Mawer Investment Management Ltd.

Introduction Mawer was founded as a partnership in 1974 by Charles Mawer and was incorporated on March 20, 2003 under the laws of Alberta, Canada. We are an employee-owned and operated investment advisory firm headquartered in Canada. A description of the advisory services provided by Mawer is below. Certain of the advisory services outlined below are not available to clients in all jurisdictions. Our activities with respect to our non-U.S. clients may differ from those described generally herein, and we may provide additional or different services to our non-U.S. clients. Mawer does not hold itself out to its non-U.S. clients as an investment adviser registered with the SEC. Investors and other recipients should be aware that while this Brochure may include information about Mawer’s activities with respect to such investment vehicles or services provided outside of the U.S. as necessary or appropriate, this Brochure should not be considered to represent a complete discussion of the features, risks, or conflicts associated with any investment product offered or advised by Mawer. All discussions of Canadian investment funds and non-U.S. advisory activities are intended solely to provide the recipients with a full description of Mawer’s business, including potential conflicts of interest. Discretionary Portfolio Management Services We provide discretionary portfolio management services in certain jurisdictions in Canada for individuals, corporations, trusts, estates, institutions, pension funds, and not-for-profit organizations. We also provide discretionary portfolio management services for U.S.-based corporations and institutions, as well as certain U.S. residents. We work closely with each client to establish specific investment objectives, risk tolerance parameters, and to consider other unique circumstances which are incorporated into a written investment policy statement or similar document (the Investment Policy Statement). Our portfolio managers encourage a close working relationship with our clients’ other service providers, including accountants, legal counsel, and financial and estate planners to ensure that long-term objectives are being met. Once investment guidelines have been established and provided to us, the client’s portfolio manager assumes discretionary responsibility for building, managing, and monitoring the client’s investment portfolio in accordance with those guidelines set out in the Investment Policy Statement. Discretionary accounts are managed using suitable investment funds and/or segregated securities for clients meeting our preferred minimum account size requirements (as described below under Segregated Accounts). Investment funds managed and distributed by Mawer may comprise all or a portion of a client’s discretionary account if this aligns with the client's investment objectives. These investment funds are considered proprietary products, and it is important to understand that Mawer does not offer any third-party investment funds for inclusion in a client account. Pooled Investment Vehicles Mawer advises and distributes both public mutual funds as well as private funds available to clients and investors in Canada (Mawer Canadian Funds). In addition, Mawer advises private funds available to U.S.

clients and investors (Mawer U.S. Funds). The terms under which an investment fund is offered are outlined in the respective fund offering documents. Given our relationship with Mawer Canadian Funds and Mawer U.S. Funds, a conflict of interest arises when we make a decision to offer these products or our representatives make an investment decision or recommendation for our clients in relation to these products, including any decision or recommendation to purchase, redeem or continue to hold these products or to switch investments from one product to another product or investment. This conflict of interest creates the risk that we are only providing clients with access to a proprietary product because we receive direct or indirect compensation related to the product, and/or have direct or an indirect interest in the success of the product. Further, because we do not offer investments in third-party products, any suitability determination conducted by Mawer and its representatives will not consider the larger market of non-proprietary products or whether those non-proprietary products would be better, worse, or equal in meeting the investment needs and objectives of our clients. We manage these conflicts by ensuring our representatives do not receive any sales-based compensation or commissions or other compensation incentives for the sale of Mawer Canadian Funds and Mawer U.S. Funds. Segregated Accounts Clients may also choose to utilize one or more investment strategies or models on a segregated basis (a Segregated Account). These Segregated Accounts are primarily comprised of individual stocks and bonds and are generally available to U.S. or Canadian individual clients investing more than U.S. $8,000,000 or institutional clients investing more than U.S. $50,000,000. Sub-Advisory Services We provide sub-advisory services to certain public mutual funds, private funds, and other investment advisers. We receive a fee based on the assets under management within each mandate or portfolio for each of these services, as determined by the sub-advisory agreements. Non-Discretionary Accounts Certain Mawer Canadian Funds are offered to eligible investors in Canada who elect to open nondiscretionary accounts with us for the purposes of purchasing such investment funds. We do not actively manage the assets in a non-discretionary account and any transaction will be conducted only upon client instruction, and completion of our suitability assessment. Wrap Fee Programs We provide model recommendations to third-party broker-dealers or portfolio managers in Canada for use in wrap fee programs that they sponsor. The models are non-discretionary, and the wrap fee program sponsors have full discretion over how they implement them for their clients participating in the wrap fee programs, based on each client’s individual suitability requirements. We do not provide

