Grantham, Mayo, Van Otterloo & Co. LLC

A. Grantham, Mayo, Van Otterloo & Co. LLC (“GMO”) was founded in 1977 and furnishes investment advisory services to clients. GMO is a Massachusetts limited liability company that is controlled by active employee-members (“Members”). The Members, analogous to partners in other organizations, include senior individuals in the firm. No Member owns more than 15% of the membership interests in the firm. GMO’s offices include its headquarters in Boston, Massachusetts, and a representative office in Tokyo. The offices of GMO’s affiliates are located in Amsterdam, London, Singapore, and Sydney. Please see Item 10, “Other Financial Industry Activities and Affiliations” for a more detailed discussion about GMO’s affiliates. B. GMO offers investment strategies in many of the major asset classes (e.g., U.S., non-U.S., emerging and global equities and fixed income), as well as multi-asset class, and alternative strategies. Within these strategies, a range of investment styles, market capitalizations, and types of securities may be represented. GMO’s investment strategies are implemented through pooled vehicles (e.g., mutual funds, private funds or exchange-traded funds (ETFs), and/or through discretionary advice provided to separately managed accounts, some of which use pooled vehicles. In certain instances, GMO also offers non-discretionary services through the delivery of model portfolios or other similar advice-only mandates. Please see Item 8, “Methods of Analysis, Investment Strategies and Risk of Loss” for more information regarding GMO’s investment strategies. An independent wealth advisor may select GMO to manage a separate account for the wealth advisor’s clients and enter into, on the client’s behalf, an investment management agreement with GMO for that client’s account (“Manager Advised Separate Account”). In such cases, the wealth advisor selects an investment strategy on behalf of the client, and the wealth advisor and/or the wealth advisor’s client enters into an agreement with GMO for GMO to provide sub-advisory services to the client’s account. The wealth advisor may request certain customizations on behalf of the client’s account, such as restricting the account from holding certain securities. Participants in the Manager Advised Separate Account program should review the terms of the investment management agreement, investment guidelines, and fees selected by their wealth advisor. GMO generally allocates investment opportunities as described in Item 7 and follows the allocation and other brokerage practices, as out set forth in Item 12. As further explained in Item 12, brokerage commissions or other costs for execution of transactions in the Manager Advised Separate Accounts may not be negotiated by GMO. GMO may tailor its advisory services for clients investing through separately managed accounts. GMO may agree to manage the client’s assets against a particular benchmark or pursuant to investment guidelines discussed and agreed upon with the client. To the extent practicable and consistent with the intended investment strategy, GMO may agree to implement client-imposed limitations on GMO’s discretionary authority with respect to the securities to be bought or sold for an account including, but not limited to, diversification requirements, benchmark deviation, industry concentration, restrictions prohibiting the purchase of certain securities or securities of certain types of issuers, prohibiting investments in certain countries or markets, limitations in relationships with counterparties, and/or

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prohibiting the employment of certain investment strategies or techniques (e.g., derivatives). Please see Item 16, “Investment Discretion,” which discusses these and other restrictions relating to GMO’s discretionary authority. Client accounts that are subject to such limitations may perform differently (and potentially less successfully) than other accounts with similar strategies managed by GMO that do not have such limitations. C. GMO does not participate in wrap-fee programs. D. As of December 31, 2025, GMO managed US$76.8 billion on a discretionary basis for its clients. These figures reflect GMO’s net assets under management, as contrasted with the assets required to be reported in Part 1A of Form ADV as GMO’s “regulatory assets under management.” GMO may provide investment advice to certain clients on a non-discretionary basis. Those services include securities analysis, model portfolio delivery, portfolio risk analysis and specific investment recommendations. As of December 31, 2025, GMO managed US$1.6 billion on a non-discretionary basis for its clients.

A. The rate of GMO’s advisory (or management) or service fee varies with the type of service, product or asset class being managed, the investment strategy being employed, and the vehicle type in which the strategy is being implemented. GMO’s fees are generally asset-based and calculated at an annual rate as a percentage of the value of the net assets in the account. In some cases, GMO is paid a combination of an asset-based fee and a performance fee. The performance fee may take the form of a special allocation of profit to GMO, or an affiliate, from a GMO pooled vehicle. Special allocations and performance-based fees or performance fees are referred to interchangeably throughout this brochure. The performance fee may be calculated in a variety of ways depending on multiple factors including, but not limited to, the nature of the strategy, relevant performance benchmarks and performance hurdles, and is generally calculated based on both realized and unrealized amounts. Please see Item 6, “Performance-Based Fees and Side-by-Side Management” for more information. Under appropriate circumstances, in GMO’s discretion and where permitted by applicable law, the terms of an investment advisory contract, including fee schedules, terms of payment and termination provisions, may be negotiable. The asset-based fees paid to GMO by clients with discretionary separately managed accounts generally range from 0.18% to 1.00%. The assetbased management fee rate for a separately managed account will typically begin at a higher rate than a pooled investment vehicle managed in the same strategy. With respect to accounts in the Manager Advised Separate Account program, GMO agrees on the advisory fee payable with the client’s wealth advisor. As stated above, for those accounts, an independent wealth advisor selects an investment strategy on behalf of a client, and the wealth advisor and/or the wealth advisor’s client enters into an agreement with GMO for GMO to provide sub-advisory services to the client’s account. The advisory fees payable for a Manager Advised Separate Account may change based on certain factors, including the -4-

aggregate amount of assets (i) in client accounts that belong to the same household or (ii) the wealth advisor’s clients, or clients of the wealth advisor’s service providers, have invested in GMO funds or strategies, including the Manager Advised Separate Accounts. Advisory fees for clients in Manager Advised Separate Accounts can differ as a result of the client’s wealth advisor and the wealth advisor’s relationship with GMO. These fees may also be payable in advance. GMO may, for fee calculation purposes, agree to aggregate the assets of related accounts that are being managed for the same client even if such account(s) is/are managed by an affiliate of GMO. In those circumstances, the aggregate accounts may receive the benefit of a lower effective fee due to the combined level of assets. Certain clients from time to time seek to include most favored nation (“MFN” and such client an “MFN Client”) clauses in their investment management agreements with GMO. GMO considers agreeing to an MFN clause in view of a number of factors, which may include the client’s overall relationship with GMO. These clauses generally require GMO to notify the MFN Client if GMO has entered into, or subsequently enters into, a more favorable fee arrangement with a comparable client and offer the MFN Client the same fee arrangement or notify the MFN Client of such fee arrangement. Whether an account will be considered comparable will depend upon the language of the client’s agreement with GMO. The agreement may provide for consideration of factors including, but not limited to, the size of the account, scope and type of relationships with GMO, restrictions on account, level of services required for the account, investment strategy, investment objectives and discretionary character of the account. GMO does not agree to MFN clauses in all circumstances and has sole discretion over whether to grant an MFN clause. The GMO Trust mutual funds (each a “GMO Trust Fund” and collectively, “GMO Trust Funds”) pay, directly or indirectly, management, service, and/or supplemental support fees to GMO. The total net annual expenses of the GMO Trust Funds generally range from 0.02% to 2.50%. Total net annual expenses are charged to and deducted from the GMO Trust Funds in arrears. Additional information on each GMO Trust Fund’s fees and expenses is provided in the respective prospectuses, as supplemented and/or amended from time to time. In consideration for the services GMO provides to each series of GMO ETF Trust (each, a “GMO ETF”) and for GMO’s agreement to pay all of the expenses incurred by the relevant GMO ETF (with certain exceptions), GMO is paid an investment advisory fee based on the average daily assets of the GMO ETF. The investment advisory fees for the GMO ETFs generally range from 0.20% to 0.65%. Additional information on each GMO ETF’s fees and expenses is provided in the respective prospectuses, as supplemented and/or amended from time to time. The stated asset-based fee rates for each private pooled product advised by GMO, excluding GMO Trust Funds and GMO ETFs (collectively, the “GMO Private Funds”), are set forth in detail in each GMO Private Fund’s offering documentation. Note that the universe of GMO Private Funds contemplated in this brochure may be broader than the list of “private funds” required to be reported in Item 7.B of Part 1A of Form ADV, and that GMO-managed UCITS and qualifying investment funds domiciled in Ireland are not “investment companies” within the Investment Company Act of 1940, as amended, by virtue of Sections 3(c)(1) and/or 3(c)(7) and are included within the defined term “GMO Private Funds” for purposes of this brochure. -5-

