LOS ANGELES CAPITAL MANAGEMENT LLC

About the Firm Los Angeles Capital Management LLC (“Los Angeles Capital” or the “Firm”) is a discretionary institutional global asset manager registered with the SEC under the Investment Advisers Act of 1940, as amended (“Advisers Act”). The Firm was founded in 2002 and offers risk-controlled active equity management services to a broad range of institutional clients and LACM sponsored funds. The Firm has a wholly owned subsidiary, LACM Global, Ltd. (“UK Subsidiary”), in the United Kingdom that is registered with the Financial Conduct Authority. Leadership and Ownership Structure The Firm is organized as a California limited liability corporation primarily owned by LACM Holdings Inc. (“LACM Holdings”), a California corporation. LACM Holdings is one hundred percent employee owned and controlled by the Firm’s board of managers (the “Board”). The Firm’s Board consists of Thomas D. Stevens, Chairman, Daniel E. Allen, Chief Executive Officer and President, Hal W. Reynolds, Vice Chairman, Stuart K. Matsuda, Chief Trading Officer, Jennifer E. Pepin, Chief Compliance Officer, and Edward J. Rackham, Chief Investment Officer. Services Offered Los Angeles Capital constructs a wide range of investment strategies to meet specific client requirements across the developed and emerging equity markets. The Firm uses a quantitative forward-looking approach that is driven by its proprietary investment model technology (the “Model”). Statistical techniques are used by the Firm to evaluate a variety of metrics that have explanatory power for measuring stock price behavior. The Firm seeks to isolate and interpret how each of these factors is behaving in the current market environment. This approach results in a proprietary forecast of expected returns across a broad universe of more than 9,000 publicly traded equity securities. Based on these forecasts, client accounts are tailored to each institutional client's unique objectives and investment guidelines. Through a structured investment process, the Firm seeks to add value relative to the specific benchmark or other metric identified for each client account or on an absolute basis. Accounts are managed independently of one another in accordance with client specific mandates, restrictions, and instructions as outlined in their respective investment management agreements or other governing documents.

The Firm’s quantitative investment model technology allows the Firm to offer customized solutions to its institutional clients. As an example, the Firm can incorporate specific environmental, social, and corporate governance (“ESG”) information or an emphasis or restriction on certain geographic regions on a customized basis upon client request. In addition, the Firm can emphasize certain factors/themes such as momentum or growth to comply with a client request to maintain a permanent investment bias. Finally, the Firm can customize accounts to align the type and level of risk based on a client’s objectives and preferences. Middle and Back Office Service Providers The Firm has engaged a third-party middle-office service provider to provide accounting support and performance computation services for accounts trading derivatives. In addition, the Firm has engaged a back-office service provider to provide accounting services, including reconciliation services, certain corporate action administrative and processing services, trade settlement processing, and custodial communications. Assets under Management As of December 31, 2025, Los Angeles Capital had approximately $40,575,577,000 of client regulatory assets under management, and all assets were managed on a discretionary basis.

Investment management fees vary by investment strategy, return or risk objective, account assets under management, size of client relationship, long/short ratio, account structure and other competitive factors. Investment fees charged by the Firm are generally computed as a percentage of the market value of the assets under management in the account. In some cases, clients pay a lower base fee plus a performance-based fee. The specific manner in which fees are charged by Los Angeles Capital is established in a client’s written investment management agreement, Limited Partnership Agreement, or other legal documentation governing the account. Clients may be billed directly for fees, or they may authorize their custodian or fund administrator to debit fees from their account following receipt of an invoice. Investment management fees are not charged on proprietary accounts. Los Angeles Capital will generally bill its fees quarterly in arrears, based on the client’s custodian or fund administrator’s value of assets under management during the applicable quarter. Such fees can be calculated either (i) at the end of the applicable quarter, (ii) based on the monthly average value of assets under management during the applicable quarter, or (iii) based on a

methodology agreed upon with the client. Some clients elect to have fees calculated and billed monthly. Los Angeles Capital typically has the authority to directly debit fees from the accounts of the privately offered pooled investment vehicles it sponsors and for which it provides discretionary investment advisory services (each a “Private Fund”). These directly debited fees are typically calculated by the Private Fund’s third-party administrator or the General Partner. If required in the written investment management agreement or other governing documentation, fees are prorated for each capital contribution and withdrawal made during the applicable calendar month or quarter, as applicable. The Firm’s investment management agreements generally allow either party to terminate the applicable mandate upon prior written notice to the other. The required notice period for termination varies across agreements. If a client mandate begins or terminates on a date other than the end of a period used to value the account for purposes of calculating advisory or performance fees, such amounts will be prorated in accordance with the terms of the client’s written investment management agreement. Upon termination of any account, any earned, unpaid fees typically will be due and payable. There is no annual minimum base fee for investment advisory services. In measuring clients' assets for the calculation of performance-based fees, Los Angeles Capital typically includes realized and unrealized capital gains and losses. Los Angeles Capital has a standard fee schedule for each strategy that is marketed by the Firm. The standard fee arrangement can be negotiated with a particular client depending on a variety of factors, including whether the client is a seed investor in a new strategy, the size of the account, scope of the overall client relationship, the particular strategy selected by the client, and other requirements for managing the account. As a result, Los Angeles Capital may offer certain clients lower or higher fees than other clients in the same strategy. Separate Accounts Los Angeles Capital’s standard annual advisory fee schedules for separate accounts are as follows: U.S. Large Cap Strategies 0.35% on the first $50 million 0.30% on the next $150 million 0.20% thereafter

U.S. Large Cap Enhanced Strategies 0.25% on the first $50 million 0.20% on the next $150 million 0.15% thereafter

U.S. Mid Cap Strategies 0.50% on the first $50 million 0.45% on the next $150 million 0.40% thereafter

U.S. Small Cap Strategies 0.65% on the first $50 million 0.50% on the next $150 million 0.45% thereafter

U.S. Micro-Cap Strategies 0.85% on the first $50 million 0.75% on the next $150 million 0.70% thereafter

U.S. All Cap Strategies 0.55% on the first $25 million 0.45% on the next $175 million 0.35% thereafter

Global Strategies* 0.45% on the first $50 million 0.35% on the next $150 million 0.30% thereafter

Global Enhanced* 0.35% on the first $50 million 0.30% on the next $150 million 0.25% thereafter

ACWI ex-U.S. Strategies 0.45% on the first $50 million 0.35% on the next $150 million 0.30% thereafter ACWI Small Cap Strategies 0.80% on the first $50 million 0.70% on the next $150 million 0.65% thereafter

ACWI ex U.S. Small Cap Strategies 0.85% on the first $50 million 0.75% on the next $150 million 0.70% thereafter

World Strategies** 0.40% on the first $50 million 0.30% on the next $150 million 0.25% thereafter

World Enhanced Strategies** 0.30% on the first $50 million 0.225% on the next $150 million 0.175% thereafter

World Small Cap Strategies** 0.75% on the first $50 million 0.65% on the next $150 million 0.55% thereafter

World ex U.S. Small Cap Strategies** 0.85% on the first $25 million 0.75% thereafter

UK or Europe Large Cap Strategies*** 0.35% on the first $50 million 0.30% on the next $150 million 0.20% thereafter

Emerging Markets Strategies 0.60% on the first $50 million 0.50% on the next $150 million 0.45% thereafter

Emerging Markets Small Cap Strategies 0.90% on the first $50 million 0.80% on the next $150 million 0.75% thereafter

World Outcome Oriented Solution Strategies 0.40% on the first $50 million 0.30% on the next $150 million 0.25% thereafter

Market Neutral Strategies 1.00% on all assets; PLUS 20% performance fee on excess return over the benchmark

U.S., EAFE, World Active Extension Strategies (120/20 – 140/40)^ 0.20% on all assets; PLUS 20% performance fee on excess return over the benchmark

*ACWI benchmarks **Includes Multi-Region and EAFE benchmarks *** Single Region ^ Base fee adjusted for higher-levered active extension strategies

Performance fees described above are applicable for clients meeting the requirements of Rule 205-3 under the Advisers Act and are typically calculated on cumulative long-term performance over an agreed upon benchmark net of certain fees and may also be subject to a high-water mark provision. Private Funds For eligible institutional clients wanting to invest in a commingled vehicle in lieu of a separate account, the Firm makes a few of its strategies available in an open-ended private fund format. The Private Fund management fees differ from the separate account fee schedule for the respective strategy. The Firm has the discretion to reduce or waive fees of investors in a Private Fund, including for principals and employees of the Firm or its affiliates. The management fees typically are calculated and accrued monthly in arrears and paid at the end of each quarter. The Firm has entered into side letters with certain investors in Private Funds that give certain investors most favored nations terms with respect to fees, reporting, or similar items. These side letters can also modify certain terms of the Private Fund offering documents or Limited Partnership Agreement. An example would be the obligation to provide additional reporting or to provide compliance with applicable local law for the investor. The Firm reserves the right not to agree to the same side letter terms with all investors, unless required by law, rule, or regulation. As such, certain terms available to one investor in a Private Fund are not available to all investors in the same Private Fund, unless required by law, rule, or regulation. Collective Investment Vehicles Third-Party Funds - The Firm receives advisory or sub-advisory fees for its services to third-party registered investment companies and other collective investment vehicles formed in and outside of the U.S. These fees are paid monthly or quarterly in arrears based on the average daily net assets or the average of the month-end net assets for the portion of the fund managed by the Firm or based on a methodology agreed upon with the client. The fund adviser’s annual rates are

disclosed in the respective prospectus, statement of additional information, or other disclosure documentation of the fund. In some cases, the Firm receives performance fees from funds. Collective Investment Trusts (CITs) - The Firm receives investment advisory or sub-advisory fees for its services to third party collective investment trusts. These fees are calculated and accrued daily and are payable monthly or quarterly in arrears at annual rates as described in the collective investment trust’s Disclosure Memorandum or advisory or sub-advisory agreement. With respect to the collective investment trusts advised by the Firm (“LACM CITs”), management fees paid to the Firm and expenses can be waived by the Firm in its sole discretion, both voluntarily and on a negotiated basis. Furthermore, Los Angeles Capital could have an incentive to reduce expenses by limiting the number of countries invested in and/or otherwise limiting transactions due to associated expenses and expense subsidies. Subject to a list of exceptions approved by the Firm’s Investment Committee, investment decisions made outside of the Model require prior authorization and are monitored by Compliance. The Firm also has procedures in place to monitor account performance. UCITS - The Firm receives investment advisory fees for its advisory services to the Los Angeles Capital Global Funds plc, an investment company with variable capital incorporated with limited liability in Ireland that is authorized and regulated by the Central Bank of Ireland pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011, as amended (the “LACM UCITS”). Fees are calculated and accrued daily and payable quarterly in arrears at annual rates as described in the prospectus. The Firm receives a performance fee from investors investing in certain share classes of the LACM UCITS. The Firm is permitted, in its discretion, to rebate management fees charged to the LACM UCITS to any LACM UCITS investor and agree to an annual expense cap on certain share classes. Due to expense limitations and expense subsidies, Los Angeles Capital could have an incentive to reduce expenses by limiting the number of countries a sub-fund of the LACM UCITS invests in and/or otherwise limiting transactions. Subject to a list of exceptions approved by the Firm’s Investment Committee, investment decisions for the LACM UCITS made outside of the Model require prior authorization and are monitored by Compliance. The Firm also has procedures in place to monitor LACM UCITS’ performance. The Firm receives sub-advisory fees for its services to a number of third party UCITS in various jurisdictions (e.g., Ireland, Luxembourg). These fees are paid monthly or quarterly in arrears based on the average daily net assets or the average of the month-end net assets for the portion

of the fund managed by the Firm. The third-party fund adviser’s annual rates are disclosed in the respective UCITS fund prospectus. The Firm’s sub-advisory fees charged to UCITS fund investors are set by the respective UCITS fund board of directors. Brokerage, Custodial, and Other Expenses For the advisory or sub-advisory services, as applicable, that the Firm provides to separate accounts, Private Funds, third-party funds, UCITS, and collective-investment trusts, the Firm receives management fees (flat fee, asset-based, performance based, a combination of these types of fees, or no fees). In addition to the Firm’s management fees, clients will incur fees and expenses from third parties unaffiliated with the Firm relating to their accounts. These fees and expenses from third parties unaffiliated with the Firm could include, but are not limited to, brokerage commissions, custodial fees, proxy voting service fees, fees charged for deferred sales charges, odd-lot differentials, transfer taxes, stamp taxes, wire transfer and electronic fund fees, other fees and taxes on brokerage accounts and securities transactions, and other transaction costs and expenses. Clients in commingled vehicles such as the Private Funds and the LACM UCITS will also incur certain charges imposed by the third-party fund administrators, custodians, and transfer agents, and any extraordinary expenses (including indemnification) as the General Partner or Managing Member (either referred to as “General Partner”) determines in its discretion. Costs incurred in connection with an investment in which more than one Private Fund or account managed by the Firm participates in shall be borne pro-rata based on the amount invested by such entities or accounts. The governing documents for each commingled fund describe the standard fees and expenses allocable to the specific fund and its investors in detail. In the case of Private Funds where the Firm serves as the General Partner, the General Partner is responsible for and pays expenses related to office space and personnel. Each Private Fund bears all of its own expenses, which generally include, without limitation, investment-related expenses, (e.g., prime brokerage fees, brokerage commissions, research expenses, third-party custodial fees, bank service fees, withholding and transfer fees, clearing and settlement charges, and consultant expenses), filing and reporting fees, registration expenses, legal expenses, accounting expenses, auditing, bookkeeping, financial reporting and tax preparation expenses and other professional expenses, administration expenses, fees for data and software providers, the investment management fee and performance fee, as applicable, other expenses related to the purchase, sale, and transmittal of investments, organizational expenses, and any expenses relating to the initial and continuing offer and sale of interests (including printing, solicitation, and related expenses) and other expenses related to the Private Fund. If a strategy for the account involves derivatives, the

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As noted in Item 4, Los Angeles Capital employs a quantitative process to select investments and construct accounts. The Firm’s strategies rely on an account construction process that utilizes proprietary quantitative tools, models, and risk management processes. The main inputs into the account construction process are the Model’s forecasts on individual equities, proprietary risk estimates, and estimated transaction costs, however, at times, the account construction process is aided by portfolio management or trading discretion. The portfolio management team provides general oversight of accounts and has authority to make operational changes. Operational changes include but are not limited to the following: (i) cash management, (ii) activity related to corporate actions, (iii) updating restricted lists, (iv) getting the account optimization to solve, (v) addressing market holidays, and (vi) complying with guidelines. Actions considered to be operational in nature are not deemed to be investment decisions. In addition, the Firm’s Investment Committee has approved a list of investment decisions permitted to be made by Portfolio Management, and or Traders (other than an executive having a 25% or greater voting interest in the Firm) in conjunction with managing an account. These investment decisions may be made prior to the account’s optimization being run or after the optimization output. Investment decisions not outlined on the approved list require the approval of two members of the Investment Committee and one executive Portfolio Manager. Portfolio Management and other personnel of the Adviser will endeavor to exercise this discretion in a reasonable manner, but no guarantee can be made that such decisions will be successful or not have unintended or unforeseen consequences.

The investment process begins with the identification of factors that Los Angeles Capital believes investors deem important in assessing the value and risk of a stock. In accordance with the Firm’s investment philosophy, the Firm seeks to select factors that capture investor preferences which inform investors’ decisions to buy, hold, or sell a stock. These investor preferences include fundamental factors that can be categorized across five different themes: valuation, earnings, management, financial, and market. Investor preferences also include sector and country membership. The contribution to expected returns from these factors can and will vary over the course of a market cycle. Through the Firm’s proprietary attribution and forecasting process, the Model estimates the current risk premium associated with each factor. The Model then generates expected returns for a stock on its current factor exposures and the estimated risk premium for each factor. The Firm’s Model incorporates a variety of statistical techniques, some standard and some proprietary, which assist the investment team in evaluating the characteristics of equity securities and their expected payoffs. The Research department seeks to identify the most appropriate tools that will facilitate the investment process but does so in a way that is also mindful of the risks with each tool. The Firm is aware of the risks of putting too great an emphasis on any one particular aspect of the process and, as a result, attempts to measure and control the risks associated with each of these techniques systematically through the use of proprietary risk management tools. Several of the tools utilized by the Firm would be considered standard methodologies embraced by other practitioners in the industry. Overview of Risk Management The management of account risk is an intrinsic part of the account construction process employed at Los Angeles Capital. Through use of optimization technology, the client account is constructed to maximize forward looking returns while simultaneously minimizing risk and transaction costs. In trading risk against return the account construction process varies the amount of risk budget used within the account to reflect both the current level of market volatility and perceived performance opportunity. In addition, the account construction process allows Portfolio Management to explicitly control the account’s exposure to systematic drivers of risk while also controlling the levels of idiosyncratic risk shouldered by the account. The Firm employs a risk model in the measurement of both absolute and relative account risk for purposes of risk monitoring. While both realized and predicted risk are measured, predicted risks may also be decomposed into contributions to risk from industry, country, fundamental and specific risk

components. While the Firm generally seeks to control risk systematically, there is no assurance that risks will be effectively managed or mitigated. When needed, the Chief Compliance Officer works with Portfolio Management to understand and potentially mitigate sources of risk. The Firm primarily seeks to control risk for a given account through a combination of strategy weightings, position limits, and other controls that are programmed into the optimizer and Order Management System and seeks to eliminate unwanted risk and factor other risks into the decision-making process when deciding which positions to hold in a given account. This process is generally automated but remains under the oversight of Portfolio Management and the Chief Compliance Officer (and their respective teams). Portfolio Management and the Chief Compliance Officer (and their respective teams) monitor each account’s risk on an ongoing basis, and Portfolio Management may take action, or the compliance teams may advise Portfolio Management to take action, if unwanted risk is detected. Such actions include reducing strategy weights, lowering optimizer risk limits, adjusting other optimizer parameters and/or managing exposure through trading. Risks of a Quantitative Investment Process Financial markets are constantly evolving; therefore, Los Angeles Capital periodically considers enhancements to its Model. While Los Angeles Capital makes reasonable efforts to ensure that its Model works as intended, there is no guarantee that any specific enhancement or revision to the Model will work as expected or that no further revision will be required. There is no guarantee that such enhancements to the various quantitative models will be implemented on a timely basis or provide the intended results and could adversely affect performance. Furthermore, the quantitative models and execution techniques cannot fully match the complexity of the financial markets, and therefore, sudden, and unanticipated changes in underlying market conditions can adversely affect strategy performance. The Firm’s quantitative investment process relies on financial information made available by issuers. The Firm has no ability to independently verify the financial information disseminated by such public companies and is dependent upon the integrity of both the company’s management and the financial reporting process in general. Accounting irregularities, fraud, and mismanagement by an issuer can result in false reporting and losses to investors relying on such reports.

The account construction process relies heavily on the use of proprietary and non-proprietary data (both market and non-traditional (i.e., alternative)), software, and licensed, third-party intellectual property. The Firm uses models in the account construction process that are predictive in nature and have inherent risks. These inherent risks include, but are not limited to: (i) incorrectly forecasting future behavior; (ii) producing unexpected results in unforeseen or certain low-probability scenarios (often involving some kind of market disruption); (iii) relying on the timely distribution, accuracy, and reliability of voluminous data inputs supplied by third parties; (iv) the mathematical and analytical underpinnings of the coding and the accuracy in translating those analytics into program code; (v) the speed that market conditions change, and (vi) the successful integration of the various quantitative models in the account construction process. Each of these inherent risks can lead to potential losses in an account. Furthermore, the Firm may determine that certain available data, while potentially useful in the Model to generate forecasts and make investment and trading decisions, is not cost effective to gather, store, process, clean and/or organize due to either technology costs or third-party vendor costs and, in such cases, the Firm will not utilize such data. The Firm has full discretion to select the data it utilizes in its investment process. The Firm’s or a third-party’s use of new technologies including artificial intelligence (“AI”), generative AI applications or models, open-source AI, language models, and machine learning models to influence investment modeling, application development and coding, or other aspects of the Firm’s investment process could have an adverse impact on the Firm’s investment process. Use of such applications may directly or indirectly create security, data, operational, and keyperson risks. Firm or third-party systems or data that are integrated in the Firm’s investment process or general workflows can rely on or utilize such generative or open-source applications or models in providing a product or service, and such applications have access to proprietary or confidential information depending on user inputs in AI models. In addition, inaccurate inputs and the resulting impact on AI modeling cannot be verified and could result in a risk of diminished quality control or false or misleading information, including coding that may be used by the Firm or a third-party. Further, inherent bias in the construction of AI models can lead to a wide array of risks including but not limited to accuracy, efficacy, and reputation. For example, the market environments used to train AI models today could materially differ from future market environments. Finally, the Firm’s use of AI increases the key-person risk associated with the expertise needed to build and parameterize custom AI applications. Additionally, significant competition exists among quantitative investment managers. As a result, to the extent Los Angeles Capital’s Model closely resembles those of other quantitative

investment managers, there is a risk of a substantial number of market participants taking the same action with respect to an investment, and some of those market participants could be substantially larger in size and impact on the market. Furthermore, there is an increased risk that a market disruption broadly affecting quantitative investment models could adversely affect an account. Such a disruption could accelerate reductions in liquidity or rapid repricing due to simultaneous trading across a number of investors in the market, thereby causing accounts to suffer material losses. The research, techniques, and quantitative models developed by Los Angeles Capital are considered confidential and generally will not be disclosed to clients or prospects. Los Angeles Capital is not required and does not expect to disclose information that the Firm reasonably and in good faith considers proprietary and/or a trade secret (e.g., quantitative models) and which cannot be presented in a way that reasonably avoids such confidential disclosure. Furthermore, the Firm may choose not to notify clients about certain of its investment or operational process changes, the vast majority of which will be made without any notification unless required by law or contractual obligations. Risks of Errors The nature of complex quantitative investment management processes is such that errors may be extremely hard to detect, and in some cases an error can go undetected for a long period of time. Furthermore, each component of the investment process has elements that present the possibility for human error. In many cases it is not possible to fully quantify the impact of an error given the dynamic nature of the quantitative models and changing markets. While the Firm has a number of controls designed to assure that the investment process and account construction process operate as intended, analytical errors, software errors, development errors, and implementation errors, as well as data errors are inherent risks. Generally, the Firm will not notify clients or investors of non-compensable investment process or data errors or incidents. Investment Process Errors - Los Angeles Capital seeks to reduce the likelihood of material errors occurring during the implementation of the Model process. Regardless of the effectiveness of the Firm’s risk mitigation efforts, including internal testing, it is not possible to completely eliminate the risk of error as it relates to the programming of the Model and systems that govern the account management and trading functions. As a result, programming and modeling errors could adversely affect a client’s account. Programming and modeling errors are often extremely difficult to detect and could go undetected for long periods of time and some will never be detected. Clients and investors should assume that programming and modeling errors are present, and their ensuing risks and impact are an inherent part of investing with a quantitative

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Los Angeles Capital provides account management services to various types of institutional clients as outlined below. The Firm typically seeks a minimum separate account size of $50 million but has accepted a lower account size. The Firm’s Private Funds and LACM UCITS have minimum initial investments identified on their respective offering documents. These minimums are typically set at either $5 or $10 million. Los Angeles Capital, in its sole discretion, when deemed appropriate, is permitted to accept investments of less than the minimum stated in the Private Fund offering documents. The minimum initial investment in the LACM UCITS may be waived by a member of the LACM UCITS Board. The Firm provides investment advisory services to the following types of clients:

Institutional Clients - The Firm provides discretionary investment advisory services and/or sub-advisory services to public pension funds, corporations and their pension and profit-sharing plans, foreign pension plans, sovereign wealth funds, endowments, foundations, unions and Taft-Hartley plans, insurance companies, charitable and religious organizations, pooled investment vehicles, trusts, and other U.S. and international institutions.

Privately Offered Pooled Investment Vehicles - The Firm also sponsors and provides discretionary investment advisory services to commingled funds offered on a private placement basis to eligible institutional investors. Each Private Fund is managed according to governing documents that may include a partnership or LLC operating agreement, articles of association, and offering memorandum. Third party service providers provide administrative back-office, accounting, and record keeping services, including trade

settlement processing, and custodial services. Periodic reports for the Private Funds are prepared for investors generally based on the records of the service providers.

Registered Investment Companies - The Firm provides sub-advisory services to registered investment companies sponsored by unaffiliated third parties.

Foreign Investment Companies - The Firm provides advisory and/or sub-advisory services to the LACM UCITS, other unaffiliated UCITS, and UK Unit Trusts.

Collective Investment Trusts - The Firm provides advisory and/or sub-advisory services to collective investment trusts offered to tax qualified pension and profit-sharing plans and related trusts, governmental plans, and certain other qualified institutional investors.

Los Angeles Capital structures any performance fee arrangement subject to Section 205(a) (1) of the Advisers Act in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205-3 of the Advisers Act.

Los Angeles Capital manages accounts for which the Firm charges a performance-based fee, an asset-based management fee, a flat fee, a combination of these types of fees, or no fees. Los Angeles Capital’s portfolio management team manage accounts in the same strategy that are charged fees under different fee rates and structures. The management of accounts with performance-based fees has the potential to cause a conflict of interest by creating an incentive to favor accounts with performance-based fees over those without a performance fee in order to generate greater revenue for the Firm. A similar conflict exists from managing client accounts paying a higher asset-based fee than other accounts or accounts containing assets owned by the Firm, its employees, or its owners. Performance-based fee arrangements and higher fee-paying accounts create an incentive for Los Angeles Capital to recommend investments which may be riskier or more speculative than those which would be recommended under a flat fee, asset-based fee, or lower or no fee arrangement, as applicable. Los Angeles Capital manages separate account mandates side-by-side with commingled funds or proprietary accounts in which the Firm or its employees have an economic interest. This raises potential conflicts of interest with respect to allocation of investment opportunities because the Firm has an incentive to favor certain accounts over other accounts that may be less lucrative to the Firm or its affiliates, or to favor accounts in which it or its affiliates or employees are invested. In addition, Portfolio Management’s day-to-day management of multiple accounts creates a conflict of interest. Members of portfolio management know the size and timing of account trades, and as a result, it is possible that Portfolio Management could use this information to the advantage of certain accounts they manage and to the possible detriment of other accounts. Furthermore, Los Angeles Capital provides investment advisory services for many clients and most advisory agreements involve customized mandates, restrictions, launch dates, overlapping benchmark constituents, and guidelines. This side-by-side management can result in investment positions or actions taken for one client account that differ from those taken in another client account, in situations where trades in one account closely precede transactions in the same securities in a different account, or in situations where clients receive different execution prices when trading the same security during the same trading day but at different times. For example, one client account can engage in short sales of or take a short position in an investment that at the same time is owned or being purchased long by another client account. Conversely, Los Angeles Capital could hold a long position in an account while at the same time taking a short position on the same issuer in another account. These situations occur due to differences in the risk and guideline constraints and exposures governing a client’s account in comparison to the other accounts managed by the Firm. In addition, as a result of the liquidity characteristics of the

securities within certain strategies, larger accounts could require extended trading horizons and experience lower completion rates on orders, higher transaction costs, and reduced performance when compared to smaller accounts in the same strategy. Additionally, certain accounts and strategies (including Firm proprietary accounts) have higher turnover, creating more competition between and among client accounts, which can result in increased transaction costs, decreased liquidity in an investment, and/or impacts on the security price. These positions and actions can adversely affect or benefit different accounts at different times. Similarly, the order of account rebalances may work on some occasions to the account’s advantage or disadvantage. The Firm does not seek to ensure that all accounts receive identical execution results but seeks to manage such conflicts in a manner it believes to be fair and equitable over time. The Firm maintains and trades one or more proprietary accounts using strategies that may be similar or substantially different than those employed for client accounts. The management of these proprietary accounts creates conflicts of interest. In particular, the Firm has an incentive to allocate investment opportunities, execution priority, or account risk in a manner that could favor proprietary accounts over client accounts, and proprietary accounts may trade with fewer constraints, smaller capital bases, or different liquidity considerations than client accounts. As client accounts and proprietary accounts invest in the same securities the Firm recognizes that differences in execution timing and strategy give rise to conflicts of interest. Lastly, from time to time, enhancements to the Firm’s investment or trading strategies may be implemented incrementally, rather than simultaneously, across accounts pursuing similar or identical investment objectives. In addition, the Firm may evaluate certain enhancements in proprietary accounts before broader implementation. These practices may cause differences in implementation timing and results among accounts. To address the conflicts of interest described above, Los Angeles Capital takes reasonable steps to ensure fair treatment for clients in accordance with the requirements of applicable law. The Firm will seek to achieve best execution on all trades by making well-informed execution decisions intended to maximize client value under prevailing circumstances while minimizing overall trading and implicit and explicit implementation costs. The implementation of account decisions is decided without consideration of the Firm’s (or any of its personnel’s) pecuniary investment, or other financial interests, including without consideration of the different fees or compensation the Firm receives from clients. Furthermore, Los Angeles Capital does not invest the assets of separately managed client accounts in commingled funds sponsored by Los Angeles Capital.

Los Angeles Capital has adopted policies and procedures that are reasonably designed to monitor and prevent the Firm from inappropriately favoring one account over another. Policies, procedures, and processes employed by the Firm to mitigate conflicts among accounts include the following:

The Firm has implemented a Code of Ethics which outlines the Firm’s fiduciary duties through a set of general principles centered around placing the client’s interest before the Firm. Proprietary accounts are not permitted to be favored over client accounts.

The Firm employs a quantitative investment process which utilizes the Firm’s proprietary investment model technology to identify securities and construct accounts. Subject to a list of exceptions approved by the Firm’s Investment Committee, investment decisions made outside of the Model require prior authorization and are monitored by Compliance.

The Firm maintains policies and procedures designed to seek best execution for each account and to monitor execution quality.

The Firm’s strategies predominantly invest in liquid benchmark equities and equity swaps.

Client and proprietary accounts are managed independent of one another in accordance with account specific mandates, restrictions, and guidelines as outlined in the account’s investment management agreement or similar governing documentation and such restrictions and guidelines are monitored for compliance.

Trade allocation is determined prior to placing the trade with the broker and all accounts, including proprietary accounts, are monitored by Compliance for adherence to the Firm’s pro-rata and same average price trade allocation policies.

Proprietary orders are not sequenced or routed in a manner intended to confer preferential execution outcomes to proprietary accounts relative to client accounts. Where proprietary and client accounts trade the same security on the same day, the Firm’s execution practices are designed so that client accounts are not disadvantaged over time as a result of differences in account type or execution strategy.

The Firm typically executes an individual account’s orders in a single security through incremental trades that are aggregated and booked at a single average price.

The Firm’s compensation structure is comparable across all departments. The Firm rewards employees for their contributions to the Firm including their contributions to

improving the investment process. Management and performance fees inure to the benefit of the Firm as a whole and not to specific individuals or groups of individuals.

The personal trading of employees is subject to the requirements outlined in the Firm’s Code of Ethics and is monitored by Compliance.

See Items 11 below for more information about potential conflicts of interest and a summary of the Firm’s Code of Ethics and see Item 12 below for more information about potential conflicts of interest and details on the Firm’s trade allocation policies and procedures.

Broker, Dealer, Commodity Registrations As of the date of this filing, none of Los Angeles Capital, its parent entities, its UK Subsidiary, and their respective management persons are registered or have an application pending to register as a broker-dealer, municipal securities dealer, government securities dealer, or representative of a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. The UK Subsidiary is discussed in Item 4 above, and each employee of the UK Subsidiary is deemed to be “a person associated with” Los Angeles Capital (as defined in Section 202(a)(17) of the Advisers Act) and subject to Los Angeles Capital’s supervision and control.

Other Material Relationships Los Angeles Capital acts as both the general partner and the investment adviser to the following Private Funds:

LACM ACWI Ex U.S. Equity Fund L.P. (the “ACWI Ex U.S. Partnership”)

LACM EMII, L.P. (the “EMII Partnership”)

LACM Global Equity Fund L.P. (the “GEF Partnership”)

LACM Global Long/Short Equity Fund L.P. (the “GLSF Partnership”)

LACM Global Long/Short Equity (Offshore) Fund Ltd. (the “GLSOF Fund”)

LACM Master GLS Equity L.P. (the “GLS Master Partnership”)

LACM Large Cap Alpha Fund L.P. (the “LCAF Partnership”)

LACM World Small Cap Equity Fund L.P. (the “WSCF Partnership”)

Private Funds are organized as domestic or offshore (non-U.S.) companies, limited partnerships, or other legal entities, in order to meet the legal, regulatory and tax demands of investors and as determined to be appropriate by Los Angeles Capital. Los Angeles Capital has engaged KPMG LLP to audit the financials of its Private Funds as well as those of the Firm. Two management persons serve on the board of the GLSOF Fund. LACM UCITS - Los Angeles Capital acts as the investment adviser to the Los Angeles Capital Global Funds plc, a UCITS fund registered with the Central Bank of Ireland. The LACM UCITS has one subfund, LACM Global Sustainable Equity Fund. The sub-fund seeks to provide capital appreciation by investing in equity securities which are listed, traded, or dealt in on regulated global markets. In countries where the UK Subsidiary is authorized, the UK Subsidiary acts as a distributor of the LACM UCITS to institutional investors in countries where the applicable sub-funds are registered or where there is an available exemption from registration. Los Angeles Capital has engaged KPMG to audit the financials of the LACM UCITS. LACM CITs – Los Angeles Capital acts as investment adviser to a collective trust fund, the Los Angeles Capital Master Collective Investment Trust, which is available for the benefit of certain

qualified defined benefit and defined contribution plans, and certain trusts, entities or accounts that invest the assets of such plans. Please see Item 5 – Fees and Compensation – Commingled Investment Vehicles for conflicts disclosures.

Los Angeles Capital has implemented a Code of Ethics that establishes the rules of conduct for Los Angeles Capital, its parent entities, and its wholly owned subsidiaries to assist the Firm in meeting the requirements of Rule 204A-1 of the Investment Advisers Act, Rule 17j-1 of the Investment Company Act of 1940, and the Financial Conduct Authority Principles for Business and Conduct of Business. These policies and procedures generally relate to the Firm’s standards of business conduct and employee personal trading practices that are designed to manage any actual or potential conflicts of interest. Every employee of the Firm is considered an Access Person, unless otherwise exempted by Los Angeles Capital’s Approving Officers. Code of Ethics Los Angeles Capital anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will buy, sell, or hold securities in client accounts that are directly or indirectly held by Los Angeles Capital and/or its Access Persons. As a result, Los Angeles Capital’s Access Persons, and their family members, including a spouse or domestic partner, a minor child, any relative or significant other living in the employee’s household (“Related Parties”) are required to follow Los Angeles Capital’s personal trading procedures. General Principles The Firm acts as a fiduciary to its clients and investors and therefore has an affirmative duty of care, loyalty, honesty, and good faith to act in the clients’ best interests. The Firm’s personnel have an obligation to uphold these duties. At a minimum, the Firm and its Access Persons must conduct themselves in accordance with the following principles at all times: • The duty to place the interests of clients before the Firm and themselves • The duty to conduct business with integrity • The duty to act in a professional and ethical manner • The duty to act with skill, competence, and diligence • The duty to communicate with clients in a timely and accurate manner

The requirement that all personal securities transactions be conducted in such a manner as to be consistent with the Firm’s Code of Ethics and to avoid any actual or potential conflict of interest or any abuse of an Access Person's position of trust and responsibility The duty to protect client assets The duty to take reasonable care to organize and control the Firm’s affairs responsibly and effectively, with adequate risk management The principle that investment adviser personnel should not take inappropriate advantage of their positions The duty to keep information concerning the identity of security holdings and the financial circumstances of clients confidential Decisions affecting clients are to be made with the goal of providing suitable advice and equitable and fair treatment among clients The duty to keep communications with clients or prospective clients candid and fulsome, true and complete, and not misleading or misrepresentative The principle that independence and objectivity in the investment decision making process is paramount The duty to report any violations of the code to the Chief Compliance Officer or General Counsel

In addition, each employee must comply with applicable federal securities laws and Firm policies, and as an adviser the Firm and its employees are prohibited from the following: • Employing a device, scheme or artifice that would defraud an investment advisory client • Making an untrue statement of a material fact to a current or prospective client or investor or omitting a material fact that would be necessary in order to make the statements not misleading • Engaging in any act, practice, or course of business which operates or would operate as a fraud or a deceit upon a client • Engaging in any manipulative practice with respect to a current or prospective client or investor • Engaging in any manipulative practice with respect to securities, including price manipulation, acting on, or spreading false market rumors • Making use of any information that an employee may have become aware of by virtue of his/her relationship with a current or prospective client or investor organization

Restrictions on Personal Trading Subject to the above, Access Persons of Los Angeles Capital and their Related Parties may trade for their own accounts in securities which are recommended to and/or transacted in for Los Angeles Capital’s clients. The Code of Ethics is designed to avoid actual and potential conflicts of interest and ensure that the personal securities transactions, activities, and interests of the Access Person and their Related Parties will not interfere with (i) making decisions in the best interest of advisory clients; and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code of Ethics, certain classes of securities have been designated as reportable, restricted, or exempt transactions, based upon a determination of materiality and potential interference with the best interest of Los Angeles Capital’s clients. In addition, the Code of Ethics requires pre-clearance authorization from both the Trading and Compliance departments for certain transactions. Nonetheless, because the Code of Ethics in some circumstances would permit Access Persons and their Related Parties to invest in the same securities as clients, there is a possibility that the Access Person or Related Party might benefit from market activity by a client in such security. Access Person and Related Party trading is continually monitored under the Code of Ethics and is designed to reasonably identify and prevent conflicts of interest between Los Angeles Capital and its clients. Outside Business Interests Employees are not permitted to engage in Outside Business Interests without written approval from their supervisor, the CCO, General Counsel, and the CEO. Approval is subject to the implementation of procedures to safeguard against potential conflicts of interest. Restrictions on Gifts and Entertainment Los Angeles Capital has a policy governing gifts, favors, entertainment, or other things of material value that include approval or reporting processes for gifts and entertainment provided to or given by Los Angeles Capital employees. Whistleblower Policy The Firm has a policy requiring employees to report any suspected or actual illegal activity or activities not in compliance with the Firm’s formal written policies and procedures, including the Firm’s Code of Ethics.

Insider Trading Rules From time to time, Los Angeles Capital employees may come into possession of material, nonpublic information (“MNPI”) which, if disclosed, might affect a reasonable investor’s decision to buy, sell, or hold a security. Los Angeles Capital has a policy on insider trading that prohibits employees from trading securities, either personally or on behalf of others, including client accounts, while aware of MNPI about the issuing company or that may impact an issuing company. The policy further prohibits the communication of MNPI to others in violation of the law. The policy establishes procedures to mitigate the receipt and spread of MNPI and to prevent insider trading that could be attributed to the Firm or its employees. Accordingly, should Los Angeles Capital employees come into possession of MNPI with respect to an issuer or a comparable issuer, Los Angeles Capital employees (i) will not take or refrain from taking any action, recommending, or transacting in the issuer or a comparable issuer on behalf of themselves or others, including client accounts; (ii) report the matter to Compliance or Legal; and, (iii) refrain from discussing the MNPI with anyone inside or outside the Firm and protect the information from others who may have access to it. Where an employee has come into possession of MNPI about an issuer, there are limited circumstances that would allow the Firm’s trading in the issuer or a comparable issuer to continue. These limited circumstances are permissible due to the Firm’s quantitative investment process and are contingent upon implementation of prescribed procedures to establish information barriers. All employees receive Code of Ethics and Insider Trading training and must provide written acknowledgement of receipt of such policies and of their intention to comply. Material changes to the Code of Ethics and Insider Trading policies are made available, as amended, to all employees. A complete copy of Los Angeles Capital’s Code of Ethics is available to clients or prospective clients upon request by contacting the Firm’s CCO via email at compliance@lacapm.com. Other Conflicts of Interest Arrangements with Affiliates and Others Los Angeles Capital acts as both the general partner and the investment adviser to the ACWI Ex U.S. Partnership, the EMII Partnership, the GEF Partnership, the GLSF Partnership, the GLS Master Partnership, the LCAF Partnership, and the WSCF Partnership. Furthermore, Los Angeles Capital acts as the investment adviser to the GLSOF Fund. As a general partner, Los Angeles Capital has up to a 1% general partner interest in each partnership. Los Angeles Capital earns management fees which sometimes include performance fees directly from each partnership or its investors. Therefore, Los Angeles Capital may recommend to clients investment products in which Los

Angeles Capital has some financial interest, and during the course of trading may buy or sell for itself securities it also recommends to clients. Los Angeles Capital recommends an investment in the partnerships only when consistent with its fiduciary duty. Los Angeles Capital acts as the investment adviser to LACM Global Sustainable Equity Fund, an Irish registered UCITS sub-fund of Los Angeles Capital Global Funds plc. In that capacity, Los Angeles Capital earns management fees directly from the fund, and if negotiated with an investor, Los Angeles Capital will receive performance fees from the investor. Los Angeles Capital’s UK affiliate recommends an investment in this sub-fund to non-U.S. investors only when consistent with its fiduciary duty. The Firm makes payments, out of its own profits, to unaffiliated platforms for distribution and sales support activities, including services related to shares or shareholders of the LACM UCITS for which the Firm provides investment advisory services. Please refer to Item 6 for a description of how Los Angeles Capital mitigates these conflicts in its investment process. The UK Subsidiary enters into distribution arrangements with respect to the LACM UCITS. The UK Subsidiary does not receive compensation from the LACM UCITS for providing such services. However, the UK Subsidiary is remunerated by the Firm under a global services agreement between them. Under this arrangement the UK Subsidiary’s remuneration is calculated on the basis of its expenses plus a fixed percentage of qualifying expenses. Furthermore, any new arrangements between affiliates are reviewed by Compliance, Legal, and/or the Firm’s Board for any potential conflicts of interest. Clients/Service Providers In addition, from time to time the Firm trades in securities issued by our clients, including for its own proprietary accounts. The Firm has a potential conflict in such circumstances because the Firm may be incentivized to favor its clients that issue securities over the account on whose behalf the Firm is making the investment. Similarly, some of our vendors and counterparties are issuers of securities that the Firm may trade in from time to time. Los Angeles Capital may determine that it is in the best interests of our clients to purchase or sell securities issued by one of these entities. It is Los Angeles Capital’s policy that its clients’ interests take precedence and that its employees and Access Persons disregard any other relationship, arrangement, material interest, or conflict of interest which may serve to influence, or appear to influence, its discretionary management.

In addition, contracts with service providers are negotiated at arms-length. Please refer to Item 6 and Item 12 for a description of how Los Angeles Capital mitigates these conflicts in its investment process.

Counterparties Los Angeles Capital does not have an affiliated broker-dealer and seeks to achieve best execution when selecting counterparties on behalf of client accounts through its approved list of brokers, dealers, Futures Commission Merchants (FCMs), and directly accessed execution venues. The Firm executes orders in a variety of exchanges and venues depending on availability in each market. In selecting brokers or dealers for client transactions, the Firm considers a variety of qualitative and quantitative factors, which may include, among others: execution capability, commission rates, access to liquidity, responsiveness, trading expertise, ability to execute trades efficiently across different market conditions, financial responsibility, operational reliability, and the quality of services provided in connection with trade execution. Counterparties may be added to the approved list without undergoing diligence or Best Execution approval at the time of addition, if they are selected for use by the client. In these cases, trading is limited to the client’s particular account until a diligence review is completed. Diligence at any interval can impact a counterparty’s internal risk rating. The Firm may elect to suspend usage of any counterparty or venue on its approved list at the direction of the chief trading officer or one of the chief trading officer’s designees. Counterparties and venues may be terminated or removed from the approved list with consent from the Best Execution Committee. The Firm conducts an ongoing review of broker-dealers and FCM’s used for client transactions to assess whether they continue to provide execution and services consistent with the Firm’s duty of best execution. As part of this process the Firm reviews where relevant: the execution quality and capability, financial strength and stability, responsiveness to the Firm, and other factors the Firm considers relevant. Los Angeles Capital negotiates equity and swap execution rates with its brokers and dealers and has negotiated the same bundled and unbundled equity execution commission rates by market

across all of its approved equity broker-dealers and execution venues 1. While the vast majority of equity trades are executed at the Firm’s standard rates, on occasion, the Firm places equity trades at higher or potentially lower commission rates. 2 Paying such non-standard rates could, for example, allow the Firm to more timely fill an order; not subject an order to market volatility; not subject an order to concerns about future liquidity; or take advantage of discounts on lower priced stocks. Futures commissions vary by contract type, broker-dealer, and account. Los Angeles Capital developed a proprietary Brokerage Allocation Randomization system designed for objectively pairing which equity broker-dealer to use when executing an account’s transactions based on regional market eligibility and suitability characteristics, as well as the broker’s perceived execution capabilities within such regional markets. The Brokerage Allocation Randomization system is automated on a weekly basis with a new pairing selection output each week. 3 For U.S. strategy accounts, equity brokers are assigned through randomized logic and the accounts are subsequently assigned to a trader by the chief trading officer or designee. For nonU.S. strategy accounts, equity brokers are assigned by randomized logic across global regions or based on strategy (e.g., emerging markets). To facilitate the Brokerage Allocation Randomization system, the Firm’s Best Execution Committee reviews its approved equity brokers to determine regional or strategy-specific suitability and to establish standards of peer equivalency for broker eligibility in various regional markets. This general selection randomization based on review of fundamental execution quality is intended to mitigate incentives to actively direct commissions to a particular equity broker. The Firm targets no more than 20% of its aggregate equity commission dollars (across all accounts managed by the Firm) to any one approved brokerage firm over the calendar year. 4 The Firm reserves the right to re-evaluate this ratio periodically. Changes require the approval of the Best Execution Committee.

Chinese securities trading on the Stock Exchange of Hong Kong may be executed at either the Developed Global rate or the Emerging Markets rate depending on the account’s strategy. For example, commissions are generally not assessed on trades that are less than USD $1.00/share, zero commissions may be negotiated on some trades, and broker principal trades may be executed at a negotiated rate higher than the Firm’s standard commission table. The chief trading officer or his/her designee may permit an exception to the randomization output for a variety of reasons, including but not limited to broker availability, news absorbed post-randomization, commission recapture directives, etc. Aggregation is based on commissions paid among all regions.

Client Directed Brokerage Unless a client’s investment management agreement states otherwise, Los Angeles Capital typically has full discretion and authority to determine the securities to be purchased or sold for clients, the amount of such securities (subject to client-established guidelines), and the counterparties or venues used for trade execution. A client may request in writing that Los Angeles Capital direct a portion of the client’s commissions, for certain strategies, to a particular broker-dealer in exchange for services received by the client. Regardless of client directed brokerage instructions, Los Angeles Capital has a duty to seek best execution and this duty may limit the Firm’s ability to satisfy client directed brokerage targets. Accounts with client directed brokerage arrangements will pay the bundled equity commission rate. Los Angeles Capital’s client directed brokerage arrangements are structured to comply with the CFA Institute Soft Dollar Standards regarding client directed brokerage. Accordingly, Los Angeles Capital will not permit commissions from one client account to satisfy the client directed brokerage requirements set by another client account. Trading Strategy The Firm will seek to achieve best execution on all trades by making well-informed execution decisions intended to maximize client value under prevailing circumstances while minimizing overall trading and implicit and explicit implementation costs. Los Angeles Capital uses a variety of different trading strategies and techniques in its efforts to achieve best execution for accounts. The trading strategies applied by the Firm’s traders and/or Portfolio Management may differ depending on the investment strategy, guideline restrictions, market conditions, liquidity considerations, client activity, risk tolerance levels, and/or other relevant considerations. Account trading strategies include, but are not limited to, varying the frequency and order of account rebalances (e.g., daily, weekly, semi-monthly, monthly, or quarterly ), varying the grouping of accounts or markets traded within accounts on a particular day (e.g., trading U.S. accounts before global accounts, or rotating strategies by week), varying account turnover, aggregating trade lists, aggregating specific names within trade lists, varying names traded as a block, using third-party algorithms, using limit orders, and adjusting executing broker-dealer trade strategy instructions. The Firm reserves the right to evaluate and implement trading strategies, methods, and processes to further its best execution mandate for client accounts.

Trading frequency for each account is determined based on a variety of factors including the applicable strategy, investment guidelines, risk metrics and turnover goals. While most accounts are currently traded at least semi-monthly, certain accounts may trade more or less frequently depending on such things as turnover goals, market conditions, and other factors unique to the strategy or markets in which the account is invested. Proprietary accounts are traded in rotation with other similarly managed client accounts. Proprietary accounts may not receive execution priority, sequencing advantages, or preferential liquidity access due to account size, flexibility, or frequency of trading. Foreign Exchange Los Angeles Capital trades foreign currency transactions to facilitate the operational cash requirements of multi-currency accounts and to facilitate the settlement of foreign equity trades in markets where it is permitted, and where the operational risks of active currency trading are not deemed excessive. These foreign currency transactions are traded for spot, short dated forwards, or in alignment with the related equity trades’ settlement cycle by utilizing, but not limiting itself to, a multi-dealer FX trading platform that generates competitive broker-dealer quotes and provides foreign currency trading algorithms, all in an effort to achieve favorable foreign exchange pricing and best execution. FX orders requiring execution at specific fixing times, such as the London 4pm close, are executed directly with a single dealer rather than through a competitive process. For countries with restricted currency markets, countries where the operational risk of active currency trading is deemed excessive, or where custodial limitations exist, certain tags are included in SWIFT instructions, or standing instructions are in place at the client’s custodian to execute these foreign currency transactions. Standing instructions are executed by the client’s custodian in accordance with its internal policies and applicable local market practices. With respect to restricted currency markets, the Firm is not able to assist in trying to achieve favorable pricing. In these circumstances, responsibility for ensuring acceptable execution rests with the client and its custodian. Los Angeles Capital’s third-party multi-dealer platform enables the Firm’s foreign exchange traders to analyze the quoted rates for currency pairs from its foreign exchange dealers to execute the most competitive rate available at the time of the trade. Participation rates among foreign exchange dealers are reviewed during Best Execution Committee meetings in an effort to maintain depth and competitiveness among the Firm’s foreign exchange execution program.

Foreign exchange dealer rosters are not uniform across accounts or currencies. For instance, some dealers only trade semi-restricted currencies for their own custody clients, and some dealers have contractually limited the accounts in their trading agreements. Accounts with limited dealer rosters are excluded from netting to not constrain clients with the full roster. Los Angeles Capital engages a third-party consulting service to assist in understanding, isolating, and monitoring the indirect or hidden transaction costs of trading foreign currency. Analysis of the trades executed through custodian standing instructions is limited due to the unavailability of detailed transaction data from the executing custodian or delays in sourcing the data. When trading foreign exchange derivatives with counterparties other than the client’s custodian bank, Los Angeles Capital negotiates and/or enters into an International Foreign Exchange and Currency Option Master Agreement (IFXCO), ISDA Master Agreement, or other agreement with the counterparty. While it is ultimately the client’s decision, Los Angeles Capital encourages client’s elect to utilize Continuous Linked Settlement 5 (“CLS”) with their custodian to ensure simultaneous wires and minimize settlement risk. Futures Trades If permitted by the client, Los Angeles Capital may utilize exchange traded futures to equitize cash balances as part of its day-to-day management of account cash at the direction of Portfolio Management. Equity Security-Based Swap Trading If permitted by the client, Los Angeles Capital may utilize equity security-based swaps to obtain long or short equity exposure to individual securities or baskets of securities at the direction of Portfolio Management. In general, swap orders are executed in a manner consistent with the best execution processes described above, however, because swaps are bilateral transactions, swap orders are generally executed exclusively with the applicable swap dealer (i.e., no give-ups), are not cleared by an exchange, and expose the Firm to counterparty risk with the swap dealer. Additionally, FX associated with global swap transactions may be required to trade exclusively with the swap dealers outside of the Firm’s FX trading platform. CLS mitigates settlement risk through the provision of its unique payment versus payment settlement service which has direct links to the real time gross settlement (RTGS) systems of the currencies it settles. In addition to mitigating settlement risk, CLS also streamlines and standardizes FX operations thereby reducing costs.

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The Firm does not currently compensate any person for client referrals. Brokers The Firm does receive indirect compensation from its soft dollar practices described in Item 12. The Firm receives research and other products and services from broker-dealers that execute trades for accounts. Broker-dealers on the Firm’s approved broker-dealer roster, Virtu Americas LLC, and Instinet, LLC, provide other services to the Firm, aside from brokerage services, free of charge. These services include such products and services as execution management systems, cost curves data, transaction cost analytics, pre-trade liquidity, macro and company specific research, market structure reports and commentary, program trading conferences, and have provided customizations to their technologies to facilitate the Firm’s trading processes. The Firm’s selection of broker-dealers to execute client trades is described in Item 12 and is based on considerations relating to best execution and is not impacted by these arrangements. Conferences and Events Los Angeles Capital provides education conferences or events for clients, prospects, and consultants. Los Angeles Capital pays the associated food, beverage, and facilities related expenses for such events. Los Angeles Capital also pays fees to attend, speak at, or assist in sponsoring conferences or events organized by others, including those that have a business relationship with the Firm or its clients. These sponsorship activities may include direct payments to vendors and/or reimbursement of expenses incurred by the organizers of such events. See Item 11 for a description of Los Angeles Capital’s code of conduct.

Registered investment advisers are required to disclosure in this Item all material facts regarding any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the Firm or the integrity of its management. Los Angeles Capital has no information to report applicable to this Item.

The primary departments that support Los Angeles Capital in its review of client accounts are Portfolio Management, Operations, and Compliance. The Portfolio Management team (the “PM Team”) touches all aspects of the investment process and is responsible for the ongoing monitoring of client accounts to review the Firm’s factor and alpha forecasts. Furthermore, the PM Team monitors client stated investment guidelines and the Firm’s optimization parameters. The PM Team reports its findings to the Portfolio Review Committee ("PRC"). The PRC is comprised of members of the Investment Committee, Portfolio Management, and Research. The PRC conducts monthly reviews of the Model’s outlook and account performance, characteristics, and risk profiles. Members of the Portfolio Management and Operations teams regularly monitor and analyze the cash balances in client accounts to confirm sufficient funds are available in local or base currencies. Client account records are reviewed on a daily basis in order to support trade activity and at least monthly to compare account market values against those of the account’s custodian or fund administrator, and to facilitate client reporting. The Compliance department provides an additional level of account review to monitor account adherence to risk budgets, and regulatory and client specific investment guidelines through the use of a compliance monitoring system. The system generates daily exception reports comparing accounts on both a pre- and post-trade basis against client and regulatory guidelines. Unless otherwise specifically directed by the written agreement governing a client account, guidelines are monitored at the time the trade list is created. Terms such as “generally” and “typically” are interpreted to mean the account will be in compliance with the respective guideline at least 80% of the time. The term “approximately” is interpreted to mean the account will be within 1-2% of the respective guideline. The term “primarily” is interpreted to mean the account will be in compliance with the respective guideline at least 65% of the time. At a minimum, on a quarterly basis, written reports which list and describe account holdings, trading activity, risk characteristics, and account performance are delivered to clients. At the client's request, Los Angeles Capital will also prepare periodic reports of a similar nature. Investors in Private Funds, LACM CITs, and the LACM UCITS will receive written partnership or shareholder statements directly from the fund administrator and/or Trustee.

Los Angeles Capital may be deemed to have custody of a client account within the meaning of Rule 206(4)-2 under the Advisers Act because the Firm may have access to or authority over client funds and securities for purposes other than issuing trading instructions. Separate account clients generally will receive a periodic client account statement from their qualified custodian (typically on a monthly or quarterly basis) indicating the amounts of any funds or securities in the client account as of the end of the statement period and any transactions in the account during the statement period. Los Angeles Capital urges clients to carefully review such statements and

compare such official custodial records to account statements provided by Los Angeles Capital. Los Angeles Capital statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Except as otherwise required by law, Los Angeles Capital will not be liable for any act or failure to act of the client’s custodian. Because Los Angeles Capital serves as a general partner or managing member of the Private Funds, the Firm is deemed to have custody of the Private Funds within the meaning of Rule 206(4)-2 under the Advisers Act. For each of these Private Funds, Los Angeles Capital provides each investor with audited financial statements that comply with U.S. generally accepted accounting practices within 120 days following the funds’ fiscal year end. Investors in the LACM UCITS receive audited financial statements within 120 days following the fund’s fiscal year end.

Los Angeles Capital usually receives full discretionary authority from the client to select the identity and amount of securities or financial instruments to be bought or sold at the outset of an advisory relationship. This authority is established in each client’s written investment management agreement, sub-advisory agreement, limited partnership agreement, or other legal documentation governing the account. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account as set forth in the investment management agreement, sub-advisory agreement, limited partnership agreement, or other agreement that Los Angeles Capital enters into prior to assuming full discretion of client assets. Except as otherwise required by law or express agreement between Los Angeles Capital and a client, Los Angeles Capital will not be liable for any action or instruction of the client or the client’s custodian. When selecting securities or financial instruments and determining amounts, Los Angeles Capital observes the investment policies, limitations, and restrictions of the clients for which it advises. For registered investment companies, Los Angeles Capital’s authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Clients with brokerage restrictions can and will be accommodated. Investment guidelines and restrictions must be provided to Los Angeles Capital in writing. Because of the differences in client

investment objectives and strategies, risk tolerances, tax status, liquidity considerations, and other criteria, there may be differences among clients in invested positions and amounts held. Los Angeles Capital typically has discretion to select the brokers, dealers, futures commission merchants, and directly accessed execution venues used to execute transactions for accounts. Refer to Item 12 for information describing our counterparty and directly accessed execution venue selection process.

Proxy voting authority is specified in a client's investment management agreement, Limited Partnership Agreement, LLC Operating Agreement, Prospectus, Trust Agreement, Offering Memorandum or other legal documentation governing the account. Voting ERISA client proxies is a fiduciary act of plan asset management that is performed by the adviser or delegated to a sub-adviser, unless the voting right is retained by a named fiduciary of the plan. Los Angeles Capital has retained an unaffiliated third-party, to act as an independent proxy voting agent (the “Outside Proxy Provider”). The Outside Proxy Provider provides proxy analysis, voting recommendations and administration, recordkeeping, and manages other operational and reporting matters of the proxy voting process. The Firm’s Proxy Committee (the “Committee”) is charged with the oversight of Los Angeles Capital’s proxy voting process and is responsible for, among other things developing, implementing, and updating the Firm’s proxy policy, reviewing approving, and/or formulating the Firm’s Guidelines, selecting and overseeing the third‐party proxy vendor, identifying any conflicts of interest, determining the votes for issues it elects to vote independently from, or that cannot be voted by, the Outside Proxy Provider, monitoring legislative and corporate governance developments surrounding proxy issues, and meeting to discuss any material issues regarding the proxy voting process. The Committee has designated certain materiality thresholds for situations in which the Committee may vote independently from the Outside Proxy Provider or may take separate actions in regard to securities lending limitations. Materiality thresholds are monitored daily and are escalated to the Committee for review. When Los Angeles Capital is given proxy voting authority together with a client’s voting policy, the Firm oversees compliance with such client’s policy. When the client elects to use the Firm’s standard proxy guidelines, the client’s proxies will be voted in accordance with the guidelines approved by the Committee. The Committee has approved the use of Glass Lewis’ market-based

U.S. and Global guidelines, as such guidelines may be modified from time to time (the “Firm’s Guidelines”). Clients with specific proxy voting goals may direct the Firm to apply a thematic set of proxy guidelines developed by Glass Lewis or provide the Firm with an alternative set of custom guidelines. Clients may request reporting on how proxies were voted for their account. On an annual basis, the Committee reviews the Firm’s Guidelines. In addition, members of the Committee review a sampling of the Outside Proxy Provider’s voting recommendations and the related proxy materials in determining whether to continue or to modify the Firm’s Guidelines. The Committee does not review all recommendations with respect to all client holdings given the large number of issuers in each client’s account. The Firm will vote according to those recommendations that it does not review. Although the Firm has adopted set guidelines, where the Firm is authorized to vote, the Firm retains the right to ultimately cast each vote on a case-by-case basis, taking into consideration the applicable proxy guidelines including any contractual obligations or the specific voting policy of the particular client account as well as all relevant facts and circumstances including information that might be gathered from sources beyond the Outside Proxy Provider. In the event there is a disagreement with the Outside Proxy Provider's analysis as to a particular vote, the Committee will determine whether it is appropriate to vote contrary to the Outside Proxy Provider’s recommendation provided that such decision is consistent with the approved guideline. In the rare circumstance that the Committee believes it is in the best interest of a client to vote contrary to an approved guideline, the Committee will seek client consent prior to placing a vote that is contrary to an approved guideline. A client may issue specific directives regarding how particular proxy issues are to be voted for the client's account holdings. Los Angeles Capital requires that the advisory or sub-advisory contract specify such instructions, including instructions as to how those votes will be managed, particularly where they differ from the Firm’s Guidelines. While Los Angeles Capital will accept direction from clients on specific proxy issues for their account, the Firm reserves the right to maintain its standard position on all other client accounts for which the Firm has proxy voting authority. Los Angeles Capital does not generally dialogue with the management of issuers with respect to pending proxy voting issues. Management of issuers, as well as other interested parties, will sometimes release supplemental information that relates to a pending proxy vote. The Outside Proxy Provider and the Firm will not always be able to consider such additional information

depending on the timing of its release and particularly when it is released close to the voting deadline. In limited circumstances, the Firm may elect to abstain from voting or may be unable to vote a client’s proxy. These circumstances include:

Where the Firm concludes that the effect on shareholder’s economic interests or the value of the account holding is indeterminable or insignificant. Where the securities related to the vote participate in a securities lending program and are out on loan. In many cases, where a client directs the securities lending, the Firm may not be aware when the security is out on loan and thus may not be able to recall the securities before the record date, subject to the special considerations outlined below. Where the related securities are issued in a country that participates in share blocking because it is disruptive to the management of the account. Where a required Power of Attorney is not on file, or it is not feasible to get one on file. Where in the Firm’s judgment the unjustifiable costs or disadvantages of voting the proxy would exceed the anticipated benefit of voting (e.g., certain non-U.S. securities); and Where multiple global custodian accounts roll up into one omnibus sub-custodian account. In the specific markets where this may occur, the account managed by the Firm is not registered individually. Therefore, if ballots are voted differently for the underlying accounts, the omnibus vote is considered split and is rejected. Where a meeting involves an issuer or transaction with a relevant U.S. or non-U.S. sanctioned entity or individual.

Certain accounts may warrant specialized treatment in voting proxies. Contractual stipulations, individual client direction, and special guideline arrangements will dictate how voting will be done in these cases. ERISA Accounts Where the Firm has authority to vote proxies for an ERISA account, the Firm employs the Firm’s Guidelines unless otherwise specifically directed by the ERISA plan fiduciary. Where the Firm has authority to vote proxies for a commingled fund that is an ERISA plan asset fund, the Firm employs the Firm’s Guidelines. Securities Lending Certain situations where Los Angeles Capital may recall securities on loan to vote proxies, if operationally feasible, include: (i) where Los Angeles Capital deems a holding materially

significant, (ii) where Los Angeles Capital is directing the securities lending, or (iii) where a client has made arrangements with its custodian to permit standing instructions for the recall of securities out on loan and Los Angeles Capital has agreed to implement the standing instructions. The Outside Proxy Provider has reported to the Firm that it has policies and procedures in place to ensure the objectivity of its proxy research and vote recommendations, as well as the integrity of the proxy votes it casts on behalf of its institutional clients. If the Outside Proxy Provider identifies a potential conflict of interest between it and a publicly held company, the Outside Proxy Provider will disclose the relationship on the relevant proxy paper research report. In these situations, members of the Committee will review the proxy paper research report and vote the proxy in accordance with the Committee charter. If an unforeseen conflict requires specialized treatment, alternate measures may be taken, up to and including having the Outside Proxy Provider refrain from writing a proxy paper research report and abstaining from making a voting recommendation on the company. In this scenario the Outside Proxy Provider would procure a substitute proxy paper research report from an alternative qualified provider, and the Committee may be required to research and vote the proxy. If the Committee identifies a potential material conflict of interest between Los Angeles Capital or an affiliated person of the Firm and the issuer whose ballot is being voted, the client whose account holds the shares of such issuer will be notified. If no directive on how to vote is issued by the client, the Committee will vote in such a way that, in the Committee’s opinion, fairly addresses the conflict in the best interest of the client. In the event that Los Angeles Capital has not been granted authority to vote client securities, clients must make arrangements to receive their proxies or other solicitations directly from their custodian, transfer agent, or other third-party fiduciary that has been granted the authority to vote proxies. In this situation, clients should direct questions relating to a particular solicitation to their voting agent. A complete version of Los Angeles Capital's Proxy Policy is available on the Firm’s website (www.lacapm.com) and is also available to clients and prospective clients upon request. Clients may direct a particular proxy vote or request at any time a copy of the voting records for their accounts through a formal request to the Firm's Director of Portfolio Operations at operations@lacapm.com.

Los Angeles Capital generally will not disclose how it has voted or intends to vote on behalf of a client account except as required by applicable law but may disclose such information to a client regarding their account who itself may decide or may be required to make public such voting information. Los Angeles Capital will not disclose past votes or share amounts voted except: (i) for a valid business purpose as determined in the discretion of the Chief Compliance Officer or Chief Legal Officer, (ii) to the respective client for such client’s account or all investors in a commingled vehicle for such commingled vehicle, (iii) as required on Form N-PX related to Sayon-Pay votes, or (iv) as otherwise required by law. Class Actions and Proofs of Claim From time to time, securities that the Firm’s clients have owned are the subject of class action lawsuits. Generally, holders of securities within a given class period are entitled to participate in the recovery or settlement in a class action lawsuit by filing a proof of claim. All members of a class are typically bound by a court-approved settlement or judgment in a class action unless they have filed with the court or claims administrator a timely notice choosing to opt-out of the settlement. Los Angeles Capital views the decision to file a proof of claim in class actions to be the responsibility of the client, custodian, or other service provider for the client, and Los Angeles Capital shall not perform such action unless the Firm has expressly agreed in writing to accept such an obligation and is provided by the custodian and client with all necessary information and authorization to permit the Firm to represent the account in such class action. In addition, the decision to elect to opt out of a class settlement is a decision to be made by the client. Custodians typically receive notices of rights to participate in or opt out of class action settlements. Los Angeles Capital sometimes receives such notices addressed to clients and has adopted procedures to notify clients and/or their custodian in such instances. The Firm’s actions and procedures with respect to class actions depend on the role the Firm has with a client and the client’s custodian.

As a registered investment adviser, Los Angeles Capital is required to provide certain financial information or disclosures about its’ financial condition. Los Angeles Capital believes that it has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Los Angeles Capital does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance.