Hermes Investment Management

Hermes Investment Management Limited (“HIML”) is a UK-

HIML’s primary purpose is to help our clients retire better by

providing active responsible investment management. Alongside this is a commitment to delivering holistic returns – outcomes that consider the impact our decisions have on society, the environment and the wider world.

Hermes Investment Management Limited

Due to the ownership structure, there could be a conflict between our ultimate parent (FHI and its US-based advisory subsidiaries, together (“FHI Advisory Companies”) and our clients. To mitigate this, information barriers may be in place or established between HIML and FHI Advisory Companies whereby FHI Advisory Companies personnel do not have access to HIML systems and confidential information (further details in item 10). At times, under certain circumstances, information barriers may be constructed between or among one or more Federated Advisory Companies, or with EOS, in connection with the sharing of material non-public information related to a security (“MNPI”) or to prevent a person from gaining knowledge that gives rise to a conflict of interest. For example, a portfolio manager may be isolated from learning information about a strategic transaction that Federated Hermes is considering.

Type of Services The Federated Advisory Companies collectively provide advisory services to a variety of separately managed accounts or wrap fee accounts (Managed Accounts), institutional, or high net worth individual, separate accounts (Separate Accounts), registered investment companies, including exchange-traded funds (ETFs) and mutual funds (collectively, Investment Companies), investment companies that are registered under the Investment Company Act of 1940 (Investment Company Act) that offer shares that are not registered under the 1933 Act (as defined below) (Private Investment Companies) and other pooled investment vehicles (Pooled Investment Vehicles).FHI also owns other companies, both in the United States and in certain other countries, such as broker/dealers, investment advisers, management companies, commodity pool operators, and trust companies. HIML primarily provides investment management services to institutional clients, including pensions, Investment companies, charitable organizations, profit-sharing accounts and pooled investment vehicles which are not registered for public sale in the United States (“private funds”). Private funds may be registered for public sale in other jurisdictions such as Cayman Islands, Ireland or the United Kingdom. Currently, interests in the Cayman Island domiciled private funds are made available to US investors that are accredited investors and/or qualified purchasers as those terms are defined under the federal securities laws, or as otherwise permitted under applicable law. Private funds domiciled in Ireland or the United Kingdom are not registered for sale to US investors.

Segregated Accounts Services HIML provides continuous and regular investment supervisory or management services (Investment Supervisory Services) pursuant to which we have discretionary authority over a client’s assets and provide ongoing supervisory or management services with respect to the client’s assets in a range of equities, fixed income, multi-asset and private markets strategies. Such discretionary authority generally does not require prior client consultation. Investments are managed in accordance with an investment management agreement with the Client that describes the Client’s

investment objectives, strategies, restrictions and guidelines. Private funds are managed only in accordance with their own characteristics and are not tailored to any specific private fund investor (each an “Investor”).

Model Portfolio Management Services HIML also furnishes investment advice and recommendations through the provision of model portfolios for some of its investment strategies and provides periodic updates to the model portfolios (“Model Portfolio Management Services”). HIML typically provides these services to investment advisory firms or other managers (“Overlay Managers”), either directly or through turn-key asset management providers that operate platforms or programs in which Overlay Managers participate. These Overlay Managers utilize HIML’s model portfolios and periodic updates, either alone or together with other model portfolios provided by the Overlay Managers or other investment advisers, to manage the assets of the Overlay Manager’s clients. HIML generally does not have investment discretion or trading responsibilities in such arrangements, nor does HIML have an advisory relationship with the Overlay Manager’s clients, and does not manage model portfolios on the basis of the financial situation or investment objectives of individual clients that participate in these programs.

Managed Accounts Services In addition, HIML participates as an investment manager or portfolio manager in certain separately managed account or wrap fee programs (Managed Accounts or Managed Account Programs), through which it provides advisory services to pension plans, charitable organizations, and certain small institutional investors. Managed Account Programs generally are investment programs under which a client is charged a single specified fee for investment advisory services (which could include portfolio management or advice concerning the selection of other investment advisers), execution of client transactions by the program’s sponsor, and custodial services. However, with respect to certain Managed Account Programs, the single Managed Account fee does not cover the cost of execution of client transactions. We receive a portion of the fees paid by the Managed Account client for our services. In Managed Account Programs, clients (with or without the assistance of the sponsors (“Sponsors”) of the Managed Account Program) select or appoint HIML to manage designated client assets in accordance with one or more of our investment strategies. The Sponsors of the Managed Account Programs typically are broker/dealers, financial institutions or other investment advisory firms which sponsor, operate and administer the Managed Account Programs. When providing investment services to Managed Accounts, we typically act as a subadviser to the Sponsors of the Managed Account Programs. The Sponsors typically enter into investment management agreements with clients, and we do not have direct investment management agreements with clients that participate in Managed Account Programs. In all cases, the Sponsors typically provide portfolio manager selection, performance monitoring and evaluation, custody, brokerage and other administrative services (or a combination of these services) to clients. We exclusively provide advisory services to Managed Account Program clients. There are certain

ADV Part 2A Brochure – March 2026

differences between how we manage Managed Accounts and how we manage other client accounts. For example, when participating in Managed Account Programs, the Sponsor is typically responsible for determining the suitability of the Managed Account Program, including HIML and our investment strategy, for the client. We are usually only responsible for managing client assets in accordance with the designated investment strategy. In certain Managed Account Programs, Sponsors and Platform Providers can limit the information that is available to us about the client, the client’s other investments or risk tolerance, and other information that would be relevant to determining whether the investment strategy or certain specific investments would be suitable for the client. Likewise, we could be restricted by Sponsors and Platform Providers from communicating directly with clients; all communications, including communications with respect to

Hermes Investment Management Limited

Asset Under Management

the clients’ investment objectives, financial condition and reasonable investment restrictions, must usually be directed through the Sponsor or Platform Provider.

As of December 31, 2025, HIML had $24.4 billion in assets managed on a discretionary basis, and $313.2 million in assets managed on a non-discretionary basis.

Segregated Account Fees HIML’s standard fee schedule for institutional segregated investment accounts (“Segregated Accounts”) for its investment strategies in basis points are as follows: Strategy

$50m

$100m

$150m

$200m

$250m

$500m

$1bn

Asia ex-Japan Equity

EM Asia (Cayman) Equity

Global Emerging Markets Equity

Global Emerging Markets ex-China Equity

China Equity

Global Equity ESG

Global Equity Low Carbon

US SMID Equity

Global Small Cap Equity

Global High Yield Credit

Sustainable Global Investment Grade Credit

Unconstrained Credit

Climate Change High Yield Credit

Emerging Markets Debt

SDG Engagement Equity

SDG Engagement High Yield Credit

Sustainable Global Equity

US High Yield Credit

MDT US Equity

Global Short Duration Bond

Direct Lending: A headline management fee of 75bps A performance fee of 10% over a hurdle of SONIA +461.93bps European Direct Lending: A headline management fee of 75bps A performance fee of 10% over a hurdle of Euribor +350bps European Direct Lending II: A headline management fee of 75bps A performance fee of 10% over a hurdle of Euribor +350bps European Direct Lending III: A headline management fee of 75bps A performance fee of 10% over a hurdle of Euribor +350bps European Real Estate Debt: A headline management fee of 60bps Note: fees are subject to negotiation and subject to change. Please refer to “Conflicts of Interest Relating to PerformanceBased Fees” in Item 6 of this brochure for further information regarding actual or potential conflicts of interest that may arise in connection with performance-based fees. Fees are typically charged quarterly in arrears and there are different calculation methodologies as follows: Using the average of the daily NAVs over the period, Using the average of the month end values within the period,

Using the market value of assets on the last trading day of each calendar quarter. In any partial calendar quarter, fees are pro- rated based on the number of days in which the account is open during the quarter. For purposes of calculating HIML’s management fees, the market value of assets in a Segregated Account shall consist of the market value of securities and other investments held in the account and will not be reduced by any margin or other indebtedness of clients with respect to such securities or other investments. Assets of Segregated Accounts that have a business relationship to each other may, at the discretion of HIML, be aggregated for purposes of calculating the management fee applicable to each Segregated Account. In certain circumstances, Segregated Account fees and minimums may be negotiable. To the extent that fees are negotiable, some clients may pay more or less than other clients for the same management services, depending, for example, on account inception date,

ADV Part 2A Brochure – March 2026

applicable investment mandates or restrictions, total assets under management by HIML or number of related Segregated Accounts. The Equity and Fixed Income Allocation policies ensure that all clients are treated fairly regardless of the fees charged. See Item 12 below, for HIML’s trading policies. Fees are adjusted and/or calculated on a pro rata basis where: (i) the effective date is on a date other than the first Business Day of a calendar quarter; (ii) the effective date of termination of the Agreement is on a date other than the last Business Day of a calendar quarter; and/or (iii) where the applicable percentage changes on a date other than the first Business Day of a calendar quarter. HIML’s fees are typically adjusted to reflect deposits or withdrawals during a quarter, by pro-rating the fees (on number of days) within the quarter to before and after the deposits or withdrawal.

Hermes Investment Management Limited

Clients’ Segregated Account agreements may be terminated in accordance with agreed terms. Typically, a refund of prepaid fees is not applicable as fees are charged in arrears. However, any unearned, pre-paid fees, should they arise, will be refunded. If you have any questions regarding a refund, you may contact your client service representative. In circumstances where HIML has appointed any of its affiliates as a sub-advisor, they will be compensated by receiving a portion of the fees as per the sub-advisory agreement. In addition to management fees payable to HIML, transaction costs will be incurred along with other costs such as custodian fees, brokerage fees, wire transfer and taxes charged by service providers such as custodian, brokers and others.

Model Portfolio Management Fees The fees HIML charges and receives for providing Model Portfolio Management Services generally are asset-based fees that are paid quarterly by, or through, an Overlay Manager, and generally equal a percentage of the total assets (or a portion of the assets) invested by the Overlay Manager in the Overlay Manager’s investment strategy derived from HIML’s model portfolio. For Model Portfolio Management Services, any “breakpoints” at which the percentage charged is reduced generally are measured based on the aggregate AUM managed by the Overlay Manager using our model portfolio(s) (rather than the AUM of any specific Overlay Manager client account). Our fees typically can be negotiated only between the Overlay Manager and us. A client of the Overlay Manager typically pays an advisory fee to the Overlay Manager for the Overlay Manager’s discretionary management. In such cases, the client does not pay a separate fee to us for the Model Portfolio Management Services we provide to the Overlay Manager. HIML receives from the Overlay Manager a portion of the fees paid by the Overlay Manager’s client for its services. HIML is not generally informed of the specific fee arrangements negotiated between each Overlay Manager and the Overlay Manager’s clients. HIML’s fee for Model Portfolio Management Services could either be payable by the Overlay Managers in arrears at or after the end of each quarter for services rendered during the quarter (in which case they are not refundable) or payable in advance of the quarter in which such services are to be rendered. If paid in advance, the Overlay Manager would receive a pro-rated refund in the event that we are terminated. The Overlay Manager also can pro rate fees if a certain amount of assets are contributed to or withdrawn from a client’s account during an applicable period. In any case, any refunding would take place as and when provided in the Overlay Manager’s agreement with us. Clients of an Overlay Manager (or, as applicable, Sponsor or Platform Provider) should refer to their agreements with, and related documentation from, the Overlay Manager (or, as applicable, Sponsor or Platform Provider) for the specific terms and conditions applicable in connection with the refunding of fees charged by the Overlay Manager (or, as applicable, Sponsor or Platform Provider).

Managed Accounts Fees As discussed in Item 4 of this brochure, Managed Account clients typically pay a single fee or fees (a “wrapped fee”) which cover HIML’s services as well as other services provided by the Managed Account Program Sponsor or a Platform Provider. These other services typically include, for example, portfolio manager selection, performance monitoring and evaluation, custody, brokerage and/or other administrative services. The total Managed Account Program fee(s) charged under such programs can be up to 3.00%. Certain Managed Account Program Sponsors or Platform Providers can charge brokerage commission and/or fees separately or as part of the client’s overall Managed Account Program fee(s). Some Managed Account Program Sponsors or Platform Providers could also charge a minimum annual Managed Account Program fee to each client that participates in their Managed Account Program. HIML is not generally informed of the specific fee arrangements negotiated between each Managed Account Sponsor and each client participating in the Sponsor’s Managed Account Program. We receive a portion of the fees paid by the Managed Account client for our services. Our fees for Managed Accounts generally are assetbased fees that are paid quarterly by, or through, the Managed Account Program Sponsor or Platform Provider as a component of the “wrapped fee.” Our fees generally equal a percentage of the total assets in the Managed Account Program for which we provide advisory services. For Managed Accounts, any “breakpoints” at which the percentage charged is reduced generally are measured based on the aggregate AUM that we manage pursuant to a Managed Account Program (rather than on the AUM of any specific client account). In certain Managed Account Programs, our advisory fees could be limited to the Managed Account Program fees actually collected by the Managed Account Sponsor or Platform Provider. Our fees could either be payable in arrears at or after the end of each quarter (in which case they are not refundable) or payable in advance of the quarter in which such services are to be rendered. If paid in advance, our fees typically will be refunded on a pro-rated basis in the event that we are terminated from managing the client’s Managed Account or the Sponsor or Platform Provider terminates its agreement with us. The Sponsor or Platform Provider also may pro rate fees if a certain amount of assets are contributed to or withdrawn from a client’s account during an applicable period. In any case, any refunding would take place as and when provided in the Managed Account Program agreements between us and the Sponsor or Platform Provider. HIML generally will continue to charge management fees during any period that a client, Sponsor, or Platform Provider limits our discretion over the Managed Account. In certain Managed Account Programs, our fees can be billed separately from brokerage, custody and other fees. The Sponsors or Platform Providers that operate the Managed Account Program in which clients participate generally determine:

ADV Part 2A Brochure – March 2026

Read the rest in the brochure

Strategies and Risk of Loss HIML is an active asset manager that provides discretionary and non-discretionary asset management services through the management of a range of portfolios in equity, fixed income and alternatives. Each of these strategies is conducted by a different investment team within HIML. Generally, each Segregated Account is managed pursuant to a single strategy determined by the Client and in accordance with investment objectives and guidelines agreed upon (or, in

Hermes Investment Management Limited

the case of Managed Account Program accounts, provided in the Managed Account Program Sponsor’s brochure or other Program documentation).

Equity HIML equity strategies encompass a variety of investment objectives and styles including value, growth & blend across different geographical regions such as emerging markets, Asia, US & global equities and different market capitalization. The Investment teams use several methods for asset selection which include fundamental analysis, quantitative analysis & qualitative analysis or combinations of all. The teams will use either a bottom-up or a top-down approach or both in their investment process, to identify and buy quality stocks that are attractively priced. The teams will also integrate ESG along with other factors including business model, financials, cash flow and growth prospects into their investment processes. ESG integration is delivered through HIML proprietary ESG tools. The Investment teams also have access and collaborate with EOS at Federated Hermes Limited (“EOS”) staff who provide stewardship services in respect of the portfolios. As discussed under “Conflicts of Interest Relating to Information Sharing Among Affiliates” in Item 6, information barriers have been implemented to prevent the exchange of material non-public information among the Federated Advisory Companies, and EOS.

Top-down analysis is applied to assess the general credit market and sector condition which determines the overall appetite for credit risk across the portfolios, how the team wants to allocate that risk and depending on the nature of the strategy, whether to employ any defensive or hedging strategies. The core consideration for the research process is the analysis of the issuer’s ability to fulfil its financial obligations and ESG related risks. Experienced portfolio managers/analysts operate on a sector responsibility basis which includes both investment grade and sub-investment grade issuer coverage, and information sharing with HIML’s equity teams. The Investment teams also have access and collaborate with EOS staff who provide stewardship services in respect of the portfolios.

Real Estate HIML Real Estate team provides client-focused property investment solutions through segregated and pooled structures that invest in real estate and real estate debt. The investment process adopts a top-down portfolio risk management and bottom-up property selection to capitalize on mismatch between price and value by targeting assets that are highly competitive within their local marketplaces and which have sustainable income streams. The team seeks to maximize performance on a risk-adjusted basis.

Direct Lending The teams will use a variety of sources in the screening and selection process including proprietary screening tools, thirdparty research materials, meetings with company management and industry & sector analyses. Risk management and monitoring is embedded in the selection and ongoing portfolio monitoring processes using different risk measures and proprietary systems as well as an investment risk oversight role performed by the Investment Risk team.

Fixed Income HIML Credit’s investment philosophy is focused on capital stability and consistency of returns rather than a series of highs and lows. By investing on a global basis, the team seeks to capture valuation anomalies across various geographic jurisdictions and to capture valuation anomalies that exist within the debt capital structure of companies and across all available debt instruments. HIML Credit team uses an active, research-intensive investment process to seek superior risk-adjusted returns through top-down and bottom up analysis. The portfolio construction process includes market risk, default risk, rating migration risk and proprietary rating.

The Direct Lending team aims to provide attractive risk adjusted returns to investors, yielding a stable income stream and preserving investors’ capital by taking a conservative approach to the asset class. The team invests in seniorsecured loans to a diverse range of UK and European midmarket businesses. The team undertakes bottom-up fundamental credit analysis of each potential investment, including undertaking management presentations, analyzing financial and commercial due diligence on borrowers and assessing the legal structure, ownership and loan terms. Following execution, the performance of each borrower is monitored and evaluated: the borrowers report on the company’s performance, usually monthly, and every quarter the company is subject to maintenance covenant tests.

Real Estate Debt The Real Estate Debt strategy aims to provide attractive risk adjusted returns to investors by investing in a diversified portfolio of senior, whole and mezzanine loans secured on real estate, including, but not limited to, office, retail and logistic assets located in Europe. The team will apply a bottom-up fundamental credit analysis in constructing the portfolio of Investments. ESG considerations will also form part of the portfolio construction and risk management, the team will seek to invest in loans secured by real estate that meets its requisite ESG criteria and, as appropriate, will actively engage with sponsors behind each borrower. The team will also carry out post investment monitoring focusing on the underlying performance of borrowers and their assets against

ADV Part 2A Brochure – March 2026

expectations as well as analyzing any ESG risks or issues that may arise during the life of the loan and updating the Investment’s ESG score.

Equity specific risks

In addition to the aforementioned strategies, HIML may, at any time, offer additional strategies which will broadly be similar in their methods of analysis and investment to those described here.

Style-specific risk – This is the risk of loss associated with a particular investment style, for example, growth stocks tend to be more volatile whereas value stocks tend to be more stable.

Risks

Equity security risk – This is the risk that the equity security’s value declines due to changes in its price due to declines in the company’s prospects or its industry or sector.

Company size risk – This is the risk of loss associated with the size of the company invested in, for example, small and medium companies tend to be more volatile and less liquid than larger ones.

As with all investments, the strategies outlined above are exposed to many risks and the value of investments and income from them may go down as well as up, and investors may not get back the original amount invested. Performance targets cannot be guaranteed, and past performance is not a reliable indicator of future result.

Fixed Income/Direct Lending/Real Estate Debt specific risks

Market risk – This is the risk of experiencing losses due to factors affecting the overall performance of the financial markets,

Default risk – This is the risk of loss from the issuer of a security not being able to make payment of interest or principal.

Liquidity risk – This is the risk that an investment held cannot be traded quickly enough to prevent or minimize loss.

Interest rate risk – This is the risk that a change in interest rate has an adverse effect on the values of the assets held.

Credit risk – This is the risk of loss resulting from a borrower’s failure to repay a loan.

