compensation). Intermediaries and Other Third Parties Goldman Sachs or the Advisory Accounts have in the past made, and may in the future make, payments to authorized dealers and other financial intermediaries and to salespersons (collectively, “Intermediaries”) to promote the Advisory Accounts or other products. These payments may be made out of Goldman Sachs’ assets or amounts payable to Goldman Sachs. These payments create an incentive for an Intermediary to highlight, feature or recommend Advisory Accounts. Subject to applicable law and regulations, such payments may compensate Intermediaries for, among other things: marketing the Advisory Accounts and other products (which may consist of payments resulting in or relating to the inclusion of Advisory Accounts and other products on preferred or recommended fund lists or in certain sales programs sponsored by the Intermediaries); access to the Intermediaries’ registered representatives or salespersons, including at conferences and other meetings; assistance in training and education of personnel of Goldman Sachs; fees for directing investors to the Advisory Accounts and other products; “finders fees” or “referral fees” or other fees for providing assistance in promoting the Advisory Accounts and other products (which may include promotions in communications with the Intermediaries’ customers, registered representatives and salespersons); various non-cash and cash incentive arrangements to promote certain products, as well as sponsor various educational programs, sales contests and/or promotions; travel expenses, meals, lodging and entertainment of Intermediaries and their salespersons and guests in connection with educational, sales and promotional programs; subaccounting, administrative and/or shareholder processing or other investor services that are in addition to the fees paid for these services by the Advisory Accounts or products; and other services intended to assist in the distribution and marketing of the Advisory Accounts and other products. Goldman Sachs, in certain circumstances and for certain financial intermediaries, pays for all or a portion of the fees associated with technology platforms that provide access to Goldman Sachs products and services on behalf of those Page | 149

financial intermediaries. In addition, Goldman Sachs could hire or dedicate Goldman Sachs employees, or pay all or part of the salaries of employees of financial intermediaries, to provide administrative or other services in connection with investments by clients of such financial intermediaries into Goldman Sachs products. Certain financial intermediaries receive an economic benefit from investing their client’s assets in Goldman Sachs products and services in the form of revenues received by Goldman Sachs offsetting a payment obligation the financial intermediary would otherwise have to Goldman Sachs or in the form of a revenue sharing arrangement whereby Goldman Sachs shares a portion of its fees and allocations with the financial intermediary. These payments may differ by Intermediary and are negotiated based on a range of factors, including but not limited to, ability to attract and retain assets, target markets, customer relationships, quality of service and industry reputation. Goldman Sachs and its personnel, including employees of GSAM, have relationships with, and purchase, or distribute or sell, services or products from or to, distributors, consultants, and others who recommend Advisory Accounts, or who engage in transactions with or for Advisory Accounts. Consultants and such other parties may receive compensation from Goldman Sachs or Advisory Accounts in connection with such relationships. In accordance with internal policies and procedures, Goldman Sachs also pays certain fees for membership in industry-wide or state and municipal organizations and otherwise helps sponsor conferences and educational forums for investment industry participants from time to time including, but not limited to, trustees, fiduciaries, consultants, administrators, state and municipal personnel and other clients. Goldman Sachs’ membership in such organizations allows Goldman Sachs to participate in these conferences and educational forums and helps Goldman Sachs interact with conference participants and to develop an understanding of the points of view and challenges of the conference participants. GSAM may pay fees to third parties (e.g., service providers to potential clients, such as record-keepers or administrators) in exchange for the right to include information regarding Advisory Accounts and other products on portals or databases to which such potential clients will have access for purposes of considering potential investment alternatives. Personnel, including employees of GSAM, may have board, advisory, brokerage or other relationships with issuers, distributors, consultants and others that have (or have interests in) Advisory Accounts or that recommend Advisory Accounts or portfolio transactions for Advisory Accounts. As a result of these relationships and arrangements, consultants, distributors and other parties have conflicts associated with their promotion of Advisory Accounts or other dealings with Advisory Accounts that create incentives for them to promote Advisory Accounts or portfolio transactions. Goldman Sachs, including GSAM, and its personnel make charitable contributions to certain institutions, including those that have relationships with clients or personnel of clients, and certain personnel have board relationships with charitable institutions. In accordance with internal policies and procedures, personnel may also make political contributions to clients. The individuals and entities with which Goldman Sachs and its personnel have these relationships may have (or have an interest in) or recommend Advisory Accounts.

On November 22, 2022, GSAMLP entered into a settlement with the SEC regarding GSAMLP’s policies and procedures with respect to environmental, social and governance investments. The SEC found that GSAMLP did not adopt written policies and procedures governing the evaluation of ESG factors until sometime after two ESG mutual funds were introduced and a socially-responsible separate account strategy was rebranded as ESG, and that, once such policies and procedures were adopted, they were not consistently followed prior to February 2020. GSAMLP was censured and ordered to cease and desist from violating Section 206(4) of the Advisers Act and Rule 206(4)-7 promulgated thereunder. GSAMLP agreed to pay a penalty of $4 million. In the ordinary course of their business, the Registrants and their management persons, as well as Goldman Sachs, Advisory Accounts, and/or other Goldman Sachs personnel, have in the past been, and may in the future be, subject to periodic audits, examinations, claims, litigation, formal and informal regulatory or other inquiries, requests for information, subpoenas, employment-related matters, disputes, investigations, and other civil, legal or regulatory proceedings involving the SEC, other regulatory authorities, or private parties. Such actions, investigations, litigation and claims have the potential to result in findings, conclusions, settlements, charges or various forms of sanctions against the Registrants or their management persons, as well as Goldman Sachs and other Goldman Sachs personnel, including fines, suspensions of personnel, changes in policies, procedures or disclosure or other sanctions and may increase the exposure of the Advisory Accounts, GSAM and Goldman Sachs to potential liabilities and to legal, compliance and other related costs. Such actions or proceedings may involve claims of strict liability or similar risks against Advisory Accounts in certain jurisdictions or in connection with certain types of activities. Information about the Registrants’ investment management affiliates is contained in Part 1 of each Registrant’s Form ADV. For information relating to other Goldman Sachs affiliates, please visit www.gs.com and refer to the public filings of The Goldman Sachs Group, Inc.

Senior members of GSAM’s portfolio management teams periodically review Advisory Accounts. They conduct the review either individually or in a group, depending upon account needs and market conditions. Reviews of Advisory Accounts include a review of the Advisory Account’s performance, investment objectives, security positions and other investment opportunities, as well as portfolio guidelines and liquidity requirements, if applicable. Additional reviews may be undertaken at the discretion of GSAM. Compliance with investment guidelines for Advisory Accounts is generally judged at time of purchase of securities or other investments. However, from time to time, there may exist certain circumstances when compliance with applicable investment guidelines will be tested as of the next occurring post-trade compliance check conducted in a relevant jurisdiction of the Advisory Account (e.g., transactions executed in multiple time zones). FACTORS TRIGGERING A REVIEW In addition to periodic reviews, GSAM performs reviews of separately managed accounts as it deems appropriate or as otherwise required. Additional reviews may be undertaken for reasons including changes in market conditions, changes in security positions or changes in a client’s investment objective or policies. CLIENT REPORTS GSAM provides advisory clients who have separately managed accounts with written reports on a quarterly basis or as otherwise agreed to with the client, which may be available through client-dedicated web access. These reports generally Page | 148

include, among other things, a summary of all activity in the client account, including all purchases and sales of securities and any debits and credits to the account, a summary of holdings including a portfolio valuation, and the change in value of the account during the reporting period. Investors in GSAM-managed private pooled investment vehicles receive certain periodic reports, which may include written individualized capital information, annual reports, monthly net asset value statements, and annual audited financial statements and cash flow statements.

Client funds and securities are held by a qualified custodian (which may be an affiliate of GSAM) appointed by clients pursuant to a separate custody agreement, or are held by the clients themselves. Under the Advisers Act, GSAM is deemed to have custody of client assets under certain circumstances, including where clients maintain assets at a bank, brokerdealer, futures commission merchant or other qualified custodian affiliated with GSAM, where GSAM debits its fees directly from the Advisory Account, where the terms of an agreement between a client and a qualified custodian permit GSAM to

Page | 150

instruct the custodian to disburse, or transfer, funds or securities, or in certain cases where GSAM purchases privately offered securities on behalf of the Advisory Account. GSAM does not endorse or guarantee the service (custody or other services) of any custodian or administrative servicer. The client is responsible for performing appropriate due diligence in selecting and entering into a separate agreement with such custodian or administrative servicer. Unless otherwise agreed with the client and except with respect to an Advisory Account that is a pooled investment vehicle and with respect to which GSAM is deemed to have custody of its funds and securities because GSAM (or an affiliate) serves as its general partner, managing member or similar capacity, GSAM is not responsible for the selection or ongoing monitoring of client custodians or administrative servicers. GSAM will not be responsible for any services of the custodian or administrative servicer or for the performance or nonperformance of any services provided pursuant to the custodian or services agreement. Clients will receive account statements directly from their custodian or trustee and should carefully review those statements. In addition, clients are urged to compare the account statements that they receive from their qualified custodian with any that they receive from GSAM. Agency Accounts In certain cases, GSAM is deemed to have custody of client assets when GSAM (or an affiliate) acts as agent in certain loan syndication arrangements. In these cases, the loans held in Advisory Accounts’ portfolios that are originated or otherwise sourced by GSAM are typically funded by a loan syndicate organized by GSAM (a “Loan Syndicate”). In many cases, GSAM (or an affiliate) serves as the administrative agent to such Loan Syndicates. The participants in a Loan Syndicate (the “Loan Syndicate Participants”) generally include GSAM and/or its affiliates, Advisory Accounts, and may include other bank and non-bank lenders. As the administrative agent to the Loan Syndicates, GSAM (or an affiliate) performs the duties and responsibilities typically assigned to an administrative agent for and on behalf of each Loan Syndicate. Each Loan Syndicate’s credit agreement requires GSAM (or an affiliate) to follow negotiated guidelines or formulas regarding the movement of cash to and from the lenders and the borrower, as applicable, for the Loan Syndicate (e.g., the collection of loan proceeds from lenders and their disbursement to the borrower, as well as the use and distribution of payments received from the borrower). Accordingly, GSAM (or an affiliate), in its capacity as the administrative agent, applies the terms of each credit agreement and has no authority to determine how the cash is used, allocated or disbursed. A single bank account (the “Agency Account”), established by GSAM (or an affiliate) and maintained by a qualified custodian, facilitates the movement of cash to and from the lenders and the borrowers, as applicable, for all of the Loan Syndicates. The Agency Account is opened by, and in the name of, GSAM (or an affiliate) as agent for the Loan Syndicate Participants (i.e., the funds related to the Loan Syndicates are not held in separate accounts or sub-accounts for each Loan Syndicate Participant under the Loan Syndicate Participant’s name, but are commingled in the Agency Account). The qualified custodian of the Agency Account does not send Agency Account statements to the Loan Syndicate Participants.

GSAM accepts discretionary authority to manage securities accounts on behalf of clients. Clients for which GSAM has investment discretion are required to sign an investment advisory agreement that authorizes the applicable GSAM entity to supervise and direct the investment and reinvestment of assets in the Advisory Account, with discretion on the client’s

Page | 151

behalf and at the client’s risk. GSAM’s discretionary authority is limited by the terms of its investment advisory agreements and the investment guidelines agreed between GSAM and each client. The investment guidelines or other account documents generally include any limitations a client may place on GSAM’s discretionary authority, including any reasonable restrictions on the securities and other financial instruments in which GSAM is authorized to invest. With respect to the Stable Value business, the terms of Stable Value Contracts impose investment restrictions on GSAMLP’s management of separate accounts or commingled fund accounts and on Unaffiliated Advisers that are generally more restrictive than those imposed by clients or that would otherwise apply. These restrictions may limit the scope or types of investments that Stable Value might otherwise include within an Advisory Account, and incentivize Stable Value to manage Advisory Accounts under more conservative or restrictive investment guidelines so that such Advisory Accounts remain eligible for access to such Stable Value Contracts. For additional information about risks related to GSAM’s discretionary authority, please see Item 6, Performance-Based Fees and Side-By-Side Management.

The following proxy voting policies and matters apply with respect to all GSAM Public business lines and GSAM Private’s business development companies business. The proxy voting policies and matters for the remaining GSAM Private businesses are described separately in this Item 17 below under “Proxy Voting Policies for Other GSAM Business Lines”. Authority to Vote

General

For Advisory Accounts for which GSAM has voting discretion, GSAM has adopted policies and procedures (the “Proxy Voting Policy”) for the voting of proxies. Under the Proxy Voting Policy, GSAM’s guiding principles in performing proxy voting are to make decisions that favor proposals that in GSAM’s view maximize a company’s long-term shareholder value and are not influenced by conflicts of interest. These principles reflect GSAM’s belief that sound corporate governance will create a framework within which a company can be managed in the interests of its shareholders. To implement these guiding principles for investments in publicly-traded equities of operating and/or holding companies, GSAM has developed customized proxy voting guidelines (the “Guidelines”) that it generally applies when voting on behalf of Advisory Accounts. The Guidelines address a wide variety of individual topics, including, among other matters, shareholder voting rights, antitakeover defenses, board structures, the election of directors, executive and director compensation, reorganizations, mergers, issues of corporate social responsibility and shareholder proposals. The Proxy Voting Policy, including the Guidelines, is reviewed annually to ensure that it continues to be consistent with GSAM’s guiding principles. GSAM has retained a third-party proxy voting platform service (the “Proxy Platform Service”) to assist in the implementation of certain proxy voting-related functions, including, without limitation, operational, recordkeeping and reporting services. GSAM applies the Guidelines to each proxy issue and determines the appropriate voting decision. The Proxy Platform Service provides a platform that facilitates the casting of those votes in an efficient manner. GSAM conducts an annual due diligence meeting with the Proxy Platform Service to review the processes and procedures related to their voting platform, including any material changes in the services, operations, staffing or processes. Page | 152

Under the oversight of GSAM, initial voting outputs (“Outputs”) are developed for each proxy vote that reflect the application of the Guidelines to the particular proposal. Final votes are then submitted by GSAM through a proxy voting platform. In some cases, in certain markets, votes may be automatically submitted in accordance with the Output, although GSAM retains the ability to recall such automatically submitted votes if warranted. If GSAM becomes aware that an issuer has filed, or will file, additional proxy solicitation materials sufficiently in advance of the voting deadline, GSAM will generally endeavor to consider such information where such information is viewed, in its discretion, as material when casting a vote. While it is GSAM’s policy generally to follow the Guidelines, GSAM’s portfolio management teams may on certain proxy votes seek approval to diverge from the Output or votes cast by other portfolio management teams by following an “override” process. Given the case-by-case nature of the Guidelines, there may be a difference of opinion as to the appropriate voting decision under the Guidelines on certain proxy votes. The override process seeks to ensure that override decisions are not influenced by any conflict of interest. As a result of the override process, portfolio management teams may vote differently on proposals for the same company. From time to time, GSAM’s ability to vote proxies may be affected by regulatory requirements and compliance, legal or logistical considerations. As a result, GSAM, from time to time, may determine that it is not practicable or desirable to vote proxies. GSAM may have voting discretion with respect to Advisory Accounts that own securities issued by Goldman Sachs, its affiliates or pooled investment vehicles managed by GSAM or its affiliates. In circumstances in which GSAM has discretion to vote proxies with respect to such securities, GSAM will generally instruct that such proxies be voted in the same proportion as other proxies are voted with respect to a proposal, subject to applicable legal and regulatory requirements. Determinations by GSAM as to whether and how to vote proxies with respect to securities issued by Goldman Sachs, its affiliates or pooled investment vehicles managed by GSAM or its affiliates creates a conflict between the interests of Goldman Sachs and GSAM, on the one hand, and Advisory Accounts, on the other hand. GSAM has implemented processes designed to prevent conflicts of interest from influencing proxy voting decisions that GSAM makes on behalf of advisory clients, including the Advisory Accounts. These processes include information barriers as well as the use of GSAM’s Guidelines and the override approval process previously discussed. Notwithstanding such proxy voting processes, proxy voting decisions made by GSAM in respect of securities held by a particular Advisory Account may benefit the interests of Goldman Sachs and/or Accounts other than the Advisory Account, provided that GSAM believes such voting decisions to be in accordance with its fiduciary obligations. Examples of material conflicts of interest that could arise in connection with a proxy voting decision include, without limitation, circumstances in which (i) Goldman Sachs has a business relationship with or other interests in the issuer or another interested party and (ii) Goldman Sachs personnel have a personal relationship with personnel of the issuer or another interested party. Conflicts of interest relating to proxy voting decisions also arise in situations in which Goldman Sachs (including GSAM) or Accounts (including Advisory Accounts), on the one hand, and a particular Advisory Account, on the other hand, invest in or extend credit to the same issuer, but in different parts of the issuer’s capital structure. See Item 11, Code of Ethics, Participation or Interest in Client Transactions and Personal Trading—Participation or Interest in Client Accounts—Investments in and Advice Regarding Different Parts of an Issuer’s Capital Structure. When GSAM engages Advisers to manage the assets of Advisory Accounts pursuant to a discretionary investment advisory agreement, such Advisers generally will be responsible for taking all action with respect to the underlying securities held in the applicable Advisory Account. In addition, when GSAM invests the assets of Advisory Accounts, including XIG Program Page | 153

Funds, in Underlying Funds that are hedge funds, GSAM generally has no ability to take any action with respect to the securities held in the Underlying Funds. However, GSAM may be responsible for voting with respect to the interests in such Underlying Funds.

Client Directed Votes

GSAM clients who have delegated voting responsibility to GSAM with respect to their Advisory Account may from time to time contact their client representative if they would like to direct GSAM to vote in a particular solicitation. GSAM will use its commercially reasonable efforts to vote according to the client’s request in these circumstances, but cannot provide assurances that such voting requests will be implemented. Clients can obtain information regarding how securities were voted by a particular Advisory Account by calling their Goldman Sachs representative. GSAM’s Proxy Voting Policy is available upon request. Proxy Voting Policies - No Authority GSAM is not delegated proxy voting authority on behalf of all of its Advisory Accounts and certain clients may retain proxy voting authority for certain securities within the Advisory Account. With respect to those Advisory Accounts for which GSAM does not conduct proxy voting, clients should work with their custodians to ensure they receive their proxies and other solicitations for securities held in their Advisory Account. Such clients may contact their GSAM client service representative if they have a question on particular proxy voting matters or solicitations. Class Actions and Similar Matters With respect to shareholder class action litigation and similar matters, GSAM’s separate account clients are encouraged to contact their custodians and ensure that they receive notices and are aware of the participation and filing requirements related to class action and similar proceedings. GSAM generally will not make any filings in connection with any shareholder class action lawsuits and similar matters (including against Goldman Sachs or its affiliates) involving securities held or that were held in separate accounts for clients, and will not be required to notify custodians or clients of shareholder class action lawsuits and similar matters. GSAM will not be responsible for any failure to make such filings or, if it determines to make such filings in its sole discretion, to make such filings in a timely manner.

PROXY VOTING POLICIES FOR OTHER GSAM BUSINESS LINES The following proxy voting policies and matters apply with respect to GSAM Private other than its business development companies business (the proxy voting policies and matters for GSAM Private’s business development companies business and the remaining GSAM business lines are described in this Item 17 above under “Proxy Voting Policies for Certain GSAM Business Lines”). Accordingly, all references in this section to “GSAM Private” does not include its business development companies business. GSAM Private generally has the authority to vote the securities held by all of the Advisory Accounts, which in certain cases may be revoked by an investor due to regulatory considerations. GSAM Private’s guiding principles are to make proxy voting decisions that (i) tend to maximize the long term value of an Advisory Account’s investment and (ii) minimize the impact of conflicts of interest. See “Proxy Voting Policies for Certain GSAM Business Lines—Authority to Vote—General” above for examples of conflicts of interest that may arise in connection with proxy voting decisions by GSAM Private.

Page | 154

Once a conflict is identified, GSAM Private will take such steps as it believes to be necessary in order to vote the proxy in accordance with the guiding principles described above and its fiduciary obligations to its clients. Material conflicts of interest between GSAM Private and an Advisory Account with respect to proxy voting (which are not otherwise addressed by the guidelines) are typically resolved as follows: 

GSAM Private may disclose the conflict of interest to the Advisory Accounts and obtain the written consent of the Advisory Account, before voting. When seeking this consent, GSAM Private must provide the client with all pertinent information, including the nature of GSAM Private’s conflict; or



GSAM Private may abstain from voting the proxies or vote the proxies in accordance with the recommendation of an independent third party such as Institutional Shareholder Services or Broadridge Financial Solutions Inc.; or



GSAM Private may take any other steps as it deems appropriate that result in a decision to vote the proxies that is based on the Advisory Account’s best interest.

In evaluating investor-voting proposals, GSAM Private may consider information from a variety of sources, including, without limitation, management of the entity presenting a proxy proposal, shareholder groups, and/or independent proxy research services. In all cases, however, the ultimate decision on how to vote a proxy rests with the relevant GSAM Private investment professionals based upon their assessment of the particular transactions or other matters at issue. Investors may contact GSAM Private to obtain information about how securities in the Advisory Accounts were voted and to obtain a copy of GSAM Private’s proxy voting policy.

This item is not applicable.

Page | 155

Glossary As used in this Brochure, these terms have the following meanings. “1933 Act” means the U.S. Securities Act of 1933, as amended. “1934 Act” means the U.S. Securities Exchange Act of 1934, as amended. “Accounts” means Goldman Sachs’ own accounts, accounts in which personnel of Goldman Sachs have an interest, accounts of Goldman Sachs’ clients and pooled investment vehicles that Goldman Sachs sponsors, manages or advises. For the avoidance of doubt, the term “Accounts” includes Advisory Accounts. “Advisers” means Affiliated Advisers and Unaffiliated Advisers. “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Advisory Accounts” means separately managed accounts (or separate accounts) and pooled investment vehicles such as mutual funds, collective trusts and private investment funds that are sponsored, managed or advised by GSAM. “Affiliated Advisers” means investment advisers that are affiliated with Goldman Sachs. “Affiliated Products” means investment products, including separately managed accounts and pooled vehicles, managed, sponsored or advised by GSAM or Goldman Sachs. “Agency Account” means a single bank account established by GSAM (or an affiliate) and maintained by a qualified custodian that facilitates the movement of cash to and from the lenders and the borrowers, as applicable, for all of the Loan Syndicates. “Alternative Investments” means intermediate investment vehicles (for example, feeder funds) formed or managed by GSAM or an affiliate. “Asset & Wealth Management” means the Goldman Sachs Asset & Wealth Management business. “BHCA” means the Bank Holding Company Act of 1956, as amended. “Brochure” means Registrants’ Form ADV, Part 2A. “CBOs” means collateralized bond obligations. “CFTC” means the Commodity Futures Trading Commission. “CLOs” means collateralized loan obligations. “CoCos” means contingent convertible bonds. “Code” means the Registrants’ Code of Ethics. “Co-Branded Model Portfolios” means model portfolios that allocate only to Affiliated Products and External Products managed by a particular Unaffiliated Adviser pursuant to a co-branding agreement or other collaboration agreement. “Co-Investment Advisers” means Advisers to which HFS has allocated Advisory Account assets or by other Advisers or other persons with whom HFS or its affiliates have a relationship.

Page | 156

“Co-Investment Opportunity” means the opportunity to invest alongside funds or other Advisory Accounts with respect to one or more investments. “Consulting Groups” means certain groups of experts, advisors, consultants, operation consulting experts, thought leaders, subject matter experts and other persons intended to provide support in connection with the activities of certain Advisory Accounts. “CPO” means commodity pool operator. “CTA” means commodity trading advisor. “Diligence Reports” means due diligence reports and other information with respect to one or more Underlying Funds and Unaffiliated Advisers. “Dodd-Frank Act” means the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, as amended. “EBITDA” means earnings before interest, tax, depreciation and amortization. “ECN/Trading Venue” means centralized exchanges and trading platforms, electronic communication networks, alternative trading systems and other similar execution or trading systems or venues. “Enrolled Participant” means an enrolled plan participant or retail investor to which GSAM provides Managed Account Services. “Enrolled Participant Account” means an account for an Enrolled Participant to which GSAM provides Managed Account Services. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. “ESG” means environmental, social and governance-oriented investing. “ETF” means exchange-traded fund. “Existing Investment Account” means an Account invested in an Underlying Fund in which a New Investment Account makes a secondary investment. “External Funds” means hedge funds and private equity funds advised by Unaffiliated Advisers. “External Products” means investment products, including separately managed accounts and pooled vehicles, managed, sponsored or advised by Unaffiliated Advisers. “FCA” means the United Kingdom Financial Conduct Authority. “Federal Reserve” means the Board of Governors of the Federal Reserve System. “forward commitment” means a contract to purchase or sell securities for a fixed price at a future date beyond customary settlement time. “Freddie Mac” means the Federal Home Loan Mortgage Corporation. “GIC” means guaranteed investment contracts. “Goldman Sachs” means, collectively, GSAM Holdings LLC, GS Group, GSAM, GS&Co. and their respective affiliates, directors, partners, trustees, managers, members, officers and employees. Page | 157

“Goldman Sachs Wealth Services” means Goldman Sachs Wealth Services, L.P. “GS Fund of Funds” means an Affiliated Product that pursues its investment objectives by allocating assets, directly or indirectly, to External Products. “GS Group” means The Goldman Sachs Group, Inc. “GS RICs” means business development companies and registered investment companies formed from time to time by GSAM. “GS&Co.” means Goldman Sachs & Co. LLC. “GSAM” means Goldman Sachs Asset & Wealth Management, which today is comprised of GSAMLP, GSAMI, GSAMC, GSAMHK, GSAMS, and various locally regulated affiliates around the world. “GSAMC” means Goldman Sachs Asset Management Co. Ltd. “GSAMHK” means Goldman Sachs Asset Management (Hong Kong) Limited. “GSAMI” means Goldman Sachs Asset Management International. “GSAMIH” means Goldman Sachs Asset Management International Holdings LLC. “GSAMLP” means Goldman Sachs Asset Management, L.P. “GSAMS” means Goldman Sachs Asset Management (Singapore) Pte. Ltd. “GSAM Approved Managers” means the Unaffiliated Advisers approved by XIG. “GSAM Employee Funds” means investment vehicles organized to facilitate investment by its current or former directors, partners, trustees, managers, members, officers, employees, and their families and related entities, including employee benefit plans in which they participate, and current consultants. “GSAM ETFs” means the exchange-traded funds for which GSAM or its affiliates act as investment adviser. “GSAM Personnel” means the personnel of the various entities comprising GSAM. “GSAM Private” means the private alternatives business of GSAMLP, together with the private alternatives businesses of other Registrants (formerly known as GS Merchant Banking). “GSAM Private Investment Committee” means an investment committee comprised of the senior professionals in GSAM Private and other control-side professionals of Goldman Sachs. “GSAM Private Investment Team” means a team of investment professionals that carries out the process of investing in or lending to a company on behalf of GSAM Private. “GSAM Public” means the businesses within GSAM other than GSAM Private. “GSAM Strategies” means investment and trading strategies developed by GSAM or its affiliates or co-developed by GSAM or its affiliates and a third party. “GSI” means Goldman Sachs International. “GSTC” means The Goldman Sachs Trust Company, N.A.

Page | 158

“GSTD” means The Goldman Sachs Trust Company of Delaware. “Guidelines” means customized proxy voting guidelines that GSAM has developed. “HFS” means GSAMLP’s Hedge Fund Strategies business. “Hybrid Securities” means preferred and deeply subordinated long-term debt. “IBOR” means an interbank offered rate. “Index” means stock market and other indexes developed, owned and operated by GSAM and its affiliates. “Industry Advisors” means certain members of a Consulting Group that may participate in one or more of the other Consulting Groups and/or serve as advisors to GSAM with respect to investment in and management of portfolio company investments. “Intermediaries” means, collectively, authorized dealers and other financial intermediaries and salespersons. “Investment Company Act” means the U.S. Investment Company Act of 1940, as amended. “IPO/New Issue” means an initial public offering or new issue. “IPS” means Inflation Protected Securities. “IRS” means the U.S. Internal Revenue Service. “LIBOR” means the London Inter-bank Offered Rate. “Loan Syndicate” means a loan syndicate organized by GSAM. “Loan Syndicate Program” means GSAM and its affiliates, Advisory Accounts, and other bank and non-bank lenders that participate in a Loan Syndicate. “Managed Account Services” means the goal and risk-based financial planning and portfolio management services offered by GSAM. “Managed Account Services Algorithms” means the algorithms used by Managed Account Services. “Managed Account Services Guidance” means non-fiduciary retirement planning guidance tools and services for Enrolled Participant Accounts. “Manager of Manager Accounts” means pooled investment vehicles and separately managed accounts managed by GSAM and/or its affiliates and sub-advised by Unaffiliated Advisers selected by XIG. “MAS” means Multi-Asset Solutions Group. “MAS Program Funds” means pooled investment vehicles formed and managed by the MAS team, including vehicles formed primarily for investment by other Advisory Accounts of MAS, and pooled investment vehicles formed and managed by others, including affiliates. “MiFID II” means the Second Markets in Financial Instruments Directive. “MLPs” means master limited partnerships.

Page | 159

“Model Portfolio Accounts” means accounts managed by Model Portfolio Advisers, including PWM, based on model portfolios provided by GSAM. “Model Portfolio Advisers” means affiliated and unaffiliated investment advisers to which GSAM provides model portfolios. “New Investment Account” means an Account that invests in a secondary investment involving an Underlying Fund in which an Existing Investment Account has invested. “Non-Discretionary Co-investors” means certain non-discretionary Advisory Accounts or other potential investors, including funds organized for the purpose of investing in the specific transaction. “OTC” means over-the-counter markets. “Outputs” means the initial voting outputs that are developed for each proxy vote. “Participating Affiliates” means GSAM’s non-U.S. affiliated advisers that may provide advice or research to GSAM for use with GSAM’s U.S. clients. “Participations” means participation interests. “PIPEs” means private investments in public equities. “Plan Sponsors” means the retirement savings plan clients of Managed Account Services. “Profits Interests” means material equity, profits or other interests with respect to Unaffiliated Advisers, their Underlying Funds or their affiliates and/or other special rights that Seeding Funds may receive in exchange for allocating assets to “start-up” Advisers. “Proxy Platform Service” means a third-party proxy voting platform service, currently Institutional Shareholder Services, a unit of RiskMetrics Group, and, with respect to U.S. equities only, Broadridge Financial Solutions Inc. “Proxy Voting Policy” means GSAM’s policies and procedures for the voting of proxies on behalf of Advisory Accounts for which GSAM has voting discretion. “PWM” means the Private Wealth Management unit of GS&Co. “QES” means Quantitative Equity Strategies. “QIS” means Quantitative Investment Strategies. “QOF” means a qualified opportunity fund. “QOZ” means a census tract (generally low-income urban, suburban or rural communities) that has been designated as a “qualified opportunity zone”. “Quantitative Strategies” means the quantitative techniques pursued by the QIS and QES teams. “Real Estate Operating Platforms” means real estate operating platforms established by GSAM Private to service Advisory Account real estate assets. “Recommendation” means a written analysis and recommendation of a proxy vote that reflects the Proxy Service’s application of the Guidelines to the particular proxy issues. “REIT” means real estate investment trust. Page | 160

Read the rest in the brochure