Impactive Capital LP

Impactive Capital was founded in 2018 and is organized as a Delaware limited partnership. Lauren Taylor Wolfe and Christian Asmar (the “Principals”) are the primary owners and Managing Partners of Impactive Capital. The Principals are primarily responsible for the management of the strategies employed by Impactive Capital. Impactive Capital LLC serves as the general partner of Impactive Capital and is also principally owned by the Principals. Impactive Capital serves as investment advisor and provides discretionary advisory services to the following private funds (each a “Fund” and collectively the “Funds” or the “Clients”):

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Impactive Capital Master Fund LP (the “Master Fund”)

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Impactive Capital Fund LP (the “Onshore Feeder”)

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Impactive Capital Fund Ltd. (the “Offshore Feeder”)

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Impactive Sierra Fund LP (the “Sierra Fund”)

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Impactive Zephyr Fund LP (the “Zephyr Fund”)

Impactive Capital’s investment objective is to generate attractive, risk-adjusted returns by identifying high quality businesses whose shares are trading at attractive valuations, and then help those companies invest capital effectively and ethically. Impactive Capital will seek to achieve its investment objective by causing Clients to take significant ownership stakes in publicly traded companies through open-market purchases, privately negotiated transactions, direct investments, participation in underwritten offerings, or a combination thereof. Impactive Capital may seek to influence management teams and boards in order to effect systemic change with respect to capital allocation, strategic initiatives, operational improvements and Environmental Social and Governance policies. Impactive Capital invests in long and short positions in equity or debt securities of public U.S. and nonU.S. issuers (including securities convertible into equity or debt securities); rights, options and warrants; bonds, notes and equity and debt indexes; swaps, swaptions, credit-default swaps, and other derivatives; instruments such as forward contracts on stock indices and structured equity or fixed-income products; exchange-traded funds; and any other financial instruments that Impactive Capital believes will achieve its Clients’ investment objective. Each Client’s investments may include both publicly traded and privately placed securities of public issuers, as well as securities sold pursuant to initial public offerings. In providing services to Clients, among other things, Impactive Capital: (i) manages the Clients’ assets in accordance with the terms of the applicable Client’s confidential offering memorandum (or other disclosure document), individual limited partnership agreement, investment advisory agreement, memorandum and articles of association or shareholder agreement and other governing documents applicable to each Client (collectively the “Governing Documents”); (ii) formulates investment objectives; (iii) directs and manages the investment and reinvestment of the Clients’ respective assets; and (iv) provides, or causes to be provided, periodic reports to investors and/or Clients, as applicable. Impactive Capital provides investment advice directly to the applicable Client and not individually to owners, limited partners or shareholders of a particular Client. From time to time, Impactive Capital and its affiliates may offer one or more investors and/or other thirdparty investors (including Impactive Capital, any affiliated entities, Employees, and investment vehicles in which Employees may hold an interest) the opportunity to co-invest with the Funds in particular investments via a Co-Investment Vehicle. Impactive Capital may, for example, offer such investment in a Co-Investment Vehicle when the size of the opportunity exceeds the amount of capital that Impactive

believes should be invested by the Funds. Fund investors are not generally permitted to impose restrictions on the types of investments in which their respective Fund may invest. Investment restrictions for a Client, if any, will generally be established in the Governing Documents of the applicable Client. Impactive Capital may enter into side letter agreements with certain large or strategic investors granting them, among other things, greater portfolio transparency, most favored nation rights and reductions in fees in comparison to other investors. As of March 1, 2026, Impactive Capital had regulatory assets under management of approximately $1,836,295,483. Impactive Capital has discretionary authority over all of its Clients’ investment activities.

Impactive Capital generally charges Clients an asset-based management fee and performance allocation or fee. Impactive Capital deducts its management fees (“Management Fee”) generally from each Client quarterly in advance. Management Fee rates generally range from 0.60% - 1.75% on an annualized basis. An affiliate of Impactive Capital, Impactive Capital GP LLC, (the “General Partner”), a Delaware limited liability company, serves as the general partner to one or more of the Clients and will receive performance-based allocations (“Performance Allocation”) in respect of each Client on an periodic basis in arrears and upon withdrawals by investors, subject to a highwater mark and in some cases, subject to certain other conditions and/or restrictions. For a further discussion of the Performance Allocation, please see Item 6. Impactive Capital may, in its discretion, waive, reduce or rebate the Management Fee and/or Performance Allocation with respect to the investment of any investor, including its employees, owners, affiliates and/or one or more investors. In the event a Client terminates its investment management agreement with Impactive Capital appropriate treatment will be given to all Management Fees and other compensation collected in advance (e.g., the Management Fee would be pro-rated based upon the number of days elapsed in the applicable period prior to termination and the balance of the Management Fee collected would be refunded). In addition to the Management Fee and Performance Allocation and as set forth in more detail in the applicable Governing Documents, each Client will generally pay all costs and expenses related to its investments and its operations. Expenses will generally be shared by all of the investors in the Funds, while expenses related to one or more particular series or classes of investments will be allocated accordingly. For each Fund that invests all or a substantial portion of its assets through a “master fund,” each such “feeder fund” will also be responsible for its pro rata portion of such master fund’s costs and expenses. Expenses of more than one Client will be shared on an equitable basis among such Clients in accordance with Impactive Capital’s expense allocation policy. Clients will reimburse Impactive Capital for any expenses it pays on behalf of its Clients. In addition, certain common expenses of Impactive Capital and its Clients, may initially be billed to Impactive Capital but will ultimately be allocated among Impactive Capital and its Clients in accordance with Impactive Capital’s expense allocation policy regarding common expenses. Notwithstanding the foregoing, Impactive Capital may elect to bear some or all of the above expenses of the Clients.

Impactive Capital and its supervised persons do not accept any compensation (e.g., brokerage commissions) for the sale of securities or other investment products, including interests in the Funds. For more information regarding Impactive Capital’s brokerage practices and brokerage expenses discussed herein, please see Item 12.

The Clients’ investment strategies are described in their respective Governing Documents. Strategies applicable to a Managed Account are expected to be tailored to the objectives of each such accounts. Impactive Capital is a fundamental, research-intensive, long-term oriented value investor in the public markets. Impactive Capital will seek to be a catalyst to realize long-term value in each Client’s investments. Impactive Capital may seek to influence management teams and Boards to effect systemic change with respect to capital allocation, strategic initiatives, operational improvements and Environmental Social and Governance policies (“ESG policies”). Impactive Capital believes these techniques can make companies more competitive and profitable, and maximize the value realization from a Client’s investments over the long-term. Impactive Capital believes a significant advantage to its concentrated long-term approach is to not be captive to trading and other strategies designed around short-term change. In the context of its strategy, Impactive Capital is willing to take on short-term price risk that other funds may be unwilling to accept, in the interest of generating long-term stock price appreciation. The initiatives that Impactive Capital recommends may also at times recommend strategic and operational initiatives that require near term investments which can dampen short term profitability for the purposes of driving superior longer term returns. Impactive Capital may employ hedges in the portfolio. Impactive Capital generally views the valuecreation process in its portfolio companies as a multi-year effort. Impactive Capital has designed the investment process to be consistent and repeatable. The goal of the investment process is to select the highest risk adjusted return opportunities from a sourcing universe of small and mid-capitalization companies. Impactive Capital intends to use analytical templates, extensive market research, deep dive diligence on companies and their industry peers, scenario analyses, capital allocation and ESG considerations to identify the most attractive actionable ideas for each Client. The Investment Process consists of Idea Sourcing, Deep Diligence, Active Engagement and Post-Investment Analysis. Finally, Impactive Capital believes a critical part of the investment process is a continuous feedback mechanism with a specific focus on: Identification of improvements in the diligence process, reassessment of indicators of management quality and board effectiveness, identification of improvements in optimizing positions and an assessment of which ESG changes were made and how they impacted returns. The description set forth above is general and is not intended to be exhaustive. The risks of each Client’s business are substantial and each Client could realize losses rather than gains from some or all of the investments described herein. Investing in securities involves a risk of loss that clients should be prepared to bear. Material Risks The following is an explanation of the material risks that Impactive Capital believes are associated with its investment strategy. Unless stated otherwise, each risk applies to all of the Clients. Further discussion of these and other risks associated with an investment in each Fund and Managed Account are set forth in the applicable Fund’s or Managed Account’s Governing Documents. The following risk factors do not purport to be a complete list or explanation of all the risks associated with an investment in one or more of the Funds and Managed Accounts. Investment and Trading Risks: An investment in a Client involves a high degree of risk, including the risk that the entire amount invested may be lost. No guarantee or representation is made that such Client’s investment program will be

