Longview Partners (Guernsey) LTD

General Description of Firms Longview Partners is a specialist investment management company, focused entirely on the management of global equity portfolios. The firm was founded in 2001. Our client base is almost entirely institutional with clients in North America, the UK, Europe, Australia and Asia. Longview Partners LLP is the investment management firm and its investment activities are all managed from its London office. Longview Partners (UK) Limited is the managing member of Longview Partners LLP. Longview Partners (UK) Limited is 100% owned by Longview Partners (Guernsey) Limited, the parent company. Longview Partners (Guernsey) Limited is majority owned by Northill Capital, part of the B-FLEXION Group with the balance owned by the following individuals: Marina Lund Alex Philipps Paul Crinion James Sellars Matthew Tunna Emma Davies Greg Wiles Ben Welsher James Williams TJ Voskamp

Chief Executive Officer (CEO) and Head of Institutional Clients Chief Investment Officer (CIO) Head of Research Deputy Head of Research Research Analyst Chief Financial Officer (CFO) Head of Operations Chief Operating Officer (COO) Optimisation Head of Global Distribution

Longview Partners (Guernsey) Ltd (“Longview Guernsey”) is an investment advisor. The company is a Guernsey limited company with its principal place of business in St. Peter Port, Guernsey. The company commenced operations in 2001 and has been registered as an investment advisor with the SEC since December 2007. In addition, Longview Guernsey is licensed and regulated by the Guernsey Financial Services Commission (“GFSC”). Longview Partners LLP (“Longview London”) is an investment advisor. It is an English limited liability partnership, with its principal place of business in London, England. Longview London commenced operations in the UK as Longview Partners LP in 2001. With effect from July 3, 2012, the business of Longview Partners LP was transferred to a new legal entity, Longview Partners LLP. Longview London has been registered with the SEC since April 2006. In addition, Longview London is also authorised and regulated by the Financial Conduct Authority (“FCA”) of the United Kingdom. Since June 2014, Northill Longview Holdings (Guernsey) Limited (formerly Northill Pallas Holdings (Guernsey) Limited), part of the Northill Capital Group (“Northill”), has owned a majority shareholding in Longview. Northill is part of the B-FLEXION Group, previously Waypoint. Ultimate ownership of the B-FLEXION Group rests with Ernesto Silvio Maurizio Bertarelli. Longview London is the investment management firm and the firm’s investment activities are all managed from our London office. As an investment manager we seek to consistently generate long-term alpha by investing in a concentrated portfolio of global equities. Our bottom-up approach invests in high quality companies with strong business fundamentals and attractive cash-based valuations. Longview Guernsey provides account management, administration and reporting functions in addition to overall Group risk and compliance oversight. Page 4 of 17

Within each client’s investment management agreement, Longview Guernsey delegates investment management responsibilities to Longview London while retaining reporting and administrative functions, as well as oversight of Longview London. This Brochure may also refer to Longview Guernsey and Longview London collectively as “Longview Partners”, “Longview”, or “the Group”. Description of Advisory Services Longview Partners is focused entirely on the management of a single Global Equity strategy. This can be accessed via a separately managed account or Longview Partners Investments SICAV (“the Fund”), although this vehicle is not available to US investors. Longview Partners does not offer any pooled investment vehicles to US investors. Longview Partners provides investment management services to sophisticated and experienced investors, almost exclusively to Institutional Clients and all on a discretionary basis. Investment management services are provided to clients such as corporate pension plans, government owned funds, pension plans of UK local authorities, sub-advisory accounts, US states, superannuation schemes, charities, foundations and endowments, as well as pooled investment vehicles. The investment objective of the Global Equity strategy is to generate alpha through investing in a concentrated portfolio of global companies. Longview Partners’ bottom-up approach invests in high quality companies with strong business fundamentals and attractive cash-based valuations. The process is disciplined, robust and rigorous within a detailed framework. The investment process analyses companies on three independent Investment Criteria – Quality, Fundamentals and Valuation. To be eligible for inclusion in the portfolio or to remain in the portfolio, a company must pass all three of these independent criteria. The independence of the Quality and Valuation criteria ensures that no company is of such high quality that any valuation will be accepted, and no company can ever be so cheap that Quality would be compromised. At Longview Partners, we have an integrated approach to evaluating Environmental, Social and Governance (“ESG”) risks and opportunities. Assessing the significance of environmental, social and governance related risks and opportunities is an integral part of our bottom-up research process and considered within our Quality rating, however ESG considerations are not Longview’s sole focus and the impact of ESG factors on performance is not separately measured. This investment process enables us to identify companies that we believe will generate long term sustainable returns. It is the output of the bottom-up, index-agnostic research process that drives portfolio construction. The portfolio is concentrated, typically investing in 25-40 companies whilst maintaining a focus on diversification and the avoidance of excessive exposure to macro factors and overexposure to common business drivers. Availability of Tailored Services for Individual Clients Longview Partners is able to tailor its advisory services to suit most particular client objectives, performance benchmark requirements and investment restrictions. For example, clients with segregated mandates may impose restrictions on investing in certain securities or certain types of securities, such as tobacco or securities from a specified country. These restrictions should not be able to have such a material effect on the construction of the client’s portfolio that it deviates substantially relative to other client portfolios in the Global Equity strategy. Philosophically, the portfolio is likely to have low carbon intensity relative to global Page 5 of 17

benchmarks due to the lack of exposure to oil and gas, mining, metals and deeply cyclical businesses. Longview tends to consider such businesses to be of insufficient predictability to pass the Quality criteria. Client Assets under Management As at 31st December 2025, Longview Partners managed USD 11.5 billion in our Global Equity Strategy, the firm’s single product offering and sole focus.

Advisory Fees and Compensation In return for investment management services performed, Longview Partners may charge either a management fee (based as a percentage of assets under management) or a combination of a lower management fee and a performance-based fee. Management Fees Longview’s Standard Management fee rate is based on the tiered fee schedule as laid out below: 0.75% on the first $50 million of assets under management; 0.65% on the next $50 million; 0.50% on the next $150 million; 0.45% on the next $250 million; and 0.40% on the remainder of assets under management. The management fee is generally payable quarterly in arrears, calculated on the average month end net asset value of the account. Performance-Based Fees A small number of clients have agreed to a lower management (base) fee (calculated in a similar way to above) with an additional annual performance-based fee. The performance fee is calculated as a percentage of the amount by which the account outperforms an agreed benchmark over a designated period. Payment of Fees With regard to all US and non-US clients with separately managed accounts, Longview Partners does not deduct any fee, whether management fees or other expenses, from client accounts. Instead, Longview Partners bills each client directly. Other Fees and Expenses In addition to paying management fees and, if applicable, performance-based fees, client accounts will also be subject to other investment expenses such as broker commissions relating to the execution of trades; interest expenses; taxes, duties and other governmental charges; transfer and registration fees or similar expenses; costs associated with foreign exchange transactions; other portfolio expenses; and costs, expenses and fees associated with services that may be necessary or incidental to such investments or accounts. Please refer to Item 12 of this Brochure for a discussion of Longview Partners’ brokerage practices.

Investment Philosophy We seek to consistently generate long-term alpha by investing in a concentrated portfolio of global equities. Our bottom-up approach invests in high quality companies with strong business fundamentals and attractive cash-based valuations. We believe in: Quality We seek to own high quality companies which can earn sustainably high returns on capital supported by demonstrable and enduring competitive advantages. Other Quality factors include identifiable growth, predictable cash flows, well-considered allocation of capital and Environmental, Social and Governance factors. We avoid investing in companies that are overly sensitive to external forces and exogenous factors beyond management control, such as commodity prices. Valuation We ensure a margin of safety in all of our investments by not overpaying for the shares of a company. We have strict buy and sell criteria based on each company’s valuation estimate, which is set using a discounted cash flow approach. Long-Term We believe that investing in companies that can compound value over the long-term will lead to superior investment returns. We believe in acting as owners of businesses rather than short-term stock speculators and that investment success should be measured over years and not quarters. The portfolio has low turnover and long average holding periods. Page 7 of 17

Concentration We believe that owning a concentrated portfolio of companies, whilst ensuring the portfolio remains diversified, offers the best opportunity to deliver strong investment returns with acceptable volatility over the long-term. The portfolio is typically composed of 25-40 names with high active share. Stock Selection We believe that stock selection drives portfolio returns, not incremental portfolio management. We dedicate our time to understanding companies and ascribing a fair market value to each company. We do not spend time predicting macro trends or trading around positions. Portfolio construction follows a rules-based philosophy founded upon new positions entering the portfolio at equal weight. Objectivity We believe that a collaborative team-based approach implementing a disciplined investment process drives objectivity and ensures consistency in decision making. Our investment philosophy has been in place since the inception of Longview Partners in 2001. Investment Process Longview’s transparent and robust investment process is disciplined, objective and consistent. Disciplined We believe that long-term returns can be best achieved through the implementation of a clearly defined, iterative and repeatable investment process that is well understood by both the Research Team and our clients. Objective We focus on a bottom-up, evidence-based process that minimises subjective judgements and seeks to reduce the influence of behavioural biases. We rate all companies on the same three independent Investment Criteria which are analysed and reviewed independently. Consistent Our process is consistently applied across our investment universe by our Research Team. We are openminded but accept that some types of companies are unlikely to pass our investment process (e.g. deep value and high growth). Every investment must pass all three of our independent Investment Criteria. The investment process judges companies on three independent Investment Criteria – Quality, Fundamentals and Valuation. To be eligible for inclusion in the portfolio or to remain in the portfolio, a company must pass all three of these criteria. The independence of the Quality and Valuation criteria ensures that no company is of such high quality that any valuation will be accepted, and no company can ever be so cheap that we would compromise Quality. Risk Management The CIO is responsible for investment risk management and risk management principles are incorporated within the whole investment process. Our risk philosophy is to incorporate risk management principles within the whole investment process, rather than just as an adjunct. Page 8 of 17

Philosophically, we believe that diversification offers the best tool for control of absolute risk in the portfolio. We do not believe that sectors, industries, or geographies provide a good framework for analysing risk and instead focus on identifying ‘risk clusters’. Risk clusters are the portfolio’s aggregate exposure to real business risks. Diversification is ensured by recognising, identifying and setting limits on any concentration in risk clusters across the portfolio. Risk clusters often cut across industries, geographies, or certain investment themes. We use our Key Risk Drivers framework to group risks into various general categories such as macroeconomic, geo-political and end-market, each of which have several sub-categories. This analysis is produced and updated by the Research Team on a quarterly basis. These groups and their sub-categories may change over time to reflect changing global macroeconomic conditions and changes to the portfolio. We strive to invest in predictable companies and to avoid investing in companies that are overly sensitive to external forces beyond their control. We view such forces as risks rather than opportunities. The CIO reports to the Head of Risk and CEO on a quarterly basis. The Head of Risk and CEO consider risk from both the absolute perspective through the Key Risk Drivers as well as the use of FactSet Analytics which aids analysis of both absolute and relative risk exposures in the portfolio. This analysis and reporting also drives both broader risk-based discussion on future expectations for the portfolio and financial markets, as well as focused discussion on specific securities with specific idiosyncratic risks. Together this ensures that consideration is taken of a wide range of potential risks and their likelihood and expected impact. Material Risks and Descriptions of Investment Risks Below is a discussion of the risks that are material to the investment strategy of Longview Partners: Equity Risk The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Such fluctuations can be significant over both short and long term periods, and different parts of the market and different types of equity securities can react differently to these developments. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer may adversely impact its securities. Geopolitical risks have led, and may in the future lead, to increased market volatility and may have adverse long-term effects on world economies and markets generally. Concentration / Stock-Specific Risk As an active manager, Longview invests in a relatively concentrated portfolio of securities. Changes in the financial condition of an issuer or counterparty, changes in specific economic or political conditions that affect a particular type of issuer and changes in general economic or political conditions can affect a security's or instrument's value, and hence the value of the overall portfolio. Securities of smaller or less well-known issuers may be more volatile and less liquid. Smaller issuers can have more limited product lines, markets, or financial resources. Foreign Investment Risk Longview invests in global securities, and foreign securities, foreign currencies and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial and other operational risks; and the less stringent investor protection, accounting and disclosure standards of some foreign markets. These factors may cause foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market. Page 9 of 17

Currency Risk Longview invests globally, and fluctuations in foreign currency exchange rates may affect the value of securities and portfolio returns when converted into the base currency. Currency movements may be volatile and are not always hedged. Even where currency hedging is undertaken by clients outside this strategy, such measures may not fully eliminate currency risk and may involve additional costs. Interest Rate Risk Changes in interest-rate environments, whether increases or decreases, may adversely affect equity markets, discount rates, consumer demand, and financing costs for companies. Rising interest rates, in particular, may lead to valuation compression for growth-oriented companies and negatively impact portfolio valuations. Inflation Risk Rising inflation may erode real investment returns and lead to higher input costs for companies, reduced consumer purchasing power, and tighter monetary policy. These factors may negatively affect equity valuations and corporate earnings. Market Liquidity Risk Securities may at times become less liquid or illiquid, particularly during periods of market stress or systemic disruption. Reduced liquidity can result in larger price movements, wider bid–ask spreads, and the inability to exit or adjust positions at desired prices or at all. Business and Operational Risk Longview’s operations may be adversely affected by failures in internal processes, systems, or controls, including technology malfunctions, human error, data-management failures, or disruptions at third-party service providers. Such events could impair the Firm’s ability to implement its investment strategy, process transactions, safeguard client assets, or maintain timely and accurate reporting, which could result in financial or reputational harm. Counterparty Risk While Longview primarily invests in listed equities, transactions, settlement, and custody activities expose the portfolio to the financial soundness and operational reliability of counterparties, custodians, and other service providers. A counterparty’s failure, insolvency, or operational disruption could result in financial loss or delays in transaction settlement. Cybersecurity and Information Security Risk Longview relies on information technology systems for research, trading, and operational processes. A cybersecurity breach, data loss, or system failure could disrupt operations, compromise confidential data, and adversely affect clients or the Firm. While Longview maintains policies and controls designed to mitigate these risks, such measures may not prevent all incidents or fully eliminate the associated risks. Regulatory and Compliance Risk Changes in laws, regulations, regulatory oversight, tax policy, or reporting standards in the jurisdictions in which Longview or its clients operate may adversely affect portfolio holdings or the Firm’s ability to conduct business. Enforcement actions, new rules, or regulatory changes may introduce additional constraints, compliance requirements, or costs. Investing in securities involves risk of loss, and clients should be prepared to bear such risks, including the possible loss of principal.

Longview Partners’ clients are almost exclusively institutions; corporate pension plans, government owned funds, pension plans of UK local authorities, sub-advisory accounts, US states, superannuation schemes, charities, foundations and endowments, as well as pooled investment vehicles. Our client base is almost entirely institutional with clients in North America, the UK, Europe, Australia and Asia.

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Longview Partners and its investment personnel provide investment management services to multiple portfolios for multiple clients. However, as a single strategy firm, with one common objective, barring any specific restrictions, a strong commonality between all client portfolios is expected. As discussed above in Item 5, Longview Partners is paid performance-based compensation by some of its clients. Longview Partners has adopted and implemented policies and procedures intended to address possible conflicts of interest relating to the management of multiple accounts. Longview Partners reviews investment decisions for the purpose of ensuring that all accounts with substantially similar investment objectives are treated equitably. Our investment process is implemented consistently for all clients regardless of the client’s underlying fee arrangements. The performance of similarly managed accounts is also regularly compared to determine whether there are any significant unexplained deviations. In addition, Longview Partners’ procedures relating to the allocation of traded investment opportunities require that similarly managed accounts participate in investment opportunities pro rata based on asset size and require that, to the extent orders are aggregated, the client orders are priceaveraged. These areas are monitored by Longview London’s Compliance team.

Longview Partners is majority owned by Northill and Northill is represented on the Board of Directors of Longview Partners (Guernsey) Limited, the group’s holding company. They are also represented on the Board of Directors of Longview Partners UK Ltd (the Managing Member of Longview Partners LLP). Longview has no other arrangements with Northill or its affiliates that are material to Longview’s business or its advisory clients. The Fund is a client of Longview’s but Longview as a firm has no ownership interest in the Fund. Longview is represented through two of four Directors on the Board of the Fund and so does not control the Board of the Fund. Longview Partners’ policy is to treat the Fund fairly and accord it the same treatment received by any separate account client using the same strategy. Subject to internal compliance policies and approval procedures, members and employees of Longview may engage, from time to time, in personal trading of securities and other instruments, including securities and instruments in which our clients may invest. Further information regarding Longview Partners’ Personal Account Dealing Policy (which is included within the Code of Ethics) is provided below in Item 11.

Code of Ethics Longview Guernsey and Longview London have both adopted a Code of Ethics (the “Code”) which, along with each entity’s Compliance Manual, collectively outlines supervisory procedures, codes of practice and guidelines expressing the firm’s commitment to ethical conduct. Longview is an equal opportunity employer and a strong advocate of diversity and inclusion and has a Diversity, Equity & Inclusion Committee. The Code describes Longview’s fiduciary duties and responsibilities to clients and sets forth Longview’s practice of supervising the personal securities transactions of supervised persons with access to client information. See below for further provisions of the Code as they relate to the personal account dealing. Members and employees of Longview Partners may from time to time have an investment in the Fund. Each new member or employee is provided with an electronic version of the Code and the relevant Compliance Manual, which are regularly updated. The Code, along with the Compliance Manual, outlines a list of guidelines, principles, policies and procedures which all members and employees must follow. It is the expressed policy of Longview Partners that no member or employee shall place his or her own interests ahead of those of an advisory client or make personal investment decisions based on the investment decisions made for advisory clients. Longview Partners claims compliance with the CFA Institute Asset Manager Code of Professional Conduct. This claim has not been verified by CFA Institute. Clients or prospective clients may upon request obtain a copy of the Code by contacting Client Services by email at clientservices@longview-partners.com Client Transactions in Securities where Longview Partners has a Material Financial Interest Page 11 of 17

Longview Partners recognises that a potential conflict of interest may exist because members and/or employees of Longview Partners may have an incentive to buy or sell securities on behalf of clients based on their own financial interests and those of the client, rather than solely in the interests of our clients. As stated within Item 10, Longview Partners’ policy is to treat the Fund fairly and accord it the same treatment received by any separate account client using the same strategy. With respect to Personal Account dealing, Longview Partners has a procedure in place to protect the interests of our clients. The prior consent of either the Guernsey or London Compliance team (as applicable) is required for all personal account transactions involving reportable securities. Once the relevant Compliance team is satisfied that no conflict/potential conflict of interest exists, permission is granted and the member or employee is free to trade within 24 hours of approval. In addition, initial, quarterly and annual reports of relevant securities owned and/or transactions undertaken are submitted to and reviewed by the relevant Compliance team. This procedure is applicable to all members and employees, regardless of position, or by any other party where an employee or member has a pecuniary interest in the transaction. All members and employees sign to accept the terms upon commencement of contractual arrangements with Longview Partners.

Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions Longview Partners is granted and accepts discretionary authority to determine the brokers used and the commissions paid. Longview pays its approved Research Providers from its own resources for all substantive investment research and does not seek to pass these costs on to clients. Initial broker selection criteria include a broker’s execution capabilities. This comprises an analysis of their quality of execution, ability to source quality liquidity, anonymity, differentiation, innovation and the breadth of the markets covered by them. In addition to execution capabilities, Longview evaluates the broker’s key personnel, looking at the feedback they provide pre-trade, during the trading process itself and also once the trade has been executed. Longview will also consider the reliability, integrity and financial stability of the broker. Longview’s goal when executing orders is to minimise market impact whilst also minimising the time it takes to complete the order. To ensure that Longview takes all sufficient steps to obtain the best possible result for our clients, we seek to balance the relative importance of costs of dealing and the following execution factors: Price: Achievement of the best possible price for the order. Implicit costs (market impact): The impact the order has on the price of the security during trading. There are subfactors that must be considered when trying to minimise this impact:

Information leakage – external knowledge of this order that could affect the price; and Footprint – leaving a ‘trail’ in the market that could affect the price.

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To minimise market impact, Longview has continued to seek greater anonymity when trading and we have developed our participation in alternative trading venues and in the use of broker algorithms. Longview uses internally developed tools to help monitor the implicit costs of market impact. Speed: The length of time to execute the order and the determination of the appropriate level of participation. Likelihood of execution: The potential opportunity cost of using one broker versus another. Longview has identified brokers through which it will most regularly seek to direct client orders. Only approved brokers may be used for client orders. Size of order: The size of the order as a percentage of the average daily volume traded of that security. Explicit costs: Commissions are regularly monitored to ensure that both the commission rate and overall commission paid are both in-line with market practice and commensurate with the level of service received. All commission rates are agreed with the executing broker prior to trading. Likelihood of settlement: Assessment of the counterparty’s operational capability and credit risk in order to maximise the likelihood of the order settling on time. The relative importance of these factors may be dependent upon the type of order. Types of orders include: Primary order: A buy or sell order of a single stock in the normal course of the investment process. Flow orders: Orders resulting from a client contribution or withdrawal. Longview uses the knowledge of each client’s circumstances and requirements to determine the factors that are considered for the purpose of providing best execution. Longview provides investment management services to a range of professional clients. Therefore, it is recognised that whilst price is an important factor in determining best execution, price alone will not determine whether best execution has been achieved. The Best Execution Committee (“BEC”) consists of the CIO, the Head of Compliance and the Head of Risk. The BEC meets on a quarterly basis and may be joined by members from teams including Compliance, Trading and Operations. The BEC are responsible for the following: • Supervision of the monitoring of best execution • Evaluation of best execution • Broker evaluation • Commission Costs • New broker approval • Broker removal • To discuss issues, adjustments, changes or improvements to brokers, execution or trading strategies Order Aggregation Longview Partners is required to have a trade allocation policy to ensure the fair aggregation and allocation of transactions between clients. Longview may place trades on behalf of its clients but is not authorised to deal on its own account. The Dealing and Trade Allocation Policy is designed to ensure that when Longview Page 13 of 17

aggregates a client order with another client’s order and subsequently allocates the executions, this is carried out consistently and in accordance with regulatory requirements, providing prompt, fair and expeditious execution of client orders. Longview allocates executions within one business day of the transaction. All allocations are intended to be fairly distributed amongst clients and in adherence with relevant investment objectives. Longview may revise an allocation of an aggregated order if an error is discovered. A reason for the re-allocation must be recorded. Where the executed amount is less than the intended aggregate order it is allocated on a pro-rata basis. The allocation is pro-rated by reference to the gross assets of each portfolio. Exceptions may occur if the execution is sufficiently small such that it is uneconomical, in terms of transaction and custody costs, to allocate pro-rata. Minimum lot sizes are set whereby certain portfolios do not participate if their allocation does not meet the minimum. Compliance monitors these allocations on a daily basis to ensure that no client is advantaged or disadvantaged. Longview allocates an aggregate order at the price received by the executing broker. If it appears that a trade error has occurred, Longview Partners promptly reviews the relevant facts and circumstances to determine an appropriate course of action. To the extent that trade errors and breaches of investment guidelines/restrictions occur, Longview Partners’ Breaches and Errors Policy ensure appropriate escalation and that clients are treated fairly.

Longview Partners has no contractual arrangements with third-party introducers of institutional clients.

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There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Longview’s advisory business or the integrity of its management.

Frequency and Nature of Review Investment review Portfolio positions are reviewed on an ongoing basis by the Research team, led by the CIO. The team meets regularly to discuss individual securities, in the context of our disciplined investment process. This iterative, bottom-up security analysis drives buy and sell decisions and, ultimately, portfolio construction. Portfolio Risk review Longview Partners has a Risk function which provides daily oversight and support. The CIO is ultimately responsible for investment risk management. The Head of Risk works alongside the CIO to oversee daily investment activities in areas such as the portfolio performance of each client account, asset allocation, exposure, volatility and liquidity. As such, securities positions for all accounts are subject to a daily review. Operations review Longview Partners’ experienced Operations department, managed by the Head of Operations, carries out daily full cash and security holdings reconciliations of all client accounts with the applicable custodian bank. Compliance review Longview London has an established and experienced Compliance department, led by the Head of Compliance, which regularly assesses and monitors all areas of business activity to ensure compliance with internal procedures and external regulatory requirements. The Compliance team carries out a full Compliance Monitoring Program to implement a set of written supervisory procedures and to test regulatory requirements on a monthly, quarterly, semi-annual or annual basis as applicable. Additionally, Compliance undertakes daily reviews of transactions and investigates any that appear to conflict with client restrictions. Also, using a compliance management and portfolio monitoring system, Compliance checks each client portfolio, checking holdings against rules to ensure that we remain within client guidelines and to highlight any potential or actual breaches. Full monthly monitoring Page 14 of 17

reviews are completed, and client-specific reports are generated as detailed in each client’s investment management agreement. Longview Guernsey has responsibility for client due diligence, including anti-money laundering, countering the financing of terrorism and countering proliferation financing. In addition, it provides oversight in all areas of compliance and reports to its own regulator, the Guernsey Financial Services Commission. Content and Frequency of Regular Account Reports Longview Partners provides clients (where requested) with a monthly report within 10 working days of the end of each month. Such a report includes the following items:

Portfolio performance Portfolio contributors and detractors Performance attribution (by sector) Regional allocation Top 10 holdings Sector and geographic allocation against the index Breakdown of exposure by currency Portfolio valuation Security transactions Income report Currency transactions Contributions and withdrawals

Longview Partners also provides clients (where requested) with a report within 15 working days of each quarter end, containing the following, in addition to the information included in the monthly report:

Market review and outlook Quarterly buys and sells ESG engagement Longview updates (changes to our people or processes) Commission Summary Carbon report

Longview also provides proxy voting reports on a quarterly basis to all clients invested in a separately managed account on whose behalf we vote. In addition, Longview Partners provides the client with any other periodic reports on their portfolio which the client may reasonably require and/or request, either in accordance with the clients’ investment management agreement or on an ad hoc basis. All such reports may be delivered electronically to the client investor in accordance with any agreements made with Longview Partners.

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This item is not applicable to Longview Partners.

Longview Partners provides investment management services on a discretionary basis to clients. Please see Item 4 above for a description of any limitations clients may place on Longview Partners’ discretionary authority. Prior to assuming discretion in managing a client’s assets, Longview Partners enters into an investment management agreement or other such agreement that sets forth the scope of Longview Partners’ discretion. Unless otherwise instructed or directed by a discretionary client, Longview Partners has the authority to determine (I) the securities to be purchased and sold for the client account (subject to restrictions on its activities set forth in the applicable investment management agreement and any written investment guidelines) and (ii) the amount of securities to be purchased or sold for the client account.

To the extent Longview Partners has been delegated proxy voting authority on behalf of its clients, Longview Partners complies with its proxy voting policies and procedures that are designed to ensure that in cases where Longview Partners votes proxies with respect to client securities, such proxies are voted in the best interests of its clients. In order to effectively meet the proxy voting requirements, Longview engages Glass, Lewis & Co. (“Glass Lewis”). Longview Partners’ policy on the exercise of voting rights on behalf of its clients is outlined in its Shareholder Activism Policy. Longview’s voting decision-making process is investment-led. Our Research Analysts use primary sources of information, in-depth discussions with company management, external research and recommendations from Glass Lewis to assist in their deliberations. Voting recommendations are made by the lead analyst for that particular company, but then must be approved by either the CIO or Head of Research. Glass Lewis casts our voting instructions across all client accounts that permit Longview to manage proxy voting on their behalf. Longview Partners seeks to always act in the best interests of our clients and where possible avoid conflicts of interest, including those which may arise through voting or engagement. Occasions may arise where a conflict or perceived conflict of interest exists. In such instances, all reasonable steps are taken to ensure that we put the interests of our clients first, as outlined in our Conflicts of Interest Policy. If Longview Partners does not have authority to vote client securities, clients receive their proxies or other solicitations directly from their custodian. Longview maintains a policy of not participating in class actions, unless specifically instructed to do so by a client. However, we do reserve the right to participate in specific cases. Clients may obtain a copy of Longview Partners’ Shareholder Activism Policy and obtain information about how Longview Partners voted a client’s proxies by contacting Client Services by email at clientservices@longview-partners.com

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Longview is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Longview has not been the subject of a bankruptcy petition at any time during the past ten years.

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