General risks

Currency risk – This is the risk that return on investments in foreign securities are lower due to fluctuations in foreign exchange rates.

Country risk – This is the risk of experiencing losses or lower returns due to political, social & economic developments in the country or adverse government actions such as nationalization. This can arise when investing in foreign countries particularly less developed ones.

Regulatory/Legal risk –This is the risk that changes in laws and regulations such as restrictions on assets or activities will negatively impact the value or marketability of an investment.

Operational risk – This is the risk of loss resulting from failures in internal procedures, people and systems.

Cybersecurity risk – This is the risk of disruptions causing the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs associated with Cybersecurity failures or breaches of HIML or its service providers or the issuers of securities in which HIML’s has invested.

Counterparty risk – This is the risk of loss from the failure or inability of a counterparty to a transaction to meet its contractual obligations.

Leverage risk – This is the risk of incurring greater losses and increased volatility due to the use of leveraged financial instruments such as derivatives.

ESG risk – An environmental, social, or governance event, or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Real Estate/Real Estate Debt specific risks

Real estate valuation risk – Real estate valuations require a degree of subjective analysis of the fair market value of the underlying assets therefore, there are no guarantees that the value of the investments held will be accurate on a given date nor that the sale of any property will be at a price equivalent to its last estimated value.

This is not an exhaustive list and risks applicable to a strategy or Client’s account will depend on the investment objective, style, guidelines and type of securities held. These will be described in more details in any presentations, prospectuses and marketing materials provided and discussions held with clients.

HIML provides investment advisory services to institutional clients, which currently includes the following:

Pension and profit-sharing plans including pension plans subject to the Employee Retirement Income Security Act of 1974 (ERISA);

Trusts;

Estates;

Charitable organizations;

Corporations or other business entities;

Broker-dealer intermediaries;

Other Investment Advisers;

Investment Companies.

Accounts Requirements Clients are required to enter into a written investment management or advisory agreement prior to the establishment of an advisory relationship with HIML, except for Managed Account clients that do not enter into an agreement directly with HIML. Instead, as discussed in Item 4 above, Managed Account clients will enter into an investment management and/or other agreements with the Sponsor or Platform Provider for the Managed Account Program. Minimum investment can vary depending on the investment strategy, but generally HIML requires a minimum investment of $50 Million to open a Segregated Account and all mandates must meet a minimum revenue requirement of$200,000. HIML’s target account size for Managed Account

Program accounts is $100,000 for Equity Accounts and $250,000 for Taxable Fixed Income Accounts. Certain asset classes can require larger account minimums to seek proper diversification. The minimum account sizes for Managed Account Programs also can differ based on the requirements of the program Sponsors, Platform Providers or Overlay Managers.

The following disclosures relate to performance-based fees and side by

Isolation: we construct information barriers to prevent a person from gaining knowledge that gives rise to a conflict of interest (e.g., we could isolate a portfolio manager from knowing information about a strategic transaction that Federated Hermes is considering);

Validation: we establish a benchmark for conduct that is designed to protect client interests or impose limitations on activities that create the conflict of interest (e.g., we follow SEC Rule 17a-7 under the Investment Company Act to obtain a reasonable value for securities in cross-trades involving Investment Companies advised by us or other Federated Advisory Companies);

Disclosure/Consent: we disclose the conflict of interest to our clients (e.g., we disclose the solicitation arrangement with our affiliate, Federated Securities Corp., and its employee-representatives) or;

Setting a De Minimis Threshold: we set a threshold for a benefit that is considered too small to influence conduct, and is therefore permitted (e.g., we set limits on entertainment and gifts under our Gift & Entertainment policy and permit de minimis political contributions as permitted under SEC Rule 206(4)-5 under the Advisers Act).

Hermes Investment Management Limited

arise in determining how to allocate them. HIML or other Federated We have adopted a Code of Ethics and written compliance policies and Advisory Companies could give advice or take action with respect to procedures that we believe are reasonably designed to prevent, detect investments of one or more clients that may not be given or taken with and cure violations by us and our employees and supervised persons of respect to other clients with similar investment strategies or objectives. the Advisers Act and other applicable federal securities laws. Our Accordingly, clients with similar strategies or objectives may not hold compliance policies and procedures also provide for various auditing the same securities or instruments or achieve the same performance. In and testing of our policies and procedures, which are reviewed no less addition, legal restrictions on the combined size of positions which could frequently than annually as required by SEC rules. Our policy is to be taken for all assets managed by HIML and/or some or all of the other manage client accounts and investment products consistent with Federated Advisory Companies, and the difficulty of liquidating an applicable law and with the other client accounts and investment investment for more than one client where the market cannot absorb products that we manage. The other Federated Advisory Companies the sale of the combined positions, could affect (including in an adverse have adopted the same Code of Ethics and similar written policies and manner) the prices and availability of certain securities or other procedures. (Please refer to “Code of Ethics, Participation or Interest in investments held by or considered for one or more clients. There also Client Transactions and Personal Trading” in Item 11 of this brochure are times when the same portfolio manager manages an Investment for further information regarding our Code of Ethics.) Company (i.e., mutual fund ), Managed Account and other client assets, The following is a further discussion of certain actual or potential and/or provides Model Portfolio Management Services, all with the conflicts of interest relating to (A) performance-based fees, (B) side by same investment style or strategy. This includes, for example, mutual side management and (C) other aspects of our business, and how we funds and Managed Accounts managed in the same style and/or other seek to address these conflicts of interest. institutional investment accounts (e.g., Segregated Accounts, Private Investment Companies, or Pooled Investment Vehicles) managed in the same style, or to the same model portfolio, as Managed Accounts. In Conflicts Relating to Performance-Based Fees certain cases, however, an affiliated Investment Company can invest in HIML and certain of the other Federated Advisory Companies manage another affiliated Investment Company, Private Investment Company or Pooled Investment Vehicle that pays, or that invests in yet another client accounts subject to performance-based fee arrangements, or subject to a performance-based fee in addition to another type of fee affiliated Investment Company, Private Investment Company or Pooled Investment Vehicle that pays, management fees or other fees to HIML (e.g., asset-based fees or flat fees). or other Federated Advisory Companies or their affiliates, in which case clients could bear those fees indirectly, including as part of the Actual or potential conflicts of interest arise in connection with investment return of the affiliated Investment Company, Private charging performance-based fees on certain client accounts while managing other client accounts at the same time for asset-based fees Investment Company or Pooled Investment Vehicle. Please refer to or flat fees. We have an incentive to favor any account for which we or “Conflicts of Interest Relating to Affiliated Investment Vehicles” and other Federated Advisory Companies receive performance-based fees. “Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management Purposes” in Item 6 of this brochure for For example, when offering investment advisory services to eligible clients for an asset-based fee and a performance-based fee, we could further information regarding actual or potential conflicts of interest have an opportunity to receive greater fees or compensation from the that can arise in connection with investments in Affiliated Investment client accounts or investment products that we charge performance- Vehicles. based fees as opposed to the client accounts that we do not charge performance-based fees (e.g., asset-based fees). As a result, we have The following discusses certain more specific examples of actual or potential conflicts of interest relating to side by side management. an incentive to direct the best investment ideas to, or to allocate, aggregate or sequence trades in favor of, or to otherwise favor (whether in terms of better execution, brokerage commissions, Conflicts Related to Management of Different directed brokerage/trading or otherwise), a client account or Investment Strategies and Certain Pooled investment product that pays a performance-based fee. Investment Vehicles To address these actual or potential conflicts of interest, the Equity and HIML provides investment advisory services to Pooled Investment Fixed Income allocation policies prohibit the consideration of the Vehicles, including private funds. We manage client assets according to compensation or other benefits received by us or our affiliates, or by different investment objectives, policies, strategies, and any of our officers or employees, when allocating trades among limitations/restrictions. In addition to conflicts of interest relating to participating client accounts or investment products. Our Compliance performance-based fees, actual and potential conflicts of interest arise Department reviews and reaffirms these allocation policies annually. from managing client accounts with different investment approaches. For example, it is possible that the various investment approaches could have different investment strategies that, at times, might conflict with one another to the possible detriment of a client’s account. One account could seek to participate in a transaction in which another account could “Side by side management” refers to an investment adviser’s practice have made (or could seek to make) an investment. The two accounts could have conflicting interests and objectives in connection with the of managing different types of client accounts and/or investment transactions, including how they view the operations or activities of the products simultaneously. HIML and our employees and supervised portfolio or issuer, the targeted returns from the transaction, and the persons could have conflicts of interest in allocating their time and services among clients. To address these conflicts, HIML will endeavor timeframe for, and method of, executing the transaction. Client to devote such time to each client as HIML deems appropriate under accounts also can be invested in different parts of an issuer’s capital the circumstances to perform our duties and obligations to each such structure which have different preferences and rights, and thus, disparate interests (e.g., credit quality versus growth potential). Some client in accordance with applicable law and our investment accounts managed by HIML and/or the other Federated Advisory management agreement(s) with each such client. Companies could short securities which we have purchased in other Certain actual or potential conflicts of interest can arise in connection accounts. A concurrent long/short position between one account and with a portfolio manager’s management of an account’s investments another account can result in a loss to one account based on a decision and the investments of other accounts for which the portfolio manager to take a gain in the other account. Taking concurrent conflicting is responsible. To the extent that the same investment opportunities positions in certain derivative instruments also can result in a loss to one might be desirable for more than one account, possible conflicts could client and a gain for another client. Uncovered option strategies,