investment advisory services to participants in these wrap fee programs. We receive a fee from each wrap fee program sponsor for the models we recommend in connection with their programs. We do not participate in wrap fee programs in the U.S. ERISA We manage accounts of U.S. employee benefit plans, such as corporate pension, profit sharing, and money purchase pension plans, that are subject to the fiduciary responsibility provisions of Title I of the Employee Retirement Income Security Act of 1974 (ERISA), and of certain plans that are subject to Section 4975 of the U.S. Internal Revenue Code of 1986 (the Code) (such plans, the Plans) on a segregated basis, or through a pooled investment vehicle such as a collective investment trust. When we manage assets of Plans, we will be subject to the prohibited transaction provisions of Section 406 of ERISA and/or Section 4975 of the Code, which provisions, among other things, may restrict the way we may be compensated by such accounts. We are subject to ERISA fiduciary responsibility, reporting and disclosure, and bonding rules when managing Plan accounts that are subject to ERISA. In addition, certain issuers of securities and other investment products may restrict investment by Plans, which may affect the composition of the portfolios of Plan accounts and result in a variance between the investments of Plan accounts and the investments of non-Plan accounts that otherwise might have similar mandates. Financial Planning We offer a suite of financial planning services to individual clients in Canada as part of our advisory services. These services may include retirement planning, tax and wealth optimization, estate and legacy planning, and debt and cash management. Financial planning is typically delivered as part of the overall advisory relationship and is not billed separately. While we provide financial planning services with the goal of helping clients meet their financial goals, clients should be aware that the recommendations are based on current information, and market conditions may change. There is no guarantee that financial plans will achieve specific outcomes, and clients are advised to review their plans periodically. Assets Under Management As of December 31, 2025, Mawer had the following amount of regulatory assets under management (AUM): Discretionary AUM: U.S. $40,297,300,000* Non-Discretionary AUM: U.S. $643,100,000* Total AUM: U.S. $40,940,400,000* * Rounded to the nearest U.S. $100,000 using a foreign exchange rate of CAD $0.7295 to U.S. $1.00.

Management Fee In consideration for the services to be rendered by Mawer in connection with your account, we may receive a management fee as set out in your account documentation. The management fee is a percentage amount that is based on the assets under management in your account. In the case of our sub-advisory services, we receive a negotiated management fee which is a percentage amount based on the assets being sub-advised by us. Fees are generally deducted directly from client accounts monthly or quarterly in arrears, as directed and authorized by the client. Aside from this ongoing management fee, if any, we do not charge additional fees to open, operate, or maintain an account. However, if your account holds individual securities, or your account is held by a custodian, you may be charged certain fees or expenses by third parties who provide services in relation to your account. Third parties may include any custodian that holds securities for the account as well as the brokers or dealers who execute securities transactions for your account. The fees and expenses charged to you by these other parties will vary from time to time and may be deducted directly from your account. A further discussion of Mawer’s brokerage policies and practices is found in Item 12 of this Brochure. Additionally, you may be working with a third-party financial planner or investment counsellor to manage your account and you may be charged a fee by those parties for their services in relation to your account with us. The fees and expenses charged by these parties will vary from time to time and may be deducted from your account with your authorization. The following shows a representative fee range for a discretionary account with Mawer, subject to adjustments for client relationship, account size, asset class, strategy and special requirements, among other things. For individual clients, assets managed at the household level are aggregated for the purpose of calculating fees. Investment size in U.S. - Institutional client first $25 million next $25 million next $200 million next $250 million on balance

Fee (%) 0.90 0.75 0.70 0.65 0.60

Investment size in U.S. – Individual client first $2 million next $3 million next $5 million on balance

Fee (%) 1.00 0.70 0.50 0.30

Other Potential Fees and Fund Expenses If, in accordance with your Investment Policy Statement, we invest some or all of the assets in your account in investment funds, you will also bear a portion of the operating fees and other expenses charged to those investment funds, including a management fee. If Mawer recommends investment into investment funds advised by us, we ensure that the management fees you pay to us in relation to your account are reflective of the fees already paid by the funds. All investment funds advised by Mawer contain a full outline of all fees and expenses charged in the relevant fund offering documents.

Investment Strategies Mawer currently engages in several different investment strategies or models that our clients may choose to meet their investment objectives. The investment strategies offered may be provided through segregated accounts or pooled investment vehicles and are outlined in the relevant fund offering documents, or the Investment Policy Statement for segregated accounts. Mawer applies a consistent research and investment process across all investment strategies. A specific discussion of the investment strategies offered by Mawer are included below. Risk of Loss Please be advised that investing in securities involves the risk of loss of all, or a portion of the amount invested. Clients and investors should be prepared to lose all, or a part of their investment. Securities laws require us to disclose the risks that should be considered when making an investment decision. Before making any investment decision, it is important to consider your investment objectives, your level of risk tolerance, and the risks associated with the investment you are considering. A complete description of the risks associated with an investment in a fund advised by Mawer is set out in that fund’s offering document and we encourage you to read those risks carefully prior to investing in any fund. If your account is invested directly in individual securities, certain other investment risks may apply depending on the types of securities you own. The following is a list of the most common risks associated with the advisory services offered by Mawer. Specific Material Risks The following is a list of the most common risks associated with the advisory services provided by Mawer: Bail-in debt risk – A client account may invest in bail-in debt securities of a financial institution, which, under certain circumstances, may be under temporary control by the Canada Deposit Insurance Corporation or by the Federal Deposit Insurance Corporation, and all or a portion of the debt issued may be subject to a forced conversion into common shares of the financial institution. In the event of a forced conversion, a client account may hold a security type and quality that it would not normally hold. Concentration risk – Concentration risk is the risk associated with its investments that are concentrated in a particular issuer, issuers, sector, or in a single country or region of the world. Concentration of investments allows a client account to focus on the potential of a particular issuer, sector or region. However, concentration also means that the value of the client account tends to be more volatile than the value of a more diversified client account because the client account’s value is affected more by the performance of that particular issuer, sector, country or region.

Counterparty risk – A client account may, if allowed under the client’s Investment Policy Statement, enter into derivative contracts with one or more counterparties and in doing so the client account will be exposed to the credit risk associated with the counterparty (see Derivatives risk). Credit risk – The value of fixed income securities depends, in part, on the perceived ability of the government or company that issued the securities to pay the interest and to repay the original investments. Securities issued by issuers that have a low credit rating are considered to have a higher credit risk than securities issued by issuers that have a high credit rating. Currency risk – The value of securities denominated in a currency other than the client account’s base currency will be affected by changes in the value of the base currency in relation to the value of the currency in which the security is denominated. Cybersecurity risk – As part of its business, Mawer processes, stores and transmits large amounts of electronic information, including information relating to investors’ transactions and personally identifiable information of the investors. Similarly, Mawer’s service providers may process, store and transmit such information. Mawer has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to Mawer may be susceptible to compromise, leading to a breach of Mawer’s network. Mawer’s systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. On-line services provided by Mawer to the investors may also be susceptible to compromise. Breach of Mawer’s information systems may cause information relating to investors’ transactions and personally identifiable information of the investors to be lost or improperly accessed, used or disclosed. Mawer’s service providers are subject to the same electronic information security threats as Mawer. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the transactions and personally identifiable information of the investors may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of Mawer’s proprietary information may cause Mawer to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing events could have a material adverse effect on strategies and the investors’ investments therein. Derivatives risk – A derivative security is a financial instrument that derives its value from an underlying security, such as a stock or bond, a currency, or a financial market. It is not a direct investment in the underlying security itself. The client accounts may invest in derivatives for hedging purposes and for non-hedging purposes, if allowed under the client’s Investment Policy Statement. “Hedging” means a transaction or a series of transactions designed to offset or reduce a specific risk associated with specific

positions held by the client accounts in certain investments or groups of investments. Trading in derivatives does entail certain risks:

When a derivative is used for hedging, if a market assumption is wrong, the client account could forego gains that it would have attained if it had not entered into the hedging arrangement. In addition, there is no guarantee that hedging will be effective and that it will eliminate or reduce a loss or exposure that it was designed to hedge.

When a derivative is used for non-hedging purposes, it may expose the client account to volatility and other risks that affect the underlying market. Any losses that the client account may incur as a result of investing in derivatives may be greater than if the client account had invested in the underlying security itself.

A client account may be unable to “close out” a position to achieve the intended result if trading in a derivative is halted, or if the market for it becomes illiquid or is subject to trading limits.

The price of a derivative may not accurately reflect the value of the underlying security. Many types of derivative contracts involve contracts with third parties. The other party to a derivative contract may not be able to honour its obligations under the contract. In addition, if money has been deposited with a derivatives dealer, the dealer may go bankrupt and money deposited with the dealer will be lost.

Electronic trading facilities risk – A client account may in the sole and absolute discretion of Mawer, make use of electronic trading and/or communication networks. Most electronic trading facilities are supported by computer- (including, without limitation, internet-) based component systems for the order-routing, execution, matching, registration or clearing of trades. As with all facilities and systems, they are vulnerable to temporary disruption or failure. Trading on an electronic trading system may differ not only from trading in an open-outcry market or telephonic market but also from trading on other electronic trading systems. A client account in undertaking transactions on an electronic trading system, will be exposed to risk associated with the system, including, without limitation, the failure of hardware and software. The result of any system failure may be that a trade order is either not executed according to its instructions or is not executed at all. A client account’s ability to limit or recover certain losses may be subject to limits on liability imposed contractually or by, without limitation, foreign or domestic law or regulation, the brokers’ internet service provider, other systems providers, market factors, foreign or domestic banking or other market regulations and/or telephonic or other communications providers. Emerging market risk – Client accounts that invest in emerging or developing markets are subject to similar risks as noted under “Foreign security risk”. These types of risk may be greater in emerging markets than in developed markets due to, among other things, greater market volatility, smaller trading volumes and higher risk of political and economic instability. The fluctuation of prices in emerging markets may be more pronounced than in developed countries, and it may be more difficult to sell securities. Further, custody and settlement mechanisms in emerging market countries may be less developed and result in delays or additional costs in the execution of trades.

Equity risk – The prices of individual equity securities can rise and fall with the fortunes of the companies that issue them or with general stock market conditions. Changes in the price of individual equity securities held by client accounts will affect client accounts’ total market value. ERISA risk – Mawer, in managing the client account assets, may be required to comply with the fiduciary duty rules of ERISA and the prohibited transaction rules of ERISA and Section 4975 of the Code. Compliance with such rules could limit Mawer’s flexibility in making investments or taking other actions with respect to the client account assets. Financial and business risk – Private equity investments generally will involve a significant degree of financial and/or business risk. Portfolio companies in which a strategy is directly or indirectly invested may be significantly leveraged and therefore may be more sensitive to adverse business or financial developments or economic factors. Portfolio companies may face intense competition, changing business or economic conditions or other developments that may adversely affect their performance. Business risks may be more significant in smaller companies or those that are embarking on a build-up or turnaround strategy. If for any of these reasons, a portfolio company is unable to generate sufficient cash flow to meet principal or interest payments on its indebtedness or make regular dividend payments, the value of the investment could be adversely affected and the strategy could experience a significant loss. Foreign security risk – The value of foreign securities will be affected by factors affecting other similar securities and could be affected by additional factors such as the absence of timely information, less stringent auditing standards, and less liquid markets. As well, different financial, political, and social factors may involve risks not typically associated with investing in Canada and the U.S. In general, investments in more developed markets, such as the U.S. and Western Europe, have lower foreign security risk, while investments in emerging markets, such as Southeast Asia or Latin America, have higher foreign security risk. Income trust risk – Income trusts generally hold securities of an underlying active business or are entitled to receive a royalty on revenues generated by such business. The investment returns of an income trust are subject to the risks to which the underlying business is subject, such as industry risks, interest rate fluctuations, commodity prices, or other economic factors. To a degree, income trusts are structured in part to provide a constant stream of income to investors, and therefore an investment in an income trust may be subject to interest rate risk. Interest rate risk – The value of fixed income securities will generally rise if interest rates fall and fall if interest rates rise. Changes in interest rates may also affect the value of equity securities. Legal and regulatory environment risk for private investment funds and their managers – The legal and regulatory environment worldwide for private investment funds and their managers is evolving. Changes in the regulation of private investment funds, their managers, and their trading and investing activities may have a material adverse effect on the ability of the private investment funds to pursue their investment programs and the value of investments held by the private investment funds. There has been an increase in scrutiny of the private investment fund industry by governmental agencies and selfregulatory organizations. New laws and regulations or actions taken by regulators that restrict the ability

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Mawer’s clients include individuals, corporations, trusts, estates, institutions, pension funds, and notfor-profit organizations. Mawer provides discretionary portfolio management services to U.S.-based corporations and institutions, as well as certain U.S. residents. In addition, Mawer offers sub-advisory services to certain public mutual funds, private funds, and other investment advisers, and participates in Canadian wrap fee programs by providing model recommendations to non-affiliated broker-dealers or portfolio managers. We generally do not have fixed minimum requirements regarding the amount of assets needed to open or maintain an account. We do have preferred minimum account sizes, as indicated below, which may be waived or lowered in our sole discretion based on the nature of the client relationship. Individual client accounts invested in Mawer Canadian Funds U.S. $800,000 Institutional client accounts invested in Mawer U.S. Funds U.S. $10,000,000 Segregated Accounts U.S. $50,000,000 for Institutional clients U.S. $8,000,000 for Individual clients Termination or withdrawal provisions are included in the relevant account management agreement or fund offering documents.

Mawer offers a performance-based fee structure to certain institutional clients. The fee structure includes a base AUM fee and a performance fee once a minimum value-added hurdle rate is achieved, up to a maximum total management fee. The management of accounts with performance-based compensation structures side-by-side with asset-based fee clients constitutes a conflict of interest for Mawer, in that we may be incentivized to favor accounts with a performance-based fee structure over other clients without such a structure in the allocation of investment opportunities. In addition, the presence of performance-based compensation may encourage us to take riskier or more speculative positions than would otherwise be the case absent the performance compensation. Mawer has adopted policies and procedures to mitigate these conflicts and to ensure that all clients are treated fairly and equitably in the allocation of investment opportunities.

Relationships with Related Persons Mawer is the Investment Fund Manager, Portfolio Manager, and Exempt Market Dealer to the Mawer Canadian Funds and the Investment Advisor to the Mawer U.S. Funds and receives management fees for its services. Mawer Investment Management Singapore Pte. Ltd. (MIMS) is registered with the Monetary Authority of Singapore with a capital markets services license for fund management and provides investment, research and trading execution services to Mawer and sub-advisory services in respective of certain of Mawer’s investment strategies. MIMS is a wholly owned direct subsidiary of Mawer. Mawer Investment Management U.S. LLC (MIMUS) is an operating company for the purpose of employing staff resident in the U.S. MIMUS is a related person of Mawer and Mawer is the sole member of MIMUS. Mawer Investment Management U.S. Fund LLC (MIMUSF) is the Manager to a number of Delaware registered LLC private investment funds. MIMUSF is a related person of MIMUS and MIMUS is the sole member of MIMUSF. Mawer Partners GP Inc. is a corporation existing under the laws of the Province of Alberta and is the general partner of Mawer Partners LP, an investment fund established as a limited partnership under the laws of the Province of Alberta. Mawer Partners GP Inc. is a wholly owned direct subsidiary of Mawer. Mawer Insurance Advisory Ltd. (MIAL) is licensed by the Alberta Insurance Council and the Financial Services Regulatory Authority of Ontario to provide insurance-related services to Mawer's individual clients residing in Alberta and Ontario, Canada. MIAL is a wholly owned direct subsidiary of Mawer. Mawer and/or MIAL may engage in referral arrangements with third parties, which may give rise to a potential conflict of interest. See Item 14 of this Brochure for a detailed description of the referral arrangements and the associated conflict.

Code of Ethics Mawer has adopted a Code of Ethics (the Code) in accordance with Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the Advisers Act). The Code consists of Mawer’s Business Conduct Policy, Conflicts of Interest Policy, Material Non-Public Information and Insider Trading Policy, and Personal Trading Policy. A copy of the Code is available to clients and prospective clients upon request. The Business Conduct Policy sets out Mawer personnel’s obligations for disclosure and/or seeking approval of gifts and entertainment, outside activities, personal financial dealings, powers of attorney and directorships. The Conflicts of Interest Policy defines conflicts of interest, establishes a framework for assessing materiality, and outlines procedures for the identification, disclosure and approval of actual or potential conflicts involving Mawer personnel. People Leaders are responsible for supervising and approving activities covered by the Business Conduct Policy for their teams and for providing periodic attestations to Compliance. The Material Non-Public Information and Insider Trading Policy defines material non‑public information (MNPI) and establishes controls designed to prevent the misuse of MNPI by Mawer and its associated persons. Mawer maintains procedures for identifying, escalating, and addressing potential MNPI, including trading restrictions where appropriate. Compliance conducts ongoing monitoring and reviews, including reviews of trading activity and communications, as part of its supervision program. The Personal Trading Policy governs personal securities transactions by employees, contractors, and other covered persons, including restrictions, pre‑clearance requirements, and reporting obligations for personal accounts and transactions. Additional information regarding the Personal Trading Policy is provided below. In addition to the Code, Mawer has adopted a Pay-to-Play and Political Contributions Policy that outlines the U.S. Pay-to-Play rule, which aims to minimize the ability to use political contributions to influence governmental officials responsible for the hiring of investment managers, such as Mawer. The policy establishes pre‑approval requirements for certain political contributions and related activities, which are administered in a manner consistent with other Code‑related disclosures and approvals. Personal Trading Policy The Personal Trading Policy is designed to, among other things, detect and prevent any personal trading activities that may conflict with or hinder client interests. All employees, contractors, officers, directors, their spouses or other people living with them, any corporation owned or controlled directly or indirectly by them or their family members, and any trust of which they are trustees (collectively, Covered Persons) are required to comply with the policy. The restrictions on individuals’ personal

trading address both insider trading prohibitions and the individuals’ duty to avoid conflicts of interest with Mawer. Upon joining Mawer, all staff are required to disclose all external brokerage accounts and accounts for which Covered Persons have trading authority and supply the Compliance department with copies of statements for their external brokerage accounts. Compliance undertakes periodic reviews of such brokerage statements to ensure that any personal trading complies with the requirements of the policy. If a Covered Person has control, access, or influence over Mawer's trading activities or the ongoing investment process of the Mawer Canadian Funds, Mawer U.S. Funds or clients, the Covered Person is classified as a Restricted Person. This includes but is not limited to all members of Research, Asset Class Managers, Traders, Client team members responsible for managing client accounts, and other Covered Persons with access to proprietary data or systems used in the investment decision-making process. Any Covered Person, who is not a Restricted Person, is classified as an Access Person. We prohibit Restricted Persons from investing in individual securities (other than Mawer Canadian Funds) in order to prevent any potential conflicts and ensure that clients’ interests take priority. Access Persons can trade in non-exempt securities but must receive pre-clearance from our Compliance department prior to execution. If any proposed trades create a potential conflict of interest, our clients’ interests will take priority and approval will not be granted. Policy Acknowledgment, Certification, and Training Mawer requires all personnel to acknowledge and certify compliance with the Code and applicable policies upon joining the firm and on an ongoing basis. This includes initial disclosures of reportable accounts and outside activities, as well as periodic certifications and reporting related to personal trading and other activities covered by the Code, such as quarterly certifications to confirm the accuracy of their reportable accounts and transactions, and an annual attestation of their holdings and adherence with the Code. Compliance provides mandatary and role-specific training to reinforce the Code and related policies. Participation or Interest in Client Transactions We are the manager and portfolio adviser of the Mawer Canadian Funds and Mawer U.S. Funds and may, in the future, be the manager and portfolio adviser of other mutual funds, unit trusts, or investment funds managed, administered or promoted by us (Related Funds). We may from time to time exercise our discretion to purchase and redeem units of Related Funds for your account. If we invest the assets of your account in Related Funds, we will ensure that the management fees paid to us by you do not duplicate any similar fees received by us from Related Funds. We will only engage in these types of transactions where they are permitted under applicable securities laws and where we believe they are in your best interests in the applicable circumstances.

In most cases, our connection to these Related Funds will be obvious to you because the names of the Related Funds will be sufficiently similar. For example, in most cases the name of a Related Funds will include the word “Mawer” as part of its name. If we believe that the name of any Related Fund is not similar enough to convey such fund’s relationship to us, we will provide you with specific disclosure regarding that relationship at the appropriate time.

Broker Selection and Best Execution Decisions as to the purchase and sale of securities and the execution of portfolio transactions, including the selection of broker-dealers, will be made by Mawer. Commissions paid to broker-dealers are negotiated and Mawer is not under any contractual obligation to allocate brokerage business to any specific firm. Brokerage transactions are not carried out through any affiliated entity. In effecting portfolio transactions, we seek to obtain best execution of trades on behalf of our clients, taking into account all factors deemed relevant. These include, but are not limited to, the price of the security, speed of execution, certainty of execution, transaction size, liquidity of the security, market conditions, and commission costs/spreads relative to the transaction. Mawer has established procedures relating to the approval and ongoing review of broker-dealers. The Trading desk is responsible for broker-dealer selection for order execution and for the ongoing assessment of broker-dealer performance, including the use of internal and third‑party transaction cost analysis tools. In addition, Mawer’s Trading and Valuation Committee meets quarterly to oversee various aspects of the trading function including best execution practices. Use of Client Commissions Effective January 1, 2025, Mawer no longer uses client commissions to pay for research goods and services offered by third-party broker-dealers and/or service providers through bundled services or commission sharing agreements. Mawer executes transactions on behalf of our clients at execution only rates with selected brokers and all trading is conducted solely on the basis of best execution. As of March 30, 2026, a nominal balance of client commissions generated under historical commission sharing agreements remained outstanding. We have been drawing down this nominal balance to pay for eligible research goods and services from third-party broker-dealers and/or service providers in accordance with Section 28(e) of Securities Exchange Act of 1934. Section 28(e) of the Securities Exchange Act of 1934 provides a “safe harbor” that allows Mawer to pay for certain research and brokerage services with the commission dollars generated by client account transactions if products and services provided by third parties directly assist Mawer in the investment decision-making process and not the management of the firm and meet the eligibility criteria under Section 28(e). These research, products or services, other than order execution services, include (i) advice as to the value of securities and the advisability of effecting transactions in securities; (ii) analysis and reports concerning securities, portfolio strategy or performance, issuers, industries, or economic or political factors and trends; and (iii) databases or software to the extent they are designed mainly to support the services referred to in (i) and (ii). Directed Brokerage Mawer generally has full discretion in selecting executing brokers for the initiation of security transactions. Certain clients may require that all or a portion of their trade commissions be directed to

brokers they designate for their own commission recapture program; directed trades are generally handled through step‐out trades. If clients direct Mawer to utilize a particular broker, they are informed that this direction may prevent them from obtaining the best price and execution by limiting our ability to negotiate elements of the trade including aggregation with other client accounts in the trade order. Specific directions for client-directed brokerage arrangements are only accepted if provided to Mawer in writing. Fairness in the Allocation of Investments Mawer uses the pro-rata method to allocate securities and the related price and commission costs for securities purchased or sold on a block basis, where such purchases are made on behalf of several client accounts. The pro-rata method involves making a proportionate allocation of price and commissions relative to each order. The pro-rata method is applied whether an order is partially filled or fully filled by the broker-dealer. Therefore, all clients and funds participating in a block trade receive the same execution price and commission cost for that block trade. There may be some circumstances when the pro-rata allocation method may appear inappropriate. An exception to the pro-rata method of allocation may be appropriate if an order is unreasonable as measured against a particular account’s asset size and target weighting for the security in question, or a minimum trading block size is maintained to ensure future liquidity. The reasonableness of the target weighting or minimum trading block size will be assessed by the portfolio manager’s review of the applicable investment guidelines. In limited offerings, where demand significantly exceeds supply, allocation based on order size may be inappropriate. In these instances, alternative allocation methodologies may be used, but Mawer will ensure that all clients are treated fairly and equitably in the allocation of investment opportunities. Principal and Cross Trades Principal and cross trades can create potential conflicts of interest and fiduciary duty issues. Mawer is prohibited from engaging in principal transactions unless Mawer complies with the notification and consent requirements of Section 206(3) of the Advisers Act. A cross trade is a transaction between two accounts managed by Mawer, where Mawer does not have a beneficial interest in any of the accounts participating in the cross trade. Mawer pursues cross transactions on a limited basis. Cross trades can only be executed by third party brokers who take both sides of the trade. If there is an opportunity to execute a cross trade that would benefit both clients on each side of the transaction, Mawer will seek to obtain best execution. In addition, the trade will be effected at the current market price determined in accordance with the SEC rules and guidance, and no brokerage commission will be charged on the trade. Mawer prohibits effecting a principal or cross trade if one of the clients is an ERISA client.

Trade Errors We recognize that from time-to-time errors can occur while trading securities. As such, Mawer will evaluate and correct any errors promptly. We will incur the costs associated with correcting an error or pass the costs to any other party responsible for the error. We do not charge the cost from corrective actions to the client.

We do not pay a cash or non-cash fee, directly or indirectly, to any third party or related party for referring clients to Mawer in the U.S. For Mawer’s individual clients in Canada, we may, at a client’s request, recommend third-party service providers such as accountants, lawyers, insurance consultants or tax advisors. We may also recommend related service providers to such clients. A conflict of interest arises when Mawer and/or its related parties provide or receive a cash or non‑cash referral fee in connection with these referrals, as we may be incentivized to participate in referral arrangements in light of the receipt of such compensation. Mawer has established policies and procedures designed to ensure referrals are made only when in the client’s best interest. Clients receive written disclosure of any referral arrangement prior to the referral being made, in accordance with applicable securities regulations. In certain situations, Mawer may pay a fee to an intermediary as a result of securing a mandate through a request for proposal process. These fees are dependent upon the consultant and the particular mandate search and are not negotiated or determined by Mawer.

Mawer does not have any disciplinary information to disclose.

Mawer will provide to you, at least quarterly, a statement of account containing certain information about the status of your account, including details about each transaction or activity conducted in your account during the time period covered by the statement, information about each security held in the account, and the cash balance, if any, in your account at the end of the period covered by the statement. Mawer will endeavor to ensure that clients with segregated accounts are also receiving at least quarterly reports from your custodians. You should compare these statements to Mawer’s reporting for consistency and accuracy. Portfolios are reviewed regularly by the appropriate portfolio manager and/or portfolio manager associate, and cash and positions are reconciled daily with the custodial data. Mawer uses SimCorp Dimension (SCD) as a compliance monitoring system. Rules and restrictions for each client account are entered into this system based on the clients' Investment Policy Statement. SCD provides comprehensive pre-, and post-trade investment compliance functionality, and restriction checking of single trade and program orders which are reviewed by Compliance and portfolio managers daily. SCD is used for a variety of functions: compliance management, order management, portfolio management, performance and attribution, pricing and valuation, corporate actions, reconciliation, trade processing, data management, warehousing and reporting.

Mawer does not maintain physical custody of client assets. Client assets are held by independent third party “qualified custodians” (as this term is defined in Rule 206(4)-2 under the Advisers Act). However, certain activities undertaken by Mawer result in us being deemed to have custody over certain client accounts, namely, directly debiting fees from client accounts and having a Related Person serving as the general partner/managing member or equivalent of a private fund offered by Mawer. In compliance with the custody rule, Mawer aims to ensure that all segregated account clients receive at least quarterly account statements from their custodians. Mawer urges each client to carefully review the statements sent by the custodian and should compare the information in those reports to the information in the statements Mawer provides to clients. Mawer’s statements may vary from custodian statements based on accounting procedures or reporting dates. Mawer is deemed to have custody of the Mawer U.S. Funds and therefore these private funds will be audited on an annual basis in accordance with U.S. GAAP by an independent auditor that is registered and subject to inspection by the Public Company Accounting Oversight Board, and the financial statements will be disseminated to all investors within 120 days of the relevant fund’s fiscal year end.

Mawer provides investment advising services on a discretionary basis to clients where discretion is expressly granted in the client account documentation signed by each client. Pursuant to this discretionary authority, Mawer seeks to obtain best execution and determines which securities are bought and sold for the account, the total amount of the purchases and sales, the brokers or dealers through which transactions are executed, and the commission rates paid to effect the transactions, as applicable. The client may restrict or prohibit transactions in certain types of securities, or direct that transactions be effected through specific brokers or dealers. In circumstances where a client directs that transactions be effected through a specific broker or dealer, Mawer is unable to assure that best execution will be received by the client because the client’s directed broker is unable to participate in block trades. Other reasons for this may include a specific fee, commission, or other arrangement exists between the client and broker.

Mawer votes proxies for all client accounts that have provided written instructions to vote the proxies in their account. With respect to ERISA accounts, Mawer will vote proxies unless the plan documents specifically reserve the plan sponsor's right to vote proxies. The primary objective of Mawer as an investment manager is to maximize the investment return on assets under management, subject to an acceptable level of risk. Corporate governance is widely recognized by regulators, advisors, investors and academics as a crucial element of long-term company performance. Mawer shares this view and feels that the voting rights that accrue to shareholders are an important tool in promoting proper governance practices. Corporate governance includes taking into account environmental and social considerations, known collectively as ESG (environmental, social, governance). Mawer believes that by assessing the relevance and materiality of ESG factors as part of our investment process, we can better identify and evaluate the quality of sustainable business practices, which supports our focus on long-term responsible investing. Investment strategies managed by us do not have an explicit focus on ESG as part of their fundamental investment objectives or principal investment strategies. Voting rights need to be exercised in the best interests of our clients and managed to maximize their potential to influence corporate behavior. Casting votes in a manner that is consistent with the longterm interests of a company’s shareholders is one of Mawer’s fiduciary responsibilities. Shareholder voting is one of the most effective methods for promoting good corporate governance. Proxies are generally used to exercise the right to vote. Mawer’s objective is to vote every share of every company owned at every shareholder meeting. It is the policy of Mawer to vote proxies in a prudent and diligent manner after careful review of each company’s proxy statement. The voting decision is made internally and is based on Mawer's Statement of Guidelines and Procedures on Proxy Voting and/or a reasonable judgment of what will serve the best interests of the shareholders. Clients may request a copy of their proxy voting records and Mawer’s Proxy Voting and Related Matters policy by contacting info@mawer.com.

Mawer has no financial obligation that impairs its ability to meet contractual and fiduciary responsibilities to clients and has not been the subject of a bankruptcy proceeding.