JENNISON ASSOCIATES LLC

Ou r Firm Jennison Associates LLC (Jennison) is an SEC-registered investment adviser organized as a Delaware limited liability company. When we use the terms “we,” “us” and “our” in this brochure, we are referring to Jennison. In 1969, we (through a predecessor company) registered with the SEC and began managing taxexempt U.S. large cap growth equity accounts, primarily for large institutions. We were acquired by The Prudential Insurance Company of America (PICA) in 1985, and we started to subadvise mutual funds in 1990. Through the years, we have expanded the types of investment strategies that we offer. Today, we manage equity, fixed income, and custom solutions portfolios in a range of styles, geographies and market capitalizations. We are an indirect wholly owned subsidiary of Prudential Financial, Inc. (Prudential Financial), a publicly held company (NYSE: PRU) which is incorporated in the United States. None of Prudential Financial or any of its affiliates referenced herein is affiliated in any manner with Prudential plc, incorporated in the United Kingdom or with Prudential Assurance Company, a subsidiary of M&G plc, incorporated in the United Kingdom. Ou r A d vis ory B u s in es s in Gen eral Our firm offers select capabilities in the following investment disciplines: Growth Equity, Small, SMid and Mid Cap Equity, Global Equity (which includes International, Emerging Markets Equity, International and Global SMid), Value Equity (which includes Income Equity), and Fixed Income. Additionally, we offer Custom Solutions, Combination Strategies (i.e., blended capabilities) and Sector Strategies. Our expertise is managing portfolios based on internal fundamental research, bottom-up security selection and a highly interactive investment process. Jennison’s manages its equity strategies from our New York headquarters and our fixed income portfolio management activities are managed from our Boston office. For additional information about our strategies, please see Item 8. Sep arate A c c ou n t A d vis ory Servic es Jennison provides investment management services to separate account clients on a discretionary basis pursuant to written agreements. We work with our separate account clients to devise mutually acceptable investment guidelines to accommodate the individual needs of our clients and to confirm that we can manage the account consistently with our investment philosophy. Examples of clientimposed restrictions include the prohibition of certain issuers or certain types of instruments (such as derivatives), the imposition of limits on the portfolio’s exposure to a single issuer or type of issuer, sector, industry or type of instrument, percent limitations on foreign securities, or customized exclusions based upon a client’s own values and objectives, including ESG objectives. (Please see Item 16 for more information regarding limitations on our investment discretion imposed by our clients and Item 8 for more information regarding our approach to ESG investing).

A d vis ory Servic es to Collec tively Man aged V eh ic les We provide subadvisory services to collectively managed funds sponsored by our affiliates and third parties. These funds, are registered in the U.S. or in non-U.S. jurisdictions or are exempt from registration and/or offered privately. These funds include, but are not limited to, U.S. mutual funds, exchange traded funds (ETFs), Undertakings for the Collective Investment in Transferable Securities (UCITS), Alternative Investment Funds (AIF)s, bank collective investment trusts, Cayman Islands unit trusts, Canadian unit trusts, commingled insurance separate accounts, and private investment funds. Additionally, we provide discretionary investment management services to private investment funds that we sponsor. Information about these funds, including a description of the services provided and advisory fees and other expenses, is generally contained in each fund’s prospectus, offering memorandum, declaration of trust, subscription agreement and other offering materials as applicable (collectively such materials are referred to as “Offering Documents”). Investors in these vehicles should refer to each fund’s Offering Documents for additional information. We enter into investment management agreements and subadvisory agreements for our services to collectively managed vehicles that govern the terms and conditions of our services to such vehicles. Investment advice for such vehicles is subject to applicable regulatory limitations and investment guidelines or limitations that are contained in the relevant Offering Documents or other guidelines or limitations agreed with the fund’s advisor or shareholder (in the case of funds of one). We refer to the services provided to separate accounts and collectively managed vehicles in this brochure as non-wrap account services. A d vis ory Servic es in Wrap an d U MA Programs Jennison also provides its discretionary investment services to separately manage account programs (“SMA Programs”), which includes programs sometimes referred to as “wrap fee programs,” sponsored by unaffiliated or affiliated banks, broker-dealers and other investment advisors (collectively, “SMA Program Sponsors”). In addition, Jennison provides investment advice to overlay managers (“UMA Program Sponsors”) through model investment portfolios or unified managed account programs (“UMA Portfolio Programs”). Jennison participation in SMA Programs and UMA Portfolio Programs is collectively referred to herein as the “Jennison Managed Accounts” or “JMA”. Participants in managed account programs are referred to herein as “participants”. There are several key differences between a UMA Portfolio Program and a SMA Program. In a UMA Portfolio Program, the UMA Program Sponsor generally determines which security suggestions provided by Jennison will be executed for the participant. However, in a SMA Program, Jennison (not the SMA Program Sponsor) directs what securities transactions will be executed on behalf of the SMA Program participant. Additionally, Jennison allows SMA Program participants to restrict investments in certain types of securities. The most common restrictions that we accept from SMA Programs are those prohibiting the purchase of securities of particular issuers, such as restrictions on securities issued by the sponsor or its affiliates, or companies that receive revenue from certain types of products or activities specified

by the client. Jennison is not aware of, nor does it control, any restrictions permitted or implemented by a UMA Program sponsor. When Jennison provides investment advisory services to SMA Programs, we typically receive a portion of the fee charged to SMA Program participants by the SMA Program Sponsor though in some cases Jennison also receives a fee from the participant directly and the sponsor (known as “dual contract”). Similarly, when Jennison provides investment advisory services to a UMA Portfolio Program, we receive a portion of the fees charged by the UMA Program sponsor to UMA Program participants. Fee terms and refund policies depend on the sponsor. Jennison advises under these programs but does not assess client suitability—this is the responsibility of the sponsor or advisor. Most Jennison interactions are with sponsors or advisors, rather than individual investors. If this document reaches parties without an advisory relationship with Jennison or where not legally required, it serves informational purposes only. Similar services could be available at lower cost if unbundled and individually negotiated. Clients should review program materials for fees, services, and account requirements. JMA portfolios are distinct from our other portfolios: they use ADRs instead of foreign shares and do not participate in IPOs or follow-on offerings. We manage JMA portfolios subject to limits on position sizes, weighting changes, and the number of securities, which do not apply to non JMA portfolios. Differences in portfolio construction and management mean performance can vary between JMA and non-JMA accounts. For additional information regarding the strategies available within our SMA Programs and UMA Portfolio Programs, please refer to Item 8. For details pertaining to trading practices and model delivery, see Item 12. Non - d is c retion ary A d vis ory Servic es (“Mod el Portfolios ”) We also provide non-discretionary advice in the form of model portfolios to some financial intermediaries, including affiliates that do not sponsor wrap fee accounts, dual contracts or UMA platforms. These financial intermediaries use our model portfolios to manage accounts for their clients and retain discretion to implement, reject or adjust the recommendations in our model portfolios. We do not effect or arrange transactions for non-discretionary model portfolios. In our investment advisory agreements for Model Portfolios we provide limited customization. The typical restrictions that we accept for a Model Portfolio are to prohibit a specific issuer or a specific type of investment (for example, non-U.S. securities). A s s ets U n d er Man agemen t As of December 31, 2025, our:

Discretionary assets under management (rounded to the nearest $100,000) were: $213,926,800,000^

Non-discretionary assets under advisement (rounded to the nearest $100,000) were: $14,513,600,000*

^This number does not include outstanding indebtedness or other accrued but unpaid liabilities that are required to be included in regulatory assets under management in Part 1A, Item 5.F of the Form ADV. *This number includes the assets that are managed by others using our non-discretionary model portfolios. We do not include assets managed by other persons based on non-discretionary model portfolios provided by us in the calculation of our regulatory assets under management in Part 1A, Item 5.F of the Form ADV.

A d vis ory Fees Fees for Sep arate A c c ou n t A d vis ory Servic es We negotiate fees with some of our clients, which could result in unique arrangements. Fees paid by clients vary based on the investment strategy, asset class, type of service provided (discretionary vs. nondiscretionary) and other factors such as the size of the client account, the assets under management aggregated across the client’s relationship with us, whether the client is an affiliate or has a relationship with one of our affiliates, whether an investment consultant or OCIO (defined below in Item 7) is utilized by the client, the nature of the overall fee structure (i.e., asset-based fee or performance-based fee), the required level of client service and potential growth of the relationship. Fees can also differ based on account type. For example, fees for commingled vehicles, including those that we subadvise, differ from fees for single client accounts. Since we negotiate fees with some clients, clients with similar investment objectives or strategies pay different fees. We offer both asset-based and performance-based fee arrangements for our discretionary investment management services. For non-discretionary advisory services, we typically offer asset-based fee arrangements. Our asset-based fees are customarily offered in tiered schedules with breakpoints linked to the amount of assets in the account, so that the fee rate decreases as the assets increase. In circumstances where a single client has multiple accounts managed by us under the same fee schedule, we have, in certain circumstances and at our discretion, agreed with the client to aggregate the client’s assets across accounts to enable the client to benefit from a lower fee tier. We charge a performance-based fee, i.e., a fee based on the investment performance of an account, for certain product offerings and where such fee arrangements are acceptable to the client, provided that such arrangements are permitted under applicable law and regulations. Our performance-based fees are typically individually negotiated and generally based on the capital appreciation in an account relative to an index or absolute performance over a period of time. Our performance-based fees typically include an asset-based management fee component, which is either flat or includes breakpoints linked to the amount of assets in the account and which we collect regardless of the performance of an account. (Please see our discussion in Item 6 for more information about our performance-based fees.) Fee schedules for our institutional clients are available upon request. Fees for Fu n d V eh ic les We subadvise collectively managed vehicles sponsored by our affiliates and third parties such as U.S. and non-U.S. mutual funds, collective investment trusts, and U.S. and non-U.S. privately offered vehicles. We also sponsor a privately offered hedge fund. Our fees for our services to these vehicles consider the factors that we consider for separate account advisory services described above as well as the vehicle’s structure and other relevant factors. We offer both asset-based fees and performancebased fees to our fund vehicle clients. Information about fees charged to investors in these vehicles is described in each fund’s Offering Documents. Investors in fund vehicles are encouraged to review their fund’s Offering Documents for additional information.

Wrap Fee an d U MA Program Fees Typically, a managed account sponsor client pays the sponsor a single asset-based fee for brokerage, custody, advisory services, performance modeling and reporting, and we are paid by the sponsor for our services. For additional information about the fees, please review the sponsor’s brochure for the wrap program. We negotiate the fee for our services to wrap and UMA programs with the sponsor of the programs (this includes dual contract relationships). The fees negotiated with the sponsor for our advisory service to such programs vary and depend on such factors as the asset class, market capitalization of the strategy, assets under management and discretionary versus non-discretionary services. Dual contract clients typically pay asset-based fees that have been negotiated with the sponsors of the dual contract programs based on the fee schedules below. Large Cap Growth Eq u ity 0.75% on the first $10 million of assets managed; 0.50% on the next $30 million; 0.35% on the next $25 million; 0.25% on the next $335 million; 0.22% on the balance. Large Cap V alu e Eq u ity 0.30% on the first $100 million of assets managed; 0.25% on the next $100 million; 0.230% on the balance. Large Cap B len d Eq u ity 0.60% on the first $50 million of assets managed; 0.50% on the next $200 million; 0.45% on the balance. Glob al Eq u ity Op p ortu n ities 0.75% on the first $25 million of assets managed; 0.60% on the next $75 million; 0.50% on the balance. Comp en s ation for Servic es to A ffiliates We provide services to our affiliates for a variety of financial products such as single client and commingled insurance separate accounts, portfolios for synthetic and separate account guaranteed investment contracts, collective investment trust funds, non-U.S. (e.g., UCITS) and U.S. mutual funds that are available to both retail and institutional clients and mutual funds that are available through variable life and variable annuity products. Typically, the insurance separate accounts are investment options of various insurance products offered by PICA, such as guaranteed investment contracts, corporate or trust owned life insurance, or group annuity contracts. Our compensation for the services

that we provide to our affiliates is sometimes less than the amount that we would receive from unaffiliated clients. Calc u lation an d Paymen t of Fees Fees for separately managed accounts are typically based on the valuation of assets, including cash and cash equivalents, provided by the client’s custodian. For such clients, Jennison, on a monthly basis, performs a reconciliation between the prior month end market values on the records maintained by Jennison and the custodian. Differences (up or down) in excess of a materiality threshold determined by us are researched and escalated to the custodian. If the custodian acknowledges the error in the market value, Jennison requests the custodian to correct its records. In many cases, the custodian corrects the current month’s market value instead of the month in which the discrepancy occurred. If the custodian follows this approach, Jennison will manually correct the prior month end market value and will use the Jennison corrected market value for billing purposes. We either bill a client for our fees or deduct fees from the client’s account held at its custodian in accordance with the client’s contractual arrangements. Asset-based fees are typically payable either monthly or quarterly in arrears. Clients can also elect to have their fees calculated based upon the market values calculated by their custodian or by us. Performance-based fees, if earned, are payable after the calculation period for such fees. Unless otherwise agreed with the client, we prorate contributions and withdrawals, including income withdrawals, in calculating the fee for the period; however, we do not prorate for de minimis contributions and withdrawals such as advisory fees, custodial fees and dividends or other interest activity. We also prorate fees for accounts initiated or terminated during a billing period. For participants in JMA portfolios, the sponsor usually pays us based on the assets invested in our strategies. For dual contract clients, we typically bill the SMA Program sponsor. Some dual contract clients are required to pay our fees in advance in accordance with their investment advisory agreement. For all other clients, we do not require clients to pay our fees in advance. If a client were to pay advisory fees in advance and the client’s advisory contract terminates before the end of a billing period, any prepaid fees would be refunded on a pro rata basis, covering the remainder of that billing period. Con flic ts R elated to V alu ation an d Fees When client accounts hold illiquid or difficult-to-value investments, we face a conflict of interest when making recommendations regarding the value of such investments since our management fees are generally based on the value of assets under management. We believe that our valuation policies and procedures mitigate this conflict effectively and enable us to value client assets fairly and in a manner that is consistent with the client’s best interests. Oth er A mou n ts Payab le b y Clien ts Clients are responsible for other fees and expenses related to their accounts. These expenses can include charges imposed by custodians, brokers, third-party investment managers and other third

parties, such as fees charged by such managers related to portfolio investments (e.g., ETFs or BDCs), custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, commissions, commission equivalents, spreads on investment transactions and other fees and taxes on brokerage accounts and securities transactions. For example, for certain portfolios we invest in exchange traded funds (ETFs) and business development companies (BDCs) which charge internal management fees, and which are disclosed in the investment’s prospectus. Some cash sweep vehicles also charge internal management fees or other fees. Investors in managed fund vehicles subadvised or sponsored by us, our affiliates or third parties generally pay all fees and expenses applicable to investors in the managed fund vehicle, which typically include management fees (including performance-based fees, if applicable), custodial, accounting, transfer agency, portfolio investment transaction, administration, legal and audit fees. Investors should consult their fund’s Offering Documents for additional information. Certain U.S. and non-U.S. trading and currency markets impose additional charges and penalties for trade and currency settlement failures that will result in additional transaction costs to Jennison clients. We seek to address these in accordance with market practice and other considerations that we deem reasonable and appropriate. For example, in an effort to reduce the overall incidence of fails in the U.S. government securities marketplace, any market participant that fails to deliver U.S. Treasury, agency debt or agency mortgage-backed securities on settlement date is assessed a “fails charge” to compensate the “non-failing” counterparty. This “fails charge” will be assessed against a client’s account even if the failure to deliver such a government security that was sold from the client’s account was caused by a different counterparty that failed to deliver or failed to timely deliver it in connection with a preceding purchase for the client’s account. Likewise, pursuant to the EU’s Central Securities Depositary Regulation effective February 2022, EU/EEA central securities depositaries impose charges for late or failed settlements of any instrument that is cleared through an EU central clearing house or is settled by an EU trading venue or an EU/EAA central securities depository. Some clients, for any number of reasons, are unable to or will not allow their accounts to pay the charges assessed against their accounts. Jennison evaluates each client’s circumstances and will make a determination on a case-by-case basis to pay such charges on behalf of a client account. Such penalties, charges, fees and commissions are exclusive of and in addition to our investment management fee, and we do not receive any portion of these penalties, charges, commissions, fees, and costs. Oth er Comp en s ation We do not receive other compensation related to the sale of securities or other investment products that we manage, such as mutual funds, UCITS, collective bank trusts, private funds or other investment vehicles. Our supervised persons do not receive compensation directly related to the sale of securities or other investment products, but the sale of our advisory services or interests in funds we manage is considered in the determination of the compensation of our sales personnel. Any such compensation would be payable by us and not our clients or investors.

Ou r Meth od s of A n alys is Each of the strategies that we offer is primarily based on our fundamental research and investment processes. Some of our strategies use quantitative methods and investment processes in addition to our fundamental research to manage portfolios. Ou r Fu n d amen tal Eq u ity R es earc h an d I n ves tmen t Proc es s es We believe that internal fundamental research, bottom-up stock selection, and a highly interactive investment process are integral to seeking superior investment performance. Investment ideas are generated through the bottom-up fundamental research of our experienced research teams. Our analysts are expected to be well versed in the sectors they cover, have comprehensively informed perspectives and seek to identify the most attractive opportunities within their areas of expertise. Our investment professionals have built strong industry and market sector networks which provide access to top company management. We routinely and frequently interact with companies, key sector competitors, and suppliers globally. Our core belief is that a deeply researched understanding of company and industry fundamentals can lead to successful stock selection. We believe that careful scrutiny of financial statements provides the foundation for building a fundamental outlook and earnings model. We further develop our views of a company and its industry in meetings with customers, suppliers, and competitors. We meet with senior company management to test assumptions. We believe our process elevates the investment debate by engaging all portfolio managers within a strategy in decision making, with our analyses, deliberations, and decisions reflecting the expertise of each participant. We believe our process ensures that this “best thinking” of all investment professionals is reflected in all client portfolios, thus producing a Jennison product. Ou r Cu s tom Solu tion s R es earc h an d I n ves tmen t Proc es s es We use quantitative insights and solutions to create and manage our customized equity portfolios and quantitatively hedged portfolios. In general, our fundamental research process serves as the foundation for our customized portfolios. We typically base our customized portfolios on existing strategies that rely on our fundamental research and apply quantitative methods to manage sector and other portfolio characteristics to client-specified risk/return objectives and investment guidelines or restrictions. Our quantitative approach is designed to provide additional insights and complement our fundamental research process in order to optimize portfolio construction. For our quantitatively hedged portfolios, we use quantitative tools to manage the short holdings of the portfolio. Generally, our customized portfolios do not participate in securities offerings (e.g., IPOs and follow-on offerings). Ou r Fixed I n c ome R es earc h an d I n ves tmen t Proc es s es The objective of our fixed income strategies is to provide the desired alpha over a full market cycle without taking excessive fundamental risk. We are focused on investment grade fixed income

securities. We believe that investment values, yield spreads, and yield curve shapes will revert to the mean (average) over time. We build our investment portfolios from the bottom-up and make decisions based on our views of the attractiveness of individual securities. The foundation of our investment process is our fundamental credit analysis and the quantitative analysis of individual securities. We look for sources of alpha from a combination of security selection, yield curve management, sector rotation, and active trading. We primarily purchase investment-grade securities, particularly the investment-grade market sectors such as Treasuries, agencies, mortgage-backed agency pools (including CMOs), investment grade corporates, asset-backed securities, CMBS, and exchange-traded U.S Treasury futures. We typically try to keep portfolio duration in close alignment to that of the portfolio’s benchmark. While our investment process is primarily driven by bottom-up analysis, we assess the overall risk position of our clients’ portfolios using our in-house portfolio management system. Our proprietary system is a deep source of information regarding the risk of each security and each portfolio versus its benchmark and versus other similar portfolios. Our system provides our portfolio managers with a detailed matrix analysis of the portfolio versus the benchmark by ratings quality, partial durations, sector and subsector weightings, and industry exposure. Additionally, our system provides index comparisons down to the level of individual issuer concentration. The information from our system allows us to adjust our bottom-up process to optimize the overall portfolio characteristics. We perform rigorous stress testing on individual securities and on the entire portfolio. We review option-adjusted duration and convexity on all securities, particularly mortgage-backed securities. We also run partial (key rate) durations daily on each bond and on the portfolio. We review closely the dispersion versus the portfolio benchmark both on a single portfolio basis and within groups of portfolios that are managed against the same benchmark. For corporate bonds, we establish internal credit opinions and review the issuers’ credit quality. We also review the portfolio concentration by industry and focus the portfolio in areas that have positive credit trends. We measure credit exposure by rating and duration daily. For example, our daily portfolio reports include the contribution to duration for each of the AAA, AA, A and BBB categories. Finally, credit quality diversification by applying market value-based thresholds based on credit quality is a key part of our risk management process. Our fixed income portfolio managers manage our portfolios on a team basis. Portfolio managers generate ideas within their areas of expertise and then compare these to relative value in other fixed income market segments. We leverage the knowledge and experience of our investment team through a consensus-oriented interactive process whereby the team scrutinizes and challenges investment ideas across the sectors. This close and constant interaction among our portfolio managers enables us to leverage the knowledge and skills of the investment team and to efficiently make cross-sector decisions. En viron men tal, Soc ial an d Govern an c e I s s u es We recognize that Environmental, Social and Governance (ESG) issues potentially affect the longterm financial condition of a company, as well as the valuation and performance of a security. We define ESG as the risk or the opportunity to a company’s market valuation or solvency resulting from

financially material ESG factors. While financially material ESG factors are be inputs into our fundamental analysis, portfolio managers are not required to consider them for every investment decision. Accordingly, each investment strategy varies in the degree of consideration of material ESG factors from some more ESG focused strategies and funds placing more emphasis on financially material ESG factors to those strategies and funds that integrate financially material ESG factors by considering such factors as one of many inputs into determining whether to include or exclude an investment or those strategies that place little to no consideration of ESG factors. In forming our opinion on the importance or impact of ESG factors on a company, we assess information from multiple sources, such as issuer disclosures, meetings with management, data and research from third-party vendors and brokers, as well as research from our sustainability team. Jennison is a signatory to the Principles for Responsible Investment (PRI). Ou r I n ves tmen t Strategies for Sep arate A c c ou n t an d Man aged Fu n d V eh ic le Clien ts We provide investment management services to separate account and managed fund vehicles in the following investment disciplines: Growth Equity, Small/SMid and Mid Cap Equity, Global Equity, Value, Custom Solutions and Fixed Income. We also manage equity portfolios in certain sectors and provide customized portfolio management services. Below is a description of select strategies in each of the disciplines and of sector and customized portfolio management services. Most portfolios are managed actively and invest free of tight benchmark sector constraints. Each fundamental equity strategy seeks to invest in specific companies regardless of benchmark sector classifications. We make no guarantee that the objectives of the strategy will be achieved. Growth Eq u ity Large Cap Growth Equity: We manage large-cap growth portfolios that vary by number of holdings and other characteristics and invest primarily in large capitalization growth stocks in the U.S. Portfolios seek capital appreciation and are built from the bottom-up, based on our proprietary fundamental research. Our growth equity team believes that growth in earnings and cash-flows drive share prices over the long-term, and the team seeks to invest in exceptional companies with sustainable competitive advantages that can create long-term growth in economic value and generate superior returns for shareholders. Global Healthcare/Health Sciences: We manage both long-only and long/short portfolios that invest in global healthcare equities. The highly experienced healthcare team seeks capital appreciation with a growth investment style that uses bottom-up, analyst-driven fundamental research. Our goal is to find companies that are bringing the most innovative products and services to the market and maintain exposure to them throughout the development cycle. This includes looking for business models that increase the efficiency of the health care system by enhancing access to care, increasing or accelerating the diagnosis of disease, improving outcomes or lowering costs. The team looks for companies with seasoned management, attractive and growing end-markets, defensible competitive positions, prospects for durable earnings growth, high returns on capital, and solid balance sheets.

Small/SMI D an d Mid Cap Eq u ity Small Cap Core Equity and Small/Mid (SMID) Cap Core Equity: We manage small cap core equity and SMID cap core equity portfolios. We define our small cap universe as primarily U.S.-based companies with market capitalizations typically between $150 million and $5 billion and our SMID cap universe as primarily U.S.-based companies with market capitalizations typically between $500 million and $12 billion. Our small cap and SMID cap portfolios represent a blend of both growth and value styles; however, our small and SMID cap portfolio managers do not distinguish stocks in those styles when considering them for the portfolio. We seek to uncover companies that have attractive valuations, and that we believe should experience superior earnings growth in the intermediate term. Mid Cap Growth Equity: We manage mid cap growth equity portfolios. We define the mid cap universe as primarily U.S.-based companies with market capitalization typically between $2 billion and $30 billion. We seek to uncover companies that we believe have attractive valuations and that should experience superior earnings growth on an intermediate term basis. Glob al Eq u ity Global Equity Opportunities: Our global equity opportunities strategy seeks capital appreciation by investing in companies around the world believed to be new market leaders with sustainable competitive advantages. It seeks to capture market upside and temper market downside and dampen portfolio volatility by assessing the correlations of individual holdings and the overall portfolio. Portfolios are built from the bottom-up based on our fundamental research. The strategy has an integrated global perspective and has broad limits on country and sector weights. We manage global equity portfolios that vary by number of holdings and other characteristics. International Equity Opportunities: Our international equity opportunities strategy seeks capital appreciation by investing in companies outside of the U.S. that our investment team believes to be new market leaders with sustainable competitive advantages. It seeks to capture market upside and temper market downside and dampen portfolio volatility by assessing the correlations of individual holdings and the overall portfolio. Portfolios are built from the bottom-up based on our fundamental research. The strategy has broad limits on country and sector weights. Emerging Markets: Our emerging markets strategy seeks capital appreciation by investing in companies around the developing world that the investment team believes to be market leaders with sustainable competitive advantages. It seeks to capture market upside and temper market downside and dampen portfolio volatility by assessing the correlations of individual holdings and the overall portfolio. Portfolios are built from the bottom-up based on our fundamental research. The strategy has broad limits on country and sector weights. V alu e Eq u ity Large Cap Value Equity: Our value investment team seeks investments in companies it believes are being valued at a discount to their true worth, as defined by the value of their earnings, free cash flow, the value of their assets, their private market value or some combination of these factors, and that possess a favorable return/risk profile. We manage large cap value portfolios that vary by number of holdings and primarily focus on large cap value stocks.

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We provide investment advisory services to a diverse range of affiliated and unaffiliated global institutional clients, including pension and profit-sharing plans, public employee retirement systems, municipalities, Taft-Hartley plans, sovereign wealth funds, central banks, credit institutions, corporations, publicly offered investment funds (including registered investment companies such as mutual funds and ETFs) and their investment managers, insurance companies with respect to their separate and general accounts, collective and common trusts, commingled trust funds, charitable institutions, foundations, endowments, collateralized loan obligations (“CLOs”), family offices, private investment funds and their investment managers, non-U.S. funds such as Undertakings for Collective Investment in Transferable securities (“UCITS”), high net worth individuals and consultants that are investment advisers and provide discretionary manager selection and oversight through outsourced chief investment officer services (“OCIOs”). We also provide non-discretionary advice to sponsors of UMA programs and other financial intermediaries. The minimum account sizes vary by certain characteristics such as investment strategy, investment vehicle and mandate characteristics, with separately managed accounts and funds of one typically having higher investment minimums than investments in commingled funds and accounts through wrap programs. We waive these minimums at our discretion. Affiliated clients and certain other clients can request and receive greater transparency, operational support, training, or other resources, as permitted under applicable law.

Performan c e- B as ed Fees As described in Item 5, we offer performance-based fee arrangements for select strategies to some clients. While the majority of our fee arrangements are asset-based, we have entered into individually negotiated performance-based fee arrangements with some clients. As described in Item 5, we charge performance-based fees for certain product offerings and also for select strategies where such fee arrangements are acceptable to the client. The majority of our fee arrangements, however, are asset-based fees that are calculated based on the value of a client’s portfolio at periodic measurement dates or over specified periods of time. Our performance-based fees are typically individually negotiated and are generally based on the capital appreciation of the account relative to an index or absolute performance over a period of time. Our performance-based fees typically include an asset-based management fee component which is either flat or includes breakpoints linked to the amount of assets in the account and which we collect regardless of the performance for the account. Some of our performance-based fees are derived from the percentage by which we outperform the benchmark against which the client’s portfolio is measured. We will generally be entitled to be paid a portion of that percentage, although the formulas and specifics of these fees vary. In measuring clients’ assets for the calculation of performance-based fees, net profits typically include both realized and unrealized capital gains and losses. Clients should refer to their fee schedule or Offering Documents for more specific information on how any performance-based fees are calculated. Performance-based fees offer greater upside potential to us than asset-based fees, depending on how the fees are structured. Sid e- B y- Sid e Man agemen t Con flic ts of I n teres t We manage accounts with asset-based fees alongside accounts with performance-based fees. This side-by-side management creates an incentive for us and our investment professionals to favor one account over another. Specifically, we have an incentive to favor accounts for which we receive performance fees, and possibly take greater investment risks in those accounts in order to bolster performance and increase our fees. Other types of side-by-side management of multiple accounts create incentives for us to favor one account over another. Examples are detailed below, followed by a discussion of how we address these conflicts. Lon g on ly ac c ou n ts /lon g- s h ort ac c ou n ts We manage accounts in strategies that hold only long securities positions as well as accounts in strategies that are permitted to sell securities short. As a result, we would hold a long position in security in some client accounts while selling the same security short in other client accounts. For example, we permit quantitatively hedged strategies to short securities that are held long in other strategies. We also permit securities that are held long by one fundamental portfolio manager to be held short by another fundamental portfolio manager. Additionally, we permit securities that are held long in quantitatively derived strategies to be shorted by other strategies. The strategies that short a

security that is held long by another strategy could lower the price for the security held long. Similarly, if a strategy is purchasing a security that is held short in other strategies, the strategies purchasing the security could increase the price of the security held short. By the same token, sales in a long only account can increase the value of a short position while shorting could create an opportunity to purchase a long position at a lower price. As a result, we have conflicts of interest in determining the timing and direction of investments. Mu ltip le s trategies We buy or sell, or direct or recommend that one client buy or sell, securities of the same kind or class that are purchased or sold for another client, sometimes at different prices. At any time, we execute trades of securities of the same kind or class in one direction for an account and in the opposite direction for another account, due to differences in investment strategy or client instructions. Different strategies that involve trading in the same securities or types of securities appear as inconsistencies in our management of multiple accounts side-by-side. I n ves tmen ts at d ifferen t levels of an is s u er’ s c ap ital s tru c tu re To the extent different clients invest across multiple strategies or asset classes, it is possible for us to invest their assets in the same issuer, but at different levels in the capital structure. As a result, these positions could be inconsistent or in potential or actual conflict with each other. A ffiliated an d p rop rietary ac c ou n ts We manage accounts for our affiliates and accounts in which we have an interest alongside unaffiliated accounts. This creates an incentive to favor our affiliated accounts over unaffiliated accounts. Additionally, our affiliated investment advisers could allocate their asset allocation clients’ assets to us, which creates an incentive for us to favor accounts used by our affiliate for their asset allocation clients to receive more assets from our affiliate. Additionally, at times our affiliates provide initial funding or otherwise invest in vehicles managed by us. When an affiliate provides “seed capital” or other capital for a fund or account, the affiliates reserve the right to redeem all or part of its interest at a particular future point in time or when it deems that sufficient additional capital has been invested in that fund or account. We typically request seed capital to start a track record for a new strategy or product. Managing “seeded” accounts alongside “non-seeded” accounts create an incentive to favor the “seeded” accounts to establish a track record for a new strategy or product. Non - d is c retion ary ac c ou n ts or mod els We provide non-discretionary model portfolios to some clients and manage other portfolios on a discretionary basis. Recommendations for non-discretionary models that are derived from discretionary portfolios can be communicated before or after the discretionary portfolio has traded. The non-discretionary clients could be disadvantaged if we deliver the model investment portfolio to them after we initiate trading for the discretionary clients. Discretionary clients could be disadvantaged if the non-discretionary clients receive their model investment portfolio and start trading before we have started trading for the discretionary clients.

High er fee- p ayin g ac c ou n ts or p rod u c ts or s trategies In general, we receive more revenues from (1) larger accounts or client relationships than smaller accounts or client relationships and from (2) managing discretionary accounts than advising nondiscretionary models and from (3) non-wrap fee accounts than from wrap fee accounts and from (4) charging higher fees for some strategies than others. The differences in revenue that we receive could create an incentive for us to favor the higher fee paying or higher revenue generating account or product or strategy over another. Pers on al in teres ts The performance of one or more accounts managed by our investment professionals is taken into consideration in determining their compensation. We also manage accounts that are investment options in our employee benefit plans such as our defined contribution plans or deferred compensation arrangements and where our employees have personally invested alongside other accounts where there is no personal interest. These factors create an incentive for us to favor the accounts where we have a personal interest over accounts where we do not have a personal interest. (Please see Item 11 for additional information). Sid e Letters We have entered into side letters with respect to certain of the funds that we manage and will likely do so with respect to funds that we manage in the future. Such side letters are agreements with investors in the funds (including affiliated investors) that grant such investors terms and conditions more advantageous than those granted to other investors. For example, some investors have side letters granting reduced fees or expenses, or access to more frequent or detailed information regarding the fund's investments to the extent permitted by applicable law. For certain investors in commingled funds managed by us, we rebate a portion of the management fee paid to us. The rebate is either reinvested into the fund on behalf of the investors or is paid to the investor in, as agreed with the investor. In some instances, we could have multiple side letters with respect to a single fund, each with a different investor. How We A d d res s Th es e Con flic ts of I n teres t The conflicts of interest described above create incentives for us to favor one or more accounts or types of accounts over others in the allocation of investment opportunities, aggregation and timing of investments. Portfolios in a particular strategy with similar objectives are managed similarly to the extent possible. Accordingly, portfolio holdings and industry and sector exposure tend to be similar across a group of accounts in a strategy that have similar objectives, which tends to minimize the potential for conflicts of interest among accounts within a product strategy. While these accounts have many similarities, the investment performance of each account will be different primarily due to differences in guidelines, individual portfolio manager’s decisions, timing of investments, fees, expenses and cash flows. Additionally, we have developed policies and procedures that seek to address, mitigate and assess these conflicts of interest.

We have adopted trade aggregation and allocation procedures that seek to treat all clients (including affiliated accounts) fairly over time. These policies and procedures address the allocation of limited investment opportunities, such as IPOs and new issues, and the allocation of transactions across multiple accounts. (Please see Item 12 for additional information about our brokerage practices.)

We have policies that limit the ability to short securities in portfolios that primarily rely on our fundamental research and investment processes (fundamental portfolios) if the security is held long by the same portfolio manager.

We have adopted procedures to review allocations or performance dispersion between accounts with performance fees and non-performance fee-based accounts and to review overlapping long and short positions among long accounts and long-short accounts.

We have adopted a code of ethics and policies relating to personal trading. (Please see Item 11 for additional information about our code of ethics and personal trading policies.)

We have adopted a conflicts of interest policy and procedures.

We provide disclosure of these conflicts as described in this brochure.

B roker- Dealer A ffiliation s Certain of our management persons and other employees are registered representatives of Prudential Investment Management Services LLC (PIMS), an affiliated SEC-registered broker-dealer. Jennison is an Office of Supervisory Jurisdiction of PIMS. CFTC Exemp tion s We are not registered with the CFTC as a commodity pool operator or as a commodity trading advisor in reliance on exemptions from registration and no action letter positions. As such, our ability to provide advice with respect to commodity interests, such as exchange traded futures contracts and options on futures contracts is limited to the scope of the exemptions. R elation s h ip s with A ffiliates an d R elated Con flic ts of I n teres t As an indirect wholly-owned subsidiary of Prudential Financial, we are part of a diversified, global financial services organization. We are affiliated with many types of financial service providers, including broker-dealers, insurance companies and other investment advisers. Some of our employees are officers of some of these affiliates. R elation s h ip s with A ffiliated B roker- Dealers PIMS provides marketing and administrative support in connection with the offer and sale of securities of commingled vehicles that we advise or subadvise for affiliated and non-affiliated persons. As noted above, certain of our management persons and other employees are registered representatives of PIMS. R elation s h ip s with A ffiliated I n ves tmen t V eh ic les Insurance Company Separate Accounts We are the subadviser of certain separate accounts of PICA. Prudential Financial’s benefit plans invest in some of the insurance separate accounts that we subadvise. Mutual Funds/ETFs We serve as subadviser to mutual funds and ETFs managed or co-managed by our affiliates PGIM Investments LLC (PGIM Investments) and AST Investment Services, Inc. (AST). These funds include the PGIM Investments family of funds, The Prudential Series Fund, and Advanced Series Trust mutual funds. Some of these mutual funds (as well as certain pooled vehicles sponsored by third-party clients) are investment options in Jennison’s defined contribution pension plan. Collective and Commingled Trust Funds Our affiliate, Prudential Trust Company (Pru Trust), a trust company organized under the Pennsylvania Banking Code, is the trustee of several common and collective trust structures as well as the trustee of certain other Pru Trust assets. We provide investment advice to certain funds under these trusts,

and certain of our employees are officers and directors of Pru Trust. Prudential Financial’s benefit plans are investors in certain Pru Trust sub-funds that we manage. Additionally, Jennison’s defined contribution plan is a participant in a sub-fund managed by Jennison within a certain collective trust sponsored by a third-party client. Affiliated Foreign Funds We manage sub-funds of PGIM Funds plc (“PF”), an Irish domiciled investment company organized as a UCITS. Certain directors of PF are employees of Jennison or an affiliate. Additionally, we manage a sub-trust of PGIM Cayman Unit Trust (“Unit Trust”), an open-ended umbrella unit trust organized in the Cayman Islands. An affiliate of Jennison has invested seed capital in all Jennison-managed sub-funds of PF and the Unit Trust. Private Funds and Hedge Funds We serve as general partner and provide investment management services to private funds that we organize and sponsor. We are the investment manager of the Jennison Global Healthcare Master Fund, Ltd. (the “GHC Master Fund”) which is a master-feeder hedge fund structure. This structure has a master fund that is domiciled in the Cayman Islands and U.S. domiciled and non-U.S. Cayman Islands domiciled feeder funds (collectively, the “GHC Funds”). Each of the feeder funds invest all or substantially all of its assets in the master fund. The directors of the GHC Master Fund and the non-U.S. feeder fund are employees of Jennison. We serve as the general partner or the managing member of the U.S. domiciled fund. Some employees, including the portfolio managers, have investments in the GHC Funds. In addition, an affiliate of Jennison has invested in the GHC Funds. We expect that our affiliate will redeem its investment at some point in the future when it deems that sufficient additional capital has been invested into the GHC Master Fund. Please see the Conflicts Related to Our Affiliations below for a discussion of potential conflicts arising out of this capital investment. R elation s h ip s with A ffiliated I n ves tmen t A d vis ers As described above, we provide subadvisory services for mutual funds or other funds managed or comanaged by PGIM Investments and AST. PGIM Investments provides marketing and sales support for our JMA business. We currently provide or could in the future provide discretionary subadvisory or non-discretionary investment advisory services to our other affiliated investment advisers, which include PGIM, Inc. (PGIM), PGIM Japan Co., Ltd., Pru Trust, PGIM Limited and PGIM Netherlands. We also have service agreements with certain affiliates, including PGIM Japan Co., Ltd., PGIM Limited and PGIM (Singapore) Pte. Ltd., under which we can perform services for them or they can perform services for us. Asset Allocation One of our other affiliated investment advisers, PGIM Quantitative Solutions LLC, provides asset allocation services to affiliates and third parties. PGIM Quantitative Solutions LLC allocates its clients’ assets to both third parties and affiliated investment advisers, including us.

Participating Affiliate Arrangement Within the guidance set forth under applicable law, relevant no-action letters and related SEC staff guidance, SEC-registered investment advisers are permitted to access, under prescribed conditions, the services of unregistered affiliates (“participating affiliates”). The prescribed conditions include that the participating affiliate provide the SEC access to trading and other records, observe specific recordkeeping rules, submit to the jurisdiction of U.S. courts and cooperate with the SEC as it relates to relevant accounts. PGIM (Hong Kong) Limited (“PGIM HK”) is a participating affiliate of Jennison and it and certain of its personnel are subject to the supervision of Jennison with respect to the services that PGIM HK provides to Jennison as a participating affiliate. Under this arrangement a member of Jennison’s emerging markets equity team provides investment research to Jennison. PGIM HK is authorized and licensed by the Hong Kong Securities and Futures Commission. Certain members of Jennison’s sales, client service and product group are employees and certified persons for PGIM Limited, an affiliated SEC registered investment adviser that is also authorized and regulated by the Financial Conduct Authority in the United Kingdom. R elation s h ip s with A ffiliated I n s u ran c e Comp an ies As described above, we provide advisory services with respect to the separate accounts of PICA. R ec ommen d ation of I n ves tmen t A d vis ers We do not currently select other investment advisers for our clients. Con flic ts R elated to Ou r A ffiliation s Con flicts Arising Out of Side-By-Side Management of Affiliated Accounts with Non-Affiliated Accoun ts Please see discussion of Side-By-Side Management in Item 6. Con flic ts R elated to Co- in ves tmen t b y A ffiliates As described in Item 6, our affiliates might provide initial funding to start a new track record for a new strategy or product or otherwise invest in vehicles managed by us. When an affiliate provides “seed capital” or other capital for a fund or strategy, it can do so with the intention of redeeming all or part of its interest at a particular future point in time or when it deems that sufficient additional capital has been invested in that fund or strategy. In addition to the conflicts related to Side-By-Side Management described in Item 6, co-investment by affiliates can give rise to other conflicts described below.

The timing of a redemption by the affiliate redeeming its interest in a fund could benefit the affiliate. For example, the fund might be more liquid at the time of the affiliate’s redemption than it is at times when other investors might wish to withdraw all or part of their interests.

In addition, a consequence of any withdrawal of a significant amount, including by our affiliate, is that investors remaining in the fund will bear a proportionately higher share of fund expenses following the redemption.

We could also face a conflict if the interests of an affiliated investor in a fund we manage diverge from those of the fund. For example, our affiliates hedge some or all of the risks associated with their seed capital investments in funds that we manage. We assist in connection with this hedging activity. Con flic ts A ris in g Ou t of Legal an d R egu latory R es tric tion s At times, we are restricted by law, regulation, contract or other constraint as to how much, if any, of a particular security we can purchase or sell on behalf of a client, and as to the timing of such purchase or sale. Sometimes these restrictions apply as a result of our relationship with Prudential Financial and our other affiliates. For example, our holdings of a security on behalf of our clients can, under some SEC or other regulations, be aggregated with the holdings of that security by other Prudential Financial affiliates. These holdings could, on an aggregate basis, exceed certain thresholds unless we limit holdings and restrict purchases. we are also restricted from purchasing or selling securities of Prudential Financial or its affiliates for client accounts. In addition, we could receive material, non-public information with respect to a particular issuer and, as a result, be unable to execute transactions in securities of that issuer for our clients. This information can be received voluntarily or involuntarily and under varying circumstances, including upon execution of a non-disclosure agreement or from an affiliate. In some instances, we might create an isolated information barrier around a small number of our employees so that material non-public information received by such employees is not attributed to the rest of Jennison. We are generally able to avoid receiving material, non-public information from our affiliates by maintaining information barriers to prevent the transfer of information between affiliates. (For additional information about our information barriers, please see Item 11). Sign ific an t Sh areh old er R ep ortin g From time to time, we are required by applicable laws, rules and regulations to file reports with regulators that contain information about our clients’ holdings of an issuer when the holdings are large enough to require reporting. Those reports are often publicly available and in certain circumstances require disclosure of the client’s identity and applicable holdings. In addition, our clients can hold a position in the securities of a portfolio company that is large enough to require reporting by the client to the regulators under applicable laws, rules and regulations. We do not monitor or advise on reporting requirements for clients because, among other reasons, Jennison does not have an ability to monitor the aggregate holdings of an individual client and such monitoring is generally handled by such client’s other service providers that have the ability to monitor a client’s aggregate holdings. Con flic ts A ris in g Ou t of Emp loyee A ffiliation s We could limit or restrict trading of an issuer in client accounts where the portfolio manager is related to a person who is senior management or a director of a public company. Con flic ts A ris in g Ou t of A ffiliation s of Ou r A ffiliates Certain of our affiliates (as well as directors or officers of our affiliates) are officers or directors of issuers in which we invest from time to time. These issuers could also be service providers to us or our affiliates. We monitor such conflicts.

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Personal Trading Gen eral We maintain a code of ethics as required by applicable SEC rules. Our code of ethics requires employees to conduct business in an honest and forthright manner in accordance with the highest of ethical standards. In addition, the code of ethics requires employees to act consistently with our fiduciary duty and put client interests ahead of our own and disclose actual and potentially meaningful conflicts of interest. We also require the reporting and pre-approval of outside business activities where such activity might create a perceived conflict. The code of ethics incorporates our personal trading policies that are described in greater detail below. Our employees are required to report any violation of the code of ethics promptly to Compliance. Employees are required to receive training on our code of ethics and complete an attestation verifying that they have complied with the Code of Ethics and Compliance Program policies. We will provide a copy of our code of ethics to clients or prospective clients upon request. Policy on Safeguarding the Receipt of Material Non-public Information and Information Barrier Policy In the ordinary course of our business, we receive material non-public information. Material non-public information can be received voluntarily or involuntarily and under varying circumstances, including upon execution of a non-disclosure agreement, through relationships with friends or any family member or individual living in the same household, or serving on an ad hoc or official investment committee. Jennison personnel expect to engage the services of expert networks and we could also involuntarily receive material, non-public information from such networks and political intelligence firms. We have policies and procedures relating to material non-public information (MNPI) as embodied in our Safeguarding the Receipt of Material Non-public Information Policy. Our policies require our employees to escalate and report the receipt of potential MNPI to the compliance and legal departments. Additionally, Prudential Financial’s information barrier standard, which applies to us, is designed to prevent the communication of MNPI across the various Prudential Financial asset management investment sectors. Under the standard, an employee of one investment sector, including Jennison, can not communicate MNPI to an employee of another investment sector without approval from each sector’s compliance department. The information barrier standard also restricts physical access to an investment sector’s offices by employees of a different investment sector. We maintain a restricted list of issuers where trading in the securities of that issuer is prohibited due to the receipt of MNPI or potential MNPI (Restricted List). Our client and personal trading activities are screened on a pre-trade basis against our Restricted List. Any transaction in an issuer on the Restricted List must be approved by our compliance department. Contractual obligations owed by us to third parties to maintain confidentiality and legal and regulatory requirements prevent us from sharing (or might limit our ability to share) material, non-public

information, information based on material, non-public information (including, but not limited to analyses), or other confidential information with clients and others. Pers on al Trad in g Polic y We maintain a personal trading policy that governs the trading activities of our employees as well as their household members and dependents. Subject to certain limited exceptions, employees are required by the policy to:

report personal securities transactions to our compliance department;

pre-clear personal securities transactions, including investments in private placements;

maintain brokerage accounts only with certain approved brokers that report transaction information to our compliance department; and

annually report securities holdings to our compliance department.

We consider all of our employees to be “access persons.” All of our employees are subject to additional restrictions under the policy, including the following:

employees are prohibited from purchasing securities in IPOs;

employees are generally prohibited from transacting in options and futures on individual securities;

employees are generally prohibited from trading any security within seven days before or after we trade such security (or an equivalent security) for client accounts subject to certain de minimis exceptions;

employees are generally prohibited from selling the same security within 60 days; and

investment personnel are subject to additional restrictions.

We review personal trading activity versus firm trading and the Restricted List, and any matches are investigated by our compliance department. Our Compliance Council meets regularly to consider possible violations and take disciplinary action where appropriate. All employees receive training regarding our personal securities trading policy and information barrier standards. In addition, employees must confirm quarterly that they have read and understand our code of ethics, including the personal securities trading policy and complied with all of our policies. Gifts & Entertain men t Our employees occasionally give or receive gifts, meals or entertainment of moderate value, subject to compliance with applicable laws and regulations and rules of self-regulatory organizations. We maintain a gifts and entertainment policy to address the conflicts of interest related to gifts and entertainment, such as the appearance of having given or received something of value that influenced our business decisions or the business decisions of our clients. The policy requires the reporting and preclearance of gifts, meals and entertainment received which exceed certain thresholds. In addition, our employees are prohibited from soliciting the receipt of gifts, meals or entertainment. Our

compliance department periodically reviews gifts and entertainment activity for trends and to confirm compliance with the policy. Politic al Con trib u tion s Due to the potential for conflicts of interest, Jennison has established policies and procedures relating to political contributions that are designed to comply with applicable federal, state and local law. Under this policy, all employees (and their immediate family members living in the same household, including but not limited to their spouses and dependent children) must obtain preapproval before making any political contribution. This policy also prohibits Jennison employees from making any political contributions with the intent of influencing a public official regarding the award of a contract to Jennison or its affiliates. Ch aritab le Con trib u tion s We have a conflict of interest when making contributions to a charitable organization that is affiliated with, or is favored by, one of our clients. Charitable contributions could give the appearance of our improperly favoring one individual or institution over another or of our seeking to exert an improper influence on the requestor or recipient of a contribution. Contributions to certain recipients could also present money laundering or terrorist financing risks. We have adopted policies and procedures that seek to address these risks as well as to review and approve requests for charitable contributions from individuals or institutions with which we have a business relationship. Our procedures require that we make contributions to bona fide charitable organizations. Each contribution is subject to a number of approvals. From time to time, we might receive marketing benefits when we provide corporate sponsorships to charitable organizations. Corporate sponsorships that convey a marketing benefit to us are subject to an additional approval process. In addition, our employees contribute personally to charitable organizations. Any personal contributions which exceed a certain threshold require reporting and pre-approval under the gifts and entertainment policy. Ou ts id e B u s in es s A c tivities From time to time, certain of our employees or officers engage in outside business activities, including outside directorships. Outside business activity where an employee is a director, officer, employee, partner or trustee or otherwise holds any other position of substantial interest is subject to prior approval pursuant to our personal conflicts of interest and outside business activities policy and procedures. Actual and potential conflicts of interest are analyzed by Jennison’s Ethics Advisory Group. We could be restricted in trading the securities of certain issuers in client portfolios in the unlikely event that an employee or officer, as a result of outside business activity, obtains material, nonpublic information regarding an issuer. Comp en s ation of ou r I n ves tmen t Profes s ion als Total compensation for our investment professionals, including portfolio managers and analysts, is typically comprised of a combination of base salary and cash bonus. We base the size of the overall incentive compensation pool on our profitability.

In determining an investment professional’s total compensation, we evaluate numerous qualitative and quantitative factors. Not all factors are applicable to every investment professional, and we have no particular weighting or formula for considering the factors. The factors considered for evaluating a portfolio manager will differ from those reviewed for a research analyst or a portfolio manager with research responsibilities. The factors that we consider can include: •

The long term (typically three – five year or longer) investment performance of all of the accounts managed in the same strategy (composite) relative to market conditions, indices and peers;

•

For the healthcare portfolio managers, carried interest from certain accounts that they manage;

•

Contribution to client portfolio performance of the investment professional’s recommended securities relative to market conditions, the strategy’s passive benchmark and the investment professional’s coverage universe;

•

Qualitative factors such as teamwork, responsiveness, experience, and other responsibilities such as being a team leader.

Additionally, senior investment professionals, including portfolio managers and senior research analysts, are eligible to participate in a voluntary deferred compensation program where all or a portion of the cash bonus can be deferred. Participants in the deferred compensation plan are permitted to allocate the deferred amounts among certain options that track the gross-of-fee pre-tax performance of accounts or composites of accounts managed by Jennison. The overall incentive compensation pool of our investment professionals is based on Jennison’s profitability and as such, it creates an incentive for a portfolio manager to favor the accounts that could have a greater impact on Jennison’s profitability. Additionally, certain investment professionals receive carried interest from certain accounts that they manage. These investment professionals could have an incentive to favor these accounts. To address potential conflicts related to these financial interests, we have procedures, including supervisory review procedures, that we believe are designed to mitigate and monitor this conflict. We believe that these procedures seek to provide that each of our accounts is managed in a manner that is consistent with our fiduciary obligations, as well as with the account’s investment objectives, investment strategies and restrictions. (Please see Item 6 for additional information about potential conflicts of interests related to our investment professionals’ compensation.) Con flic ts A ris in g Ou t of Sec u rities Hold in gs Prudential Financial, PICA’s general account, our proprietary accounts and accounts of other affiliates of ours (collectively, affiliated accounts) might, at times, have various levels of financial or other interests in companies whose securities we could hold, purchase or sell in our client accounts. This can occur because affiliated accounts hold public and private debt and equity securities of a large number of issuers and might invest in some of the same companies as our client accounts. Additionally, investments of affiliated accounts and our client accounts might be at different levels in the capital structure of a company. At any time, these interests could be inconsistent or in potential or actual conflict with positions held or actions taken by us on behalf of other client accounts. For example, we could invest client assets in the equity of companies whose debt is held by an affiliate. Additionally, to the extent permitted by applicable law, we might also invest client assets in offerings of securities the

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B rokerage Gen erally Transactions in equity securities are usually executed through brokers (including prime brokers) that act as agent and receive a commission paid by the client account for which the transaction is executed. Fixed income and over-the-counter securities are generally traded with dealers acting as principal without a stated commission. The dealer’s compensation (margin or spread) for principal transactions is reflected in the price of the security. Money market obligations can be transacted directly with the issuer. Underwritten offerings of stock and intermediate and long-term debt securities can be purchased at a fixed price including an amount of compensation to the underwriter. Transactions for client accounts must be made through brokers, dealers, futures commission merchants and other counterparties on our approved counterparty list. Fac tors Con s id ered in A p p rovin g Cou n terp arties Counterparties for our equity and fixed income securities transactions are approved by Jennison’s Chief Risk Officer. Criteria for approval includes but is not limited to:

Regulatory net capital Adverse regulatory or legal findings or proceedings Long- and short-term credit rating Share price and share price trend Credit default swap, spreads and spread trends

Relevant news Market presence Industry reputation Regulatory standing, including but not limited to, fines, sanctions, etc. Cyber security, operational resiliency, or business continuity

Fac tors Con s id ered in Selec tin g Cou n terp arties Factors we consider in selecting an approved counterparty to execute a particular transaction include:

Market liquidity for the security and broker-dealer market access; Trading expertise, including specialized expertise; Efficient execution, including the ability to work orders over time; Quality of back-office operations, settlement processes, and the absence of errors; Willingness to commit capital; Sophistication of the broker-dealers trading facilities, trading style and strategy, including order routing arrangements;

Trading infrastructure, such as access to trading algorithms or networks, or basket trading capabilities; Creditworthiness, reputation, and financial responsibility of the counterparty; Responsiveness and administrative cooperation of the counterparty; and The counterparty’s ability to execute large transactions and to limit the market impact of large transactions

We do not consider sales of mutual fund shares or the compensation paid in connection with the sales of mutual fund shares in selecting brokers to execute transactions for our clients’ accounts. Wrap A c c ou n ts an d U MA s an d Non - Dis c retion ary Mod els For JMA Accounts, securities trades are not typically executed through Jennison’s trading desk. Accordingly, communication of changes to portfolio holdings information for JMA Accounts (both Traditional SMA and Model Portfolio) is handled using a separate process. Jennison releases its JMA Account holdings information to a third-party service provider (“Implementation Agent”) on each day the New York Stock Exchange is open for business. When the applicable investment team makes core changes to a JMA portfolio, Jennison generally communicates the changes to the Implementation Agent. The Implementation Agent then executes the trades resulting from these model changes in accordance with the Implementation Agent’s trade rotation schedule. The trade rotation process described above is designed to maintain fair and equitable treatment of JMA Accounts over time. JMA Accounts can experience differences due to the timing and implementation of order execution by their sponsors. JMA Accounts might trade the same securities before, at the same time, in close time proximity or after trading activity of Jennison’s other discretionary accounts, but the trading activity of Jennison’s other discretionary accounts is independent of the JMA Accounts’ trade rotation process. Jennison also provides custom model portfolios directly to certain advisers, broker-dealers or other financial intermediary clients. In these circumstances where there is no sponsor program/platform involved and the model is customized to a particular client, the model will be provided directly to such client and any such model is not subject to the trade rotation requirement. Exec u tion of Trad es We seek to obtain efficient executions for client accounts at a price (including commissions where applicable) that provides the most favorable total cost or proceeds reasonably attainable in the circumstances (best execution). In light of the factors above, and in accordance with applicable law, our clients could pay transaction costs in excess of that which another firm might have charged for executing the same transaction. Jennison believes that the interests of our clients are best served by brokerage policies that include a fair commission rather than merely requiring the payment of the lowest possible commission rates. Additionally, a larger commission could be more than offset by a more favorable execution quality or price or other service provided by the broker. Additionally, these prices can be influenced by the size of our past and future business with respect to all of our clients’ trading activity with a broker. Subject to our duty to seek best execution, when we believe it to be appropriate under the circumstances, we use “step outs,” where the executing broker steps out all or a portion of a transaction to another broker which receives the commission and settles the trade. Typically, step outs enable us to place aggregated transactions with our primary execution brokers, satisfy client directed brokerage arrangements or pay for research provided by a non-execution broker. We have policies and procedures to review and assess brokers/dealers and the quality of their executions. We periodically review the allocation of brokerage, commission rates where applicable, the services that they provide, the quality and cost of research provided, and other relevant information.

We believe that we are able to negotiate costs on client transactions that are competitive and consistent with our policy to seek best execution. Jennison continues to monitor commission rates in the industry to help determine the reasonableness of commissions to be charged to the accounts. Exec u tion of FX Tran s ac tion s We execute foreign currency (FX) transactions in order to settle trades in non-U.S. securities, income repatriation and non-U.S. currency cash flows. We execute FX transactions through our approved counterparties or our clients' custodians. We will execute FX transactions through a client’s custodian when directed by a client or when local market rules or settlement practices indicate this to be a more efficient method for settling our trade orders. We will seek to aggregate FX transactions when doing so would be in the clients’ best interests and where permitted by applicable regulation. When we execute through custodians at the direction of our clients, our execution is generally subject to the limitations and considerations described below under “Client Directed Brokerage.” We have a process to monitor and review the quality of executions of FX transactions. R es earc h an d Soft Dollar B en efits We receive both proprietary research (created or developed by the broker-dealer) and third-party research (research developed or created by third-party) that aid in our investment decision making or services that aid in trade execution from brokers (brokerage services). Under the safe harbor provided under Section 28(e) of the Securities Exchange Act of 1934, our equity business pays for these research and brokerage services with our equity clients’ brokerage commissions (soft dollars). Accounts in our wrap fee programs and our fixed income business do not pay for research with soft dollars. The use of soft dollars to pay for this research is a benefit for us because we do not have to pay for this research using our own money (hard dollars). The receipt of soft dollar benefits creates a conflict of interest because it can create an incentive to select or recommend a broker-dealer based on our desire to receive research or brokerage services rather than our clients’ interest in receiving best execution. In order to mitigate this conflict, when selecting a broker to execute client transactions in return for soft dollar benefits, we seek to obtain the best execution and most advantageous price in light of the overall quality and reliability of brokerage taking into account the factors outlined above. We could pay higher commissions than would be obtainable for execution by other brokers where research is not obtainable in recognition of the value of the soft dollar benefits. In such cases, we make a good faith determination that the higher commission is reasonable in relation to the value of research and brokerage services provided, viewed in terms of either that particular transaction or our overall responsibilities with respect to all of our clients’ accounts. We have policies and procedures to address and track the use of client commissions to pay for eligible soft dollar services. In accordance with the procedures, we have a comprehensive CSA program (described below) and regularly review the amount of brokerage allocated to brokers that provide us with soft dollar services.

Each quarter, a budget for research to be paid for with client commissions is established. The budget is then allocated through a research vote (“Research Vote”) process in which equity portfolio managers and research analysts (“Investment Professionals”) assess the value of research provided to Jennison during the applicable quarter. Subject to Jennison’s duty to seek best execution and applicable laws and regulations, Investment Professionals allocate a dollar amount to each research provider based on the Investment Professional’s assessment of the value of the research provided by such research provider. The determination and evaluation of the reasonableness of the commissions paid is based primarily on the professional opinions of the Investment Professionals who utilize the research. We use agency or eligible riskless principal transactions executed through unaffiliated broker-dealers to generate soft dollar credits to pay for the research and brokerage services and products described below. We do not make binding commitments as to the level of brokerage commissions we will allocate to a broker, nor do we commit to pay cash if informal targets are not met. Commis s ion Sh arin g A rran gemen ts Jennison makes payments for permissible soft dollar benefits either via a portion of the commissions paid to the executing broker, or through a commission sharing arrangement (“CSA”). CSAs enable us to effect transactions, subject to best execution, through brokers who agree to “unbundle” their commission rates in order to allocate a portion of eligible commissions into a pool that can be used to pay for research from providers with which Jennison does not have a brokerage relationship. In the event of a broker-dealer’s default or bankruptcy, commissions allocated through CSAs could become unavailable for the benefits described below. Jennison pays for proprietary research that is not paid through a CSA by trading directly with the broker that produced the proprietary research (“Research Trades”). Jennison also pays for brokerage services such as execution management services by trading with the broker that provides the brokerage services. These commissions do not separate out the cost of research or brokerage service from the cost of execution and are considered bundled commissions. Orders are generally aggregated across all accounts purchasing or selling the same security at the same time pursuant to Jennison’s Trade Aggregation Policies, as described below. Accordingly, all accounts participating in a CSA or Research Trades pay the same commission rate for trades and share pro rata in the costs of the particular transaction. Participation in CSAs enables Jennison to consolidate payments for brokerage and research services through one or more channels using accumulated client commissions or credits from transactions executed through a particular broker-dealer to obtain brokerage and research services provided by other firms. Such arrangements also help Jennison strengthen its relationships with key brokers while still maintaining relationships with research providers which facilitates our ability to seek best execution in the trading process. Jennison believes CSAs are useful in its investment decision-making process by, among other things, providing access to a variety of high quality research, individual analysts, and resources that Jennison might not otherwise be provided absent such arrangements. Moreover, CSA arrangements allows Jennison to select the research services it feels are the most valuable to its research process and in turn most beneficial to its clients.

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Clien t R eferrals From time to time, we have arrangements where we compensate, either directly or indirectly, affiliated and/or unaffiliated parties for client referrals. The manner and amount of compensation would typically be negotiated on a case-by-case basis, in compliance with legal requirements. To the extent required by law, we will enter into a written agreement with such solicitors. We have an agreement with a third-party solicitor based in the U.S. to introduce prospective investors to our global healthcare hedge funds and to provide client service to such investors. Under this agreement, we pay the solicitor a referral fee based upon a percentage of the manager’s compensation we receive from clients introduced by the solicitor. Oth er Comp en s ation Other than research and brokerage-related services described in Item 12 under the caption “Soft Dollar Benefits,” we do not receive economic benefits from anyone who is not a client in connection with the advisory services we provide to our clients.

We are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of us or the integrity of our management. We have no facts or events to report in response to this Item.

Period ic R eview of Clien t A c c ou n ts b y th e I n ves tmen t Teams A s s et Man agemen t A c c ou n ts in Gen eral We have a team approach to portfolio management, although each portfolio manager has individual accountability for the accounts under his or her supervision. Each strategy group meets regularly to discuss such topics as the results of trading, the performance of client accounts and new or ongoing issues. Our investment team heads have responsibility for reviewing analytics on a regular basis and providing oversight of their investment teams. Pooled V eh ic les Some of our assets under management are held in U.S. registered mutual funds, collective investment trusts and other managed investment funds that we subadvise. In these subadvised accounts, we and the investment portfolios we manage are subject to the oversight of the investment manager for the account, in addition to oversight by the boards of directors, plan trustees or investment committees of each account, as applicable. A d d ition al On goin g R eview of A c c ou n ts Control functions such as our compliance team also review and monitor that our trading processes follow our policies and procedures. The control functions report results of these analyses to senior management in the Legal, Compliance and Risk teams. Other functions such as product management also review and assess information regarding accounts. Some examples of these independent reviews include:

daily compliance review of accounts to assess consistency with guideline restrictions;

periodic review of trading to examine allocation, trade errors, and timing of placements of orders; and

periodic review by the appropriate groups of individuals charged with oversight responsibility for our investment management, trading and related activities. These groups of individuals are identified below.

The groups of individuals (which can be constituted as committees, councils, or advisory groups) charged with oversight responsibility as mentioned above include our:

trade management oversight councils; pricing committee; proxy committee; performance council; operations council; risk council; and compliance council.

R ep orts to Clien ts We offer written reports to our clients regarding their accounts. Our written reports that we offer to clients generally include the following: Eq u ity Sep arate A c c ou n t Clien ts Monthly:

(1) Statement and Appraisal of Assets (2) Statement of Activity (3) Summary of Security Transactions (4) Statement of Performance Evaluation (5) Portfolio & Benchmark Characteristics (6) Portfolio Attribution (7) Commission Analysis

Fixed I n c ome Sep arate A c c ou n t Clien ts Monthly:

(1) Statement and Appraisal of Assets (2) Statement of Activity (3) Cross Section Analysis (Accounts that do not trade futures only) (4) Analysis of Bond Transactions (5) Collateral Movements (6) Statement of Performance Evaluation (7) Statement of Realized Gains and/or Losses

Additionally, we offer commentaries in which our investment professionals discuss the general performance of the strategy during the preceding quarter to all discretionary account clients. The commentaries describe economic and market conditions that might have influenced performance, as well as other factors, such as particular industry, sector, security or other weightings. We understand that our clients can have varying requirements to complete their due diligence and ongoing monitoring programs, and we work with our clients to provide the necessary information and reporting. Wrap Program Clien ts Clients in wrap fee or managed account programs (including Dual Contract accounts) receive reports from the sponsor or financial intermediary. Jennison provides reporting to the program sponsors and will, upon request, provide reports to a client’s financial intermediary.

We do not take physical custody of the assets of our clients, and if we were to receive such assets inadvertently, they would be returned or redirected in accordance with regulatory requirements. Client assets are typically held in custodial accounts with banks, broker-dealers or other qualified custodians typically retained by our clients under arrangements negotiated by them. Although we do not have possession of client assets, under SEC rules we are deemed to have custody of client assets when we or one of our affiliates act as a general partner of a limited partnership, managing member of a limited liability company or comparable position for a pooled vehicle or trustee of a trust that we manage. Additionally, we are deemed to have custody when our clients permit us or an affiliate to deduct our management fees directly from their custodial accounts. Our clients for which we are deemed to have custody generally will receive account statements from their custodians no less frequently than quarterly and should carefully review those statements. Where our fees are deducted from the client’s custodial account, the statements will show those deductions. As described in Item 13 above under “Review of Accounts: Reports to Clients,” we also generally provide reports to our clients. Some of the types of information we provide in those reports are comparable to information in the account statements clients receive from their custodians. Our statements can vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities or sources of market data. We urge our clients to compare the account statements they receive from their qualified custodians with those statements that they receive from us. Private funds managed by Jennison are subject to an annual independent audit, and the audited financial statements must be distributed to investors within 120 days of the end of the funds’ fiscal year. A client’s custody agreement with its custodian might contain authorizations with respect to the transfer of client funds or securities broader than those in the client’s written investment management agreement with Jennison. In these circumstances, Jennison’s authority is limited to the authority set forth in the client’s written investment management agreement with Jennison regardless of any broader authorization in the client’s custody agreement with its custodian. The custodian’s monitoring, if any, of the client’s account is governed by the client’s relationship with its custodian.

We typically have the discretionary authority to purchase and sell assets for client accounts. For most of our clients, this authority is granted pursuant to a written investment management or similar agreement between the client and us. For clients in wrap fee programs, clients enter into wrap fee account agreements with the sponsor that contain a power of attorney appointing us to manage the client’s wrap fee account in the selected strategy. Clients in dual contract wrap fee programs enter into investment management agreements directly with us to grant us authority to manage their account in the selected strategy. Our discretionary authority to manage client accounts is in all cases subject to the specific objectives, guidelines and limitations set forth in the investment management agreement, separate agreement or other written instruction by an authorized party. Investment guidelines generally set forth the universe of eligible investments and issuers. As noted in Item 4, guidelines can also contain restrictions or limitations such as the following:

a list of prohibited issuers or types of issuers;

percentage limitations regarding the investment in certain issuers, groups of issuers, sector or instruments or types of investments;

percentage limitations regarding deviation from the holdings of the account’s benchmark;

specifications regarding the credit quality of holdings for the account;

limitations on the use of derivatives; or

percent limitations on foreign securities.

Additionally, some clients impose certain investment limitations on purchasing securities of companies that engage in certain types of businesses (for example, prohibit investment in tobacco or cannabis companies). If the client has not provided a list of prohibited securities, we rely on the list provided by a third-party vendor. These vendors provide the information “as is” and we cannot guarantee the accuracy of such information. We are not responsible for incomplete or inaccurate data. Certain clients are subject to additional investment, diversification and other limitations imposed by applicable law, including the Employee Retirement Income Security Act of 1974 (ERISA), the Investment Company Act of 1940, the Internal Revenue Code, other local or state laws or UCITS. Some clients impose limitations or restrictions on the receipt of unrelated business taxable income or U.S. effectively connected income. The clients should be aware that certain publicly traded investments are structured in a manner that could result in the allocation of income that could be treated as unrelated business taxable income (“UBTI”) if the security is held by tax exempt entities, such as corporate pension plans, foundations or endowments, or treated as effectively connected income (“ECI”) to non-U.S. clients. Although we seek to identify and avoid such investments for these clients, due to the difficulty in identifying these securities and the reliance on third-party vendor information that can be inaccurate or incomplete, we cannot guarantee that a client will not receive UBTI or ECI.

Client-imposed investment restrictions limit our freedom of action with respect to an account, and, as a result, the performance for accounts for which such investment restrictions are imposed will differ from, and could be worse than, the performance of accounts within the same strategy that lack such restrictions. Client accounts in which client-imposed investment restrictions are believed to have a potentially material impact on the implementation of the strategy are, based on Jennison’s judgment, excluded from the strategy’s performance composite. Clients should also understand that in order for Jennison to fully exercise our discretionary investment management authority, Jennison asks clients to execute and deliver any and all agreements, instruments, contracts, bond powers, stock power, transfer instructions, receipts, waivers, consents and other documents, provide any and all information and perform any and all such acts, as Jennison might deem necessary or reasonably desirable (collectively, “Necessary Actions”). If a client fails to any extent to perform any Necessary Action, Jennison might be unable to fully exercise its discretionary investment management authority and, consequently, the performance of the client’s portfolio might differ from the performance of similarly managed portfolios of Jennison with respect to which all Necessary Actions have been fully performed.

I n Gen eral We accept the authority to vote proxies on securities held in our clients’ accounts when our clients wish to provide us with this authority. Our investment management agreements with our clients will generally specify whether or not we have the authority to vote proxies on their behalf. Typically, where we have the authority to vote proxies, we vote in accordance with our proxy voting policy and procedures as further described below. Ou r Proxy V otin g Polic y an d Proc ed u res Our policy is to vote proxies in the best long-term economic interests of our clients without regard to our interests or the interests of our affiliates. In the case of pooled accounts, our policy is to vote proxies in the best long-term economic interest of the pooled account. We recognize that ballot issues, including environmental and social matters, can vary significantly depending on a company’s industry operations and geographic footprint. We will consider relevant factors in a manner consistent with our fiduciary duties and our objective of maximizing long-term shareholder value. We will not consider our own interests, or those of any affiliates, when voting proxies. Our proxy voting guidelines contain detailed voting guidelines on a wide variety of issues commonly voted upon by shareholders. These guidelines reflect our judgment of how to further the best longterm economic interest of our clients (i.e. the mutual interest of clients in seeing the appreciation in value of a common investment over time) through the shareholder voting process. Our guidelines for some ballot issues recommend deciding on a case-by-case basis. Additionally, from time to time, our investment professionals can, after considering their responsibilities under this policy, vote differently from our guideline recommendation for a particular situation. Such overrides of guideline recommendations are reviewed quarterly by our Proxy Voting Committee. Our Proxy Voting Committee includes representatives from our operations, risk, legal compliance, and sustainability areas. This committee is responsible for interpreting our proxy voting policy as well as reviewing potential conflicts of interest and annually assessing the policy’s effectiveness. The committee seeks to address any issues that might come up in the proxy voting process. Any proxy vote that represents a potential material conflict is reviewed by our Proxy Voting Committee. The committee also reviews the performance of our proxy voting vendor annually to determine if we should retain their services. We use the services of third-party vendors that provide proxy voting research and or voting administrative services, which include the receipt of and tracking of ballots, the implementation of our proxy voting guidelines, acceptance and recording of our vote instructions, recordkeeping and reporting. We typically rely on the issuer or our clients’ custodians to forward any materials regarding shareholder meetings to our vendor and we do not always receive all ballots in advance of voting deadlines. When ballots are received in a timely fashion, we strive to meet our voting obligations within industry standards. However, we cannot guarantee that every proxy will be voted prior to its deadline.

With respect to international holdings, in addition to the principles outlined above, we take into account additional restrictions in some countries that might impair our ability to trade those securities or have other potentially adverse economic consequences. For example, we do not typically vote foreign proxies for meetings where routine matters are considered if shares must be restricted from trading in order to vote at the meeting. We generally vote foreign securities on a best efforts basis if we determine that voting is in the best economic interest of our clients. From time to time, clients could deposit securities that are not actively researched by our fundamental equity research analysts into the accounts that we manage. Additionally, other accounts could be invested in securities that are selected through our quantitative investment process. In voting proxies for these securities, for issues where we have established a proxy voting guideline, we will vote in accordance with our proxy voting guideline recommendation. Additionally, in those circumstances where no specific guidelines exist, Jennison will consider the recommendations of the proxy voting vendor. Jennison’s proxy voting policy and procedures and proxy voting records are publicly available on our website. Clients can obtain a copy of our proxy voting policy, guidelines and procedures, as well as the proxy voting records for that client’s securities, by contacting the client service representative responsible for the client’s account. Note with R es p ec t to th e V otin g of Sec u rities on Loan Jennison might be unable to vote proxies when the underlying securities have been lent out pursuant to a client’s securities lending program. Jennison does not know when securities are on loan and are therefore not available to be voted. In rare circumstances, our investment professionals could ask our Proxy Team to work with the client’s custodian to recall the shares so that Jennison can vote. Efforts to recall loaned securities are not always effective since such requests must be submitted prior to the record date for the upcoming proxy vote; therefore, voting shares on loan is on a best efforts basis. In determining whether to call back securities that are out on loan, the investment professional will consider whether the benefit to the client in voting the matter outweighs the benefit to the client in keeping the security out on loan. Clien t Direc tion of V otin g Although most of our clients for whom we vote proxies authorize us to vote in accordance with our proxy voting policy, a client might request that we vote its proxies in accordance with a different policy. We try to accommodate such requests where appropriate. Where we have accepted client specified proxy voting guidelines, if the client guidelines do not address a proposal, we will vote in accordance with our proxy guidelines and procedures. In addition, a client might direct us to vote its securities in a particular way on a particular proposal and we will seek to do so, if appropriate, assuming timely receipt of the instruction. A third-party proxy voting vendor is responsible for operational implementation of client directed guidelines. Cu s tom Gu id elin es For certain investment products or vehicles that are developed and managed by Jennison that seek to follow certain religious values or sustainability objectives, Jennison adopts custom guidelines that are

aligned with the particular Jennison Investment Product. Certain Jennison Custom Guidelines are provided by a third-party proxy vendor. Prior to the adoption of Jennison Custom Guidelines for Jennison Investment Products, the Proxy Committee will review the custom guidelines. The Proxy Team will review the proxy voting records of the Jennison Investment Products that utilize the Jennison Custom Guidelines on a quarterly basis and provide reporting to the Proxy Committee. Con flic ts of I n teres t in th e V otin g Proc es s Occasionally, a conflict of interest can arise in connection with proxy voting. Examples include:

Management of a client solicits proxies, voting against management could affect Jennison’s relationship with the client A Jennison employee has a personal or familial relationship with an issuer’s management that could influence the voting decision An Investment Professional holds a personal position in an issuer’s security for which Jennison has a material investment and proxy voting responsibility.

Material conflicts must be reviewed and approved, in accordance with our proxy voting policy and procedures, by the investment professional’s supervisor and the Proxy Voting Committee. A c c ou n ts for Wh ic h We Do Not V ote Sec u rities Some of our clients elect to retain voting authority for themselves. Those clients receive proxies and other solicitation materials from their custodians, and if we receive these materials for the account of such a client, we will forward them to the client’s custodian. If a client has a question about a particular solicitation, the client can contact its client service representative and we will try to address the client’s question. Clas s A c tion s an d Corp orate A c tion s In addition to voting rights with respect to securities held in our clients’ portfolios, there could be other rights associated with those securities, including the right or opportunity to participate in class action settlements and corporate actions. With respect to class actions, we generally do not have responsibility, aside from affiliated accounts, for filing claims on behalf of our clients. Most clients have their custodians or other service providers handle notices of claim or can handle such notices themselves. In the instances where we have accepted responsibility to file notices of claims for class action lawsuits relating to securities held, or formerly held, in their portfolios while managed by us, we have retained the services of a third-party provider. The service provider will charge a fixed percentage of any amounts recovered. Utilizing data provided by us, our service provider will seek and use its best efforts to file such notices in all class action lawsuits in which the client is eligible to participate. In so doing, we will not inquire into the particular circumstances of any client. As a result, we will not seek to determine on an individual basis whether facts and circumstances relevant to that client would suggest that non-participation in the class action is appropriate or more advantageous to that client. For example, a client on whose behalf a notice of claim is filed can, as a result of having joined the

class, waive or relinquish other claims that it might have against the target of the class action. The client might also have an interest or position with respect to the nature of the class action claim that is adverse to that of the class of plaintiffs. We would generally not be aware of those circumstances. Had the client elected to handle class action lawsuits for itself, it might have determined not to file the notice of claim in such a class action. Unlike the U.S. class action process, investors are generally required to join non-U.S. actions as named plaintiffs or to “opt-in” at commencement of the lawsuit. This “opt-in” process usually requires an affirmative decision to join the lawsuit at an early stage in order to participate in any subsequent recovery of proceeds. The investor is also usually required to enter into one or more legal contracts for retention of counsel, funding arrangements and limitations of liability. We do not provide any legal advice or analysis, so we generally do not handle non-U.S. class actions for our clients. In addition, we generally do not act on behalf of our unaffiliated clients as a lead plaintiff in a class action lawsuit or as a plaintiff in any potential direct action. We do not provide any legal advice or services in connection with class actions or bankruptcies. With respect to corporate actions (such as an issuer’s merger, tender offer, dividend distribution, etc.), we participate on behalf of clients who authorize us to do so, taking such action as we deem to be in the best interest of the clients’ accounts and consistent with the investment strategy and objectives.

We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients.

For clients and prospective clients subject to ERISA: This brochure is being provided for informational purposes. In providing this brochure, Jennison (i) is not acting as your fiduciary as defined by the U.S. Department of Labor (DOL) and is not giving advice in a fiduciary capacity and (ii) is not undertaking to provide impartial investment advice as Jennison will receive compensation for its investment management services.