Other Conflicts Relating to Side-by-Side Management

ADV Part 2A Brochure – March 2026

portfolio leveraging and significant positions in illiquid securities also regulating investments in Affiliated Investment Vehicles . can result in conflicts of interest for us when managing certain client assets side by side with other client accounts and investment products.

Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management

To address these actual or potential conflicts of interest, records are maintained regarding the investment and allocation decisions made by When HIML is providing Investment Supervisory Services with respect to our portfolio managers, and our Compliance Department periodically Managed Accounts, Model Portfolio Management Services and certain reviews documentation of allocations in an effort to confirm other accounts, we generally do not have discretion over the selection compliance with allocation policies and procedures. The Compliance of investment.vehicles used for cash management purposes. The Department also periodically monitors against limits or other guidance selection of investment vehicles used for cash management purposes amounts imposed on short sales, derivatives usage, options strategies, will typically be made by, or by an agent appointed by, the client or the leverage and liquidity. Sponsor, Platform Provider or Overlay Manager. Outside of Managed Accounts and Model Portfolio Management Services, we can, in certain cases, be responsible for the selection of investment vehicles used for cash management purposes in a client’s portfolio, or for recommending investment vehicle options to the client, the client’s custodian, or HIML could invest client assets in Affiliated Investment Vehicles (i.e., another agent of the client, subject to the client’s investment policies, Investment Companies, Private Investment Companies or other Pooled guidelines and restrictions, and applicable law. Actual and potential conflicts of interest arise for HIML in connection with the selection of Investment Vehicles) that are advised by us or other Federated investment vehicles used for cash management purposes. Cash is Advisory Companies. These Affiliated Investment Vehicles generally typically invested in money market mutual funds or other liquid pay their investment advisers and service providers based on a investments or cash management vehicles, which could include, in percentage of their average net assets. Accordingly, we have an incentive to invest client assets in these Affiliated Investment Vehicles certain cases, Affiliated Investment Vehicles. For example, since HIML or our affiliates can receive investment in order to increase the compensation that will be paid to us, other advisory fees, other service fees, or other compensation from Affiliated Federated Advisory Companies and/or our other affiliates by these Investment Vehicles, we have an incentive to leave larger cash balances Affiliated Investment Vehicles. in client accounts because the cash balances can be invested in Affiliated Investment Vehicles. However, in connection with Managed Accounts To address these actual or potential conflicts of interest, we invest and Model Portfolio Management Services, we generally do not have client assets in Affiliated Investment Vehicles only when such discretion over the selection of or know the investment vehicles investments are consistent with a client’s investment objectives, policies, guidelines and restrictions, and applicable law. To the extent selected for cash management purposes (as noted above), including whether such cash will be invested in an Affiliated Investment Vehicle. required by applicable law, prior to recommending or making The same is true outside of Managed Accounts and our Model Portfolio investments in Affiliated Investment Vehicles, HIML or our related Management Services when a client’s custodian invests the cash. persons will:

Conflicts of Interest Relating to Affiliated Investment Vehicles

Read the rest in the brochure

Activities and Affiliations Registration as a Broker-Dealer or Broker-Dealer Representative Neither HIML, nor any of its management person, are registered in the United States as a broker-dealer or as representatives of a broker-dealer.

Registration as a Futures Commission Merchant, Commodity Pool Operator or a Commodity Trading Advisor Neither HIML nor any of its management persons are registered as Futures Commission Merchant, CPO or CTA. However, HIML has an exemption as a CTA.

Relationship with broker-dealers

Hermes Investment Management Limited

As discussed under in Item 4 of this brochure, HIML is an affiliate through common ownership with Federated Securities Corp., a dually-registered investment adviser, municipal securities dealer and broker/dealer. Federated Securities Corp., 1001 Liberty Avenue, Pittsburgh, PA 15222, acts as distributor of the registered Investment Company and Private Investment Company clients of affiliated advisers (i.e., the other Federated Advisory Companies) and as placement agent for Pooled Investment Vehicle clients of other Advisory Companies. (Please refer to Item 6 of this brochure for additional information regarding Federated Securities Corp.’s other activities and related arrangements.) The following management persons of HIML are registered representatives of Federated Securities Corp.: Jane Lambesis is listed on the Part 1 of HIML, as someone having indirect control of the management or policies.

Rich Novak listed as a Director of HIML

HIML also has certain related persons who are general partners, members or trustees of certain family limited partnerships, limited liability companies or trusts or similar family entities. From time to time, these family entities can invest in companies (such as broker/dealer) that participate in the financial services industry. (Please refer to “Performance-Based Fees and Side by Side Management” in Item 6 of this brochure for a discussion of conflicts of interest that arise as a result of these relationships.)

Relationship with other advisers As per its ownership structure outlined in item 4, HIML is affiliated through common ownership with the following SECregistered investment advisers:

Hermes GPE LLP (“HGPE”)

Hermes GPE (USA) INC (“HGPE USA”)

Federated Advisory Services Company

Federated Hermes (UK) LLP

Federated Investment Management Company

Federated Investment Counselling

ADV Part 2A Brochure – March 2026

Federated Equity Management Company of Pennsylvania

Federated Global Investment Management Corp

Federated MDTA LLC

Federated Securities Corp.

Hermes Fund Managers Ireland Limited (“HFMIL”) (an Exempt Reporting Advisers)

HIML along with HGPE & Federated Hermes (UK) LLP are also authorized and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom. Additionally, HIML is also affiliated with the following foreign advisers:

HGPE Singapore Pte Limited which is licensed with the Monetary Authority of Singapore (“MAS”).

HFMIL which is authorized and regulated by the Central Bank of Ireland (“CBI”).

Federated Investors Australia Services Ltd which is authorized and regulated by the Australian Securities and Investments Commission.

Federated Hermes Japan Ltd which is authorized and regulated by the Japan Financial Services Agency.

HIML provides portfolio management services to HFMIL’s range of funds and has Service Level Agreements (SLAs) with and shares some directors and other employees with FHL Advisory Companies. All FHL Advisory Companies have common compliance policies and procedures. Additionally, HIML can provide sub-advisory services for certain clients of the FHI Advisory Companies, and the FHI Advisory Companies can provide sub-advisory services for certain clients of the FHL Advisory Companies including HIML. Please refer to “Conflicts of Interest Relating to Affiliated Investment Vehicles” and “Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management Purposes” in Item 6 of this brochure for further information regarding actual or potential conflicts of interest that can arise in connection with investments in affiliated investment vehicles.

Other relationship HIML is also affiliated with EOS, an unregulated company that provides stewardship services to HIML and other thirdparty clients. From time to time, certain HIML clients may engage EOS to provide services at a discounted rate. The cost of such EOS services could increase if the clients were to terminate their arrangement with HIML, or HIML were to terminate its services to the clients. HIML has controls in place to address the conflicts of interest arising from the relationships discussed above such as information and operational barriers between itself and its affiliates.

The Federated Hermes Group has a group-wide Code of Business Conduct and Ethics which sets down requirements with regards to personal conflict of Interest, payments & gifts, outside business activities, confidentiality, insider trading and

fair dealing. Under the Code, all employees have a duty to act in the best interests of its clients and all potential conflicts and violations of the Code must be promptly reported to the Chief Compliance Officer (‘CCO’). The Code is designed to ensure that the personal securities transactions, activities and interests of Federated Hermes employees will not interfere with making and implementing investment decisions in the best interest of Clients. As such, it is HIML’s expressed policy, as reflected in the Code, that no employee shall prefer his or her own interest to that of a Client or make personal investment decisions based on investment decisions made on behalf of Clients. All employees must acknowledge the terms of the Code annually, or as amended. Subject to satisfying applicable requirements set forth in the Code, and applicable laws, employees can trade for their own accounts in securities which are recommended to and/or purchased for clients. Item 6 of this brochure, “Performance-Based Fees and Side by Side Management”, contains a detailed discussion of HIML’s Code of Ethics and how it addresses conflicts related to HIML’s participation or interest in client transactions and personal trading. (Please refer to “Conflicts of Interest Relating to Personal Trading” in Item 6 of this brochure for further information regarding our Code of Ethics.)

Hermes Investment Management Limited

Under the Code of Ethics, certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of clients. The Code requires preclearance by Compliance of all non- exempt personal account transactions so that such transactions are consistent with policies and procedures set forth in the Code. Furthermore, personal trading by employees is monitored by Compliance to reasonably detect and prevent conflicts of interest between the personal interests of such employees and the interests of clients. To permit such monitoring, all employees are required to provide quarterly securities holding reports to Compliance relating to all securities held in, or transacted on behalf of, their personal accounts.

Conflicts of interest Examples of Conflicts of Interest that have been identified are as follows:

There could be a conflict where a member of staff or a related person deals in securities on his/her personal account that the firm buys or sells for clients. To mitigate this, HIML requires staff members to pre-clear transactions in their personal account and implement a monitoring test designed to detect front-running.

There could be a conflict where either member of staff are offered lavish hospitality by prospects to secure deals or are offering similarly extravagant hospitality to prospects. To mitigate this, HIML has in place a Gifts & Entertainment policy and procedure designed to manage the risk by requiring disclosure and preclearance of gifts and hospitalities sent and received by staff. There could be a conflict between a member of staff’s interests and HIML or its clients’ interests arising from that employee outside activities. HIML has put in place an Outside Business Interests policy and procedure which require disclosure and pre-clearance before employees can take up any Outside Business Activity. There could be a conflict where a HIML fund or segregated account invests in another affiliate fund. This could occur where cash held in one HIML fund/segregated account is swept into another affiliate Money Market Fund, as part of cash management where the investment restrictions allow and both funds have an annual management charge. This is mitigated as no management fee will be charged for the investment made by the HIML fund/ segregated account. Please refer to “Conflicts of Interest Relating to Affiliated Investment Vehicles” and “Conflicts of Interest Relating to the Selection of Investment Vehicles Used for Cash Management Purposes” in Item 6 of this brochure for further information regarding actual or potential conflicts of interest that could arise in connection with investments in affiliated investment vehicles. There could be a conflict to the extent that HIML or its affiliates (e.g., the FHL Advisory Companies, the other Federated Advisory Companies and EOS) share material non-public information (MNPI) in relation to a security or transaction. At times, under certain circumstances, information barriers may be constructed between or among one or more Federated Advisory Companies, or with EOS, in connection with the sharing of MNPI or to prevent a person from gaining knowledge that gives rise to a conflict of interest. For example, a portfolio manager may be isolated from learning

information about a strategic transaction that Federated Hermes is considering. A copy of the Conflicts of Interest policy is available on our website. An existing or prospective Client can obtain a copy of the Code of Business Conduct and Ethics upon request.

ADV Part 2A Brochure – March 2026

Item 12 – Brokerage Practices Broker-Dealers Selection Criteria Depending on the terms of the Client’s agreement with HIML, HIML is generally given authority to make the following determinations without obtaining Client consent before effecting transactions:

Which securities are to be bought and sold;

The total amount of the securities to be bought or sold;

The broker or dealer through whom securities are to be bought or sold and;

The commission rates or prices at which securities transactions for client accounts are effected.

HIML uses the Central Dealing Desk model to ensure a separation of duties. Portfolio managers are responsible for the investment decision to trade which is then routed to the Central Dealing Desk for execution. The Central Dealing Desk is made up of a team of experienced dealers with a wide knowledge of the markets and instruments the firm deals in. It is their job to focus on achieving the best possible execution of trades on behalf of clients. Orders transmitted to the Central Dealing Desk are passed on to third parties to execute in the relevant financial markets. For equity investment teams the Central Dealing Desk operates a hybrid dealing model using both internal dealing desks and an outsourced external dealing desk operated by CF Global Trading UK Limited (‘CF Global’). CF Global execute orders for trades in the APAC and MEA regions in alignment with our Policy. Hermes Investment Management Limited and other Federated Advisory Companies are the entities trading on behalf of clients for jurisdictions and instruments not traded by CF Global. This hybrid model provides local market coverage for markets which operate outside of standard UK business hours. we have oversight over and monitors the quality of execution of all orders placed by CF Global. The Counterparty Credit Risk Summary Policy sets out the framework to monitor and manage counterparty credit risk. Separate processes exist to identify and approve Trading Counterparties prior to utilization. The distinction between a Broker/Dealer (“B/D”) and a Trading Counterparty lies in the types of transactions being executed and the level of credit exposure to that entity that exists. Equally, an assessment of the counterparty’s risk profile is undertaken commensurate to the level of trading risk. B/D related transactions are done on a delivery vs. payment basis (DVP), in which the risk of not receiving either monetary value or securities is low. This would also include margined forward settling U.S. Agency and Non-Agency MBS transactions. The risk to an Executing Broker, where the roles of an Executing Broker and Clearing Broker are bifurcated, would also be viewed similarly. Transactions executed with a Trading Counterparty (Non-DVP), for example margin, free delivery, or unmargined extended settlements; or acting as a Clearing Broker can include additional risks, such as a higher risk of not receiving either monetary value or securities.

While the standard B/D approval process is robust, the Trading Counterparty approval process establishes a higher standard, as

many of the transaction types identified can expose the funds/ segregated accounts directly to the Trading Counterparty. The process used to determine a “minimal credit risk” for unsecured credits within Federated Hermes money market fund franchise is the same process and standard used in approving and monitoring Trading Counterpart. The process of taking on new counterparties will normally be initiated by trading or Investment Management to the applicable Desk head or Global Investment Operations (GIO). The requests will be in writing and include a justification on best execution for an asset class or specific security and any additional relevant information about the B/D. Additional applicable criteria may be included (e.g. Regulatory requirements etc.), however not at the expense of obtaining best execution.

Global Trade Services Team reviews the full legal name of the broker as it is known to its underlying regulatory body; the name of its regulator and its regulatory identifier (FINRA, FCA, SEC, etc.); the Broker’s Legal Entity Identifier (LEI), the last three years’ worth of audited financial statements and, if applicable, the last two - three years’ worth of Focus Report and depending on the domicile of the B/D entity, either the current W9 or W8 tax form.

Compliance conducts an internal review including highlighting significant or non-standard results for additional review. Compliance focuses on confirming that the proposed B/D does not present risks from an AML perspective and/or a reputational risk perspective. This review may include, but is not limited to checking for economic sanctions, evaluating key individuals, seeking identity information for the company, and considering any negative news about the B/D. Compliance maintains applicable processes, policies, and procedures based on the requirements of the regulator governing the entities seeking to engage with the B/D.

The Global Liquidity Group conducts a review of the B/D’s financial statements, as well as additional research to evaluate the B/Ds ability to function as a going concern to execute and timely settle DVP trades. Baseline criteria for the evaluation will include current and recent trends in net income, capital, capital market activity and any additional information relating to operational functions that may impact the ability of the B/D to timely settle trades.

If the B/D is not approved, the requesting Trader and relevant other parties will be notified. If the B/D is approved, the approval will be sent to Legal for completion of any required contracts / agreements, and subsequently, instructions will be issued to set up the entity within the broker database.

Trading Counterparty Approval (Non-DVP transactions) If a Trader identifies a Trading Counterparty that he/she would like to utilize, it is first determined if the Trading Counterparty is already on the Approved Repo Counterparty list (a list of all approved Trading

Hermes Investment Management Limited

Counterparties maintained by the Taxable Money Market Credit Analysts). If approved, the Trader may use the Trading Counterparty without additional review. If the Trading Counterparty is not already on the Approved Repo Counterparty list, the Trader will discuss the name with an assigned investment analyst who will review the credit of the Trading Counterparty which will be documented in a credit report.

Trading Counterparties (Non-DVP transactions) not on the Approved Repo Counterparty List. There may be times where there is a need to execute a specific transaction with a Trading Counterparty that is not included on the Approved Repo Counterparty list for purposes of obtaining best execution and minimizing opportunity cost. In these instances, exceptions will be vetted, including how counterparty risk and/or risk of delayed or failed settlement is mitigated, by the Global Liquidity Group and the Head of Global Trading, and reviewed at the Counterparty Risk Committee. The Counterparty analysis will include a determination that the Counterparty represents minimal credit risk for the transaction based on the mitigating factors discussed.

