IMPAX ASSET MANAGEMENT (AIFM) LIMITED

A. Description of the Firms Impax Asset Management Limited (“IAM”) and Impax Asset Management (AIFM) Limited (“AIFM”), (each, a “Firm”, and, collectively, the “Firms”) are UK investment management companies authorized and regulated by the U.K. Financial Conduct Authority (“FCA”). Both Firms are also SEC registered investment advisers, which does not imply a certain level of skill or training. IAM and AIFM started operations in 1998 and 2014, respectively, and each is wholly owned by, and is a principal operating subsidiary of, Impax Asset Management Group plc (“Impax”), which is listed on the AIM market of the London Stock Exchange. IAM and AIFM operate as integrated advisers. Certain IAM employees are dual hatted with AIFM, meaning the employees provide investment advisory services on behalf of both Firms. Consequently, conflicts of interest can arise in the allocation of investment opportunities and the potential sharing of material non-public information. The Firms have adopted policies and procedures to address or mitigate those conflicts. Impax Asset Management LLC (“Impax LLC”) is a U.S. registered investment adviser and an affiliate of IAM and AIFM. In performing advisory services, the Firms utilize the talents of investment professionals employed by Impax LLC to assist with management of certain investment strategies or products. In keeping with applicable regulatory guidance, Impax LLC has entered into an agreement with the Firms pursuant to which Impax LLC is considered a "Participating Affiliate" of the Firms, as that term is used in certain no-action positions taken by the staff of the Commission. These arrangements allow the Firms to use the resources and professional expertise of Impax LLC to render portfolio management services to clients of the Firms. The Firms are specialist asset managers focused on investing in companies and assets that we believe are well positioned to benefit from the shift to a more sustainable global economy. The Firms offer a well-rounded suite of investment solutions to publicly and privately offered pooled investment vehicles, professional clients and institutional investors in accordance with the requirements of client specific investment agreements. Additional details regarding the types of clients to which each Firm provides investment management services are disclosed in each Firm’s Form ADV Part 1A. As of September 30, 2025, the Firms had discretionary Regulatory Assets under Management of $27,845.1 million as follows:

B.

Impax Asset Management Limited: o Discretionary: $24,448.5 million o Non-Discretionary: $ 1,392.5 million o Total: $25,841.0 million

Impax Asset Management (AIFM) Limited: o Discretionary: $2,004.1 million

Types of Advisory Services for IAM

Separately Managed Accounts IAM provides ongoing investment services to the separately managed accounts of various institutional clients based on the investment goals, objectives, time horizon and risk

tolerance of each client. IAM has entered into investment agreements with each of its clients. Pooled Investment Vehicles IAM provides investment services to non- affiliated pooled investment vehicles. IAM provides discretionary investment services to its clients according to the investment objectives described in the applicable investment management agreement and not individually to the investors in such pooled investment vehicles. Sub-Advisory Services IAM also acts as sub-adviser to additional types of clients, also based on the investment goals, objectives, time horizon and risk tolerance of its clients, which include:

Affiliated and non-affiliated open-ended investment companies registered under the Investment Company Act; Non-affiliated non-US funds registered under the securities laws of offshore jurisdictions, including Undertakings for Collective Investments in Transferable Securities (also known as UCITS); US collective investment trusts and other investment trusts; and Separate Accounts.

Wrap Fee Programs Additionally, IAM manages certain “wrap fee” accounts of one or more wrap fee program(s) (“Wrap Fee Program”) sponsored by unaffiliated brokers or other financial institutions (“Program Sponsor”) where the wrap fee client selects IAM as the investment adviser for the client’s Wrap Fee Program account. The Program Sponsor monitors and evaluates IAM’s performance and provides custodial services for the client’s assets, all for a single fee paid by the client to the Program Sponsor. IAM’s fees and services for managing the wrap accounts are set forth in IAM’s agreement with the Program Sponsor. As compensation, IAM receives a portion of the fee the Program Sponsor charges the wrap fee client. IAM’s role as an investment adviser participating in Wrap Fee Programs is substantially similar to its role in managing other separately managed accounts in that IAM manages each account in accordance with the model portfolio utilized by the investment strategy chosen by the client or Program Sponsor, subject to client-imposed guidelines. Due to such client-imposed guidelines, it is not always possible to manage wrap fee accounts identically to other Wrap Fee Program accounts or separately managed accounts that IAM also manages. IAM anticipates that the majority of transactions for the Wrap Fee Program accounts will be executed through the Program Sponsors. In rare instances and where feasible, IAM may ‘step-out’ orders on a best-efforts basis if it determines that doing so is in the best interest of all applicable clients. Model Portfolios IAM also provides model portfolios to unaffiliated brokers or other financial institutions (“Model Program Sponsors”) or the overlay managers appointed by the Model Program Sponsors (each a “Model Recipient”), which they use to construct portfolios on behalf of institutional clients. In these circumstances, IAM does not have discretion to execute trades. IAM is generally only responsible for providing the updated model portfolio to the

Model Recipient on a periodic basis and is compensated based on a percentage of the total assets of the accounts managed by the Model Recipients or applicable to the model. The Model Recipients are responsible for effecting the trades recommended to achieve the model portfolio. Please refer to Item 12 for additional information regarding the model portfolio arrangements and how IAM communicates model portfolio holdings under different circumstances and trading processes.

C. Types of Advisory Services for AIFM Pooled Investment Vehicles AIFM serves as the investment manager to the Private Equity Funds (defined below), other private funds and an investment trust that invests in listed equities. AIFM provides discretionary investment services to its clients according to the investment objectives described in the applicable investment management agreement and not individually to the investors in such pooled investment vehicles.

D. Conflicts of Interests and Other Considerations Regarding AIFM’s Private Equity Funds Side Letters AIFM and/or a fund has and is expected to at any time enter into other written agreements (“Side Letters”) with one or more investors, with respect to the listed or private equity strategies. These Side Letters do and are expected to entitle an investor to make an investment in a fund on terms other than those in the governing documents. Any such terms, including (but not limited to) with respect to: (i) opting out of particular investments, (ii) reporting obligations of the fund or the Firm, (iii) transfers to affiliates, (iv) co-investment opportunities, (v) withdrawals due to adverse tax or regulatory events, (vi) consent rights to certain governing document amendments, (vii) certain fee structures, or (viii) any other matters described in the governing documents, are expected to be more favourable than those offered to any other investors. Furthermore, subject to the provisions of the applicable governing documents, the Firm and/or the fund are expected to permit certain business associates of the Firm and/or its affiliates to invest directly or indirectly in the fund or a parallel vehicle on terms which are expected to be more favourable than those offered to the other investors, including with respect to the payment of management fees and carried interest. If the Firm and/or the fund enter into a Side Letter entitling an investor to opt out of a particular investment or, with the consent of the Firm, to withdraw from the fund, any election to opt out or withdraw by such investor may increase any other investor’s pro rata interest in that particular investment (in the case of an opt-out) or all future investments (in the case of a withdrawal). Co-Investments in the Private Equity Funds AIFM may offer co-investment opportunities to investors other than a fund client, even in situations where the fund client is not fully invested in the applicable investment opportunity. For instance, when AIFM considers that the PE Fund lacks the capacity to acquire the entire investment or where it would not be consistent with the PE Fund’s investment objective, investment strategy or investment restrictions to acquire the entire investment, or it would otherwise not be in the best interests of the Fund to acquire the entire investment on its own, or if, in the opinion of AIFM, the amount invested by the fund client is sufficient for its purposes, or such co-investment may, among other potential considerations, (i) encourage reciprocal investment offers to the fund client, (ii) enhance

the investment opportunity, (iii) improve the economics of the investment in which the fund client participates, (iv) resolve regulatory matters in the country of investment, or (v) allow the fund client to participate in transactions, which if entered into without co-investors, would actually or potentially over time exceed the limits set forth in the fund client’s risk management guidelines or the Firm’s sense of prudence or the portfolio construction plan. Such co-investors might include third-party investors that are not current investors in a private equity fund client (a “PE Fund”). Decisions to seek and accept a co-investor will be made in the best interests of the applicable PE Fund. However, participation in coinvestment opportunities is not expected to be offered to all investors and priority may be given to certain investors. To the extent such opportunities are offered, it will be in compliance with the applicable PE Fund governing documents. In certain instances co-investors may, however, demand a significant level of control over the joint investment and may not, in all cases, have the same economic interests or objectives as the fund client, even if the Firm has not offered special terms to a co-investor. The Firm’s policy is generally to allocate all costs and expenses (including abort costs) relating to a co-investment opportunity proportionately to the co-investing parties, including the fund client. However, there are circumstances where, for commercial or other reasons, such allocation is not possible and such costs and expenses are allocated entirely to the fund. For further information around the risk associated with such co-investment opportunities, see the disclosures under Item 8. Co-investment in the PE Funds by the Impax team Certain professionals of the Firm and its affiliates may commit capital in the PE Funds via (i) a carried interest vehicle of a relevant PE Fund (“Carry Vehicle”) or (ii) another investment vehicle that has been established to facilitate the investment of investment professionals of the Firm in a PE Fund (each, a “Team Co-Investment Vehicle”). As a result of this, every investment made by a PE Fund involves an indirect interest attributable to related persons of the Firms. The Carry Vehicles and the Team Co-Investment Vehicles generally are not subject to any management fee or carried interest. The fact that the Firms’ employees and affiliates have financial interests in the PE Funds could create an incentive for the Firm to make riskier or more speculative investments on behalf of the PE Fund or to otherwise manage the timing and terms of an exit than would be the case in the absence of this arrangement. However, the Firms believe that this financial interest will generally serve to align the Firms’ incentives with investors. The summary above is not a complete or exhaustive list or explanation of all actual or potential conflicts of interests that could arise in connection with the PE Funds and their activities. Prospective and existing investors are advised to review the offering materials and other governing documents for a more detailed and complete description of the actual or potential conflicts of interest that could arise in connection with a particular PE Fund and its activities. Other conflicts may be disclosed throughout this brochure and the brochure should be read in its entirety for other conflicts.

Fees and Compensation Regarding IAM Fees are negotiated between IAM and its clients based on the strategy and services provided, prior to execution of the client agreement. Fees are charged either monthly or quarterly in arrears. For the listed equity strategies, fees are either calculated by reference

to the average or month end net asset values (“NAV”) or NAV plus performance fee and are invoiced to clients in arrears.

Fees and Compensation Regarding AIFM Fees are negotiated between AIFM and its clients based on the strategy and services provided, prior to execution of the client agreement. For the PE Funds, fees are calculated by reference to committed capital during the relevant fund’s investment period, and thereafter invested capital, and are invoiced to clients in advance. AIFM generally charges the funds (i) a priority profit share ranging from 1.4% 1.6% during the investment period based on total commitments and thereafter the same rate applies to the remaining-asset cost basis and (ii) a profit share of 20% after an 8% performance target is achieved. Since investors are generally not permitted to withdraw or redeem their investment in a fund prior to the dissolution of the fund, refunds of management fees are not available to investors. In the event the advisory arrangement is terminated during a quarter, advisory fees that have been prepaid would be returned on a prorated basis, minus reasonable expenses. For Global Resource Optimization Fund LP (i.e., the listed equities private fund), AIFM charges a management fee of 1.1% per annum, based upon the private fund’s NAV on the last business day of each month; however, the general partner may assess a higher or lower management fee to certain limited partners in its discretion. Compensation and termination arrangements apply in accordance with client agreements. Funds managed by AIFM pay normal transaction and brokerage charges incurred in the management of the funds. Clients also pay the costs and charges of the custodian and administrator. In addition to the PE Funds’ fees described above, the PE Funds and/or their investee companies generally bear the following fees and expenses without limitation:

Organizational expenses, including all legal and other expenses incurred in connection with the establishment of the PE Fund and the offering of the Interests in the PE Fund up to an amount (excluding value-added tax) subject to limitations, if any, as described in the governing documents, and organizational expenses in excess of this amount and commissions payable to placement agents, brokers and intermediaries will be paid by the investment manager.

Operating expenses, which include, without limitation: o All costs, charges and expenses properly incurred by the PE Fund directly or through an investment vehicle in connection with the PE Fund’s activities; o All interest and other expenses related to a specific acquisition financing, refinancing, hedging, disposal (to the extent they are not capitalized as part of the cost of acquisition) including all broken deal expenses (where pertinent fund investment committee has approved a due diligence budget) or any bridging facility, whether or not such acquisition, financing, hedging, disposal or bridging facility is completed (including but not limited to all legal accounting and brokerage fees and expenses and registration fees and expenses); o External consultant fees, including indirectly those of the operating partners, which are charged to the applicable investee company, financing costs and expenses relating to the evaluation, negotiation, acquisition, protection, monitoring, including software and technology solutions

relating to portfolio companies compliance and reporting, and attending meetings of investors or investor advisory committees in respect of each portfolio investment, performing anti-money laundering and commercial “know your client” checks on the relevant portfolio investment and disposition of the PE Fund’s assets; The costs, fees and expenses of all legal, auditing, consulting, accounting administrative, custodial, depositary, paying agent, transfer agent, representatives of a PE Fund appointed in certain jurisdictions pursuant to applicable law, appraisal, valuation, regulatory, ESG consulting, advisory, production and disclosure of ESG reporting, compliance fees and expenses, including expenses associated with foreign account reporting regimes compliance, (including the relevant Form PF, U.S. Commodity Futures Trading Commission filings, reports, filings, disclosures and notices pursuant to the AIFM Directive, including reporting under Annex IV of the AIFM Directive, reporting under the European Market Infrastructure Regulation ((EU) No 648/2012)), disclosures and notices prepared in connection with the collection of data and preparation of filings, reports, disclosures and notices prepared in connection with the European Union Sustainable Finance Disclosure Regulation ((EU) No 2019/2088) (the “SFDR”) and any other applicable legislation or regulation related to the European Commission’s Action Plan on Financing Sustainable Growth, disclosures, notices and reporting prepared in connection with the European Union Solvency II Directive, as amended (2009/38/EC) and antimoney laundering and “know your client” checks on investors in such PE Fund) as well as any financial or other professional advisers (including the overhead costs of personnel providing accounting services) and all independent consultants retained to advise the general partner or investment manager in respect of the PE Fund whether generally or with respect to actual or potential acquisitions (including the construction or operation of underlying assets), ownership or disposals by the PE Fund (to the extent they are not capitalized as part of the cost of acquisition); Expenses associated with tracking and monitoring of obligations arising from the PE Funds governing documents and Side Letters or (whether inhouse or via a third-party technology platform provider), as well as any financing arrangements and any other documents that create contractual, regulatory or similar obligations in connection with the management and operation of a PE Fund, as well as costs and expenses of establishing, updating and maintaining legal entity management systems in connection with the PE Fund.All out-of-pocket costs and expenses incurred in relation to transactions with or for investee companies (unless reimbursed by the investee companies) and the acquisition (including the construction or operation of underlying assets), ownership and disposal of PE Fund assets (including reasonable travel expenses or extraordinary expenses, such as litigation or the cost of enforcing rights, if any) and the exercise by the general partner or the investment manager of any and all voting, conversion or other rights attaching to PE Fund assets; The fees and expenses of the auditors in the preparation of the annual audit of the PE Fund and/or all costs and out-of-pocket expenses incurred by any person in the preparation of partnership tax forms, financial statements and tax returns and the payment of any taxes due from the PE Fund; The expenses (including reasonable travel expenses) of all meetings of the partners, the limited partnership committee and the applicable advisory board in connection with matters relating to the business of the PE Fund and all fees (if any) payable to the members of the LP Committee;

The expenses of the independent member of any investment committee in connection with matters relating to the business of the PE Fund and all fees payable to the independent member of the investment committee; Fees and expenses incurred on behalf of the PE Fund in relation to the interpretation of the applicable limited partnership agreement, including expenses associated with amendments to the governing documents and the solicitation of consent to such amendments, provided the PE Fund is not responsible for any fees or expenses incurred by the investment manager or any of its associates in connection with any legal dispute between the investment manager and/or the general partner on the one hand, and the limited partners on the other, on the interpretation of any provision in the applicable limited partnership agreement; All expenses of any proceedings, litigation, arbitration or mediation (including fees of lawyers engaged to act in relation to any such proceedings, litigation or arbitration or the cost arising from enforcing any rights arising therefrom) by or against the PE Fund or in relation to any investment made by the PE Fund, the amount of any settlements paid in connection therewith and all legal fees incurred for the purposes of the PE Fund; All taxes and any statutory fees, if any levied against or in respect of the PE Fund, with certain limited exceptions; The amount of any VAT paid by the general partner or the investment manager or the PE Fund in relation to the business of administration of the PE Fund which is not recoverable by the general partner, the investment manager or the partnership and any cost suffered by the general partner, the manager and any other company in the same VAT group as the general partner as a result of the priority profit share not being subject to VAT; Expenses associated with the preparation, printing and distribution of reports to the investors of a PE Fund and any parallel vehicle thereof as required pursuant to the applicable governing documents or by applicable law or regulation (including AIFMD The amount of any expenses incurred in relation to any indemnity given in relation to the PE Fund or any insurance premiums payable in respect of the PE Fund or investee companies (other than any such premiums borne directly by the investee companies); All fees and expenses incurred in relation to any broker or to any custodian or nominee of PE Fund assets in relation to the safeguarding, administering and/or holding (or similar) of the PE Fund assets or to perform the other functions of a depository contemplated by the AIFMD; All fees and expenses incurred in relation to any fund administrator appointed by the PE Fund, including those associated with the preparation of the PE Fund’s financial statements, tax returns and the payment of any taxes due from the PE Fund; All fees and expenses incurred in relation to any valuer appointed to value the PE Fund assets; The amount of any advance in respect of the priority profit share. Costs and expenses related to the transfer of interests (to the extent not reimbursed by the parties to any such transfer); Costs of winding up and liquidating a PE Fund (including its special purpose vehicles); and Premiums for insurance directly acquired for the specific and sole purpose of protecting a PE Fund or any of its holding special purpose vehicles and any persons that are entitled to indemnification under the terms of the governing documents of such PE Fund (including D&O insurance);

All reasonable costs and expenses of a PE Fund, its alternative investment fund manager, the investment manager, the general partner or any third party with respect to directorial services, corporate secretarial services, domiciliation agent services, or similar services, provided that any expenses attributable to the PE Fund alternative investment fund manager, investment manager or general partner shall not exceed the rates that the general partner reasonably determines would be charged by a third party providing equivalent services;

Transactions fees may be charged to actual or potential investee companies in respect of the PE Fund’s own investment in such companies. Costs and fees related to the raising of third-party capital such as third party equity or debt for investee companies, as well as the cost of technical consultants and other expenses of AIFM and/or the applicable general partner who provide services to or for the benefit of investee companies, may also be chargeable to such investee companies by the applicable general partner and such costs and fees shall not constitute “Transaction Fees” or be applied to reducing the Management Fee payable to the general partner. The foregoing list is intended to provide a summary of the expenses that may be generally borne by the PE Funds but is not intended to be exhaustive. Prospective and existing investors are advised to review the offering materials and governing documents of the applicable PE Fund for the specific expenses to be borne by a particular PE Fund. The general partner of the PE Fund may, in its sole discretion, determine not to allocate certain expenses to such PE Fund, which would otherwise be permitted pursuant to such PE Fund’s governing documents. The listed equities funds bear the following fees and expenses without limitation:

Management fee of 0.50% or 1.1% per annum based on the fund’s NAV on the last business day of each month (the general partner may assess a different management fee or waive the management fee in its sole discretion); Organization and offering expenses; Fund operating expenses including, but not limited to: o Securities brokerage commissions and other transaction costs; o Margin and interest expenses; o Legal accounting, consulting, valuation and other professional fees; o Audit and tax preparation fees; o Administration fees; o Transactions costs and expenses, including trade matching fees; o Costs of research and execution services which are of benefit to the fund and not otherwise provided by brokers; and o Regulatory and filing expenses.

Item 12, below, further describes brokerage expenses and the factors that the Firms consider in selecting broker-dealers for client transactions and eligible research costs.

A. General The Firms invest on behalf of their clients in both listed equity and private equity infrastructure strategies. The Firms believe the transition to a more sustainable global economy provides a helpful backdrop to construct high conviction, low turnover equity portfolios that are well positioned to achieve long-term capital growth. The Firms’ investments are based on a strong conviction that among other macro-economic trends, population dynamics, resource scarcity, inadequate infrastructure and environmental constraints will profoundly shape global markets, creating investment risks and opportunities. The Firms expect that these trends, reflecting the transition towards a more sustainable global economy, will drive earnings growth for well-positioned companies. The Firms’ investment framework identifies and calibrates the rising risks and expanding opportunities from this transition and guides the Firms’ search for investments that will deliver long-term outperformance. For strategies managed utilizing designated personnel of the Participating Affiliate, the Firms have oversight and supervisory responsibilities for the services provided by the personnel of the Participating Affiliate.

B. Methods of Analysis Environmental, Social and Governance (“ESG”) Analysis Corporate Resilience (“CR”) (formerly ESG) analysis is an integral part of the Firms’ investment process, a fundamental, proprietary analysis at the company-level. Impax conducts a detailed, proprietary analysis of new companies considered for the investable universe and reviews the analysis on a periodic basis. Impax considers five main pillars within its analysis: 1. Governance This includes analysis of companies’ governance structures, considering common and best practice in the areas of: o Board structure o Compensation o Shareholder rights o Internal controls o Governance of sustainability 2. Material environmental, social, and other risks

This includes analysis of companies’ environmental and social policies, processes and disclosures identifying the most material risks at the company or issuer level. Materiality is defined as the sustainability issues or risks that may most materially disrupt a company’s operations through financial, physical, or reputational loss or disruption. Material risks can include:

Natural Resources & Biodiversity Pollution and waste externalities Health & Safety Vulnerability Product liabilities, including cyber risk Supply chain dependency Bribery & Corruption

o Anti-trust and government regulations Impax seeks investment in companies that have addressed the material risks with robust policies, processes, management systems and incentives that are scaled appropriately to the importance of the risk. Ideally, companies will discuss and disclose their own assessments of the main sustainability risks they are facing. 3. Climate change Climate change is a systemic issue for all companies and this pillar assesses the preparedness, management, target-setting, performance, and disclosures by companies of: o Transition risks o Physical climate risk (PCR) 4. Human capital management and E, D & I Human capital and E, D & I are systemic and critical issues for all companies and this pillar assesses the management, target-setting, performance, and disclosures by companies of: o Diversity in leadership (gender, racial/ethnic diversity in board and management teams) o Workplace equity (hiring/retention efforts, goals, targets, disclosures) o Human capital (talent pipeline, compensation/benefits, and employee engagement) 5. Controversies 1 This includes analysis of companies’ past and on-going controversies, seeking strong processes and management systems to address and avoid any repeat events. o Types of controversies, incidents (repeats, reputational, financial, operational) o Severity (widespread, systematic, isolated incident) o Timeframe and status of issues (on-going, closed, company responded/addressed) The CR analysis is the responsibility of the lead analysts and the Impax Sustainability Centre provides coordination, guidance, but also a peer review of all the evaluations, which includes confirming the overall CR scores for the companies. Companies that do not have adequate levels of quality and resilience in their corporate governance structures, risk management approaches and transparency, are not eligible for investment. Research sources For the CR analysis, company disclosures and reports are assessed and we use external, third party ESG research as input and support in the analysis. The Firm uses the following research tools in support of the core proprietary bottom-up ESG research conducted in house:

External specialist ESG research providers: MSCI ESG Manager (ESG and Controversy data), Sustainalytics (quarterly UN Global Compact Screen), Glass Lewis (Proxy voting and governance research).

This is not a separate pillar in the CR analysis for Private Markets.

Databases: Bloomberg (ESG data, litigation and controversy data), CDP (CO2 data), ENDS Europe (environmental policy data). Sell-side analysis: CLSA (Asian sustainability and governance research), Jefferies ESG research, Morgan Stanley (ESG and sustainability research).

All companies must meet financial and Impax’s Corporate Resilience (CR) criteria before entering the Firms’ universe of investable companies. The investment team members are responsible for integrating the CR analysis into the investment process. The insights from the CR analysis are then utilised to establish the priorities for engagement with investee companies.

Listed Equity Methods of Analysis and Strategies Investment Philosophy Impax Asset Management’s Listed Equities strategies aim to deliver superior long-term returns by leveraging our deep understanding of the opportunities and risks arising from the transition to a more sustainable economy (TSE). We use proprietary insights into structural changes associated with the TSE to identify mispriced opportunities and manage risks effectively. In this section we describe both our Active Equities (AE) and Systematic Equities (SE) using the expected structure of Investment Process, Methods of Analysis and Strategies.

ACTIVE EQUITIES (AE)

Impax Active Equities approach combines rigorous bottom-up research with disciplined portfolio construction and valuation, supported by a global investment team operating under a single, integrated process. Investment Process (AE) Our investment process is consistent across strategies and built on four stages: (1) Idea Generation – combining bottom-up and top-down research with insights from Sector Expert Groups and the Sustainability Centre. Investment ideas may come from a variety of top down and bottom-up sources including, but not limited to: Sustainable & Thematic Research, Quantitative & Asset Class insights, PM Insights, Sector Expert Groups, Company meetings and site visits, conferences and external providers. (2) Fundamental Analysis – applying the 10-Step framework. The 10-step fundamental analysis is common to all Impax strategies and is used by the Primary Analyst to prepare an initiation report which outlines the qualitative and quantitative investment case for the specific company as well as an investment recommendation and rating, this includes Corporate Resilience (ESG) Analysis integration, financial and valuation analysis. (3) Portfolio Construction – Security selection and position sizing informed by conviction, valuation, and risk considerations. (4) Portfolio Review & Stewardship – Portfolio oversight and risk monitoring, engagement and proxy voting to enhance resilience and protect shareholder value.

Methods of Analysis (AE) -

Bottom-Up Fundamental Research

Stock selection is the primary driver of performance. Our research process is intensive and analyst-led, focusing on financial quality, competitive advantage, and resilience. Analysts employ Impax’s proprietary 10-Step Analysis, which includes: 1. Investment Thesis – Investment opportunity, drivers and thesis roadmap, recommendation and rating. 2. Market Dynamic & Thematic Landscape – Structural and thematic outlook, market size, regulation & growth, competitive landscape, customers and suppliers. 3. Business Model – Company overview and TSE profile, divisional/geographic breakdown, advantages and durability. 4. Strategy & Capital Allocation – Company’s plan, credibility of plans, consistency of delivery, uses of capital. 5. Management & People – Experience, effectiveness, succession and retention. 6. Risks – Industry dynamics, policy, geopolitics, macroeconomics, societal forces and structural headwinds. 7. Corporate Resilience (ESG) Analysis – Governance structures and management of material stock-specific risks. 8. Financial Statement Analysis – Balance sheet health, growth and margin trajectory, free cash flow, capex and R&D trends, returns and estimates. 9. Valuation & Scenarios – Base case valuation and assumptions, bull and bear valuations and respective assumptions. 10. Trading – Liquidity and technical analysis. -

Role of Sector Expert Groups

Idea generation and thematic insights are supported by Sector Expert Groups, which bring together specialists across geographies and sectors. These groups drive bottom-up research by sharing sector knowledge and emerging themes, and collaborate with the Sustainability Centre to review and update the Impax Sustainability Lens, a proprietary framework assessing opportunities and risks at the sub-industry level. -

Top-Down Research

While stock selection is bottom-up, we incorporate top-down investment insights to contextualize sector and regional exposures. This includes asset class and investment strategy analysis and thematic views to guide portfolio positioning. -

Portfolio Construction

We build portfolios through a disciplined, bottom-up process focused on stock selection from Impax’s approved A-List of companies. Co-portfolio managers share equal responsibility for portfolio construction, ensuring alignment with client objectives and risk parameters. Position sizing reflects conviction, valuation discipline, and portfolio risk factors, supported by tools in the Impax Portal for monitoring exposures, liquidity, and benchmark-relative characteristics. Portfolio changes are typically made following structured review meetings, incorporating analyst insights, sustainability considerations, and macro themes, while maintaining a holistic approach to risk management.

Strategies (AE) Impax manages Listed Equity strategies consistent with the Investment Philosophy and (4step) Process described above. Our Strategies can be described by two complementary approaches – Thematic using taxonomies to define investable universes and Core using multiple tools and frameworks (including Impax Lens) to generate ideas across global equities. -

Thematic Strategies (Taxonomies)

These strategies invest in companies providing solutions to environmental and social challenges, organized under six proprietary taxonomies:

Environmental Markets – Specialists, Leaders, Asia Environmental. Water – Infrastructure, treatment, utilities. Sustainable Food – Across seven sectors and 17 subsectors. Climate Opportunities – Mitigation and adaptation solutions. Sustainable Infrastructure – Resource and social infrastructure. Social Leaders – Meeting basic needs, broadening economic participation, improving quality of life.

Companies must meet minimum revenue thresholds (typically ≥20% or ≥50%) aligned with these taxonomies. -

Core Strategies

The Core Strategies utilise multiple frameworks, insights and tools to undertake idea generation and fundamental analysis on sectors and stocks, the Impax Lens is one of these and it is a top-down proprietary framework for consistently assessing sustainability opportunities and risks at a GICs sub-industry level. It is driven by fundamental insights from Impax’s Sector Expert Groups and the Sustainability Centre. It provides the Equity Team with a forward-looking perspective on investment opportunities and risks arising from the Transition to a Sustainable Economy. It is particularly relevant for the following strategies.

Global Opportunities Global Emerging Markets Opportunities US Large Cap US Small Cap

Core strategies prioritize quality, valuation discipline, and sustainability insights across all sectors. Valuation Approach (AE) Valuation is central to our process. Analysts estimate intrinsic value using, but not limited to discounted cash flow models, multiples, and sum-of-the-parts analysis, complemented by scenario testing. Each stock is assessed within a valuation barometer framework, providing a range of outcomes (bear, base, bull cases) to inform risk management and portfolio construction.

Risk Management (AE) Risk is managed holistically at both company and portfolio levels. Steps 6 and 7 of the 10Step framework address risk at a company and industry level. Corporate Resilience analysis addresses governance, environmental and social risks, climate preparedness, and human capital. Portfolio risk is monitored daily using proprietary tools and reviewed formally at Portfolio Review Meetings and the Investment Committee.

SYSTEMATIC EQUITIES (SE) Investment Process (SE)

Impax's Systematic Equities strategies follow a disciplined and repeatable process designed to construct diversified portfolios aligned with the transition to a more sustainable economy. The process consists of four steps:

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IAM’s Types of Clients IAM provides discretionary and non-discretionary portfolio management services to, among other, the following types of clients:

Corporations Pension and profit-sharing plans Endowments and foundations Trusts Charitable organizations Insurance companies Investment companies (including mutual fund companies) Investment consultants Religious organizations Pooled investment vehicles (including a private equity fund) Banking institutions Municipalities

The Firm provides investment management and advisory services to professional and institutional clients. The Firm does not market or provide investment services directly to individuals but advises the accounts of individuals through the Wrap Fee Program.

AIFM’s Types of Clients AIFM provides discretionary portfolio management services solely to pooled investment vehicles, which include the PE Funds and two listed equities funds.

Performance-based Fees In addition to asset-based fees, the Firms charge some of their clients performance-related fees. The Firms manage listed equity funds and private equity funds. The Firms charge a performance-related fee with respect to some of the listed equity funds and the carried interest partner of all of the private equity funds receives carried interest. As a result, the Firms have a financial incentive to favor those funds and accounts that are charged a

performance-based fee or incur carried interest over accounts that do not. As described below, the Firms have designed and implemented allocation policies and procedures to help ensure all clients are treated fairly and equitably over time, and to prevent this conflict from influencing the allocation of investment opportunities among their clients.

Side-By-Side Management The Firms have adopted policies and procedures to mitigate possible inherent conflicts associated with managing accounts for multiple clients. In addition, the Firms have adopted trading and allocation policies designed to ensure that their side-by-side management of accounts with different types of fees is consistent with their fiduciary responsibilities to their clients. These policies include requirements that all accounts in the same strategy are managed the same way, that is, the accounts must have the same portfolio holdings and must be traded at the same time subject to certain restrictions. The investment teams for the listed equity strategies and private equity strategies are segregated and operate independently of each other with appropriate electronic information barriers in place. Order allocation and trading procedures are designed to establish a process whereby clients are treated equitably and fairly over time. The allocation policies are reviewed at least annually or when a material change occurs. All re-allocations must be pre-approved by the Investment Compliance team.

The Firms and their employees are not registered, nor do they have an application pending to register, as a broker/dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. The Firms have a number of affiliated investment advisers. All are subject to appropriate information barriers and a Global Trading Policy that addresses certain conflicts of interest, including the allocation of investment opportunities. Arrangements with related persons that are material to the Firms’ advisory business are as follows:

Impax has helped to seed funds managed by the Firms:

Impax is a limited partner in Impax New Energy Investors II LP, a fund investing in projects in the renewable energy and related sectors. Impax has committed to invest up to Euro 3.298m into the fund. Impax is a limited partner in Impax New Energy Investors III LP, a fund investing in projects in the renewable energy and related sectors. Impax has committed to invest up to Euro 4.0m into the fund. As a limited partner of the carried interest vehicle, Impax receives carried interest if payable.

Impax has also made investments in, and subsequently redeemed such investments from, other funds managed by the Firms. These investments are fully disclosed in the accounts of Impax.

IAM acts as an investment manager to Impax New Energy Investors IV SCSp, BNRG USA Co-Invest SCSp, and AIFM acts as investment manager to Impax New Energy Investors II LP and Impax New Energy Investors III LP.

Impax Asset Management (Hong Kong) Limited (“Impax HK”), a wholly owned subsidiary of Impax, is registered with the Securities and Futures Commission of Hong Kong. Impax HK provides investment services to the Firms and certain funds managed by the Firms. The Firms pay a fee for these services. No material conflict of interest is considered to exist in respect of the arrangement.

Impax Asset Management Ireland Ltd., a wholly owned subsidiary of Impax, was incorporated and registered with the Central Bank of Ireland as an asset management company, in order to facilitate the Group’s continued operations into the EU.

Impax LLC, a wholly owned subsidiary of Impax, is registered with the SEC and is the investment manager to the Impax Funds. IAM acts as a Sub-Adviser to certain funds managed by Impax LLC. IAM has full investment discretion and makes all determinations with respect to the investment of each sub advised fund’s assets, subject to the general supervision of Impax LLC and the Board of Trustees of the

relevant Impax fund. Impax LLC (and not the Impax Funds) pays a portion of the advisory fees it receives to IAM in return for its services.

Additionally, AIFM is affiliated with the general partners to each of the funds it advises. These general partners include: Impax Global Resource Optimization (GP) Limited, Impax Global Opportunities (GP) Limited, INEI II GP (UK) LLP and INEI III GP (UK) LLP. IAM is also affiliated with INEI I GP (UK) LLP and INEI IV GP S.à r.l.

Personal Trading Code of Ethics The Firms place the utmost importance on client trust and their fiduciary responsibilities to clients in all aspects of the business. The Firms have adopted a Code of Ethics (the “Code”) that complies with SEC Rule 204A-1 under the Investment Advisers Act of 1940 (the “Advisers Act”).

Standards of Business Conduct and Compliance with Federal Securities Laws The Code sets forth standards of business conduct for the Firms and their “Supervised Persons” (e.g., employees, contractors (short and long-term), consultants, interns and any other persons so designated by the Firms’ Chief Compliance Officer). The Code is based on the principle that the Firms and their Supervised Persons have a fiduciary duty to act in the best interests of the Firms’ clients. Supervised Persons must comply with federal securities laws, acknowledge that they have read and understand the Code upon employment and at least annually thereafter and report any violations of the Code to Compliance.

Pre-clearance Requirements for Personal Trading by Access Persons The Firms deem all Supervised Persons to be “Access Persons” for purposes of the Code. Access Persons must obtain clearance from the Chief Compliance Officer or his delegate prior to effecting any securities transaction, other than those specifically exempted by the Code, in which they, their families (including spouse (or spousal equivalent), minor children and adults living in the same household), or trust of which they are trustees or in which they have a beneficial interest, are parties. This includes a specific requirement for Access Persons to obtain clearance prior to directly or indirectly acquiring any beneficial interest in securities in an initial public offering or in a private placement.

Reporting Requirements for Access Persons Each Access Person of the Firms and his/her family members (including spouse (or spousal equivalent), minor children, and adults living in the same household) will submit to the Chief Compliance Officer periodic report regarding accounts, securities held and transactions in securities owned of record and beneficially held.

Copies of the Code Available A copy of the Code is available to any client or prospective client on request to John Boese at (603) 431-8022 or by writing to John Boese, Impax Asset Management, 30 Penhallow Street, Suite 100, Portsmouth, NH 03801.

Participation or Interest in Client Transactions and Conflicts of Interest The Firms do not invest in securities for their own accounts. The Firms’ personnel can trade in securities for their own accounts, including securities that the Firms have purchased and sold, or recommended for purchase and sale, for clients provided however, that Access Persons are required to obtain clearance in advance for trading in securities as described above. Clearance to trade will generally not be granted if any of the Firms’ clients traded or intend to trade within a 24-hour period (or more) before or after clearance is requested. Participation or interest in client transactions is further detailed above in Item 10. The Firms have a Global Conflicts of Interest Policy which applies to conflicts of interest that may give rise to a material risk to the interests of any client. The Firms conduct their business according to the principle that they must manage conflicts of interest fairly, both between themselves and a client, and between one client and another. In identifying conflicts of interest, the Firms consider the factual circumstances and will take into account whether they are likely to:

make a financial gain, or avoid a financial loss, at the expense of the client or clients; have an interest in the outcome of a service provided to the client, or the outcome of a transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome; have a financial or other incentive to favour the interest of one client or group of clients over the interests of another client or group of clients; carry on the same business as the client; receive, from a person other than the client, an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service; or if proceeding with the conflict of interest is in violation of law applicable to the Firms or governing documents or is otherwise prohibited.

The Firms’ policy is to take all reasonable steps to maintain and operate effective organizational, procedural and administrative arrangements to identify and manage conflicts. The Firms have in place procedures that address the identification and management of actual and potential conflicts of interest that may arise in the course of the Firms’ business. The Firms are required to manage any conflict of interest which arises promptly and fairly.

Principal and Cross Transactions The Firms do not engage in principal transactions whereby the Firms trade portfolio securities directly with a client account. To the extent permitted by, and in compliance with, applicable law and any applicable governing documents, the Firms may effect a “cross transaction” between their client accounts in which one client will purchase a security held by another client. The Firms may enter into a cross transaction for rebalancing purposes, where a particular client needs liquidity, to reduce or eliminate transaction costs or market impact, or otherwise. The Firm will enter into cross transactions only when the transactions are consistent with the best interests of both clients and at a price that the Firm believes constitutes best execution for the clients. The Firms do not receive any commission or other compensation in connection with these transactions and will always execute these transactions on a trading venue. The Firms place the utmost importance on client trust and their fiduciary responsibilities to

clients in all aspects of the business. All cross trades must be pre-approved by Investment Compliance.

Clients’ Interests As a fiduciary, the Firms have to act in accordance with the best interests of their clients and seek best execution when placing orders with brokers for execution that result from decisions by the Firms to deal in financial instruments on behalf of our clients and funds and to take all sufficient steps to seek the best possible result for their clients and funds when directly executing orders with an execution venue on behalf of their clients. The Firms will always execute client orders acting as agent. Best execution requires the Firms to execute transactions for clients in such a manner that is the most favorable under the circumstances, taking into account all relevant factors. The best price, while very important, is not the only consideration. We seek best execution for all our funds, regardless of whether commissions are charged. Broker Selection The Firms will select the execution broker that in their judgement is the most appropriate, taking into account the execution factors and execution criteria. The trading desk will only execute with approved counterparties with whom the Firms have confidence in the confirmations and settlements process of the market and particular counterparty. The Firms continuously monitor and evaluate the performance and execution capabilities of brokers that transact orders for our clients to ensure consistent quality executions. This information is reported to the Firms’ Global Best Execution Committee, which oversees broker-selection. Execution Factors When executing orders, the Firms will take all sufficient steps to achieve best execution, subject to and taking into account, any specific instructions from the client, the nature of such orders, the priorities its clients’ place upon it in filling those orders and the nature of the markets and products in question. In order to deliver best execution, the Firms use knowledge, experience and judgement to execute trades on behalf of its clients taking into consideration a number of execution factors including: ● ● ● ● ● ● ●

The price that the order can be executed at; The costs of execution of the transaction to the client; The speed of execution of the transaction; The size and nature of the order; The current liquidity of the relevant security; The likelihood of achieving execution and settlement; Any other consideration relevant to the execution of the specific order (the “Execution Factors”).

Execution Criteria

The Firms are required to determine the relative importance of the Execution Factors for its clients by taking into account the following criteria: ● ● ● ●

The characteristics of the client, including the categorisation of the client; The characteristics and nature of the client order; The characteristics of the financial instruments that are the subject of that order; and The characteristics of the execution venues/brokers to which that order can be directed (the Execution Criteria”).

In considering the Execution Criteria and the importance of the Execution Factors, the Firms also take into account the client’s understanding and experience of the market in question, the client’s dealing profile, the nature of the dealing service the client requires, and the specific and general instructions given to the Firms by the client which may prioritise how the Firm fills client orders. Aggregation and Allocation of Orders Impax will aggregate client orders when it is in the clients’ best interests (which will not work to the disadvantage of each client). Orders will be aggregated in order to facilitate best execution in a manner intended to help ensure no participating client is favoured over any other client, on average, over time. Aggregated orders should receive the same average price and transactions costs on execution. In situations where two orders for the same security are entered into the same direction for different clients, the trader will generally aggregate the initial order with the subsequent order. IAM may aggregate orders for the same security entered in the same direction at different times, unless doing so would disadvantage existing orders. In some cases, aggregation may not occur if deemed impractical or unlikely to materially impact execution quality or cost. In accordance with ERISA, an investment made on behalf of one or more clients should not be made at the expense of another group of clients. Impax’s trade allocation standard requires transactions to be allocated fairly among portfolios. Trade allocation must be determined on a basis that is fair, reasonable and equitable to all clients based on Impax’s policies and client investment objectives and to avoid giving unfair preference to one client or a group of clients over another. In cases of partial fills, the received quantity is allocated proportionally across applicable accounts. Impax promptly allocates part or all of an aggregated order that has been filled in accordance with local regulatory requirements. Impax will not give preference to one client or group of clients over another and will endeavour to ensure fair allocation occurs. This principle will also apply when purchasing less liquid stocks. Reallocations should reflect the original intention and must be carried out prior to settlement unless in exceptional circumstances. Any errors in allocation will be promptly corrected so as to not benefit any one client above another.

Reallocations are not permitted from one account to another except where: ● ●

The initial allocation was erroneous; or Where the order is only partially executed resulted in an uneconomic allocation to some clients

Reallocations require sign off by Investment Compliance and trading should ensure documentary evidence of the reallocation is maintained. A reallocation should be: ● ●

At the price paid for each designated investment concerned (net of all relevant fees and commissions); or Priced at the volume weighted average price of a series of transactions

Brokerage and Eligible Research Services The Firms negotiate specifics around payment for research services with their clients, but overall believe that, in aggregate, the services it receives benefits clients and assists in fulfilling its overall fiduciary duty to clients. The Firms determine in good faith that the amount of the commission is reasonable in relation to the value of such services. Client commissions utilized to pay for brokerage and research often are referred to as “soft dollars.” The Firms act in the best interest of their clients and ensure that any conflict of interest arising are adequately managed and mitigated. The Firms do not receive research paid for with soft dollars as research and execution services are “unbundled”, managed separately and independently. The Firms are required to make explicit payments for any third-party research consumed and demonstrate that research contributes to better investment decisions and is therefore not an inducement. The Firms use a Research Payment Account (“RPA”) through which all research collections and payments must flow. Third party research providers are paid for eligible research services that have assisted the portfolio managers in investment decisions for client portfolios directly from the RPA. The Firms only pay for research that supports the portfolio managers’ investment decision making responsibilities. This process enables the Firms to accurately track expenditure on research services and identify the best providers of the research services the Firms receive. The quality of all research received is analyzed by the portfolio managers and the Firms’ research teams as part of the Firms’ investment process. Impax use a research platform and commission manager to assist with the process, including commission collection, budgeting, evaluation and provider payments. This process enables the Firms to accurately track expenditure on research services and identify the best providers of the research services the Firms receive. The Global External Research Oversight Committee approves the annual budget, monitors any regulatory impact and meets quarterly to oversee the quarterly evaluation process. Wrap Fee Programs and Communication of Model Portfolio Holdings As previously noted in Item 4, IAM participates in Wrap Fee Programs. Additionally, IAM delivers model securities portfolios to Model Recipients. In most cases, IAM delivers the model to the Model Recipient who then handles trading on behalf of the clients, however IAM may execute orders for some Wrap Fee Program accounts. From time to time, IAM’s

Wrap Fee account clients and Model Recipients may trade the same securities at the same time. In these circumstances, IAM will use a methodology to deliver model holdings to Model Recipients and effect trading on behalf of its other clients, including Wrap Fee Program accounts, that it believes to be fair and equitable. Normally, this methodology will place Wrap Fee Program accounts and Model Recipients and their clients under a simultaneous trading program. To achieve this, the Firm will provide model trade instructions to all accounts on a simultaneous basis. This process of simultaneous notification is designed to avoid systematically favoring one account or group of accounts over another. From time to time, IAM may use another methodology that it believes to be fair and equitable. Typical Account Groups: Discretionary clients generally have the following characteristics:

The Firm has full discretion to trade securities that are consistent with the investment strategy and limitations on a client’s behalf.

Non-discretionary clients generally manage the implementation and execution of portfolio ideas without the involvement of Impax and have the following characteristics:

Advisory - typically institutional clients who implement the trade recommendations sent by Impax. Model delivery - when Impax transmits periodic (example: upon model change, or monthly) security weightings or buy and sell instructions to a client, which typically is another investment adviser. There are various methods of delivery of the models, including email, SFTP or direct entry to their investment platform. The platform or recipient then has complete discretion to execute trades on behalf of its underlying investors, considering any client restrictions.

Trade recommendations and model portfolios are delivered simultaneously to discretionary and non-discretionary clients following PM adjustment sign off in MPM. The Firms’ approach to providing simultaneous trade instructions will remain consistent. The Firm acknowledges that a rotational arrangement for trading and trade recommendations may be introduced for certain strategies over time, for reasons specific to those strategies. Where a need to introduce such an arrangement occurs, the Policy can be reviewed and updated to ensure that the features relating to such an arrangement are appropriately captured. Impax utilises pre-determined capacity limits on eligible strategies, and strategy capacity is subject to regular review. Impax also conducts Transaction Cost Analysis (“TCA”) to assess and avoid the trading conflict that may arise as a result of Impax’s discretionary and non-discretionary business. IAM may seek to aggregate trades among wrap programs that allow “step out” trades to be executed. These trades may be further aggregated with trades that the Firm is effecting on behalf of other discretionary accounts. There will, from time to time, be circumstances that cause a particular wrap sponsor or Model Recipient to not be able to receive trade instructions in accordance with the above process (depending on a variety of factors), but

the Firm will ensure the method is appropriate under the circumstances and such alternative trading is fair and equitable. Because of the mechanics of the simultaneous process and other factors, trading for the IAM’s institutional and other discretionary accounts may be completed prior to the completion of all trades for wrap accounts and may be effected at the same time as trades are being executed for wrap accounts and Model Recipients. As a consequence, trading by or for a Model Recipient or wrap program client may be subject to price movements, particularly with large orders or where the securities are thinly traded, which may result in Model Recipients or wrap program clients receiving prices that are less favorable than the prices obtained by the Firm for its discretionary client accounts or other accounts managed by the Firm. As such, the Firm’s institutional or other discretionary accounts may, over time, obtain better execution, including more favorable prices for their transactions than wrap accounts or Model Recipients purchasing or selling the same securities. Alternatively, the same factors may result in wrap clients or Model Recipients completing trading before or at the same time as the Firm’s trading on behalf of institutional or other discretionary accounts. The Firm considers the delivery of a model to a Model Recipient, or communication of trading instructions to a wrap program client as simultaneous notification. In some cases, the wrap accounts or Model Recipients may obtain better execution because the Firm does not control a Model Recipient’s execution of transactions, and the Firm cannot control the market impact of such transactions.

The Firms do not receive compensation from third parties for advisory services to clients. The Firms can engage one or more persons to act as agent for a fund in connection with the offer and sale of interests to prospective investors, subject to compliance with applicable law. Fees payable will be negotiated individually between the Firms and the agent.

The Firms have no legal, regulatory or disciplinary events that are material to a client’s or prospective client’s evaluation of the Firms or their management.

The portfolio managers are generally responsible for the daily management and review of the institutional client accounts and funds under their supervision. Such reviews are likely to include a number of factors, including compliance with client investment objectives and guidelines, asset allocation and variance from target allocation, performance, valuation and current investment processes. These reviews are conducted regularly but can also be triggered by factors that may include changes in market conditions, strategy or investment objectives. Clients receive regular monthly or periodic reports and these reports include investment performance, investment strategy, and market outlook and portfolio holdings.

IAM does not accept “custody” within the meaning of Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) of its clients’ assets. If, in the future, IAM accepts a private fund client where the general partner is IAM’s related person, IAM will have custody regarding the assets of that fund client and will follow the procedures described below for AIFM. AIFM has “custody” within the meaning of the Custody Rule of the assets of the private funds it manages because the Firm is under common control with the general partner of

each such fund and each general partner has access to the assets of the applicable private fund’s assets. AFIM complies with the Custody Rule regarding each such fund by preparing and providing audited financial statements to the private fund investors on an annual basis.

In accordance with the rules of the FCA, the Firms have signed investment management agreements for all clients before undertaking any discretionary management services for clients. This agreement is negotiated with each client and clearly states, inter alia:

the categorization of the client the services to be provided the limits on the discretion to be exercised by the firm specific investment guidelines for that client reporting requirements fees payable termination provisions

The investment guidelines are monitored pre and post trade by the Investment Compliance department using the order management system compliance tools.

The Firms have authority for voting client securities on behalf of the funds relating to the portfolio companies in which they invest. The Firms are committed to ensuring the consistent exercise of proxy voting, which is conducted following publicly disclosed voting guidelines and policies. Fund investors are not able to direct how the Firms will vote the applicable fund’s proxies. The Firms also vote proxies on behalf of other clients that have granted us their voting rights. Clients who have granted their voting rights to the Firms understand the Firms’ voting approach and have agreed to follow it. Clients who choose to vote according to their own voting policies, have retained their voting rights. The Firms aim to enhance the long‐term value of their clients’ shareholdings, foster corporate governance best practices and promote greater accountability and transparency in investee companies. Hence, proxy voting is a key component in the on-going dialogue with companies in which the Firms invest on their clients’ behalf. The Firms follow voting guidelines and policies in deciding how to vote on resolutions. Voting Guidelines are reviewed annually. The Firms use a third-party voting platform to facilitate vote execution, reporting and record keeping. The Firms also use third-party service providers, including proxy advisor service and research providers, to help inform analysis of relevant proxy issues and proxy votes. Ultimately the Firms decide how to vote on the resolutions independently and in the best interests of the clients. The Firms aim to exercise voting rights on all shares held. In voting proxies, the Firms will seek to avoid material conflicts of interest between their interests on the one hand, and the interests of the client on the other. The Firms review proxy votes to assess the extent, if any, to which there may be a material conflict between the interests of clients and the Firms’ own interests.

If it is determined that a Potential Proxy Conflict of Interest exists, the potential conflict will be promptly reported to Impax’s Chief Compliance Officer (the “CCO”). The CCO will then determine whether a Potential Proxy Conflict of Interest exists and is authorized to resolve any such conflict in a manner that is in the collective best interests of all affected clients. The CCO may decide to resolve a Potential Proxy Conflict of Interest in any of the following manners:

The Firms may disclose any potential conflict to affected clients and obtain the consent of the majority of those clients, before voting in the manner approved by the majority of those clients; The Firms may elect to engage an independent third party to help determine how the proxy should be voted on; or The Firms may elect to establish an internal information barrier between the relevant person(s) that are involved in the potential conflict and the person(s) involved in making the proxy voting decision, in order to insulate the potential conflict from the proxy vote decision maker.

The Firms have a Stewardship Policy and Voting Guidelines publicly available on their website. Further proxy voting and stewardship information can be found in the UK Stewardship Code Statement and Stewardship & Advocacy Report, which discloses proxy voting activities and detailed proxy voting outcomes on an annual basis. Upon request, each Firm will provide clients information about how the proxies relevant to the client are voted.

The Firms do not have any financial impairment that could affect the Firms’ ability to meet all contractual commitments to clients and complies with all financial regulations and liquidity requirements of the rules of the FCA.