The asset-based fee rates for the GMO Private Funds generally range from 0.025% to 2.625%. With respect to the fees charged by GMO Private Funds the general partner, investment adviser or board of directors of such vehicles, as the case may be, has discretion to waive, modify or calculate differently, or rebate a portion of the asset-based fees and/or performance fees for any period for some or all investors and admit investors or accept additional subscriptions from existing investors subject to such other fee arrangements as each of them deems appropriate and generally without notice to or consent from other investors, subject to applicable, law, rule or regulation. GMO also serves as the investment advisor to pooled funds established within the GMO Collective Investment Trust (each, a “CIT”) for investment by tax-qualified retirement, pension, profit-sharing, stock bonus and other employee benefit trusts and certain eligible governmental plans. Investors in a CIT are charged an annual fee based on the specific fee class designated in the investor’s participation agreement. In some instances, a different fee may be negotiated with an investor. The third-party trustee of the CIT may retain a portion of the fee for trustee, administrative and other services provided to the CIT. A portion of this fee may be paid to CIT service providers to help defray the costs incurred in connection with maintaining and servicing the CIT. Additional information about fees and expenses is provided in the CIT organizational and offering documents. Investment advisory fees and other terms of an investment in a CIT vary due to a variety of factors, including the CIT’s strategy, the particular circumstances of the investor and account size, among others. The GMO Private Funds, GMO Trust Funds, GMO ETFs and CIT are collectively referred to as “GMO Funds” throughout this document. For some clients, including GMO Trust Funds and GMO ETFs, GMO is given authority to allocate (and reallocate) a client’s assets among GMO Trust Funds, GMO ETFs and, in some cases, other pooled vehicles, on a discretionary basis. For some of those asset allocation clients, GMO receives no direct fee for advising or performing the allocation but will receive fees from the underlying pooled vehicles to which it allocates. In such cases, GMO will earn a higher total fee to the extent a client’s assets are allocated among pooled vehicles that have higher fees payable to GMO. Therefore, a conflict of interest exists because GMO has an incentive to allocate client assets into pooled vehicles that produce the greatest fees for GMO. In other cases, a client that has granted such asset allocation authority to GMO will be assessed an account-level fee which may consist of an asset-based fee or a combination of an assetbased fee and a performance fee. To the extent that such a separately managed account is invested in GMO Trust Funds or GMO ETFs, GMO generally will credit against the accountlevel fee payable to GMO the amount of any management and shareholder service fees paid to GMO by the GMO Trust Funds or GMO ETFs in respect of such account’s investment in such funds. To the extent a separately managed account is invested in a GMO Private Fund, GMO generally reduces the GMO Private Fund’s advisory or management fee to zero with respect to such account’s investment in the GMO Private Fund. In all these cases, GMO has a conflict of interest because GMO can earn the same amount (and therefore earns a higher fee for its allocation services) when a client’s assets are allocated among products that have a lower average fee. In addition, a conflict of interest exists when GMO is allocating assets among pooled products when GMO is also considering whether to close to new investment pooled products with limited capacity but whose investors may pay GMO fees. GMO has an incentive -6-

to accept additional investments in those GMO Funds with higher fees even if a larger asset base may be more difficult to manage. GMO, in its sole discretion, may permit investment by GMO Funds in other GMO Funds that are otherwise closed to unaffiliated investors and may restrict investment by GMO Funds in other GMO Funds that remain open to unaffiliated investors. GMO, on behalf of GMO Private Funds, may also, in its sole discretion, reduce all or a portion of the management fee or performance fee or bear other costs and expenses related to investments held by GMO, its affiliates, and their respective Members and employees. B. For accounts that are pooled vehicles, fees are generally accrued daily or monthly and paid in arrears. For accounts that are separately managed, asset-based fees are typically billed and payable quarterly in arrears, although such accounts may be billed more or less frequently. Performance fees for separately managed accounts and certain pooled products, if applicable, are typically billed annually, but GMO and a client may agree to billing based on an initial, partial calendar year or to a more or less frequent billing cycle. From time to time, a client, whether in a separately managed or asset allocation account, may provide a standing instruction to GMO in its investment management agreement to redeem shares of GMO Funds held in its account to the extent necessary to pay their base (or advisory) fee and any performance fee owed to GMO. For all accounts, the amount of the asset-based fee is prorated if GMO provides advisory services for periods of less than a full payment cycle (e.g., at the beginning or end of GMO’s engagement to provide advisory services). For accounts investing in a GMO Fund (or a class thereof) that charges performance fees, accrued performance fees are generally payable at the time of each redemption from such GMO Fund and at the end of other account performance measurement periods (typically, annually). In all cases, and even if a contract is silent, GMO requires that fees billed from January through November be paid by March 15 of the following year (except for certain corporations and non-US clients who must remit payment by the end of the calendar year in which they were billed) and, with respect to fees billed as of December 31 of each year, no later than December 31 of the following year. C. Clients that have a separately managed account will incur brokerage costs, third-party execution costs (if any) and other transaction costs associated with GMO’s management of the accounts’ portfolio securities. Please see Item 12, “Brokerage Practices” for a description of GMO’s brokerage practices. In addition to advisory (or management) fees and brokerage and transaction costs, clients invested in the GMO Trust Funds will, either directly or through a separately managed account, bear the other fees and expenses paid by the GMO Trust Funds, as applicable, including shareholder service, and/or supplemental support fees paid by the GMO Trust Funds to GMO and other fees and expenses paid by the GMO Trust Funds (to the extent not otherwise waived or reimbursed by GMO), which include but are not limited to, expenses of the independent Trustees and their independent counsel; fees and expenses of underlying funds (including GMO Trust Funds) in which the GMO Trust Funds invest; fees and expenses for legal, fund accounting, transfer agency, custodial, tax and auditing services; insurance premiums; fees of proxy advisory firms; securities lending fees and expenses; interest expense; transfer taxes and other investment-related costs (including investment-related legal expenses and overdraft charges); governmental, regulatory, licensing, filing or registration fees; hedging transaction fees; extraordinary or non-recurring and expenses not incurred in the ordinary course of the GMO Trust Fund’s business (e.g., taxes, litigation, judgments and indemnification expenses). -7-

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A. GMO investment professionals may employ a variety of tools in providing investment advice to GMO clients including, but not limited to, proprietary techniques used to research and evaluate securities based on historical and forecasted financial information, as well as fundamental investment analysis. GMO believes that material environmental, social and corporate governance (“ESG”) factors can, in many cases, be helpful in assessing future risks and prospects of the companies and countries which it invests, and by integrating ESG into the investment processes of certain strategies GMO can improve long-term risk-adjusted returns. For example, ESG may help GMO identify issuers who are working to address underappreciated ESG risks and, in turn, enhance their long-term profitability and command a higher premium into the future. The weight that ESG criteria are given, overall or individually, for a particular investment decision is dependent upon GMO’s assessment of their materiality and relevance to that investment decision. The consideration of ESG criteria as part of a strategy’s investment process does not mean that the strategy pursues a specific “ESG” investment strategy, and, depending on the strategy, GMO may make investment decisions that are based on other (non-ESG) material financial information or risk considerations. Each GMO investment team may apply different approaches to capturing, assessing, and weighing ESG risks in integration processes, and the incorporation of ESG criteria into the investment process for a particular strategy does not mean that every investment or potential investment undergoes an ESG review, and GMO may not consider ESG criteria for every investment a strategy makes (such as, for example, in cases where ESG-related data for a company is -11-

unavailable). GMO believes that active engagement can help to better assess key ESG risks and opportunities and, critically, how these matters support or risk hurting long-term investment results. For many strategies, GMO may use engagement and proxy voting practices to understand how issuers are addressing key ESG risks and to encourage behavior that supports positive long-term results. GMO offers investment strategies in many of the major asset classes (e.g., U.S., non-U.S., emerging and global equities and fixed income), as well as multi-asset class, and alternative strategies. Please refer to Appendix A for a general description of each of GMO’s investment strategies as of the date of this brochure. Descriptions of strategies offered through pooled investment vehicles are qualified in their entirety by the information contained in the relevant vehicle’s offering materials. Descriptions of strategies offered through separately managed accounts are qualified in their entirety by reference to the applicable investment advisory agreement and related investment guidelines; and this brochure shall govern to the extent the contract is silent. Investing in securities involves risk of loss that clients should be prepared to bear. Please note that ‘invested in’ as used in this brochure includes both direct and indirect investments and long and short positions unless otherwise indicated. When used herein the terms ‘bonds,’ ‘fixed income investments,’ and ‘fixed income securities,’ include (a) obligations of an issuer to make payments on future dates of principal, interest (whether fixed or variable) or both and (b) synthetic debt instruments created by GMO through the use of derivatives (e.g., a futures contract, swap contract, currency forward or option). B. The following chart identifies the material risks associated with the strategies described in Appendix A. Risks not marked for a particular strategy, may, however, still apply to some extent to that strategy at various times. All strategies could be subject to greater or additional risks due to the types of investments they make and changing market conditions over time. Where exposures are achieved using derivatives, the risks of owning the reference assets still apply, in addition to the risks of the derivatives themselves. This summary of the material risks is supplemented by the information contained in a GMO Fund’s offering materials, if any. Some clients may request variations on the strategies described in Appendix A. For those separately managed accounts, such variations may subject the accounts to risks in addition to the material risks identified below.

Borrowing and Leverage Risk Commodities Risk Convertible Securities Risk Counterparty Risk Credit Market Illiquidity Risk Credit Risk Currency Risk

Equities

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Multi-Asset Class Alternative

Equities Custodial Risk Derivatives Risk Event Driven Risk Focused Investment Risk Focused Investment Risk – Climate Change, Natural Resources, and Resource Transition Illiquidity Risk Inflation Risk Interest Rate Risk Large Investor Risk Legal and Regulatory Risks Management and Operational Risk Market Disruption and Geopolitical Risk Market Risk-Equity Securities Market Risk- Fixed Income Securities Non-U.S. Investment Risk Options Risk Portfolio Turnover Risk Preferred Securities Risk Prime Brokerage Risk Real Estate Risk Risks of Pooled Investment Vehicles Short Sales Risk Smaller Company Risk Underlying Strategies Risk

Fixed Income

Multi-Asset Class Alternative

Borrowing and Leverage Risk – If permitted by the strategy’s investment policies, the strategy may purchase securities on margin and may arrange with banks, brokers and others to borrow money. A strategy may use leverage to increase its exposure to the underlying investments and may borrow money without limitation or use derivative instruments in connection therewith. The use of leverage creates opportunities for greater total return but at the same time creates greater risks. While gains made with borrowed funds generally would cause a strategy’s net asset value to increase faster than without the use of borrowed funds, if the market value of securities purchased with borrowed funds declines or does not appreciate sufficiently to cover the costs of borrowing, the strategy’s value will decrease faster and more significantly than without the use of borrowed funds. Such decrease in value could be substantial. As the -13-

strategies do not have specific limitations on long or short exposure, the risks associated with leverage may be greater than would otherwise be the case. In addition, a strategy will be leveraged if it exercises its right to delay payment on a redemption, and losses will result if the value of the strategy’s assets declines between the time a redemption request is deemed to be received by the strategy and the time the strategy liquidates assets to meet redemption requests.

Commodities Risk – Commodity prices can be extremely volatile and may be directly or indirectly affected by many factors, including changes in overall market movements, real or perceived inflationary trends, commodity index volatility, changes in interest rates or currency exchange rates, population growth or decline and changing demographics, and factors affecting a particular industry or commodity, such as drought, floods, or other weather conditions, livestock disease, trade embargoes, competition from substitute products, transportation bottlenecks or shortages, insufficient storage capacity, fluctuations in supply and demand, war, tariffs, and international regulatory, political, and economic developments (e.g., regime changes, “trade wars” and changes in economic activity levels). Exposure to commodities can cause the net asset value of the strategy’s assets to decline or fluctuate in a rapid and unpredictable manner.

Convertible Securities Risk – The market value of a convertible security is a function of its ‘investment value’ (determined by its yield in comparison with the yields of other securities of comparable maturity and quality that do not have a conversion privilege) and its ‘conversion value’ (the security’s worth, at market value, if converted into the underlying common stock). The investment value of a convertible security is influenced by changes in interest rates, with investment value declining as interest rates increase and increasing as interest rates decline. A convertible security may also be subject to redemption or conversion under specified circumstances and/or at the option of the issuer at a price established in the convertible security’s governing instrument.

Counterparty Risk – The strategy runs the risk that the counterparty to a derivatives contract, a clearing member used by a client account to hold a cleared derivatives contract, or a borrower of a client account’s securities is unable or unwilling to make timely settlement payments or otherwise honor its obligation. To the extent that GMO’s view with respect to particular counterparty changes (whether due to external events or otherwise), does not mean that existing transactions with the counterparty will necessarily be terminated or modified. Additionally, new transactions may be entered into with a counterparty that GMO no longer considers a desirable counterparty (e.g., re-establishing the transaction with a lesser notional amount or entering into a countervailing trade with the same counterparty). Counterparty risk also may be more pronounced if a counterparty’s obligations exceed the amount of collateral held by a strategy (if any), the strategy is unable to exercise its interest in collateral upon default by the counterparty, or the termination value of the instrument varies significantly from marked-to-market value of the instrument. To the extent the strategy allows a prime broker, if any, or any over-the-counter derivative counterparty to retain possession of any collateral, the strategy may be treated as an unsecured creditor of such counterparty in the event of the counterparty’s insolvency. -14-

Counterparty risk may also be higher for a strategy that allows its counterparties to transfer collateral posted by the counterparty to affiliates of the counterparty, including the strategy’s prime broker. Such arrangements may enable a strategy to incur higher leverage, because the strategy’s margin requirements to such counterparty to secure such leverage may be lower since such requirements are determined across all lines of business between the strategy and such counterparty and its affiliates. However, in those circumstances, the strategy may find itself in the position of being treated as an unsecured creditor of its counterparty (and/or its affiliate) in the event of the counterparty’s (and/or its affiliate’s) insolvency notwithstanding the formalities of the collateral arrangements. Also, to the extent the strategy’s assets are transferred to an entity governed by the laws of a different jurisdiction, the strategy might need to institute proceedings in that jurisdiction in order to seek the return of its assets. To the extent that the strategy engages in futures and options contract trading and the futures commission merchants with whom the strategy maintains accounts fail to segregate the strategy’s assets, the strategy will be subject to a risk of loss in the event of the bankruptcy of any of its futures commission merchants. The strategy will assume the credit risk associated with placing its cash, margin and securities with brokers, and the failure or bankruptcy of any of such brokers could have a material adverse impact. If the futures brokers become bankrupt or insolvent, or otherwise default on their obligations to the strategy, the strategy may not receive all amounts owing to it in respect of its trading, despite the clearinghouse fully discharging all of its obligations. Furthermore, in the event of the bankruptcy of a futures broker, the strategy could be limited to recovering only a pro rata share of all available funds segregated on behalf of the futures broker’s combined customer accounts, even though certain property specifically traceable to the Fund was held by the futures broker. Also, in contrast to the treatment of margin provided for cleared derivatives, the futures broker does not typically notify the futures clearing house of the amount of margin provided by the futures broker to the futures clearing house that is attributable to each customer. Therefore, a strategy is subject to the risk that its margin will be used by the futures clearing house to satisfy the obligations of another customer of its futures brokers.

Credit Market Illiquidity Risk – It is possible that illiquidity in the credit markets could cause the price of investments held by the strategy to decline, which may have the result of forcing the strategy to sell assets to reduce leverage, satisfy requirements under its borrowing arrangements or to meet margin calls, all of which could, in turn, create further downward price pressure. If there is a substantial decline in the market value of a strategy’s portfolio of investments, investments may need to be liquidated quickly.

Credit Risk – The strategy runs the risk that the issuer or guarantor of a fixed income investment (including a sovereign or quasi-sovereign debt issuer) or the obligor of an obligation underlying an asset-backed security will be unable or unwilling to satisfy its obligations to pay principal and interest payments or otherwise to honor its obligations in a timely manner. The obligations of issuers also may be subject to bankruptcy, insolvency and other laws affecting the rights and remedies of creditors. The market price of a fixed income investment will normally decline as a result (and/or in anticipation) of the failure of an issuer, underlying obligor or guarantor to meet its -15-

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GMO provides investment advice to a wide variety of clients, including, but not limited to, endowments, foundations; employee benefit, pension and contribution plans; governmental and supranational entities; family offices; high net worth individuals; taxable entities; investment companies; pooled investment vehicles; trusts; other institutions (including financial intermediaries) and individuals (including individual retirement accounts). The minimum account size for investment in certain share classes of the GMO Trust Funds varies but generally requires at least a $1 million commitment. For the GMO Private Funds, the minimum account size varies depending on the vehicle, but is generally at least $1 million and there are generally legal and/or regulatory based limitations on the types of eligible investors. Minimum account size requirements are waived for Members and employees and for other investors at GMO’s discretion including, without limitation, intermediaries. GMO may waive a GMO Fund’s investment minimum for certain clients in certain circumstances (e.g., for clients whose investment consultant has full discretion or exercises substantial influence over its clients’ assets and where the relationship meets the investment minimum). The minimum account size for separately managed accounts varies by investment strategy.

Performance Based Fees and Side-by-Side Management

GMO may be paid an asset-based fee or a combination of an asset-based fee and a performance fee. Please see Item 5, “Fees and Compensation” and the related Schedules for more information about GMO’s fees. To the extent GMO charges a performance fee, the client must -9-

be eligible, and the performance fee must generally comply with the requirements of Section 205 of the Investment Advisers Act of 1940, as amended (“Advisers Act”) and Rule 205-3 thereunder. In situations where GMO has entered into a performance fee arrangement, it may have an economic incentive to make riskier investments, pursue riskier strategies, seek less downside risk when a GMO Fund has outperformed its benchmark and allocate superior investment ideas to those accounts capable of generating higher performance-related compensation than it might otherwise. In addition, because many of GMO’s investment personnel manage accounts with only asset-based fees and accounts with an asset-based fee and a performance fee component, they face conflicts of interest in that they may have an incentive to favor accounts for which GMO receives a base and performance fee. GMO’s compensation program for its investment professionals is designed to align compensation of the investment professionals managing an account to such accounts’ performance over various periods. Importantly, GMO emphasizes maintaining a long-term view, which GMO believes best aligns its rewards system with its clients’ interests. An investment team’s compensation pool for the year generally is determined by the team’s investment performance over the measurement periods (using 5-year, 3-year and 1-year, where available) versus their benchmark and peer universe (as applicable) and the firm’s performance. Additional considerations include, among other things, product fee structures and maturity, talent and experience levels, collaboration with other teams and contributions to firm-wide research. Individual awards are discretionary and determined based on a number of factors, which can include, among other things, investment performance (over multi-year periods), conducting innovative research, rigorously pursuing new investment concepts, participating constructively in the vetting of ideas and their ultimate incorporation into portfolios, as well as how an individual exhibits attributes that are aligned with GMO’s investment philosophy, values, competencies and culture. In limited circumstances, GMO uses a formulaic approach that includes a portion of revenues from base and performance fees. As a result, individual investment professionals may have some or all the same economic incentives that GMO itself may have when GMO is eligible to earn a performance fee. Specifically, whether or not GMO is earning or is eligible to earn a performance fee, individual investment professionals may have compensation-related incentives to make riskier investments, pursue riskier strategies, seek less downside risk when a GMO Fund has outperformed its benchmark and allocate superior investment ideas to those accounts capable of generating higher performance-related compensation than they might otherwise. GMO may also have an incentive to favor accounts in which it and/or its Members and employees may own a substantial interest. GMO maintains firm-wide trade allocation standards, and GMO’s trading desk has specific allocation procedures designed to allocate investment opportunities fairly and equitably over time. Information regarding these procedures is provided under Item 12, “Brokerage Practices.” To manage further the potential conflicts of interest associated with side-by-side management of accounts and funds with performance fees and those that have solely asset-based fees, dispersion among accounts employing similar investment strategies is periodically reviewed to ensure that any material divergence in expected performance is adequately understood.

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GMO may also have conflicts of interest related to engaging in short sales of, or taking a short position in, an investment owned or being purchased by other client accounts managed by GMO or vice versa. See also Item 11, “Code of Ethics, Participation in Client Transactions and Personal Trading: Conflicts Related to Advisory Activities” for additional information on potential conflicts.

A. GMO is not registered, nor does it have an application pending to register as a U.S. broker/dealer. Certain of GMO’s personnel are principals and/or registered representatives of Funds Distributor LLC, an unaffiliated broker/dealer that has been retained (for regulatory reasons only) to effect client transactions in shares/interests of GMO Funds and to act as a placement agent for the majority of the GMO Private Funds.

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B. GMO is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor and a commodity pool operator and is a member of the National Futures Association (“NFA”) with respect to the management of pooled products and separately managed accounts that utilize futures contracts and other derivatives. Certain of GMO’s management persons and client-facing personnel are registered with the NFA as principals and/or associated persons. C. Related pooled investment vehicles and general partners. GMO manages the constituent funds of GMO Trust and GMO ETF Trust. GMO Trust was organized by GMO in June 1985. GMO Trust is a registered management investment company (SEC File No. 2-98772, 811-4347). GMO ETF Trust was organized in Delaware. GMO ETF Trust is a registered management investment company (SEC File No. 811-23895, 333-274096). The GMO ETFs are exchangetraded funds with a U.S. principal listing exchange on NYSE Arca, Inc. GMO provides advisory and other services to the GMO Private Funds. GMO or an affiliate of GMO serves as the general partner to several of the GMO Private Funds advised by GMO. Members and employees of GMO serve as officers and/or Trustees of GMO Trust and GMO ETF Trust. In addition, Members and employees of GMO serve as officers and/or members of the boards of directors of certain GMO Private Funds that pay fees to GMO, including performance fees. In the case of many GMO Private Funds, GMO Members and employees constitute a majority of the board of directors. GMO Members and employees who serve as officers, directors or trustees generally have conflicts of interest. GMO may also hold the only voting securities issued by a GMO Private Fund or otherwise may hold a majority of the shares voting at a meeting and will generally have a conflict of interest in exercising its voting rights. Related advisers. Please note that all investment personnel of a related adviser are associated persons of GMO with respect to the services they provide to GMO and/or GMO clients as agreed with GMO. GMO Australia Ltd. is a wholly-owned subsidiary of GMO, located at Suite 43.02, Grosvenor Place, 225 George Street, Sydney NSW 2000 Australia. GMO Australia Ltd. commenced operations in November 1995 and manages or services accounts similar to those managed by GMO in the U.S. GMO Australia Ltd. holds an Australian Financial Services Licence issued by the Australian Securities and Investments Commission. GMO Singapore Pte. Ltd. (“GMO Singapore”), a U.S. registered investment adviser (SEC File No. 801-78717), is a wholly-owned subsidiary of GMO, located at 6 Battery Road, #34-01 Singapore 049909. GMO Singapore commenced operations in February 2003 and manages or services accounts similar to those managed by GMO in the U.S. GMO Singapore has a Capital Markets Services License from the Monetary Authority of Singapore authorizing it to provide the regulated activities of ‘dealing in capital markets products’ and ‘fund management’.’ Ernest Chew, Gunwoo Lim, and Alicia Yeo are employees of GMO Singapore. All the aforementioned employees are associated persons of GMO with respect to services they provide to GMO and/or GMO’s clients as agreed with GMO. GMO Singapore provides services to certain of the GMO Funds and is compensated by GMO for providing those services. -28-

GMO’s investment adviser affiliates may provide advice to their clients with respect to strategies that are similar to strategies offered by GMO and those investment advisory affiliates may purchase on behalf of their clients the same securities that GMO may purchase for its clients. Affiliates of GMO also sponsor limited partnerships or other pooled products. As a result, interests of GMO’s clients may conflict with the interests of clients of GMO’s investment advisory and other affiliates. Please see the discussion below in Item 11 describing conflicts related to GMO’s advisory activities. Any of the foregoing related advisers may serve as a placement agent, distributor or marketer of GMO Funds in jurisdictions outside the United States and share revenue for providing such services. Please see Item 14, “Client Referrals and Other Compensation,” for further discussion on any distribution arrangements. Related commodity pool operators. GMO Investment Partners, LLC, a wholly-owned subsidiary of GMO and general partner and/or managing member to several GMO Private Funds, is registered with the CFTC as a commodity pool operator. Other. GMO UK Limited (“GMO UK”) is a wholly-owned subsidiary of GMO located at No. 1 London Bridge, London SE1 9BG England. The firm commenced operations in December 2003 and services accounts similar to those managed by GMO in the U.S. GMO UK is authorized and regulated by the Financial Conduct Authority. Anthony Hene and Vineta Salale are Members of GMO and are also employees of GMO UK. Riversdale Waldegrave, Linda Gruendken, and Tommy Garvey are employees of GMO UK. All the aforementioned employees are associated persons of GMO with respect to services they provide to GMO and/or GMO’s clients as agreed with GMO. GMO Netherlands B.V. (“GMO Netherlands”) is a wholly-owned subsidiary of GMO located at Gustav Mahlerplein 109-115, 26th Floor, 1082 MS Amsterdam. GMO Netherlands was incorporated in November 2018 and is authorized by the Netherlands Authority for the Financial Markets to provide investment services. GMO Australia Operating Partnership is a wholly-owned subsidiary of GMO. GMO Australia Operating Partnership is located at Suite 43.02, Grosvenor Place, 225 George Street, Sydney NSW 2000 Australia. GMO Australia Operating Partnership commenced operations in April 2022 to continue the operations of GMO Australia Partnership (which commenced operations in November 1995) in providing management, marketing, client and other services to GMO Australia Ltd. Jason Halliwell is the head of the Systematic Global Macro Team, a Member of GMO and an employee of GMO Australia Operating Partnership. George Ferizis is a Member of GMO and employee of GMO Australia Operating Partnership. Peter Martin, Daniel Olshansky and Martin Emery are employees of GMO Australia Operating Partnership. All the aforementioned employees are associated persons of GMO with respect to services they provide to GMO and one or more of GMO’s clients as agreed with GMO. A foundation and a charitable trust established by a GMO Member lease office space at GMO’s offices. The GMO Member has agreed that the charitable trust and the foundation are subject -29-

to many of the provisions of GMO’s Code of Ethics and Insider Trading Policy and Procedures, including restrictions on securities trading by the charitable trust and the foundation. The Member has also agreed that certain employees of the foundation will comply with the terms of GMO’s Code of Ethics and Insider Trading Policy and Procedures, as well as GMO’s Code of Conduct, GMO’s Gifts and Entertainment Policy, any restrictions or policies implemented by GMO from time to time with respect to employee investments in GMO funds, and all other GMO workplace conduct policies. The Member, the foundation and the charitable trust have reported that each of them has retained a consulting firm to provide bona fide investment advisory services; the consulting firm also recommends GMO to potential clients. Please see Item 14, “Client Referrals and Other Compensation,” which describes the arrangement. GMO Members and employees may serve on the boards of directors and/or investment committees of external organizations, including public companies and organizations that are currently, or may become, GMO clients. Such service may present conflicts of interest to the extent the Member or employee becomes aware of material non-public information and he or she may be unable to initiate some transactions for other clients while in possession of that information. GMO will, to the extent possible, take steps to mitigate such conflicts of interest, if and when, they arise. D. GMO does not recommend or select other investment advisers for its clients for compensation.

GMO has adopted a Code of Ethics that is generally applicable to all of its related entities and their members, employees and, in general, on-site consultants world-wide (collectively, “access persons”). GMO directors who are not Members of GMO or do not provide additional consulting services to GMO are not treated as “access persons” under the Code of Ethics. The Code of Ethics is designed to comply with Rule 17j-1 of the Investment Company Act of 1940 and Rule 204A-1 of the Advisers Act. The Code of Ethics establishes personal trading procedures, including certain pre-clearance and reporting obligations. While GMO’s access persons may, subject to the terms of the Code of Ethics, purchase investments for their own accounts, including the same investments as may be purchased or sold for client accounts, GMO’s Code of Ethics is designed to prevent its access persons from engaging in personal securities transactions that may compete or interfere materially with trading of client accounts. In order to give effect to the prohibitions in the Code of Ethics, procedural requirements are also set forth in the Code of Ethics, including pre-clearance by the Compliance Department of many types of trades. Some securities (e.g., certain mutual fund shares, U.S. government securities and money market instruments) and some transactions (e.g., dividend reinvestment, de minimis trades, and transactions in accounts managed by third parties) are exempt from the substantive and/or procedural requirements of the Code of Ethics. Exceptions from the Code of Ethics may be granted. GMO also maintains a Code of Conduct policy that sets forth GMO’s professional expectations of its personnel, as well as a Gifts and Entertainment Policy and an Anti-Bribery and Corruption Policy that are designed to provide reasonable oversight of potential conflicts associated with the receipt and giving of entertainment and other gifts.

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GMO also has adopted an Insider Trading Policy and Procedures (“Insider Trading Policy”) applicable to all employees, on-site consultants, officers, GMO Members, and directors that forbids such persons from trading, either personally or on behalf of others (such as mutual funds and private accounts managed by GMO), while either aware of material non-public information or on the basis of material non-public information or communicating material non-public information to others (commonly referred to as “insider trading”), except in specific, limited circumstances described in the Insider Trading Policy. GMO directors who are not Members of GMO or do not provide additional consulting services to GMO are not treated as “access persons” under the Insider Trading Policy. In connection with its activities, GMO may seek and/or receive information that is not generally available to the public, which may restrict the ability to transact in any related securities. Please see below, “Conflicts of Interest Related to Information Known by or Provided to GMO.” The Insider Trading Policy does not provide absolute assurance as to the correct handling of material non-public information but does contain procedures reasonably designed to aid GMO personnel in avoiding insider trading, and to aid GMO in preventing, detecting and imposing sanctions against insider trading. Those procedures also include provisions designed to manage the issues associated with GMO’s interactions with sources who may have access to material non-public information, including GMO’s use of “expert networks,” whose members provide expertise in particular sectors or industries to assist GMO personnel in analyzing securities. GMO’s procedures specifically permit GMO’s Chief Compliance Officer (“CCO”), in their discretion, to establish temporary ethical screens to control the flow within the firm of material non-public information received by persons subject to the Insider Trading Policy. The use of a temporary ethical screen may enable GMO to restrict specific GMO accounts from trading the securities of an issuer, and therefore avoid placing securities of an issuer on a firm-wide restricted list, whereby any or all GMO accounts would be prohibited from transacting in securities of such issuer. From time to time, however, based on the relevant facts and circumstances, GMO’s CCO or their designee may deem it necessary or appropriate to restrict trading by all GMO accounts in the securities of particular issuers and will place such securities on a firm-wide restricted list. Placement of a security on the restricted list will restrict its purchase or sale by GMO client accounts, including GMO employee accounts, rendering illiquid any such security already held in a client’s account until such time as the security is removed from that list. Conflicts. GMO attempts to disclose material conflicts of interest in this document. However, because conflicts are endemic for registered investment advisers, in responding to the particular items of Form ADV Part 2A, GMO has focused on identifying those conflicts that may be most salient. Set forth in this section is a description of certain conflicts that arise in the course of GMO’s activities as well as a description of how GMO seeks to address such conflicts. Other sections of this brochure also provide a description of additional conflicts of interest that may arise in the operation of GMO’s business. Please also see Item 12, “Brokerage Practices,” and Item 16, “Investment Discretion,” for a description of GMO’s procedures with respect to the allocation of investment opportunities among its clients, including the allocation of limited opportunities, and a discussion of the research and other factors GMO considers when selecting brokers/dealers to effect transactions for clients. Please also see Item 5, “Fees and Compensation,” and Item 6, “Performance Based Fees and Sideby-Side Management,” for a description of conflicts associated with the fees charged by GMO, -31-

including performance fees and fees for asset allocation, as well as analogous incentives associated with GMO’s compensation system. Please also see Item 10, “Other Arrangements,” for a discussion on conflicts associated with the foundation and charitable trust established by a GMO Member. Item 14, “Client Referrals and Other Compensation,” describes conflicts that may arise with consultants that recommend GMO to their clients and Item 17, “Voting Client Securities,” describes conflicts relating to proxy voting. Conflicts of interest related to advisory activities. GMO serves as investment adviser to pooled vehicles and separately managed accounts that have similar investment objectives and pursue similar strategies to the pooled vehicles. Certain investments identified by GMO may be appropriate for multiple clients. Investment decisions for these clients are made by GMO in its best judgment, but in its sole discretion, taking into account factors GMO believes are relevant. Such factors may include investment objectives, regulatory restrictions, current holdings, availability of cash for investment, pending contributions or withdrawals, the size of the investments generally, counterparty limitations (e.g., adjustments to a previously established derivative position with a particular counterparty) and limitations and restrictions on a client’s account that are imposed by law or by the client (including but not limited to restrictions and limitations resulting from the client having a limited number of trading or other appropriate contractual arrangements in place with counterparties). GMO generally is not under any obligation to share any investment, idea or strategy with all of its clients. Decisions to buy and sell investments for each client advised by GMO are made by the relevant GMO Investment Team with a view to achieving each client’s investment objectives taking into account the factors noted above. Therefore, a particular investment may be bought or sold for only one client or in different amounts and at different times for more than one but less than all clients, even though it could have been bought or sold for other clients at the same time. Likewise, a particular investment may be bought for one or more clients when one or more other clients are selling the investment, including in the form of corporate actions such as tender offers (where different clients may tender shares, choose not to tender shares, or even convert to private ownership in an issuer). Such transactions may occur through the same broker, particularly in the case of derivatives (e.g., total return swaps) where the ability to utilize a different broker may be limited, and such transactions may be executed at the same or different prices. Additionally, one account may trade in advance of another account within the same or similar investment strategy due to operational considerations and other circumstances. Moreover, it is possible that the transactions in, and holdings of, securities of a particular issuer in one or more accounts could impact the ability of other accounts to buy and/or sell securities of that same issuer for regulatory or other reasons (e.g., the short-swing profit rule). Conflicts may also arise in cases when clients with different strategies invest in different parts of an issuer’s capital structure, including circumstances in which one or more clients own private securities or obligations of an issuer and other clients may own public securities of the same issuer. Actions by investors in one part of the capital structure could disadvantage investors in another part of the capital structure. It is also possible that GMO may cause a client to engage in short sales of, or take a short position in, an investment owned or being purchased by other client accounts managed by GMO or vice versa. These positions and actions may adversely affect or benefit different clients at different times. In addition, purchases or sales of the same investment may be made for two or more clients on the same date. There can be no assurance that a client will not receive less (or more) of a certain investment than it would -32-

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A. Best Execution. Orders for the purchase or sale of securities may be placed on a principal or agency basis with brokers/dealers, in GMO’s discretion. In selecting brokers/dealers to effect portfolio transactions, GMO seeks best execution and considers a number of factors, described in more detail below. Best execution is not based solely on the explicit commission charged by the broker/dealer and, consequently, a broker/dealer effecting a transaction may be paid a commission higher than that charged by another broker/dealer for the same transaction. Seeking best execution involves the weighing of qualitative as well as quantitative factors, and evaluations of best execution are, to a large extent, possible, if at all, only after multiple trades have been completed. The accounts in the Manager Advised Separate Account program and GMO ETFs may be traded differently than other GMO-traded accounts. For example, GMO may not have discretion to effect trades, there may be operational limitations or practicalities or GMO may be obligated to affect trades with the designated broker/dealer which may impact trade execution achieved on behalf of those accounts. With respect to non-discretionary accounts where GMO delivers a model portfolio and does not otherwise execute transactions such delivery may vary based on various factors that may include the method of delivery, the investment strategy being implemented, best execution and fiduciary considerations (as applicable), the nature and scope of the business relationship and other considerations. Taking into account such factors and considerations, portfolio weights may be communicated either (i) over the course of the trading day, (ii) after the close of business, (iii) contemporaneous with the communication of trades for GMO-managed separate accounts to GMO’s trading desk, or (iv) in such other manner as may be agreed with a client. The determination of what may constitute best execution involves a number of considerations in varying degrees of emphasis, including, without limitation: the overall net economic result to accounts; the efficiency with which the transaction is effected; access to order flow; the ability of the executing broker/dealer to effect the transaction where a large block is involved; reliability (e.g., lack of failed trades); availability of the broker/dealer to stand ready to execute possibly difficult transactions in the future; technological capabilities of the broker/dealer, including but not limited to execution technology; the broker/dealer’s inventory of securities sought; reported broker flow; post-transaction reporting capabilities; the financial strength and stability of the broker/dealer; past bids and willingness to commit capital in the case of principal trades; and the relative weighting of opportunity costs (e.g., timeliness of execution) by different trading strategies. Most of the foregoing are subjective considerations made in advance of the trade and are not always borne out by the actual execution. Due to the similarities among brokers/dealers in technological execution capabilities and commissions paid, GMO often allocates program or algorithmic developed market equity trades across multiple brokers. Additionally, other factors may lead GMO to identify and trade with one or a limited number of brokers/dealers, including but not limited to regulations in certain markets (particularly emerging markets) and differences in trading documentation and/or arrangements among GMO Funds and accounts. GMO may place trades with broker/dealers even if the relevant broker/dealer has not yet demonstrated an ability to effect best execution; however, trading with such a broker/dealer (as with any and all brokers/dealers) will typically be curtailed or suspended in due course if GMO is not reasonably satisfied with the quality of trade executions, unless or until the broker/dealer has altered its execution capabilities in such a way that GMO can reasonably conclude that utilizing the broker/dealer for trade execution -35-

is consistent with GMO’s obligation to seek best execution. Additionally, in the case of the GMO ETFs, GMO may place portfolio trades with brokers/dealers who serve as authorized participants with respect to the GMO ETF and may give additional consideration to authorized participants who facilitate portfolio transactions. With respect to transactions executed by GMO’s Trading team, GMO determines the overall reasonableness of brokerage commissions paid upon consideration of the relative merits of a number of factors, which may include: (i) the net economic effect to the particular account; (ii) historical and current commission rates; (iii) the kind and quality of the execution services rendered; (iv) the size and nature of the transactions effected; and (v) in some cases, brokerage and research services received (see “Soft Dollar Practices”). These factors are considered over multiple transactions covering extended periods of time in varying degrees of emphasis. In some instances, GMO may evaluate best execution on principal bids based on the total commissions charged (the bid for handling a trade as a principal trade) because the trades were filled at the price set at an agreed upon time (e.g., previous night’s close). In those cases, any additional “impact” or cost is represented by the cents per share or basis points paid in addition to a typical commission rate. GMO may also direct trades to broker/dealers based in part on the broker/dealers’ history of providing, and capability to continue providing, pricing information for securities purchased. GMO’s relationships with broker/dealers, particularly those affiliated with large financial institutions, are complex. Because GMO may purchase information from brokers/dealers with whom it effects trades on behalf of its client accounts, the broker/dealer may believe it has a financial incentive to charge a favorable fee to GMO for such information in return for client brokerage. In addition, GMO may conduct business with institutions such as broker/dealers or investment banks that invest, or whose clients invest, in pooled vehicles sponsored or advised by GMO, or its affiliates, or may provide other consideration to such institutions or recognized agents. As a result, GMO has a potential conflict of interest in placing its brokerage transactions with those brokers/dealers. Furthermore, certain broker/dealers act as agents for securities borrowing programs for GMO Funds where the lenders may be entities that GMO, separately, advises as separately managed accounts. Clients who have or seek non-U.S. equity or fixed income exposure in their accounts frequently give GMO discretion to execute foreign exchange transactions. In general, GMO seeks best execution in the execution of foreign exchange transactions by comparing rates across counterparties and selecting the counterparty that GMO believes can provide best execution. For spot currency trades, GMO generally nets buy and sell orders in the same currency and selects the counterparty providing the most competitive price for the resulting net trade. All of the buy and sell orders receive the price provided by the selected counterparty and each account trades independently with the counterparty. While the purpose of trading spot currency trades in this manner is to achieve a more favorable execution price for all clients, there can be no assurance that all clients will benefit or that they will benefit equally over time. For legal, regulatory and/or operational purposes, foreign currency orders for some accounts may not be netted for price discovery (as described above). As a result, such accounts may receive inferior prices than accounts that are netted for price discovery even though the trades may be executed at or close to the same time and/or by the same counterparty.

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If a client has not granted GMO discretion to place foreign exchange trades with counterparties other than the client’s custodian bank (e.g., because of a client’s “all-in” fee arrangement with its custodian), GMO will have limited ability to seek best execution. In certain jurisdictions where it is general market practice (e.g., restricted currencies) or under circumstances when GMO believes operational or trading efficiencies may be gained (e.g., income and dividend repatriation; trading in some emerging markets), GMO may arrange standing instructions with a client’s custodian (who may in turn arrange instructions with a subcustodian) to execute the foreign exchange transaction, subject to the custodian’s (or subcustodian’s) terms and conditions. In the event that a client’s custodian offers more than one program for standing instruction trades, and if the client has granted GMO discretion to do so, GMO will select the program it believes is in the best interests of the client under the circumstances and over time. GMO, subject to client restrictions noted above, may also determine to select a third-party bank or brokers/dealer to execute trades in restricted currencies if GMO believes that the third-party has the ability to provide best execution. GMO recognizes that centralized maintenance of a client’s futures, exchange-traded options and cleared derivative positions can provide favorable netting of variation margin requirements for the client and provide significant operational efficiencies for the client in reconciling outstanding positions. Consequently, GMO is prepared to accommodate clients seeking centralization of those functions with the client’s clearing broker, but may request that GMO is permitted to enter into “give-up” or similar arrangements with the executing brokers of GMO’s choosing and that such arrangements do not, in GMO’s judgment, affect the ability to achieve overall best execution of these transactions. Soft Dollar Practices. Subject to GMO’s obligation to seek best execution, GMO may use a portion of the commissions paid when executing client transactions to acquire external research and brokerage services (“soft dollar benefits”) in a manner consistent with the “safe harbor” requirements of Section 28(e) of the Securities Exchange Act of 1934 or other applicable law. Specifically, GMO may utilize client commissions (typically only for transactions in listed equities) to purchase eligible brokerage and research services where those services provide lawful and appropriate assistance in the investment decision-making process for GMO’s discretionary client accounts, and where GMO in good faith believes the amount of the client commission is reasonable in relation to the value of the product or services provided by the broker/dealer. Accounts in the Manager Advised Separate Account program and accounts with respect to which GMO may be engaged to provide turnkey asset management services will not participate in the soft dollar program. In most cases, GMO makes payments for eligible research and brokerage services either via a portion of the commission paid to the executing broker/dealer or through client commission sharing arrangements (“CSAs”). Where a commission paid to a broker/dealer with whom GMO has established a CSA includes both an execution component and a research component, the broker/dealer may retain the execution portion and either credit or transmit the research portion to a CSA pool or rebate the research portion to the clients generating those commissions. GMO evaluates the research and brokerage services it receives from independent research providers and brokers/dealers and GMO allocates a portion of the CSA pool to the research provider that reflects GMO’s assessment of the value of the research and/or brokerage service. In this manner, CSAs enable GMO to effect transactions, subject to best -37-

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GMO does not receive an economic benefit from anyone who is not a client for providing investment advice or other advisory services to GMO clients.

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Funds Distributor LLC, an unaffiliated broker/dealer, has been retained (for regulatory reasons only) to effect client transactions in shares/interests of certain GMO Funds and to act as a placement agent for the majority of the GMO Private Funds. Similarly, Robson Capital Management, Inc. (“Robson”) an unaffiliated broker/dealer, has been retained (for regulatory reasons) to effect client transactions in shares/interest of certain GMO Funds for Canadiandomiciled clients. Neither Funds Distributor LLC nor Robson solicit clients on behalf of GMO. GMO or certain GMO Funds may retain other third-party placement agents to place interests or shares with investors, or to otherwise assist with the offer and sale of GMO Funds’ interests or shares – often in connection with opportunities in specific jurisdictions. Specifically, GMO Singapore, an affiliate of GMO, entered into an agreement with GI Capital in Japan to perform similar services and the agreement contemplates payments based on a percentage of base and/or performance fees. The compensation paid to Funds Distributor LLC, Robson, and other third-party placement agents, may be paid by GMO or out of the relevant GMO Funds’ assets. Clients should inquire of their consultants or other advisers as to whether GMO is involved in any arrangement where the consultant or adviser believes it has any financial or other incentive to give favorable evaluations of GMO. GMO may enter into arrangements with, and/or make payments from their own assets to, certain intermediaries to enable access to GMO and/or GMO Funds on platforms and through programs by such intermediaries. Such arrangements or payments may establish contractual obligations on the part of such intermediary to provide GMO and/or its clients with certain services. These arrangements and/or payments present conflicts of interest because they may provide incentives for intermediaries, or customers or clients of intermediaries to recommend, or otherwise make available, GMO strategies or GMO funds to their clients in order to receive or continue to benefit from these arrangements. GMO relies primarily on the business development and marketing activities of its personnel to solicit new business. However, GMO, or any of its affiliates, may retain third parties to solicit clients and/or place interests or shares with investors, or to otherwise assist with the offer and sale of GMO Funds’ interests or shares. GMO, or any of its affiliates, may directly compensate such third parties for client referrals. GMO, or any of its affiliates, may enter into a written agreement with such solicitor which outlines the compensation for such referrals, and describes the various procedures the solicitor is required to follow. As a result of the compensation offered to the solicitors, those solicitors may have a financial incentive to recommend GMO, a GMO affiliate, or a GMO Fund, to prospective investors. Additionally, certain third parties may provide capital introduction services on behalf of GMO and/or the GMO Private Funds. Such third parties could include brokers, dealers or other counterparties that GMO transacts with on behalf of GMO Funds and/or separately managed accounts or other service providers to GMO and/or the GMO Funds. While no compensation is paid by GMO or the GMO Funds in connection with these services, the third parties may seek to influence their selection by GMO as a service provider or counterparty by providing such capital introduction services. All counterparties and third-party service providers, including those that provide capital introduction services, are subject to GMO’s standard practice for the selection of counterparties (as described in Item 12 above, in the case of broker/dealers that effect trades on behalf of GMO clients).

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GMO may purchase: (1) access to information such as subscriptions to periodicals or search services that contain requests for proposals, (2) participation in conferences, (3) research papers, (4) access to surveys from organizations affiliated with professional consultant or financial services firms that advise (or whose affiliates advise) potential GMO clients and (5) access for inclusion in searches for prospective clients in the form of administration fees. In addition, the foundation and the charitable trust described in Item 10, “Other Financial Industry Activities and Affiliations,” and the Member that established the foundation and trust may purchase quarterly performance reporting services from professional consultants. Additionally, the foundation referenced in Item 10 has reported that it, the Member who established the foundation, and a related trust have each retained for bona fide investment advisory services a consulting firm that also recommends GMO to potential clients. GMO directors, Members and employees may have familial and/or personal relationships with personnel of professional consultant or financial services firms that advise (or whose affiliates advise) potential GMO clients or that recommend GMO services. GMO does not make payments to consultants or financial services firms conditioned on favorable evaluations of GMO or for client referrals. Nonetheless, as a result of the arrangements described in the prior paragraphs or otherwise, consultants or financial services firms and/or their personnel may believe that they have a financial incentive to give favorable evaluations of GMO and may therefore operate as if they are faced with a conflict of interest. GMO, in its sole discretion, may also waive investment minimums. In particular, GMO may waive a Fund’s investment minimum for clients whose investment consultant has full discretion or exercises substantial influence over its clients’ assets and where the relationship meets the investment minimum. Clients should inquire of their consultants or other advisers as to whether GMO: (1) waived investment minimums for their clients or personnel, (2) purchases or receives any information from such firm or any affiliate thereof, (3) has directors, Members or employees that have familial and/or personal relationships with a consultant or adviser, and/or (4) is involved in any other arrangement where the consultant or adviser it has (or believes it has) any financial or other incentive to give favorable evaluations of GMO or to promote GMO’s services or GMO Funds.

There are no legal or disciplinary events that GMO believes are material to a client’s or prospective client’s evaluation of GMO’s advisory business or the integrity of its management.

A. GMO Funds are subject to regular review by members of the Investment Teams. Members of the relevant Investment Teams report regularly to the Board of Trustees of GMO Trust and GMO ETF Trust, the Boards of Directors of those GMO Private Funds organized as Bermuda corporations, the Boards of Directors of the GMO Private Funds domiciled in Ireland, and the Board of Directors of GMO Australia Ltd. Client Relationship Managers (“CRMs”) and members of the Investment Teams generally provide client account reviews on a periodic basis. Reviews generally include a summary of relevant market conditions that have affected the accounts since the last reporting period and that may affect the accounts in the future. General reviews of accounts usually involve consideration of investment objectives, types of portfolio securities owned, investment process and performance, and similar matters; however, the matters reviewed may be limited to the factors that triggered the reviews. All CRMs and appropriate members of the Investment Teams are expected to participate in client account reviews as needed. Manager Advised Separate Account program clients may receive reports from their wealth advisor. For those clients, GMO provides reporting to their wealth advisors upon request, which may include account summary information, account values, portfolio characteristics and performance. B. In addition to the regular review performed by members of the relevant Investment Teams, factors that may trigger a review include, but are not limited to: changes in market or economic conditions; changes in information regarding particular issuers; purchases and sales of securities; changes in the investment process or investment team personnel; and changes in a client’s needs communicated to GMO. Client requests may also trigger a review. C. GMO provides written reports to clients at various frequencies including daily, monthly, and quarterly or in response to heightened market interest. A client report will contain some or all of the following components: account performance, change in market value, transaction details, estimated fees, attribution or contribution analysis, investment review, market review, profile summary, and holdings. Client reports may be augmented by additional written or oral communications. The Board of Trustees of the GMO Trust Funds and the GMO ETFs, the Boards of Directors of the GMO Private Funds incorporated in Bermuda, the Boards of Directors of the GMO Private Funds domiciled in Ireland and the Board of Directors of GMO Australia Ltd. periodically receive reports that include a summary of market conditions relevant to the portfolios they oversee. These Boards also have the opportunity to review performance of all relevant portfolios at the time of their respective meetings.

In general, GMO takes steps to avoid having custody of client funds and securities. Most of GMO’s clients with separately managed accounts engage third-party custodians (including prime brokers) to maintain custody of their funds and securities, and GMO’s authority with respect to such funds and securities is generally limited to issuing instructions to the client’s custodian (or prime broker, if applicable) to effect or to settle trades pursuant to an investment management agreement. GMO has no control over separately managed account clients’ thirdparty custodians. Some clients give GMO the power to withdraw funds from the relevant client’s GMO Fund account and invest those proceeds in another GMO Fund that is a permitted investment for that client. Other clients may provide standing instructions to GMO to redeem shares of GMO Funds held in their account to the extent necessary to pay GMO’s base or advisory fee and any special allocation. Without coming to a legal conclusion as to whether GMO has custody in these instances (or, for example, whether the allocation of assets among funds is merely settling -46-

of trades), GMO operates as if it does have custody with respect to those accounts. Accordingly, GMO has procedures reasonably designed to ensure that the transfer agent or administrator of the relevant GMO Fund will deliver account statements at least quarterly to each such account and certain of those accounts are subject to an annual surprise exam by an independent auditor. Clients should carefully review those statements and, to the extent GMO also delivers statements to such clients, compare the GMO statement to the statement of the transfer agent or administrator.

GMO accepts authority to manage client assets on a discretionary basis. In general, clients enter into a written investment advisory agreement with GMO, which sets forth the parties’ responsibilities and the scope of GMO’s authority over the client’s account. The standard of care applicable to GMO and the agreed-upon methodology for calculating damages, if any, are often set forth in the investment advisory agreement. Unless otherwise provided, and where appropriate, GMO may net any gains or losses in the client’s account associated with the breach of the standard of care. As described above in Item 4, “Advisory Business,” GMO’s discretionary authority as to the securities to be bought or sold for an account is subject to the agreed-upon investment objectives, guidelines, limitations and restrictions for the account. Such investment limitations vary from one account to another and may include, but are not limited to, diversification requirements, benchmark deviation, industry concentration, restrictions prohibiting the purchase of certain securities or securities of certain types of issuers, prohibiting investments in certain countries or markets, and prohibiting the employment of certain investment strategies or techniques (e.g., derivatives). Decisions to buy and sell portfolio securities for each of GMO’s investment advisory clients are made by GMO with a view to achieving each client’s investment objectives taking into consideration other account-specific factors such as, without limitation, cash flows into or out of the account, current holdings, the account’s benchmark(s), applicable regulatory limitations, liquidity, cash restrictions, applicable transaction documentation requirements, market registration requirements and/or time constraints limiting GMO’s ability to negotiate adequate transaction documentation or seek interpretation of investment guideline ambiguities. Therefore, a particular security may be bought or sold only for certain GMO clients even though it could have been bought or sold for other clients at the same time. As noted above, there may also be situations where a limited opportunity is theoretically eligible for investment by multiple accounts but GMO determines that the limited opportunity is an appropriate investment for only some of the accounts (including, perhaps, those on which GMO charges a performance fee). A particular security may be bought/sold for one or more clients when one or more other clients are selling/buying the security or taking a short position in the security, including clients invested in the same investment strategy. Additionally, one of GMO’s Investment Teams may share investment ideas with one or more other Investment Teams and/or may manage a portion of another Investment Team’s client accounts.

For separately managed account clients who have explicitly delegated responsibility for proxy voting to GMO in writing, GMO has adopted proxy voting policies and procedures. In some -47-

instances, GMO may agree to implement a client’s own proxy voting policy. GMO has engaged a third-party service provider to be its proxy voting agent. GMO’s policies and procedures describe its proxy voting guidelines, the administration of the proxy voting process, how conflicts of interest will be addressed and recordkeeping requirements. Separately managed account clients who have delegated responsibility for proxy voting to GMO, whether according to GMO’s proxy voting policies and procedures or according to such clients’ own proxy voting policies and guidelines, may contract for the right to direct GMO’s vote in a single, particular solicitation by contacting GMO with respect to such solicitation. A copy of GMO’s Proxy Voting Policy is available on request or may be found on the SEC’s website, www.sec.gov, as part of the GMO Trust and GMO ETF Trust registration statement. In instances where GMO has the responsibility and authority to vote proxies on behalf of its clients for shares of GMO Trust and GMO ETF Trust, there may be instances where a conflict of interest exists. Accordingly, the policies and procedures provide that GMO will: (i) vote such proxies in the best interests of its clients with respect to routine matters, including proxies relating to the election of Trustees; and (ii) with respect to matters where a conflict of interest exists between GMO and GMO Trust and/or GMO ETF Trust, such as proxies relating to a new or amended investment management contract between GMO Trust or GMO ETF Trust and GMO, or a re-organization of a series of GMO Trust or GMO ETF Trust, GMO will either (a) vote such proxies in the same proportion as the votes cast with respect to that proxy, (b) seek instructions from its clients (which may be the governing body of a GMO Fund), or (c) take such other action as GMO deems appropriate in consultation with the Chief Compliance Officer of GMO Trust or GMO ETF Trust. In addition, if GMO is aware that one of the following conditions exists with respect to a proxy, GMO shall consider such event a potential material conflict of interest: (1) GMO has a material business relationship or potential relationship with the issuer; (2) GMO has a material business relationship with a proponent of the proxy proposal; or (3) GMO Members, employees or consultants have a personal or other material business relationship with the participants in the proxy contest, such as corporate directors or director candidates. In the event that GMO is aware of a potential material conflict of interest, GMO will (i) vote such proxy according to its guidelines; (ii) seek instructions from the client or request that the client vote such proxy; or (iii) abstain. To the extent a GMO Trust Fund or GMO ETF lends its portfolio securities in conjunction with a securities lending program such Fund bears the risk of delay in the recovery of loaned securities, including possible impairment of such Fund’s ability to vote the securities. Voting rights or rights to consent with respect to the loaned securities pass to the borrower. A GMO Trust Fund or GMO ETF that has loaned securities has the right to call loans at any time on reasonable notice and to exercise voting rights associated with the security and will do so if both (i) GMO receives adequate notice of a proposal upon which shareholders are being asked to vote, and (ii) GMO believes that the benefits to such fund of voting on such proposal outweigh the benefits to the GMO Trust Fund or GMO ETF of having the security remain on loan. A GMO Trust Fund or GMO ETF bears the risk of delay in the return of the security, impairing such fund’s ability to vote on such matters. GMO may use third-party service providers to assist it in identifying and evaluating proposals, and to assist it in recalling loaned securities for proxy voting purposes. -48-

For investors in the GMO Trust Funds and the GMO ETFs, information regarding how such Funds voted proxies relating to portfolio securities during the most recent 12-month period ended June 30 is and will be available on the GMO website at www.gmo.com and on the Securities and Exchange Commission website at www.sec.gov no later than August 31 of each year. For clients invested in GMO Private Funds or separately managed accounts for which GMO has been delegated proxy voting authority, each client may contact its designated CRM to receive information regarding how such fund or account voted proxy securities. If GMO has not accepted authority to vote a client’s proxies, such client should arrange to receive proxy solicitation materials directly from its custodians or transfer agents. A client may contact its designated CRM with questions regarding a particular solicitation. For separate accounts, unless explicitly provided to the contrary in the relevant investment management agreement, GMO does not advise clients on the merits of joining class actions or other litigation relating to securities held in separate accounts and has no direct role with respect to clients’ participation in class action settlements. Neither GMO nor the GMO Funds generally serve as lead plaintiff in class action lawsuits. For GMO Funds, GMO may retain a third-party service provider to facilitate participation in class action settlements.

A. Clients in the Manager Advised Separate Account program may pay their fees in advance. B. GMO confirms that there is no financial condition that would be reasonably likely to impair its ability to meet contractual commitments to clients. C. GMO has not been the subject of a bankruptcy petition at any time during the past ten years.

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APPENDIX A Investment Strategies The bolded and underlined headings below correspond to the chart located at Item 8, “Methods of Analysis, Investment Strategies and Risk of Loss,” which identifies material risks associated with investment strategies employed by GMO investment professionals. For example, the Global Allocation Absolute Return Strategy described below is subject to those material risks identified under “Multi-Asset Class” in the chart at Item 8. Multi-Asset Class Global Allocation Absolute Return The GMO Global Allocation Absolute Return Strategy seeks to generate positive total return, rather than “relative” return, by allocating dynamically across asset classes, free from the constraints of traditional benchmarks. Benchmark-Free Allocation The GMO Benchmark-Free Allocation Strategy seeks to generate positive total return, rather than “relative” return, by allocating dynamically across asset classes, free from the constraints of traditional benchmarks. Real Return Global Balanced Asset Allocation The GMO Real Return Global Balanced Asset Allocation Strategy seeks to generate total return greater than that of its benchmark by allocating dynamically across asset classes. Global Asset Allocation The GMO Global Asset Allocation Strategy seeks to achieve a total return greater than that of its benchmark, 65% MSCI All Country World Index and 35% Bloomberg U.S. Aggregate Index, over a complete market cycle by allocating dynamically across asset classes. Dynamic Allocation The GMO Dynamic Allocation Strategy seeks positive total return. GMO intends to allocate dynamically across asset classes and strategies, while typically maintaining an exposure to equity assets of between 40% and 80%. Equities Global All Country Equity Allocation The GMO Global All Country Equity Allocation Strategy seeks total return in excess of that of the MSCI All Country World Index by investing in other GMO-managed equity strategies of any style or market capitalization.

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Global Developed Equity Allocation The GMO Global Developed Equity Allocation Strategy seeks total return in excess of that of the MSCI World Index by investing primarily in other GMO-managed equity strategies of any style or market capitalization. The Strategy is allowed to invest up to 10% in emerging market equities. Quality The GMO Quality Strategy seeks to achieve its investment objective, total return, by investing primarily in equities of companies believed to be of high quality. Small Cap Quality The Small Cap Quality Strategy seeks to generate total return by investing primarily in equities of U.S. small cap companies that the team believes to be of high quality. Domestic Resilience The GMO Domestic Resilience Strategy seeks total return by investing in equities GMO believes are poised to benefit as companies bring industrial production back onshore and the United States aims to strengthen its position in a changing world. Climate Change The GMO Climate Change Strategy seeks to achieve its investment objective, high total return, by investing in equities of companies believed to be positioned to benefit, directly or indirectly, from efforts to curb or mitigate the long-term effects of global climate change, to address the environmental challenges presented by global climate change, or to improve the efficiency of resource consumption. Resources The GMO Resources Strategy seeks to achieve its investment objective, total return, by investing in the securities of companies in the natural resources sector. Resource Transition The Resource Transition Strategy seeks to generate total return by investing primarily in equities of companies in the resource transition sector. International All Country Equity Allocation The GMO International All Country Equity Allocation Strategy seeks total return in excess of that of the MSCI All Country World ex USA Index by investing primarily in other GMO-managed non-U.S. equity strategies.

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International Developed Equity Allocation The GMO International Developed Equity Allocation Strategy seeks total return in excess of that of the MSCI EAFE Index by investing primarily in other GMO-managed non-U.S. equity strategies. The Strategy is allowed to invest up to 10% in emerging market equities. International Equity The GMO International Equity Strategy seeks to generate high total return by investing primarily in non-U.S. developed market equities. The Strategy’s measures its performance against the MSCI EAFE Index. International Opportunistic Value The GMO International Opportunistic Value Strategy seeks to generate total return by investing primarily in international equities that GMO identifies as the most undervalued. The Strategy measures its performance against the MSCI World ex-U.S.A. Index. International Quality The GMO International Quality Strategy seeks to achieve its investment objective, total return, by investing primarily in non-U.S. equities of companies believed to be of high quality Usonian Japan Value The GMO-Usonian Japan Value Strategy seeks long-term capital appreciation over a full market cycle and measures its performance against the TOPIX Total Return Index for performance comparison purposes. The Strategy employs a fundamental, value-oriented approach to invest in Japanese equities. Usonian Japan Value Creation The GMO-Usonian Japan Value Creation Strategy seeks long-term capital appreciation over a full market cycle and measures its performance against the TOPIX Total Return Index for performance comparison purposes. The Strategy employs a fundamental, value-oriented approach to invest in Japanese equities. U.S. Equity The GMO U.S. Equity Strategy seeks to generate high total return by investing primarily in U.S. equities. The Strategy measures its performance against the S&P Composite 1500 Index. U.S. Opportunistic Value The GMO U.S. Opportunistic Value Strategy seeks to generate total return by investing primarily in U.S. equities that GMO identifies as the most undervalued. The Strategy measures its performance against the MSCI U.S. Value Index.

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U.S. Small Cap Value The GMO U.S. Small Cap Value Strategy seeks to generate total return in excess of that of its benchmark, the S&P S 600 Index, by investing primarily in equities of U.S. companies that are included in the S&P SmallCap 600 Value Index or whose market capitalization at the time of investment is less than that of the companies in the bottom decile of market capitalization of the MSCI U.S. IMI Index. U.S. Quality The GMO U.S. Quality Strategy seeks to generate total return by investing primarily in U.S. equities the Focused Equity team believes to be of high quality. Beyond China The GMO Beyond China Strategy seeks to deliver total return by investing primarily in equities of companies GMO believes are positioned to benefit, directly or indirectly, from the expected trend of companies diversifying their supply chains. The Strategy will primarily invest in emerging market equities with the exception of Chinese securities. Emerging Markets Equity The GMO Emerging Markets Equity Strategy seeks total return by investing primarily in emerging (non-developed) market equities. The Strategy measures its performance against the MSCI Emerging Markets Index. Emerging Markets ex-China The GMO Emerging Markets ex-China Strategy seeks total return by investing in emerging (nondeveloped) market equities excluding China. The Strategy measures its performance against the MSCI Emerging Markets ex-China Index. Horizons The GMO Horizons Strategy is a global strategy reflecting the view that the world economy is transitioning to a lower carbon future, and that this process will create opportunities for investors to generate excess returns. The Strategy seeks to capture these opportunities and mitigate related risks through significant exposure to impactful climate solutions and reduced total emissions intensity (direct and indirect), while controlling for exposure to Environmental, Social, and Governance (ESG) risks. Fixed Income Multi-Asset Credit The GMO Multi-Asset Credit Strategy seeks to maximize alpha potential by harvesting the most attractively priced credit risk premia through a dynamic allocation process across the credit spectrum. A-53

Opportunistic Income The GMO Opportunistic Income Strategy seeks capital appreciation and current income by investing in what GMO believes are the most attractively priced sectors and securities in the structured finance marketplace. High Yield The GMO High Yield Strategy seeks to generate total return in excess of that of its benchmark, the Markit iBoxx USD Liquid High Yield Index, by applying a systematic, factor-based approach to portfolio construction. U.S. Treasury The GMO U.S. Treasury Strategy seeks liquidity and safety of principal by investing in securities that are secured and backed by the full faith credit of the U.S. government explicitly or implicitly. Ultr-Short Income The GMO Ultra-Short Income Strategy aims to generate current income while preserving capital. The Strategy invests in a diversified portfolio of low-duration, high-quality fixed income securities, including U.S. Treasuries, collateralized loan obligations, repurchase agreements, and other investment-grade assets. Emerging Country Debt The GMO Emerging Country Debt Strategy’s objective is total return in excess of that its benchmark, the J.P. Morgan Emerging Markets Bond Index Global Diversified. The Strategy invests primarily in external debt of sovereigns and quasi-sovereigns. Emerging Country Local Debt The GMO Emerging Country Local Debt Strategy’s objective is total return in excess of that of its benchmark, the J.P. Morgan Government Bond Index-Emerging Markets Global Diversified. The Strategy invests in local currency emerging debt. Emerging Markets Blended Debt The GMO Emerging Markets Blended Debt Strategy integrates all of the elements from GMO’s hard and local benchmarked strategies, enhanced by disciplined asset allocation timing and aiming to deliver total return in excess of any combination of hard and local currency benchmarks.

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Systematic Investment Grade Credit The GMO Systematic Investment Grade Credit Strategy seeks to generate total return in excess of its benchmark, the Bloomberg U.S. Corporate Index, by employing a factor-based bond selection process. Alternative Strategies Alternative Allocation The GMO Alternative Allocation Strategy seeks to generate positive total return by investing in a diversified portfolio of underlying alternative strategies, all run by GMO investment teams. Systematic Global Macro The GMO Systematic Global Macro Strategy’s investment objective is long-term total return. The Strategy takes both long and short positions in a range of global equity, bond, commodity and currency markets using exchange-traded and over-the-counter (OTC) futures and forward exchange contracts, swaps on commodity indices, equity indices and equities, and index options and other investments. Equity Dislocation The GMO Equity Dislocation Strategy seeks high total return by owning attractively valued equities while correspondingly shorting equities where GMO believes that valuations are reflective of implausible growth expectations. Quality Spectrum The GMO Quality Spectrum Strategy invests in a concentrated long book of high-quality companies and levers the long portfolio by shorting a diverse portfolio of “junk” companies, with an emphasis on valuation. Event-Driven The GMO Event-Driven Strategy seeks to generate absolute return by investing in opportunities that arise from significant corporate events where there is generally some uncertainty about the outcome of the event in question and where the outcome will be known relatively soon. In practice, the Strategy’s portfolio generally includes a heavy focus on merger arbitrage transactions, supplemented by other opportunities that exhibit similar risk, return and time horizon characteristics. Risk Premium The GMO Risk Premium Strategy seeks to generate a total return over the long term commensurate with that of global equity markets primarily by writing put options on U.S. and non-U.S. stock indices.

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World Market Neutral The GMO World Market Neutral Strategy seeks total return by maintaining long exposure to stocks that GMO considers attractive and short exposure to stocks that GMO considers unattractive. The Strategy uses a combination of proprietary stock selection models such as Valuation, Quality, and Momentum to determine the attractiveness of each individual stock. The eligible universe for both the long and short side consists of developed market equities.

The strategies described above are subject to change without notice to any recipient of these materials. Clients interested in investing in a strategy that may be offered through a pooled vehicle should rely upon disclosure included in a prospectus or private placement memorandum prepared for that fund. The information contained in these materials is subject in its entirety to and superseded by the disclosure in such prospectus or private placement memorandum to the extent of a conflict. To the extent that the terms of this brochure conflict with an investment management agreement governing a separately managed account, the investment management agreement will control. Pooled vehicles may be subject to restrictions on the types of investors who may invest. Nothing herein is intended to operate as an offer to sell securities.

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