An assessment of the counterparty’s risk profile is undertaken commensurate to the level of trading risk. Compliance undertake KYC and AML checks and sanctions screen counterparties on a daily ongoing basis. The Guidelines Monitoring team code and monitor counterparty guidelines. The Legal department arranges the completion of the relevant legal documentation as necessary and Operations facilitate the setup of counterparty risk management controls such as collateral and margin. Following completion of all required reviews and signoffs, the Risk team will recommend rejection or approval of the counterparty. A list of approved counterparties is maintained by the Risk team. Where a DVP (Delivery-versus-Payment) or ETD (Exchange Traded Derivative) broker is required for a singular transaction and no permanent relationship is envisaged, a one-off counterparty approval can be granted. A simplified assessment process will be followed

Read the rest in the brochure

broker/dealers in pursuit of best execution, which transactions can be aggregated with trades for other client accounts. As a result of these transactions, Managed Account Program clients typically bear additional brokerage expenses in addition to the single fee associated with such programs. Certain other Managed Accounts can pay a single fee or fees for investment management and custody, except that unlike a traditional Managed Account Program, the wrapped fee would not include brokerage commissions. Thus, to the extent permitted by the Managed Account Program and consistent with the policies discussed under the heading “Selection Criteria for Broker/Dealers” in this section, HIML typically would execute transactions with other broker/dealers in pursuit of best execution, which transactions can be aggregated with trades for other client accounts, and which would result in additional charges to such account. Similar to Segregated Accounts, Managed Account clients (either directly or through the Managed Account Program Sponsor or Platform Provider) can also expressly limit HIML’s discretionary authority, including directing us to use a particular broker/dealer to execute portfolio transactions. In such a case, we may not be in a position to negotiate commission rates or spreads or obtain volume discounts, and such transactions may not be aggregated with orders for the same securities of other accounts managed by HIML.

Trading Error HIML has adopted written policies and procedures that it believes are reasonably designed to identify and resolve errors made in the trade execution and management process (“Trade Errors”). HIML will evaluate any exception made in the process of managing or placing an order for, or executing a security transaction on behalf of, a client account over which HIML has investment discretion to determine if it is a Trade Error. Regarding Model Portfolio Management Services, HIML also evaluates any exception made in the

process of providing a model recommendation to an Overlay Manager in a program to determine if it is a model delivery error (collectively, as applicable, with Trade Errors, “Errors”). Consistent with HIML’s policies and procedures, and obligations under applicable law, HIML strives to identify and resolve Errors promptly, document such Errors, take reasonable steps to seek to prevent the reoccurrence of such Errors and treat clients fairly in resolving such Errors. Where a single Error results in multiple transactions in a client account, gains and losses on these transactions may be netted in evaluating the net impact of such an Error.

Compensation HIML may from time to time compensate, either directly or indirectly, either employees or third parties for Client referrals. Any such referral arrangements will comply with the relevant portions of the Marketing rule (Rule 206(4)-1). In particular, third-party referral arrangements will be pursuant to a written agreement between HIML and the solicitor and all required disclosures will be made. HIML has an agreement with the below affiliates under which it receives compensation, as agreed from time to time in writing, for referring prospects to them:

Hermes GPE

Federated Investment Counseling

Hermes Fund Managers Ireland Limited

Federated Hermes (UK) LLP

Federated Securities Corp

. Additionally, HIML has an arrangement with the below entities under which it pays them compensation, as agreed in writing, for referring prospective investors to HIML:

What Is Innovation Limited (third-party)

Federated Securities Corp (affiliate)

The cost of the referral fees is borne entirely by HIML not its clients. Some of HIML’s clients can retain consulting firms to assist them in selecting investment managers. Some consulting firms provide services to both those who hire investment managers and to investment management firms. HIML can pay to attend conferences sponsored by consulting firms and/or purchase services from consulting firms where it believes those services will be useful in operating our investment management business. HIML’s clients and prospective clients should be aware that consulting firms might have business relationships with investment management firms that they recommend to their clients. Please refer to “Conflicts of Interest Relating to Receipt of

Compensation or Benefits, Other Than Advisory Fees” in Item 6 of this brochure for a further discussion of these conflicts of interest and how they are addressed.

HIML has no information applicable to this Item.

Account review Holdings across client accounts are reviewed continuously. The investment teams meet daily to discuss ongoing market events, as well as company and industry news. The investment teams also hold twice-weekly meetings to focus on their portfolio holdings and risk composition of their strategies. Performance on all accounts is monitored daily and formal performance reviews for the strategy including attribution analysis are typically conducted monthly. The entire portfolio management team is involved in reviewing client accounts. Compliance performs daily investment restriction monitoring on a pre-trade and post trade basis. Client Guidelines are coded from the Client’s Investment Management Agreement (IMA) or the fund prospectus prior to investment and subject to a four eyes coding and testing review.

Client Reporting The nature and frequency of reports to clients varies and will usually be determined by the specific requirements of each client. All our client reports are typically written and delivered electronically via email with some reports delivered via client portals or to distributor platforms (applies to our EU products only). HIML can provide monthly or quarterly performance or other reports to Separate Account clients as set forth in the investment management agreement with the clients. Separate Account clients will also receive account statements and other reports from the custodians for their accounts.

Hermes Investment Management Limited

As part of HIML’s Model Portfolio Management Services, HIML provides Overlay Managers with model portfolios and updates thereto, and other reports as set forth in its agreement with the Overlay Manager. Overlay Managers could incorporate such reports into the reports the Overlay Managers provide to their clients. HIML can also provide quarterly performance or other reports to Managed Account Program Sponsors or Platform Providers as required by the Managed Account Program Sponsors or Platform Providers. The reporting requirements are usually stated in our agreement with the Managed Account Program Sponsor or Platform Provider. Managed Account Program Sponsors and Platform Providers can reasonably modify, duplicate or incorporate such reports into the reports that they provide to Managed Account Program participants.

It is HIML’s policy not to accept custody of client funds or securities. We also have policies and procedures designed to prevent us from having inadvertent or deemed custody. From time to time, if custodians or other parties mistakenly send us share certificates, dividend checks or other client assets; HIML has procedures that require such assets to be returned in a timely manner.

ADV Part 2A Brochure – March 2026

HIML usually receives discretionary authority from the client at the outset of a relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives, policies, guidelines and restrictions for the particular client account. In certain Managed Account Programs, HIML’s investment discretion can be limited by policies, procedures and limitations imposed in connection with the Managed Account Programs by the program Sponsor, Platform Provider, custodian or other third parties involved with the administration and management of the Managed Account Program. HIML’s authority to trade securities can also be limited by tax, laws or regulation that require diversification of investments and favor the holding of investments once made. Before accepting discretionary authority, HIML will discuss with the client, its investment strategy for the client to decide if it meets with their investment objective. Client’s investment guidelines and restrictions must be provided to HIML in writing and are usually part of the IMA signed by the Client and HIML.

HIML believes that voting proxies is an important aspect of portfolio management as it represents an opportunity for shareholders to make their voices heard and to influence the direction of a company. HIML is committed to voting corporate proxies in the manner that it reasonably believes serves the best interest of its clients. In accordance with Advisers Act Rule 206(4)-6, the FHL advisory companies, which includes HIML, have adopted a Global Voting Policy

HIML has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, has not been the subject of a bankruptcy proceeding and is not required to include a balance sheet as it does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance