Janney Montgomery Scott LLC

Janney currently offers eleven (11) fee-based advisory “wrap” programs that are broadly characterized as professional money management, asset allocation and internal portfolio management (each a “Program” and collectively, the “Programs”). Your Janney Financial Advisor will assess the potential suitability of the wrap fee program and establish whether one of the Programs may be appropriate for you based on your stated investment objectives and goals. General Fee Information In general, Janney’s fee is negotiable and may vary based upon a number of factors discussed further below. Janney generally charges a wrap fee based on a percentage of the assets in a Program account. A wrap fee is a bundled fee for services such as investment advice, including portfolio management, research, custodial services, reporting and trading and execution. A wrap fee is not based directly on the amount of transactions in a client’s account but rather the fee is calculated based on the asset value of the Client’s account. Accordingly, if there is little or no trading activity in the account, it is possible that a Client may pay more in advisory fees than he or she would have in commission charges if the account was a brokerage account, depending upon the number of trades that occur in an account from year to year. Each Program generally includes investment management, custody, reporting, performance-monitoring and trade execution services. Janney’s advisory fees are typically billed quarterly in advance, except as specifically noted below. The initial fee is charged on the date such assets are accepted for management and calculated on a pro-rata basis based on the days remaining in the calendar quarter. Thereafter, Janney calculates the fee at an annual rate based upon the market value of the Client’s account as of the last business day of the calendar quarter (i.e., March 31st, June 30th, September 30th and December 31st). Fees will be refunded if the account is terminated in writing by Janney or the Client for the pro-rata portion of the quarter for which no advisory services were provided. Additional deposits with a value of $15,000 or greater will be charged a pro-rata advisory fee for the partial calendar quarter, beginning on the date of the deposit. Intra-quarter contributions to 529 savings plans held away from Janney will not be assessed the pro-rated advisory fee. Withdrawals in any amount are not subject to a pro-rata refund of fees paid in advance. In computing the asset value of the Advisory Accounts held at Janney, the firm generally relies on pricing available from securities exchanges, third-party pricing sources, issuers, sponsors and other custodians. Advisory Account Assets traded on a national securities exchange or quoted on an automated quotation system are valued at the last sale price on the exchange or automated quotation system, or, if there has been no sale that day, at the last known bid price. Advisory Account Assets that are traded over-thecounter are valued according to the broadest and most representative market and valued at the known current bid price Janney believes most closely represents the current market value. Mutual fund shares are valued at their net asset value on the valuation date as described in the funds’ prospectuses. For mutual fund shares held away from Janney like those in 529 savings plans, Janney utilizes the most recent value reported to us by the 529 savings plan. The value of held away mutual funds is reported to Janney on a delay, which means that the value utilized by Janney to calculate your advisory fee may be more or less than the net asset value of the fund on the billing date. Additional deposits received intra-quarter will not be subject to a pro-rated fee for the remaining days of the quarter. Instead, the additional funds will be included in the account value during the next quarterly billing cycle.

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For privately offered securities, Janney utilizes the most recent position value reported to us by each fund administrator. The value of privately offered securities is reported to Janney periodically and the timing of such reporting may vary between fund administrators. This means that the value utilized by Janney to calculate your advisory fee may be more or less than the net asset value of each fund on the billing date. Any other securities or investments in the Advisory Account are valued in a manner that Janney determines in good faith to reflect fair market value on the date of valuation. Janney relies, without verification, on valuations furnished by an independent party Janney selects that it believes to be reliable. These good faith valuations may vary between other independent parties and other factors not assessed may substantially affect the valuation(s). Therefore, valuations may reflect a higher or lower fair market value depending on the independent party selected and relied upon. There are no assurances that (i) these good faith valuations reflect the prices that the Advisory Account actually paid for the securities or investments or (ii) that this is the price that would be realized upon a sale of the assets in the Advisory Account. With respect to each Program, fees may be negotiated with the Janney Financial Advisor (“FA”) and are based on a number of factors, including, but not limited to, the size of the Client’s account, other related accounts with Janney, the extent of services to be provided by Janney to the Client’s account, and the projected nature of trading in the Client’s account. Janney offers the following Programs, which are described in greater detail below:

Professional Money Management

Asset Allocation

Internal Portfolio Management

Adviser’s

Keystone Discretionary

Partners Advisory

Janney UMA (Formally Adviser’s MSP)

ETF Advantage

Compass

Classic

Janney Goals-Based Portfolio Solutions (GPS)

Investors Select (formerly FIED)

Janney Capital Management Direct

Pioneer

Janney offers Clients a choice between two primary advisory fee structures: a flat fee schedule and a tiered fee schedule, each based on a percentage of assets under management and subject to negotiation. Under the flat fee schedule, a single asset-based fee is applied to the entire value of the Client’s account. Under the tiered fee schedule, the advisory fee is calculated based on the total value of the Client’s household advisory assets under management, with different fee rates applied incrementally to portions of assets within specified tiers, such that the effective fee rate may decrease as assets increase. Individual account fees reflect a proportional allocation of the total household advisory fee.

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The fee schedule set forth below is the current fee schedule for new Clients and represents the portion of the fee payable to the Janney Financial Advisor. Additional fees may be applied by a Third-Party Manager, if applicable. Other fee schedules may go into effect from time to time, which may provide for lower or higher fees, as the case may be, than that shown below. As new fee schedules are put into effect, they are made applicable only to new Clients, and fee schedules applicable to existing Clients are not affected. Therefore, some Clients may pay different fees than those shown below. Flat Fee Schedule* Program Type All Advisory Programs

Maximum FA Fee Up to 2.00%

Tiered Fee Schedule (Household-Based)* Advisory Household Assets First $500,000 next $500,000 next $1,000,000 next $3,000,000 next $5,000,000 next $15,000,000 over $25,000,000

Maximum FA Fee

Up to 2.00%

* Additional sub-advisory or third-party manager fees may apply and vary by program and strategy. In certain accounts managed pursuant to a strategy of a third-party manager (“Third-Party Manager”), Janney pays a portion of the fee received from Clients to the Third-Party Manager. In the Adviser’s Program, the fees paid to a Third-Party Manager for a Model-Based Strategy generally range from .25% to .45% and the fees paid to a Third-Party Manager in the Manager-Traded Strategy generally range from .15% to 1.00%. Janney will retain a portion of the Client fee when Clients choose to utilize a select Third-Party Manager in the Adviser’s Program that provides tax optimization services. Janney will retain .025% of the Client fee and the Third-Party Manager will receive .075% of the Client fee. The purpose of this fee-splitting arrangement is to offset the costs that Janney incurs for marketing and distribution of the investment strategy on behalf of the Third-Party Manager. Janney also offers its own tax optimization services in the Janney UMA designed to enhance after-tax returns by actively managing the tax impact of investment decisions. Janney’s tax optimization service does not utilize Third-Party Manager management; however, Janney utilizes a third-party technology provider to support portfolio rebalancing and tax optimization processes, while retaining full discretion over the applicable tax-loss harvesting thresholds, drift parameters, and portfolio management rules. Janney will retain .05% of the Client fee for portfolio management designed to enhance after-tax returns by actively managing the tax impact of investment decisions. This presents a conflict of interest as Janney has a financial interest in recommending either the Third-Party Manager’s tax optimization strategy or the Janney UMA tax optimization service to Clients. Janney mitigates this conflict of interest by requiring Janney Financial Advisors to act in accordance with their fiduciary obligations to serve the best interests of the Client and recommend the tax optimization

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investment strategy only when doing so meets the Client’s goals and investment objectives as provided to Janney. In the Janney UMA Program, Janney retains .05% portion of the Client fee to support trade discretion and overlay management services (“the overlay fee”). Janney does not apply an overlay fee in Janney UMA accounts that only maintain a single sleeve ETF, mutual fund, or separate managed account. Fees paid to the Third-Party Manager are applied as a weighted average based on each sleeve’s allocation relative to the total portfolio and generally range from .25% to .45% per investment strategy including Janney that receives between .12% to .22% per investment strategy managed by JCM. Some Third-Party managed investment strategies and model portfolios available in the Janney UMA Program are also available in other wrap fee programs sponsored by Janney, including those managed by JCM (i.e., Advisers Program, Pioneer Program, and Janney Capital Management Direct). Because of the Janney UMA Program unique structure that offers Clients the ability to bundle multiple model portfolios and investment strategies together in one Janney account, the Client could pay more for an investment strategy in the Janney UMA Program than they would otherwise pay for the strategy in one of Janney’s other wrap fee programs. For JCM managed accounts, Janney receives .25% of the total Client fee, except for accounts in the Keystone Discretionary Program and Ladder Fixed Income Strategies accounts under the JCM Direct Program for which Janney receives .15% of the Client fee. Janney receives .10% of the Client fee for accounts in the Short Duration Income Strategy also under the JCM Direct Program. The Janney Client Service Center (“JCSC”) is an internal Janney team of licensed financial professionals that provides administrative services and trade execution for brokerage accounts and offers limited investment advisory services to eligible Clients through Janney’s call center. The JCSC provides advisory Clients with access to a limited number of third-party managed model portfolios available in Janney’s Pioneer Program, as well as financial planning services, ongoing monitoring of advisory accounts and performance reporting. The JCSC assesses an annual fee of 0.95% based upon the market value of the Client’s account as of the last business day of the calendar quarter and billed quarterly in advance. When the Client has entered into a dual contract agreement with a Third-Party Manager in Janney’s Classic Program, the Client maintains a separate agreement with the Third-Party Manager that governs the terms of the services to be provided by the Third-Party Manager as well as the fees to be charged by the manager for such services in addition to the Advisory Agreement they maintain with Janney. The Third-Party Manager fee is not included in the fee schedule above. Janney will not be a party to this agreement. In the Classic Program, Janney will generally deduct and pay the Third-Party Manager’s management fee from the Client’s account for each calendar quarter based on an invoice received from the Third-Party Manager, unless the Client elects to pay the Third-Party Manager directly. Clients in the Classic Program may select to pay commissions on trades to their Janney Financial Advisor instead of an asset-based fee. In certain cases, Clients may be able to negotiate a lower management fee with a Third-Party Manager for certain investment strategies available in the dual contract program. Similar strategies may also be available in a single contract (wrap fee) program; however, the total fees and expenses associated with each program may differ. Clients should be aware that any negotiated fee arrangements are determined between the Client and the Third-Party Manager, and not all Clients will receive the same or similar pricing. As a result, similarly, situated Clients may pay different fees for comparable services or strategies.

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Janney offers investment advisory services to a broad range of individual and institutional Clients including, but not limited to, individuals, families, trusts, estates, corporate and non-corporate entities, retirement plans, pension plans, profit-sharing plans, and government entities. In most cases, Janney requires a minimum initial investment to open a Program account which varies depending on the Program. The following chart sets forth the initial minimum investment by Program.

Program

Minimum Initial Investment

Professional Money Management Adviser’s

$100,000*

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Janney UMA Classic

$50,000* $100,000*

Janney Capital Management Direct

$100,000*

Asset Allocation Keystone ETF Advantage

$25,000 $25,000

Goals-Based Portfolio Solutions (GPS)

$5,000

Pioneer

Varies* Internal Portfolio Management

Partners** Compass Investors Select

$10,000 $25,000 $25,000

*The initial minimum investment amount required for select strategies in the Pioneer, Adviser’s, Janney UMA, Janney Capital Management Direct and Classic Programs may be lower or higher than the Program minimums required by Janney for an account. For example, the minimum investment for a Janney Capital Management Direct account is generally $100,000, with the exception of account(s) in the Short Duration Income strategy which has an investment minimum of $250,000. Janney may waive, in its sole discretion, the initial minimum investment required by Janney for an account. In determining whether to waive an investment minimum, Janney considers the following factors: household asset value, investment vehicles and the anticipation of upcoming contributions and/or necessary withdrawals in the account. A ThirdParty Manager may have a higher minimum investment depending on the strategy selected. Janney UMA accounts must meet the minimums for each sleeve of the account. ** A minimum investment amount of $1,000 will be applied to Advisory 529 savings plans when held in the Partners Program.

Clients are permitted and encouraged to contact their Janney Financial Advisor at any time with questions about their account. If a Client utilizes a Third-Party Manager, the Third-Party Manager may be contacted through the Client’s Janney Financial Advisor, who will make arrangements for a consultation. Under the Classic Program, Clients have contracted separately with the Third-Party Manager and arrange their own contact with the Third-Party Manager.

When a Client selects a Third-Party Manager, Janney provides information about the Client to the ThirdParty Manager to ensure the Client’s investment objectives are addressed. The Client information sent to an unrelated Third-Party Manager includes: (i) the investment advisory contract signed by the Client; (ii) current Client account holdings; and (iii) certain Client information such as name, address, and tax identification number. Janney will update this information with the Third-Party Manager on an as-needed basis. Janney maintains separate agreements with Third-Party Managers recommended under the Manager-Traded Strategies in the Adviser’s Program. These separate agreements require Third-Party Managers maintain confidentiality of Client information.

Janney Wealth Management Research is responsible for the initial research & due diligence as well as the ongoing monitoring of all model-based and manager traded strategies at Janney. All Separately Managed Accounts (“SMAs”) and Unified Managed Account (“UMA”) strategies available at Janney are actively monitored either internally by WM Research or by an independent third-party vendor. Single contract SMA and UMA strategies are monitored by both WM Research and the third-party vendor, while dual contract managers are only monitored by WM Research. All SMA and UMA strategies undergo an initial and ongoing due diligence process. Janney’s affiliated asset manager, Janney Capital Management, undergoes formal reviews by the independent third-party vendor on an ad hoc basis.

Strategy Identification SMA and UMA strategies are identified through a number of different sources, including third-party investment analysis databases, client recommendations, trade journals, industry conferences, as well as

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personal and professional networks. All SMA strategies available on the Janney platform are labeled as either Recommended or Approved. Recommended strategies are backed by WM Research’s highest conviction and are published on the Outsourced Solutions Guide. The starting universe for investment strategies considered for inclusion on the Outsourced Solutions Guide is the Morningstar Direct database. Approved strategies have met basic due diligence standards. All single contract SMA/UMA strategies receive the same treatment from an ongoing due diligence perspective and are reviewed at least quarterly. Dual contract SMA managers on Janney’s Classic Platform also must undergo an initial review and are required to meet basic due diligence standards and are reviewed annually.

Initial Criteria An initial review of an investment strategy includes, but is not limited to, the following criteria, which is intended to represent the most basic due diligence requirements*. • Minimum of $100 million in firm assets under management • Minimum of 3 investment professionals at the firm • Minimum of a 3-year track record illustrating the investment manager’s ability to manage a portfolio in the same or similar fashion as the product under consideration • Consistency of style, philosophy, process, and risk-adjusted returns • Reasonable fee structures • Verifiable, reputable service providers *These criteria will serve as a guide and may vary depending on the reviewed strategy.

Initial Evaluation WM Research reviews the performance of a strategy with the goal of understanding how it is likely to behave throughout different points in the market cycle as evidenced by historical data. This involves close examination of both absolute and relative returns versus the style benchmark and peer returns, taking long-term performance into account but emphasizing the 3- and 5-year rolling time frames. Riskadjusted performance is crucial in this evaluation. The use of various risk-adjusted measures allows the team to study the returns of recommended managers relative to the various layers of risk investment to which portfolios are subjected. Some of these risk metrics include, but are not limited to, systematic risk (beta), absolute volatility (standard deviation), downside volatility (downside deviation) and active risk (tracking error). On a qualitative basis, WM Research reviews the following key areas of a strategy: Firm Characteristics: • The firm's size, assets under management, years in business, infrastructure, ownership, and service capabilities. • Whether the firm has a business plan which outlines its strategic direction, including future growth and succession plans. • If management incentives are in line with investors objectives. • The policies and procedures the firm has in place to address and limit the impact of conflicts of interest. Management personnel:

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• • • •

The professional background, education, tenure, and experience of personnel making the investment decisions, as well as other departments within the firm such as Compliance, Operations, and Trading. Whether the investment professionals are transparent and accessible. Whether the compensation of the investment professionals align with the interests of investors. If the structure and geography of the team members promote effective communication and idea sharing.

Philosophy & Process: • Presence of an explainable, understandable philosophy that states the manager's longterm investment goals. • If and how the manager intends to add value. • Whether there is a clearly defined market inefficiency the manager seeks to exploit and if there is a repeatable investment process in place. • If the investment manager’s process has a strong buy/sell discipline to support the philosophy and if the manager has adhered to this discipline over time. • Whether the manager's philosophy has proven successful through performance and risk metrics. Progress: • How the strategy/product has evolved over time. • What changes, if any, the team has made to the philosophy and process in response to evolving market conditions and the lessons learned. Positioning: • Where the product fits within the firm's offerings and the amount of attention and resources is it likely to garnish. • How the strategy compares to its peers and the value that it could bring to the existing product lineup on the Janney platform. • How the strategy complements existing recommended strategies.

On-going Research On a recurring basis, but no less than quarterly, WM Research, in conjunction with a third-party investment consultant, assesses the qualitative characteristics referenced above and conducts a quantitative performance review to ensure the timely delivery of information to Janney’s existing or potential investors. Formal updates on Recommended or Approved strategies will be published when performance falls out of line with expectations or when there has been a meaningful change in process, investment team or firm that can reasonably be expected to impact performance in the future. Dual contract SMA managers on Janney’s Classic Platform are required to complete an annual due diligence questionnaire and are viewed by WM Research on an annual basis.

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JCM Methods of Analysis and Investment Strategies JCM’s approach to security analysis is based primarily on fundamental research. This approach entails conducting an examination of the operating, financial and industry conditions affecting each company whose security is under consideration, all from a long-term perspective. On a recurring basis, the Investment Committee, comprised of the firm’s investment personnel, meets to evaluate global and domestic macroeconomic trends and the opportunities they present, and to identify asset allocation, asset class and sector weightings, strategic and tactical portfolio strategies and security selection. Investment monitoring, rebalancing, and portfolio management are an ongoing focus of the Investment Committee. The Investment Committee also strives to incorporate economic analysis into its overall views of the markets in general, to employ certain relative valuation disciplines and to utilize technical analysis as part of the overall process. JCM’s investment professionals take into account factors such as current yield, price attractiveness, earnings and dividend growth potential, and economic, political and sociological factors, as applicable. In portfolio construction, the investment managers seek a prudent level of diversification to reduce risk. While any or all sources of information may be used, JCM’s principal sources of information are: (i) issuerprepared information (annual reports, proxy materials, press releases, etc.); (ii) SEC filings; (iii) management interviews and contacts; (iv) industry trade association statistics; (v) government data; and (vi) financial publications. Additional research materials are obtained from equity research departments of other financial institutions and independent research services. JCM’s investment approach to ESG portfolio management focuses on identifying the leading ESG rated companies and then applying fundamental research analysis to enhance performance and manage investment risks. Security selection begins by utilizing a quantitative screening process that first groups the universe of eligible securities into economic sectors and then each individual stock is ranked by a thirdparty composite ESG score. Since JCM focuses on the overall composite score, ESG factor weights are not considered although in general, composite level scores tend to be weighted equally across the environmental, social, and governance segments. The highest-ranking securities then undergo a fundamental analysis for potential inclusion in the strategy. Fundamental analysis focuses on overall attractiveness of the company’s industry, competitive position, financials, leverage, growth outlook and valuation amongst other considerations. Portfolio construction is also considered in the selection process which will include but is not limited to, beta comparisons, end market exposures of existing holdings, and quantitative risk characteristics. At the time of purchase, a new position to the strategy will typically have a composite ESG score in the highest quartile of the company’s relevant sector, however, the highest absolute ESG rated company may not always be selected if fundamental research and portfolio construction considerations identify a more attractive option. Additionally, JCM employs a negative screening process that excludes from the strategy companies that derive a significant portion of their revenues through Tobacco, Alcohol or Firearms businesses. Portfolio holdings are monitored at least quarterly to identify changes in overall ESG composite ranks for individual securities as well as overall portfolio rank vs the benchmark and fundamental merit. Securities that experience a decline in ESG rating below the average for a specific sector will generally be replaced by a higher-ranking alternative. However, because the portfolio may continue to own below average rated ESG composite ranked securities, a high level of consideration is also given to fundamental and portfolio construction merits. JCM uses the ACWI benchmark to compare against the Global Sustainability Strategy.

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Client accounts are managed independently of one another, and JCM is under no obligation or requirement to buy or sell the same investments for all or some of the accounts, even when the investment strategy may be similar. JCM’s investment strategies involve certain risks. There can be no assurance that any particular strategy will be successful in achieving the client’s investment goals and objectives. Neither JCM, nor Janney, guarantees the future performance of a client’s account or any specific level of performance.

Mutual Fund Product Due Diligence All mutual funds available for sale on the Janney platform undergo an initial due diligence process to ensure that they meet certain criteria set forth by Janney. The Wealth Management Department utilizes a third-party vendor to perform the initial due diligence while Janney provides ongoing due diligence on a semi-annual basis once a fund is added to the Janney platform. Janney may vary the initial criteria depending on certain factors of the mutual fund however, it typically includes, but is not limited to, length of active management, amount of assets under management and also incorporates independent thirdparty product analysis. Funds that fail to meet the due diligence standards are moved to a liquidation only status and will be closed to new investments until they meet the due diligence standards during a subsequent semi-annual review. Although new purchases are not permitted in mutual funds that fail to meet the aforementioned criteria, it’s important to note that Janney does not force liquidation of existing positions and continues to accept incoming transfers of these funds.

Exchange Traded Products Due Diligence All ETFs available on the Janney platform must first meet several initial requirements, including but not limited to, length of performance history and a minimum value of AUM. All ETFs on the Janney platform are surveyed daily and are restricted from new purchases if they fall below the minimum required thresholds. Restrictions may be lifted daily if the ETF achieves the minimum requirements. No new purchases will be allowed in ETFs that fail to meet Janney’s due diligence standards; however, Janney does not force liquidations of existing positions and incoming transfers of these funds will be accepted.

Closed End Fund Due Diligence All closed-ended funds available on the Janney platform must meet initial minimum requirements as well as semi-annual due diligence requirements to remain active on the platform. Closed-end funds evaluated by Morningstar must achieve a 1-star Morningstar rating and an expense ratio of 2.0% or less in order to meet Janney’s minimum criteria. For funds not covered by Morningstar, Janney requires $100 million in AUM and an expense ratio less than 2.0% in order to remain available for new purchases on the Janney platform. As with ETFs, no new purchases will be allowed in closed-end funds that fail to meet Janney’s due diligence standards, but Janney does not force liquidations of existing positions and incoming transfers of these funds will be accepted.

Alternative Investment Due Diligence Due to the differences in product structure and corresponding legal implications, alternative investment products often require a more stringent gathering of product and firm documentation to be permitted for sale, when compared to mutual fund or managed account products. In addition to the evaluations conducted by WM Research, Janney utilizes an independent third-party consultant to assist in the

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Other Financial Industry Activities and Affiliations Janney is registered with the SEC as a broker-dealer, a municipal adviser under the Exchange Act and as an investment adviser under the Advisers Act. Janney Financial Advisors are registered as both registered representatives for brokerage related services and investment advisory representatives for investment advisory related services. Janney may provide advice and take action as performing the actions of an

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investment advisor with accounts in various investment advisory services/programs. Janney also may not be free to divulge or act upon certain information in our possession on behalf of other Clients. Under certain Advisory Programs, Janney may buy or sell securities of issuers that may also be brokerage clients. Any decisions to buy or sell such securities are made independent of any other relationship with Janney and Janney Financial Advisors do not participate in other services provided to such Clients. Additionally, many Third-Party Managers recommended by Janney are also Clients of Janney in its capacity as a brokerdealer.

Investment by the KKR Stockholder The KKR Stockholder acquired all of the issued and outstanding limited liability company interests of Janney in November 2024. The KKR Stockholder, which is indirectly controlled by investment funds, vehicles and/or accounts advised and managed by Kohlberg Kravis Roberts & Co. L.P. (“KKR”), holds its equity stake in Janney for investment purposes. Janney is not a direct or indirect subsidiary of KKR & Co. Inc. or of KKR. KKR is an affiliate of KKR Capital Markets LLC and MCS Capital Markets LLC, each of which is registered as a broker-dealer in the U.S. with the SEC and FINRA and is also affiliated with certain nonUS entities authorized to conduct broker-dealer activities. KKR does not participate in or manage the dayto-day management or operations of Janney. Janney acts autonomously and separately from KKR. KKR sponsors and manages investment funds that invest in private equity, credit, and real assets and has strategic partners that manage hedge funds. KKR also sponsors and manages investment funds and other vehicles that facilitate co-investment alongside proprietary investments or in specific or multiple portfolio companies and other assets invested in by investment funds managed by KKR. Janney Financial Advisors are able to recommend that eligible Janney clients invest in alternative investments, including investment funds advised and managed by KKR, including funds in which Janney Financial Advisors and employees are investors and have a financial interest. Janney and Janney Financial Advisors receive fees based on investment recommendations and management of client accounts. KKR and Janney are able to recommend investments in companies and products (which may be in the same or different levels of the capital structure) and recommend investments or take actions (or omit to take actions) that are inconsistent with or contrary to the interests of one another. Janney clients may make investments in companies and products in which KKR has also invested (and such investments by KKR may be in the same or different levels of the capital structure), and in connection with such investments, KKR may take actions (or omit to take actions) that are inconsistent with or contrary to (otherwise conflict with) Janney clients’ interests. Janney and Janney Financial Advisors stand to benefit from making investment recommendations to clients and customers that will result in financial benefits to Janney and Janney Financial Advisors as investors in KKR sponsored funds. Because certain Janney Financial Advisors have a financial interest in KKR-sponsored funds that invest in Janney, they benefit from Janney’s financial performance. Janney Financial Advisors and JCSC financial professionals also participate in an employee ownership plan in which they benefit from Janney’s financial performance. This results in a conflict of interest as Janney Advisors and JCSC financial professionals have a financial incentive to make recommendations that result in the accumulation of client assets in advisory accounts to generate greater fees and therefore greater returns for Janney. Janney mitigates this conflict of interest by requiring Janney Financial Advisors and JCSC financial professionals to act in accordance with their fiduciary obligations to serve the best interests of Clients and make account type recommendations based on the Client’s goals and investment objectives as provided to Janney. KKR’s affiliates that earn certain fees (i.e., management fees, incentive fees) in

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connection with investments in KKR sponsored funds benefit from Janney client investments in such funds. KKR owns Global Atlantic Distributors, LLC and Global Atlantic Investment Advisors, LLC, (collectively “Global Atlantic”), which are the affiliated broker-dealer and investment adviser of Forethought Life Insurance Company (“Forethought”). Forethought is a wholly owned subsidiary of KKR and operates as a standalone insurance company. Janney Financial Advisors can recommend Forethought’s insurance investments to you, which creates a conflict of interest. Because Janney is owned by KKR Stockholder, Janney has an incentive to recommend its investments based on this ownership structure. To mitigate this conflict, Janney does not specifically promote the sales of Forethought, or any other KKR affiliated insurance products, over non-KKR affiliated insurance products. Neither Janney, nor its Financial Advisors, receive any special or additional compensation for recommending Forethought investment products over those issued by non-affiliated companies. Janney seeks to mitigate these conflicts through operational independence from KKR and through its policies and procedures reasonably designed so to ensure that recommendations are made in the best interest of Janney’s clients and are consistent with Janney’s and Janney Financial Advisors’ duty to act in the best interest of clients.

Other Affiliations Janney is a licensed insurance agency and certain Janney Financial Advisors are also licensed insurance agents. In this role, Janney offers insurance products to its Clients. In addition, as it relates to the financial planning services described above, Janney also provides advice from time to time with respect to insurance matters. Janney’s subsidiary, Janney Trust Co Inc., is a non-depository trust company which acts as a custodian for assets maintained in IRAs, Coverdell Education Savings Accounts and a small number of Qualified Retirement Plan accounts. Janney acts as sub-custodian for these assets. Janney Trust Co Inc. is a New Hampshire-chartered trust company and wholly-owned subsidiary of Janney.

Disciplinary Information Details of Janney’s disciplinary information, along with it’s affiliate, Global Atlantic, are described in more detail in Part 1 of its Form ADV, available on the SEC’s website at www.adviserinfo.sec.gov. Consistent with the requirements of Form ADV Part 2A, please find information regarding the following disciplinary matters. On May 6, 2009, Janney entered into an Acceptance, Waiver and Consent agreement (“AWC”) with FINRA. Without admitting or denying any findings by FINRA, the firm agreed to a $200,000 monetary sanction with respect to certain Client transactions involving auction rate securities (“ARS”). The firm currently does not purchase ARS for Client accounts and has taken steps beyond those required by regulators to ensure that Clients were not harmed by the developments negatively impacting the ARS marketplace. On November 3, 2010, Janney entered into an AWC with FINRA. Without admitting or denying any findings by FINRA, the firm agreed to a $175,000 monetary sanction with respect to its failure to establish certain elements of an adequate anti-money laundering program, failure to follow procedures designed to prevent a supervisor or their subordinate from approving the supervisor’s activities, failure to approve

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and maintain records of certain marketing and media activities, failure to document the review of certain discretionary option activity, and the failure to maintain certain records. On July 12, 2011, Janney entered into an AWC with FINRA. Without admitting or denying any findings by FINRA, the firm agreed to a $850,000 monetary sanction with respect to its failure to establish, maintain and enforce policies and procedures reasonably designed, taking into consideration the nature of its business, to prevent the misuse of material nonpublic information pursuant to Section 15(G) of the Exchange Act. In 2013, Global Atlantic Distributors, LLC (“GAD”), not Janney, entered into a AWC with FINRA, without admitting or denying FINRA’s findings that a brochure, prepared by a third-party but approved by a GAD affiliate, contained unwarranted and misleading statements in respect of conditions in the bank loan market and that GAD failed to establish and maintain supervisory procedures reasonably designed to ensure compliance with FINRA rules. Since 2013, GAD no longer distributes mutual funds and no longer is affiliated with the firm that approved the brochure for distribution. In 2014, GAD, not Janney, entered into an AWC, without admitting or denying FINRA’s findings that GAD failed to retain all business-related electronic communications. Specifically, on January 1, 2013, GAD began using a new outside vendor for its email retention system. On three separate occasions, in February, September, and November 2013, GAD discovered that, as a result of inadvertent gaps in internal processes, GAD had not properly set up a total of approximately 28 individual email accounts to journal automatically to the email retention system. In February 2013, after discovering 11 email accounts affected by the issue, the Firm took steps to correct and prevent its recurrence. However, in September 2013, after receiving a request from FINRA for email concerning a registered representative, the Firm discovered that the issue had reoccurred with respect to certain additional email accounts and reported the issue to FINRA in October 2013. In May 2015, the firm self-reported that some eligible customers had not received available sales charge waivers. As a result, the firm estimates that eligible customers were overcharged by approximately $1,030,235 for mutual fund purchases made between July 1, 2009 and June 24, 2015. As part of this settlement, the firm agrees to pay restitution plus interest. On June 29, 2015, without admitting or denying the SEC’s findings, KKR, not Janney, consented to the entry of an order to cease and desist from committing or causing any violations and future violations of sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. According to the SEC order, during the period from 2006 to 2011 KKR did not expressly disclose in its flagship private equity fund limited partnership agreements that it did not allocate broken deal expenses to KKR co-investment vehicles (including co- investment vehicles established for third party co-investors and co-investment vehicles established for executives, certain consultants and others) and this lack of disclosure resulted in a misallocation of expenses to KKR’s flagship private equity funds for that period. The order also finds that KKR did not adopt and implement a written compliance policy or procedure governing its fund expense allocation practices until 2011. On February 2, 2016, Janney consented to the entry of an SEC order. Without admitting or denying any findings, the firm agreed to a $500,000 monetary sanction with respect to the firm’s self-reporting of antifraud provision violations and inadequate due diligence in connection with the underwriting of certain municipal securities offerings pursuant to Section 15(C)2-12 of the Exchange Act.

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