successful. Impactive Capital intends to invest substantially all of the Clients’ assets in securities, some of which may be particularly sensitive to economic, market, industry and other variable conditions. The markets in which the Clients expect to invest have in recent years experienced significant volatility and losses. No assurance can be given as to when or whether adverse events might occur that could cause immediate and significant losses to the Clients. Long-Term Investments: A Client is likely to pursue investment opportunities that seek to maximize asset value or create market opportunities on a long-term basis. In pursuing such long-term strategies, a Client may forego value in the short term or temporary investments in order to be able to avail a Client of additional and/or longer-term opportunities in the future. Consequently, a Client may not capture maximum available value in the short term, which may be disadvantageous, for example, for shareholders who redeem all or a portion of their Shares before such long-term value may be realized by a Client. Investments in Undervalued Securities: A Client will seek to invest in undervalued securities and other financial instruments. The identification of investment opportunities in undervalued securities and other financial instruments is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued investments offer the opportunity for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from a Client’s investments may not adequately compensate for the business and financial risks assumed. In addition, a Client may be required to hold such securities or other financial instruments for a substantial period of time before realizing their anticipated value. During this period, a portion of a Client’s capital would be committed to the securities purchased, thus possibly preventing a Client from investing in other opportunities. In addition, a Client may finance such purchases with borrowed funds and thus will have to pay interest on such funds during such waiting period. Activist Role of a Client: A Client may pursue an activist role in effecting corporate change with respect to an investment. The costs in time, resources and capital involved in such activist investments depend on the circumstances, which are only in part within Impactive Capital’s control, and may be significant, particularly if litigation against a Client and/or the Impactive Parties ensues. In addition, the expenses associated with an activist investment strategy, including potential litigation or other transactional costs, will be borne by a Client. Such expenses may reduce returns or result in losses. The success of a Client’s activist investment strategy may require, among other things: (i) that Impactive Capital properly identify portfolio companies whose equity prices can be improved through corporate and/or strategic action; (ii) that a Client acquire sufficient shares of the securities of such portfolio companies at a sufficiently attractive price; (iii) a positive response by the management of portfolio companies to shareholder engagement; (iv) a positive response by other shareholders to shareholder activism and Impactive Capital’s proposals; and (v) a positive response by the markets to any actions taken by portfolio companies in response to shareholder activism. None of the foregoing can be assured to succeed. Corporate governance strategies may prove ineffective for a variety of reasons, including: (i) opposition of the management or shareholders of the subject company, which may result in litigation and may erode, rather than increase, shareholder value; (ii) intervention of one or more governmental agencies; (iii) efforts by the subject company to pursue a “defensive” strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iv) market conditions resulting in material changes in securities prices; (v) the presence of corporate

governance mechanisms such as staggered boards, poison pills and classes of stock with increased voting rights; and (vi) the necessity for compliance with applicable securities laws. In addition, opponents of a proposed corporate governance change may seek to involve regulatory agencies in investigating the transaction or a Client and such regulatory agencies may independently investigate the participants in a transaction, including a Client, as to compliance with securities or other law. Furthermore, successful execution of a corporate governance strategy may depend on the active cooperation of shareholders and others with an interest in the subject company. Some shareholders may have interests which diverge significantly from those of a Client and some of those parties may be indifferent to the proposed changes. Moreover, securities that Impactive Capital believes are fundamentally undervalued or incorrectly valued may not ultimately be valued in the capital markets at prices and/or within the time frame Impactive Capital anticipates, even if a corporate governance strategy is successfully implemented. Even if the prices for a portfolio company’s securities have increased, no guarantee can be made that there will be sufficient liquidity in the markets to allow a Client to dispose of all or any of its securities therein or to realize any increase in the price of such securities. Regulatory Restrictions: The investment strategies pursued by a Client may be affected by U.S. state and federal laws governing the beneficial ownership of securities in public companies, which may inhibit a Client’s ability to freely acquire and dispose of certain securities. Should a Client be affected by such rules and regulations, it may not be able to transact in ways that would realize value. In addition, any changes to government regulations could make some or all forms of corporate governance strategies unlawful or impractical. Accordingly, such changes, if any, could have an adverse effect on the ability of a Client to achieve its investment objective. Litigation and Regulatory Investigations: Some of the tactics that Impactive Capital may use involve litigation. A Client could be a party to lawsuits either initiated by it, or by a company in which a Client invests, other shareholders, or state and federal governmental bodies. There can be no assurance that any such litigation, once begun, would be resolved in favor of a Client, and there is a risk of monetary damages and equitable relief against a Client. In addition, as an activist investor, Impactive Capital may subject from time to time (and especially in the context of a proxy contest), to formal or informal investigations or inquiries by the SEC and other governmental and self-regulatory organizations in connection with its activities. Litigation and regulatory investigations may involve distraction of Impactive Capital’s time and significant expenses to a Client. Control Issues: Although Impactive Capital may seek protective provisions, including, possibly, Board representation, in connection with certain of its public and private investments, to the extent a Client takes minority positions in companies in which it invests, Impactive Capital may not be in a position to exercise control over the management of such companies, and, accordingly, may have a limited ability to protect its position in such companies. Reduced Liquidity due to Inside Information: From time to time Impactive Capital or its affiliates, or members of a group of investors or managers with which Impactive Capital is acting, may work with the management team of a company in which a Client has invested or proposes to invest in order to design an alternate strategic plan and assist them in its execution, and may secure the appointment of persons selected by Impactive Capital or other members of the group to the company’s management team or board of directors. In the course of such activities, Impactive Capital may come into possession of material, non-public information concerning such company,

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Impactive Capital provides investment advisory services to one or more Funds and/or Managed Accounts. Investors in the Fund and/or owners of Managed Accounts may include, but are not limited to, high net worth individuals, family offices, fund-of-hedge funds, endowments, foundations, trusts, charitable organizations, pension plans, and corporate or business entities. Details concerning applicable investor suitability criteria are set forth in the respective Client’s Governing Documents. The minimum commitment for an investor in a Client is outlined in the applicable Governing Documents, including the discretion of Impactive Capital and its affiliates to accept less than the minimum investment threshold. Each investor is required to meet certain suitability qualifications.

Impactive Capital is entitled to receive from each Client a Performance Allocation, generally at the end of each performance period. Performance periods generally range from one to three years. The Performance Allocation is an amount equal to a percentage generally ranging from 15%-25% of the increase from net realized and unrealized profits of each investor’s investment measured at the end of each year (or other performance period). Such Performance Allocation amounts may be subject to highwater marks, hurdles, preferred returns and/or clawback provisions. The Performance Allocation creates an incentive for Impactive Capital to make more speculative investments than would otherwise be made or make decisions regarding the timing and manner of realization of investments differently than if such Performance Allocation was not received. Impactive Capital is required to act in a manner that it considers fair and equitable, depending on the particular facts and circumstances and the needs and financial objectives of Impactive Capital’s various Clients, in allocating investment opportunities to the Clients. Impactive Capital shall address the manner in which investments will be allocated among its Clients through the application of trade allocation procedures that are designed to avoid or minimize potential and actual conflicts of interest with respect to such Clients, including policies designed to ensure that investment opportunities will be allocated fairly and equitably among Clients in a manner that is consistent with the investment objectives of each Client. As a general matter, Impactive Capital shall allocate investments among the Clients that pursue the same or substantially similar investment strategy on a pro rata basis. This approach, however, may be subject to change based on a number of factors, including, capital flows, new issue eligibility, investment restrictions and other circumstances where non-pro rata treatment is deemed necessary by Impactive Capital. Impactive Capital periodically reviews allocation of investment opportunities and sequencing of transactions to determine whether Clients are treated fairly and equitably.

Impactive Capital has claimed an exemption from registration as a commodity pool operator, pursuant to Rule 4.13(a)(3) under the Commodity Exchange Act of 1936, as amended (the “CEA”), and Impactive Capital has also claimed an exemption from registration as a commodity trading advisor, pursuant to Rule 4.14(a)(8), each under the CEA. Impactive Capital GP LLC, a Delaware limited liability company and an affiliate of the Investment Manager, is the general partner of the Funds and is responsible for their overall management. Impactive Capital and its principals, supervised persons (i.e., directors, officers, partners and other persons occupying a similar status or performing similar functions) and employees and other persons providing advice on behalf of Impactive Capital and that are subject to Impactive Capital’s supervision and control (the “Staff Members”) are not registered, and do not have any application pending to register, with the SEC as a broker-dealer or a registered representative of a broker-dealer. Impactive Capital does not currently expect to engage third party investment advisers to manage any portion of the Clients’ assets. In addition, Impactive Capital does not currently expect to invest any portion of the Clients’ assets in partnerships or joint ventures with other investment advisers. In the event that any such activities were to occur, neither such engagements or investments would result in the payment on a net basis of additional management fees, carried interests or performance allocations by the Clients. Impactive Capital will evaluate any material conflicts of interest presented by any proposed relationship or arrangement it may contemplate with a service provider, broker or similar party that has a material business relationship with the Clients to ensure that the transaction or arrangement is fair and equitable to the

investors in the Clients, and on terms that are consistent with arm’s length dealings, and Impactive Capital reviews any such arrangement on an ongoing basis thereafter to ensure continued benefit to the Clients and their investors. Currently, Impactive Capital does not have, and is not aware of any Staff Member that has, any relationships or arrangements that pose material conflicts of interest.

Trading Pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended (“Advisers Act”), Impactive Capital has adopted a written code of ethics (“Code of Ethics”), which is designed to address and avoid potential conflicts of interest and is applicable to all Staff Members. The Code of Ethics may also be applied to any other person designated by the Chief Compliance Officer of Impactive Capital (“CCO”). A summary of the Code of Ethics is provided below. A full copy of the Code of Ethics will be made available to investors in each Fund upon written request. The Code of Ethics addresses personal trading of “reportable securities” (as such term is defined in Rule 204A-1 of the Advisers Act), receiving and giving gifts and entertainment, engaging in outside activities, making political contributions and payments, making other donations, and the administration and enforcement of the Code of Ethics. The personal trading policy and procedures place restrictions on personal trading of reportable securities by all Staff Members, including that they disclose to Impactive Capital on a periodic basis all security accounts and reportable security holdings and transactions, in which a Staff Member has a direct or indirect beneficial ownership. Impactive Capital requires prior approval from the CCO and one of the Principals before any transactions in “covered securities” (as defined in the Code of Ethics) in any personal account of a Staff Member; except for certain exempt transactions, such as non-volitional transactions and purchases of shares in mutual funds or money market funds or ETFs. The Code of Ethics has specific provisions relating to identifying potential conflicts of interest. The provisions prohibit a Staff Member from directing Client transactions for the purpose of obtaining a personal benefit. They also generally prohibit personal business dealings with Clients or investors without the prior approval of the CCO. All violations of the Code of Ethics must be promptly reported to the CCO (or in his absence to one of the Principals), who is primarily responsible for administering and enforcing Impactive Capital’s Code of Ethics. A violation of the Code of Ethics may result in the imposition of disciplinary and remedial measures, including, without limitation, letter of reprimand, disgorgement, suspension, demotion or termination.

Selection of Brokers and Dealers Impactive Capital has complete discretion in deciding which securities are bought and sold, the amount and price of those securities, the broker-dealers to be used for a particular transaction, and commissions or markups and markdowns paid. In selecting broker-dealers to effect portfolio transactions for its Clients, Impactive Capital shall use its best judgment to choose broker-dealers most capable of providing best execution on an overall basis. In connection therewith, Impactive Capital will consider a number of factors to assess the overall value and quality of services provided by broker-dealers, including execution capability, diversity, commission rates,

financial responsibility, the value of research provided and responsiveness to Impactive Capital. In addition, Impactive Capital has established an Operating Committee that meets quarterly and is responsible for developing, evaluating and changing, when necessary, Impactive Capital’s order execution practices. Accordingly, if Impactive Capital determines in good faith that the amount of commissions charged by a broker-dealer is reasonable in relation to the value of the research and brokerage products or services provided by such broker, the Funds and/or applicable Managed Account may pay commissions to such broker-dealer in an amount greater than the amount another broker-dealer might charge for effecting the same transaction. Soft Dollar Arrangements Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), provides a safe harbor that allows an investment adviser to pay more than the lowest available commission in order to obtain research and brokerage products and services (commonly referred to as a “soft dollar” arrangement). That practice involves a conflict of interest, but Section 28(e) of the Exchange Act provides that it does not breach Impactive Capital’s fiduciary duty to the Client if the products and services consist of “research” or “brokerage” and certain other conditions and requirements are met. Impactive Capital does not currently anticipate using soft dollar arrangements. Investor Introductions Impactive Capital may receive introductions to investors through broker-dealers that execute trades on behalf of Impactive Capital. Impactive Capital does not believe that it pays any additional fees or higher commissions as a result of these introductions. Impactive Capital seeks best execution on all transactions. However, Impactive Capital may have an incentive to select or use a broker-dealer based on receiving investor referrals from that counterparty. Trade Errors Impactive Capital will seek to detect trade errors and to correct and mitigate them in an expeditious manner. Except as may otherwise be set forth in the applicable Governing Documents, any gains from trade errors will be kept by the affected Clients while any losses from trade errors (other than those due to gross negligence or willful misconduct regardless of the materiality of the loss in circumstances of gross negligence or willful misconduct) will be absorbed by the applicable Clients; provided, however, that such losses may (but are not required to be) reversed with Impactive Capital taking responsibility to make the affected Clients whole. Investment Allocation and Aggregation Impactive Capital is committed to allocating investment opportunities on a fair and equitable basis and in a manner that is consistent with the investment objectives of each Client. As a general matter, Impactive Capital allocates securities among the Clients that pursue the same or substantially similar investment strategy on a pro rata basis. This general approach, however, may be subject to change based on a number of factors. Investment opportunities are allocated by Impactive Capital’s order management system (“OMS”). Generally, all orders are allocated pro-rata across all Clients that follow the same or substantially similar strategies. Allocation percentages are based on the asset levels in each Fund. In certain circumstances, trades may be allocated other than pro-rata to allow for, among other things: (i) capital flows; (ii) new-issue eligibility; (iii) investment restrictions; and (iv) other circumstances where such non-pro-rata treatment is deemed necessary by Impactive Capital.

As a general matter, the accounts and funds utilizing the Fund strategy, or similar strategy, will receive their full and pro-rata allocation to investments ahead of any co-investment opportunity accounts or funds. For investment opportunities that require co-investment capital to implement the investment approach, the accounts and funds utilizing the Fund strategy, or similar strategy, will also receive their full and pro-rata allocation to such investments ahead of any co-investment opportunity accounts or funds. However, there may be instances where another allocation methodology is employed. In determining the method to allocate such trades, Impactive will consider factors such as (a) available capital, liquidity needs and the timing of capital inflows and outflows of the Fund/Co-Investment Vehicle; (b) regulatory restrictions that would or could limit a Fund’s/Co-Investment Vehicle’s ability to participate in a proposed investment; and (c) actual and anticipated redemptions/withdrawals/ subscriptions/contributions from the investors. Aggregation, or “bunching,” describes a procedure whereby an investment adviser combines the orders of two or more clients into a single order for the purpose of obtaining better prices and lower execution costs. Aggregation opportunities for Impactive Capital generally arise when more than one Client is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. Impactive Capital is not required to aggregate Client trades; however, it will generally do so, subject to best execution. When aggregating orders, Impactive Capital will aim to treat all Clients in a fair and equitable manner.

Impactive Capital does not directly or indirectly compensate any third party for client referrals. However, Impactive Capital may receive introductions to investors through broker-dealers that execute trades on behalf of Impactive Capital. Impactive Capital does not believe that it pays any additional fees or higher commissions as a result of these introductions. Impactive Capital seeks best execution on all transactions. However, Impactive Capital may have an incentive to select or use a broker-dealer based on receiving investor referrals from that counterparty. Other than the circumstances described above, Impactive Capital does not receive any economic benefits from non-clients in connection with the provision of investment advice to the Clients.

Impactive Capital is not aware of any legal or disciplinary events that are material to an investor’s or prospective investor's evaluation of Impactive Capital’s advisory business or the integrity of Impactive Capital’s management.

Clients’ portfolios are reviewed on a regular basis. Impactive Capital’s investment personnel hold investment meetings to discuss investment ideas, investment strategies, economic developments, current events, and other issues related to current portfolio holdings and potential investment strategies. Impactive Capital will provide each investor in a Fund with the following reports in accordance with the terms of the applicable Fund’s Governing Documents: (i) monthly unaudited NAV, investor capital statements and aggregate portfolio information; (ii) annual audited financial reports; and (iii) annual tax information necessary to complete any applicable tax returns. Managed Account Clients will receive from Impactive Capital, upon request, any information, documentation or other materials reasonably requested in order to enable the Managed Account client to ensure that Impactive Capital is managing the assets of the Managing Account in an equitable manner relative to Impactive Capital’s management of the accounts of other Clients.

Impactive Capital is deemed to have custody of the Clients’ assets because of the authority that Impactive

Capital and/or its affiliated entities have over those assets. The Clients’ financial statements are subject to an annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and the audited financial statements are distributed to each investor in each Client generally within 120 days following the end of each fiscal year of the applicable Client. The audited financial statements are prepared in accordance with generally accepted accounting principles (GAAP). Impactive Capital urges investors to carefully review the audited financial statements of the Clients in which they are invested.

In accordance with the terms and conditions of the Clients’ Governing Documents and subject to the direction and control of the Clients’ general partner and directors, as applicable, Impactive Capital will generally have discretionary authority to determine, without obtaining specific consent from the Clients or their respective investors, the securities and the amounts to be bought or sold on behalf of the Clients and to perform the day-to-day investment operations of the Clients.

In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Advisers Act, Impactive Capital has adopted and implemented written policies and procedures governing the voting of client securities. The general policy is to vote proxy proposals, amendments, consents or resolutions in a prudent and diligent manner that will serve the Clients’ best interest and is in line with the Clients’ investment objectives. In certain cases, Impactive Capital may determine that not voting is in the best interest of the Clients or otherwise appropriate. Investors may not direct Impactive Capital’s vote on behalf of the Clients. Conflicts of interest may arise between the interests of the Clients on the one hand and Impactive Capital and Staff Members on the other hand. At a minimum, the Staff Member responsible for instructing the vote by Impactive Capital on behalf of the Funds will be required to disclose any personal interest or other conflict of interest it has with respect to such proxy. Any conflict of interest will be reviewed and resolved by the Chief Compliance Officer. A copy of Impactive Capital’s proxy voting policies and procedures will be made available to investors upon written request.

Impactive Capital has not filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts.

Item 19: Requirements for State-Registered Advisers