LYRICAL ASSET MANAGEMENT LP

Lyrical is a Delaware limited partnership founded in 2008 by Andrew Wellington and Jeffrey Keswin who are the principal and only owners of Lyrical. Lyrical is the investment adviser/manager for separately managed accounts, and the following commingled funds (the Funds and, together with the separately managed accounts, the Accounts): Lyrical U.S. Value Equity Fund (ticker: LYRIX), Lyrical Value Funds (Lux), WS Lyrical Value Funds (UK) ICVC, Lyrical Long-Only Partners LP (Long-Only LP), Lyrical Long-Only Partners II LP, Lyrical International Value Equity Fund (ticker: LYRWX), and Lyrical U.S. Value Equity CIT. As of February 28, 2026, Lyrical managed $7,198.7 million on a discretionary basis with an additional $1,038.0 million of assets under model portfolio delivery programs. Lyrical directs and manages the investment and reinvestment of the Accounts’ assets and provides reports to investors. Investments are limited to publicly-traded equity securities and cash equivalents. In our U.S. Value Equity strategies, we invest in U.S. listed equity securities. In our International Value Equity strategy, we invest in non-U.S. developed markets listed equity securities. In our Global Value Equity strategy and Global Impact Value Equity Strategy (GIVES), we invest in U.S. listed and other developed markets listed equity securities. Separately managed account clients may impose restrictions on investing in certain securities or types of securities; investors in the Funds may not impose such restrictions. We participate in model delivery programs under which we earn fees for providing a model portfolio to the sponsors of those programs and we do not exercise discretion over accounts. Except where we are able to control and monitor the timing of trades, we update these model portfolios only after we complete trading for our discretionary accounts. In one such program we earn not only fees but also receive research credits for providing trade information. Some of these programs may constitute “wrap fee programs” as the sponsor may charge specified fees for their investment advisory services which include what we are paid for providing a model portfolio. Additionally, we have entered into sub-advisory arrangements under which we manage portfolios through a wrap fee program sponsor. The sponsor provides investment supervisory services to its clients, including recommending us to provide investment advice with respect to client portfolios. The clients enter into an agreement with the sponsor and the sponsor has a separate master agreement with us. For these accounts, we may effect transactions through other broker-dealers, but it is expected that most of the transactions will be executed through the sponsor (or the brokerage firm the sponsor designates) because part of the sponsor’s negotiated fees with the clients include brokerage commissions and trading costs. We manage these wrap program accounts on a discretionary basis and receive a portion of the wrap fee from the sponsor. We attempt to manage these accounts in the same manner as our non-wrap accounts.

Our standard fee structure for our generally equally weighted portfolios (EQ Portfolios) consists of an asset-based fee and a performance-based fee, each detailed below.

We manage market capitalization scaled portfolios (CS Portfolios) for which our standard fee structure consists of an asset-based fee, detailed below, and no performance-based fee. We offer International Value Equity strategy, Global Value Equity strategy and GIVES separately managed accounts. We charge a standard quarterly asset-based fee with respect to these accounts; for International Value Equity and Global Value equity, that fee equals ¼ of 0.75% per annum of the value of each account, and for GIVES that fee equals ¼ of 0.85% per annum of the value of each account. Please refer to the offering documents of the respective Funds for information about the fees that we charge. Asset-Based Fee We charge a standard quarterly asset-based fee with respect to EQ Portfolios and CS Portfolios equal to ¼ of 0.75% per annum of the value of each account. Asset-based fees generally are charged in advance. Upon termination of an account we return to the client any amount paid for the balance of the quarter in which the termination occurs, on a pro rata basis. We also charge a prorated asset-based fee on contributions made following the beginning of a quarter. Performance-Based Fee We charge a standard performance-based fee with respect to EQ Portfolios equal to 20% of the amount by which the value of each account as of December 31 of each year exceeds the amount the account would be worth if it instead were invested in the S&P500® Index (with dividends reinvested) since the last time a performance-based fee was paid. Separate account clients may select another appropriate index, such as the S&P 500® Value Index, to be used for the purpose of determining performance-based fees. Certain CS Portfolio, International Value Equity, Global Equity and GIVES accounts are charged a performance-based fee in exchange for a lower asset-based fee. Fees are negotiable, and certain client fee schedules vary from and are lower than the fee schedules indicated above based on size of mandates, relationship style, service requirements, and other factors. Lyrical does not charge fees to Lyrical’s employees and certain family members. In some instances, assets are aggregated across a client’s or an advisor/consultant’s relationship with Lyrical for purposes of determining fees. Clients are billed quarterly for asset-based fees and annually for any performance-based fee or allocation. Generally, a client’s custodian remits payment to us, at the client’s direction. In some other instances we bill clients directly. Investors in the Accounts will bear not only Lyrical's fees, but also other fees and expenses of the Accounts such as brokerage commissions and any custody fees. Item 12 below discusses

brokerage practices. In addition, investors in the Funds bear audit, legal and administrative fees, and other fund related expenses. Lyrical's investment management agreements with its clients generally provide that the client will indemnify, and not hold liable, Lyrical and its affiliates for certain expenses, losses and claims that may arise in connection with the performance of its duties (including management of the client's investments and execution of investment trades), provided that such persons' conduct has not breached the applicable standards of conduct (i.e., the relevant actions were, in general, taken in good faith and did not involve breach of fiduciary duty, willful misconduct, gross negligence, a violation of federal or state securities laws or criminal wrongdoing). In the opinion of the SEC, an agreement to waive or indemnify against certain liabilities under the federal securities laws may be against public policy and therefore may be unenforceable.

We employ a value approach to investing. We believe that a portfolio of companies with low valuations relative to their long-term normalized earnings power will outperform the overall market over time. Furthermore, unlike some traditional value investors who are willing to own any business at the right price, our philosophy is to invest only in businesses that we believe are of high quality. For our U.S. Value equity strategies, we start with a universe of the top 1,000 stocks traded in the U.S. (roughly $4.9 billion market cap); for our International Value Equity strategy we start with a universe of the top 1,500 stocks traded in developed, non-U.S. markets (roughly $1.8 billion market cap). Our Global Value Equity strategy uses both universes. We then use a proprietary screen to generate investment candidates. The screen can trace its origins back to 1996 and has been implemented in its current form since 2001. The screen estimates a fair price for each stock in the universe applying a normalized multiple to an estimate of five year forward normalized earnings, calculated by taking the historical earnings trend line of a company and consensus estimates for future earnings and statistically extrapolating forward five years. The screen is run

monthly, and sometimes more often if stock prices are changing rapidly. All data for the screen are downloaded from FactSet. While the screen is subject to various errors and biases, we believe it is a proven, systematic approach to identifying potential investment ideas. Following the initial screen, each portfolio candidate/stock idea goes through an extensive fundamental research process. The research process has two objectives. The first is to develop an in-depth understanding of the business, including: drivers of growth and profitability, position relative to competitors and competitive advantages, position and leverage with customers and suppliers, historical and potential business threats and opportunities including those relating to aritificial intelligence, and management style, objectives, and incentives. This process includes financial statement analysis, study of competitors, customers and suppliers, discussions with company management, review of past earnings calls and investor presentations, and some use of sell-side research. The second research objective is to understand the investment controversy surrounding the stock, i.e. the reason why the stock is currently valued as it is. We are looking to determine if the factors depressing the stock price are temporary or permanent. We seek to make that determination by applying our in-depth understanding of the business and, as necessary, performing additional analysis specific to each investment controversy. At the conclusion of our research/due diligence, investment ideas that are deemed attractive are considered for inclusion in the portfolio. These are companies where we believe the investment controversy to be temporary, where the underlying business has sufficient quality and durability, and where the discount in the stock price is large enough to compensate for the risks of the investment. For GIVES accounts we additionally pursue a sustainable investment objective, investing in companies whose core business, in our opinion, aims to generate positive environmental and/or social change alongside a financial return. This means that we only invest in companies that have a clearly stated and significant commitment and contribution to at least one of the United Nations Principles for Responsible Investment sustainability goals. We determine a company’s qualification on this basis by reviewing publicly available information and information we request of each company. Risk Factors We do not attempt to time the markets or focus on weightings relative to any index. Accordingly, client returns are expected, at certain times, to significantly diverge from those of market indices. Investing in securities involves a risk of loss that investors must be prepared to bear. Because the Accounts invest primarily in publicly-traded equity securities, Lyrical believes their primary risk of loss is associated with securities selection and broad market movements (which can result from economic, political, health, terrorist and other events in the U.S. or elsewhere), and wide and sudden fluctuations in market value can occur. Equity holdings of the International Value Equity strategy and the non-U.S. equity holdings of the Global Value Equity strategy and GIVES involve risks and considerations not typically associated with investing in U.S. companies. The performance of foreign markets does not necessarily track U.S. markets. Foreign investments may be affected favorably or unfavorably by changes in currency rates and exchange control regulations. There may be less publicly available information about a foreign company than about a U.S. company, and foreign companies may not be subject to

accounting, auditing and financial reporting standards and requirements comparable to those applicable to U.S. companies. Foreign securities often trade with less frequency and volume than domestic securities and therefore may exhibit less liquidity and greater price volatility than securities of U.S. companies. There may be less governmental supervision of securities markets, brokers and issuers of securities than in the U.S. Changes in foreign exchange rates will affect the value of those securities, which are denominated or quoted in currencies other than the U.S. dollar. Therefore, for foreign securities which are denominated or quoted in currencies other than the U.S. dollar, there is a risk that the value of such security will decrease due to changes in the relative value of the U.S. dollar and the securities’ underlying foreign currency. Additional costs associated with an investment in foreign securities may include higher custodial fees than those applicable to domestic custodial arrangements, generally higher commission rates on foreign portfolio transactions, and transaction costs of foreign currency conversions. Investments in foreign securities may also be subject to other risks different from those affecting U.S. investments, including local political or economic developments, expropriation or nationalization of assets, restrictions on foreign investment and repatriation of capital, imposition of withholding taxes on dividend or interest payments, currency blockage (which would prevent cash from being brought back to the U.S.), limits on proxy voting and difficulty in enforcing legal rights outside the U.S. Currency exchange rates and regulations may cause fluctuation in the value of foreign securities. In addition, foreign securities and dividends and interest payable on those securities may be subject to foreign taxes, including taxes withheld from payments on those securities. While we believe the sustainability objective we pursue for GIVES accounts is consistent with achieving our objectives for performance and risk, GIVES accounts are necessarily more concentrated than our Global Value Equity strategy accounts. As well, by pursuing GIVES’s sustainability objective clients will not gain exposure to certain companies that might offer better investment returns. Trade Allocation. Typically, we aggregate trades at each executing broker and follow a randomly generated order of trade execution and, further, for the executing broker with the largest number of shares to transact, aggregate trades at each custodian and follow a second randomly generated order of trade execution. We view this process as fair and equitable by design, and we monitor these trading practices to confirm they are being implemented fairly. Yet, for certain trades some Accounts may trade days or weeks after other Accounts, possibly resulting in material differences between the prices at which Accounts’ trades are effected. When we aggregate trades across Accounts, each Account involved receives the same, average execution price. Force Majeure. Lyrical and its clients may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, labor strikes, major plant breakdowns, pipeline or electricity line ruptures, failure of technology, defective design and construction, accidents, demographic changes, government macroeconomic policies, social instability, etc.). Some force majeure events may adversely affect the ability of a party (including a portfolio company or service provider) to perform its obligations until it is able to remedy the force majeure event. These risks could, among other effects, adversely impact the cash flows available from a portfolio investment, cause personal injury or loss of life, damage property, or instigate disruptions of service. In addition, the cost to a portfolio company or a client of repairing or replacing damaged assets resulting from such force

majeure event could be considerable. Force majeure events that are incapable of, or are too costly to, cure can have a permanently adverse effect on a portfolio company. Certain force majeure events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international business activity generally, or in any of the countries in which we invest. Financial Institutions Risk. Brokers and custodians chosen by investors or by Lyrical could encounter financial distress, including insolvency or bankruptcy. There can be no assurance that the federal government would intervene to protect assets against losses or substantial access delays. Even where client assets are not directly involved, bank distress or failures could adversely affect market conditions.

We provide advisory services to high-net-worth individuals, institutional investors, investment companies, a collective investment trust, and UCITS funds. We impose a minimum investment of $2.5 million to invest in Long-Only LP or to open a CS, International, Global or GIVES account. Lyrical Long-Only II LP was established for a group of investors and is not open to other investors. These account minimums are negotiable. Note also that LYRIX and LYRWX each impose a lower minimum of $100,000 for their institutional class and $2,500 for their investor class. A and C shares of each mutual fund are available with a $1,000 minimum.

Lyrical charges performance-based fees to certain of its funds and other clients. To the extent Lyrical charges a client solely asset-based fees, we do not believe that investors are subject to a risk that Lyrical will favor accounts on the basis of fee choice because Lyrical allocates investments in publicly traded equities in relative proportions based on factors other than fee class.

Lyrical has a material business relationship with Lyrical Partners, L.P. (Lyrical Partners). Lyrical and Lyrical Partners have overlapping, but not identical, ownership. Lyrical Partners provides Lyrical offices, computers, telecommunications, and other facilities necessary to operate Lyrical’s business, and Lyrical Partners’ staff provides Lyrical general business, marketing, administrative and compliance services. Lyrical Partners allocates certain costs to Lyrical, which are borne by Lyrical and not by the Accounts. We do not believe that our relationship with Lyrical Partners causes a conflict of interest with our clients. Lyrical-Antheus Management, LP (Antheus), which provides investment management services with respect to real estate-related investments, is deemed commonly controlled with us, given Mr. Keswin’s ownership interest in that firm. We do not believe that such common ownership causes a conflict of interest with our clients because Antheus operates out of separate offices, with separate operating staff and operations from us. Lytical Ventures LLC (Lytical), which provides investment management services with respect to venture capital investments, is deemed commonly controlled with us, given Mr. Keswin’s ownership interest in that firm. We do not believe that such common ownership causes a conflict of interest with our clients because the respective investment processes of Lyrical and Lytical are separate.

Trading To avoid potential conflicts of interest involving personal trades, Lyrical has adopted a Code of Ethics (Code). The core principles set forth in the Code are: 

We must at all times place the interests of our Accounts first.

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All personal securities transactions must be conducted in a manner consistent with the Code and avoid any actual or potential conflicts of interest or any abuse of an employee's position of trust and responsibility.

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Employees must not take any inappropriate advantage of their positions at the firm.

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Information concerning the identity of securities and financial circumstances of the Accounts and their investors must be kept confidential.

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Independence in the investment decision-making process must be maintained at all times.

Lyrical and its principals, partners, officers, employees, affiliates and other related parties may transact in their personal accounts in mutual funds, ETFs, ETNs, stocks, bonds, and securities that are not traded publicly including privately held companies, hedge funds, venture capital funds and commodity pools. Lyrical requires certain personal securities transactions, specifically those related to equity securities which may also be traded by or are held at the time by the Accounts and transactions in private placements and initial public offerings, to be subject to pre-clearance by our Chief Compliance Officer. This preclearance process includes an assessment of whether such transactions pose any actual or potential conflicts of interest with respect to transactions executed by Lyrical for the Accounts. A copy of Lyrical’s Code shall be provided to any client or prospective client upon request. Employees of Lyrical and/or Lyrical Partners invest in funds and managed accounts managed by Lyrical. Lyrical will abide by trade allocation practices described herein aimed at assuring fair allocation of investments between Accounts, including any Accounts of its employees or affiliates. Lyrical has an indirect economic stake in the managed accounts and funds it manages which provide for compensation based upon performance.

We consider the following factors in selecting broker-dealers for client transactions and determining the reasonableness of their compensation: 

Quality of execution - accurate and timely execution, clearance and error/dispute resolution

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Reputation, financial strength and stability

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Block trading and block positioning capabilities

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Willingness to execute difficult transactions

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Willingness and ability to commit capital

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Ongoing reliability

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Desired timing of the transaction and size of trade

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Confidentiality of trading activity

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Market intelligence regarding trading activity

We need not solicit competitive bids and do not have an obligation to seek the lowest available commission cost. Accordingly, in any transaction or series of transactions, our clients may pay commissions to a broker in an amount greater than the amount another broker might charge. In selecting brokers, Lyrical also considers any proprietary and third-party investment research provided. Accounts do not pay higher commission rates to brokers that provide research benefits, and Lyrical holds these brokers to the same best execution standard as brokers who do not provide any investment research. We do not have any “soft dollar” arrangements. Subject to seeking best execution, we may also consider other relationships as factors in the selection of broker-dealers. For example, brokers to our clients have in the past, and may in the future, refer investors to Lyrical or engage in other transactions with us. Provision of services, including client referrals, could provide us with an incentive to select the respective broker-dealer for client transactions without regard to best execution. We will, however, provide compensation that we consider to be arm's length in any case in which such services have material value and will endeavor not to allocate brokerage transactions to a provider of such services as compensation for client referrals or other services or otherwise in violation of our duties to our clients. In the past fiscal year we did not direct client transactions to a particular broker-dealer in return for client referrals. We permit clients to direct us to a particular broker-dealer, subject to our ability to obtain best execution. Directed brokerage may cost clients more money. For instance, the client may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. To the extent Accounts are custodied at the same broker-dealer, trades for such Accounts are typically aggregated and allocated among the Accounts in a manner intended to cause the holdings of the related security to be proportional to their Account values, subject to any special parameters for a client. To the extent that orders are not aggregated across all Accounts it is possible that different Accounts will experience different transaction prices. We communicate orders across multiple broker-dealers in a manner aimed at fairness among Accounts over time.

Lyrical has entered into solicitation agreements under which it compensates third parties for certain client referrals. Investments by such referred clients in any Account will be subject to Lyrical’s standard terms and conditions and will not be subject to any incremental fees or allocations payable to Lyrical or any affiliate as a result of such solicitation agreements. We may also receive client referrals from brokers providing services to our clients, as discussed in Item 12 above.

Lyrical and Lyrical’s employees have not been involved in any legal or disciplinary events in the past ten years (and, to the best of our knowledge and belief, in years preceding that ten-year period) that would be material to a client’s evaluation of our advisory business or the integrity of our management.

Accounts are reviewed daily by our Chief Operating Officer under the guidance of the respective portfolio managers for each strategy. We provide monthly written reports to investors in separately managed accounts setting forth account balances, performance of the account and relevant benchmarks, and fees. On a quarterly basis we provide written commentary.

All client assets are held in custody by broker/dealers or banks unaffiliated with Lyrical. Clients are urged to compare any statements provided to them by their custodian to statements provided by Lyrical.

Lyrical has been granted discretionary authority to manage the Accounts of its clients pursuant to the written investment management agreements entered into with such clients. Clients may negotiate restrictions such as prohibiting or limiting investment in specific securities or industries.

Lyrical’s investment management agreements with its clients generally grant us the authority to cast all proxy votes. Lyrical has adopted a proxy voting policy, as required by the Advisers Act. The policy provides that we will act in the best interests of our Accounts in determining whether and how to vote on any proxy voting matter. The Firm has hired Broadridge Financial Solutions Inc. to help implement these policies and procedures. Broadridge’s default is to follow the recommendations of Glass Lewis. The Firm can override any such recommendation. Lyrical's Portfolio Managers and Chief Compliance Officer will consult with each other concerning the best method to resolve any actual or apparent conflict between the interests of Lyrical and its Accounts in a manner that affords priority to the interests of the Accounts taken as a whole. Clients may negotiate terms in their investment management agreements that provide for the retention or delegation of voting rights in accordance with their circumstances. Clients may obtain a copy of the policy and information on how Lyrical voted client securities upon request.

We do not believe that there are any financial conditions reasonably likely to impair our ability to meet our contractual commitments to our clients.