Mondrian Investment Partners Limited

Firm Ownership Mondrian Investment Partners Limited (“Mondrian”) was founded and SEC registered in 1990 under the name Delaware International Advisers Limited. It was then affiliated with Delaware Investments. Mondrian is also authorized and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom. On September 24, 2004, a senior management team, together with private equity funds sponsored by Hellman & Friedman LLC, a private equity firm (“Hellman & Friedman”), completed the acquisition of Delaware International Advisers Limited. Upon closing of the transaction, Delaware International Advisers Limited’s name was changed to Mondrian Investment Partners Limited. Between the periods of September 24, 2004 and July 12, 2011 Mondrian was ultimately controlled by a partnership of senior management and Hellman & Friedman, private equity fund sponsors. Over this period, Hellman & Friedman became a minority investor. In July 2011, senior management purchased the minority investor’s stake and the business became 100% employee owned through an employee partnership (Atlantic Value Investment Partnership LP) consisting of its senior employees, including the majority of investment professionals, senior client service officers and senior operations personnel. AVGP Limited is its General Partner. Approximately half of Mondrian employees are currently partners. Mondrian Investment Partners (U.S.), Inc. (an indirectly owned subsidiary of Atlantic Value Investment Partnership LP), is a Pennsylvania Department of Banking and Securities registered investment adviser and is the entity that carries out the marketing and client services activities for Mondrian in North America. Mondrian Investment Partners (U.S.), Inc. does not provide investment advisory services. In 2023, Mondrian Investment Partners Singapore Private Limited was incorporated to provide client servicing and institutional marketing services in Asia. Mondrian Investment Partners Singapore Private Limited is an indirect, wholly-owned subsidiary of Atlantic Value Investment Partnership LP. Investment Advisory Services Generally, Mondrian will manage assets on a fully discretionary basis. Advisory services are provided either on a Directly Managed basis or as a Managed Account Program through a third-party Sponsor. Securities will be selected on a global basis including marketable securities of issuers that are domiciled in both developed and developing countries. Equity and fixed income securities are utilized (according to client investment objectives) in the management of such accounts. Investment Advisory Services - Directly Managed Directly Managed accounts are those where Mondrian contracts directly with the client and has end-to-end investment and administrative responsibilities. Trades for Directly Managed accounts are typically executed by the Mondrian centralized Trading Desk. For a limited number of Directly Managed accounts, clients execute their own trades. These relationships are described as ‘Directly Managed Portfolio Consulting Clients’ who receive specific trade and implementation instructions from Mondrian which they in turn execute for their own account. This is distinct from Managed Account Programs described below where Mondrian contracts with a thirdparty Sponsor. Investment Advisory Services - Managed Account Programs: SMA and Model Delivery Mondrian provides discretionary and non-discretionary investment advisory services to certain Managed Account Programs (“Programs”) sponsored by third parties. These services will be provided through a manager traded separately managed account or through non-discretionary model portfolio investment services where the sponsor retains investment discretion.

Sponsors of these Programs include various broker-dealers, investment advisers, consultants, or other organizations (collectively referred to as ‘Sponsors’). Through these Programs, the Sponsors typically provide a package of services to their clients, which include assistance in determining investment objectives, choosing a strategy or strategies offered by participating investment advisers, trade execution and custodial services, performance monitoring, periodic reporting, and other related services. A client of the Sponsor, with assistance and/or advice from the Sponsor, typically selects one or more investment advisers, such as Mondrian, from a list of Sponsor-approved advisers to provide investment advisory services for all or a portion of their assets allocated to their program. All Program clients and prospective Program clients should carefully review the terms of the agreement with the Sponsor and the relevant Program brochure provided by the Sponsor and/or other disclosure documents to understand the terms, services, minimum account size, and any additional fees or expenses that may be associated with a Program account. Managed Account Programs: Manager Traded SMA Sponsors may offer different types of accounts through their Programs. One type of account is called manager Traded Separately Managed Account (‘Manager Traded SMA’). For Manager Traded SMAs, the Program client has a contract with the Program Sponsor and Mondrian enters into a management agreement with the Sponsor to provide discretionary investment advisory services to the Sponsor’s Program clients. The Sponsor then typically pays Mondrian a portion of the fee paid to the Sponsor by the client. Mondrian participates in such Programs with single and dual-contract agreements. Under a single contract, the client contracts directly with the Sponsor. In a dual contract, the client executes agreements with the Sponsor as well as directly with Mondrian; such clients will typically pay Mondrian an advisory fee in addition to the fee they pay to the Sponsor. Managed Account Programs: Model Delivery Mondrian provides non-discretionary or model portfolio investment services and recommendations to Sponsors, or their designee, through the provision of model portfolios. For such accounts, the Sponsor retains investment discretion and Mondrian is responsible only for providing the model portfolios. Consequently, Mondrian classifies such assets as “assets under advisement.” Managed Account Programs: Operational Support Mondrian has engaged a third-party service provider to provide operational and administrative support in maintaining the Programs for which Mondrian provides investment advisory services. This third- party provider will perform certain functions on a day-to-day basis, such as new account setup and maintenance, trade order generation and routing, confirmation and settlements, account asset cash reconciliation, guideline monitoring and recordkeeping, and other related services. Investment Guideline Restrictions For separate account clients, Mondrian may agree to certain mutually acceptable investment parameters and guidelines. Additionally, separate account clients may occasionally request that Mondrian avoid investments based on specific criteria e.g. no tobacco. Such clients are required to provide Mondrian with either a recognized industry classification or a list of prescribed issuers with identifiers. Clients are responsible for updating this list of restricted names and furnishing Mondrian with a copy. Clients must deliver their investment guidelines and restrictions in writing, and Mondrian will endeavor to adhere to such guidelines and restrictions when making investment decisions. These restrictions may have an adverse effect on performance relative to similar or equivalent accounts. Total Discretionary and Non-Discretionary Assets Under Management As of December 31, 2025, firm discretionary regulatory assets under management totaled USD 49,307,964,822. Additionally, Mondrian has approximately USD 3,520,057,620 in non-discretionary assets under advisement via Model Delivery Managed Account Programs arrangements with financial intermediaries and institutional clients.

Institutional Separate Accounts For the provision of Investment Advisory Services, Mondrian charges a fee based on a percentage of the assets under management. In certain limited instances, Mondrian will negotiate a portion of the fee calculated on a percentage of performance basis, which may be greater or less than the standard fee schedule (see Item 6 for further information on performance fees). Investment management fees for separately managed investment accounts are generally calculated and payable quarterly in arrears. Fees are normally prorated for a period of less than a full quarter in the event of a termination of the investment management contract. Generally, the fee is based upon the market value of the account as of the end of each calendar quarter, unless the client requests a different method of calculation. Mondrian’s clients may choose for the Mondrian or custodian market value to be used as the basis of the fee calculations. Mondrian provides invoices to all its clients who are able to either elect for the fees to be deducted from their custodian account or may opt to pay Mondrian directly (as specified in their Investment Management Agreement). In addition to paying Mondrian a management fee, clients will incur other expenses in relation to the account. Asset owners are responsible for all costs and expenses associated with an investment account. Common operating costs include, without limitation, custody, accounting, administration, legal, tax advice, tax filing and auditing. Common investment activity costs include, without limitation, brokerage commission, bid-ask spreads, mark-ups, interest and security loan expenses, regulatory and other governmental fees, transaction charges, transfer fees, market charges and tax. Other than brokerage commissions, Mondrian does not negotiate or handle any of these costs or expenses on behalf of the asset owner. Item 12 further describes the factors that Mondrian considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Item 8 below addresses tax matters. As described in Item 15 below, Mondrian does not act as custodian. Clients are responsible for negotiating their custody agreements. These agreements typically include ticket charges for each transaction Mondrian executes. Custodian charges will also be affected by the type and number of markets in which Mondrian may request to be opened for it to invest. Mondrian’s investment management fees may be higher than those of other investment managers providing similar portfolio management services. Fee rates are negotiable and certain clients may have more favourable fees to those stated below. Fee structures vary based on factors such as account type, relationship to other accounts managed by Mondrian, account size, required level of client service, potential for growth, and other relevant considerations. For example, early investors in a strategy may qualify for lower fee schedules. The table below outlines Mondrian’s standard fees for establishing a separate account as of the date of this brochure.

Investment Strategy

Asset Base (USD)

Annual Fee Rate

International Equity Value Opportunities

First $50 Million

0.65%

MSCI EAFE

Next $50 Million

0.45%

Minimum Account size: $100 Million

0.35%

International Equity ESG

0.65%

MSCI EAFE

Next $50 million

0.45%

Minimum Account Size: $50 Million

0.35%

International Equity Value

0.65%

MSCI EAFE

Next $50 million

0.45%

Minimum Account Size: $50 million

0.35%

All Countries World ex-US Equity

First $100 million

0.70%

MSCI ACWI ex US

Next $100 million

0.60%

Minimum Account Size: $100 million

0.45%

Focused All Countries World ex-US Equity

First $100 million

0.65%

MSCI ACWI ex US

Next $100 million

0.55%

Minimum Account Size: $300 (utilizing separate account only)

0.45%

Global Equity

0.65%

MSCI World

Next $50 million

0.45%

Minimum Account Size: $50 million

0.35%

Global Equity ESG

0.65%

MSCI World

Next $50 million

0.45%

Minimum Account Size: $50 million

0.35%

Global All Countries World Equity

0.65%

MSCI ACW

Next $50 million

0.50%

Minimum Account Size: $50 million

0.40%

US Large Cap Equity

0.45%

Russell 1000 Value

Next $50 million

0.35%

Minimum Account Size: $10 million

0.30%

Emerging Markets Equity

Below $100 million

MSCI Emerging Markets

0.90%

Minimum Account Size: $50 million

Next $50 million

0.70%

$100 million and above First $100 million

0.70%

Next $100 million

0.65%

0.60%

Emerging Markets Equity ESG

0.90%

MSCI Emerging Markets

Next $50 million

0.70%

Minimum Account Size: $50 million

0.60%

Emerging Markets ex-China Equity

Below $100 million

MSCI Emerging Markets ex-China

Minimum Account Size: $50 million

Next $50 million $100 million and above All assets

0.70% 0.55% 0.50%

Concentrated China Equity (All-China and China A)

Below $100 million

MSCI China

0.70%

Minimum Account: $50 million

Next $50 million

0.55%

$100 million and above

0.50%

All assets

0.50%

Investment Strategy

Asset Base (USD)

Annual Fee Rate

International Small Cap Equity

First $25 million

0.85%

MSCI World ex-US Small Cap

Next $25 million

0.75%

Minimum Account Size: $50 million

Next $50 million

0.70%

0.65%

Global Fixed Income

0.32%

FTSE WGBI

0.28%

International Fixed Income

0.32%

FTSE WGBI ex-US

0.28%

All assets

0.30%

Global Debt Opportunities

0.50%

80% FTSE WGBI / 20% JPMorgan GBI-EM Global Diversified

Next $50 million

0.44%

Minimum Account Size: $25 Million

Next $100 million

0.40%

Minimum Account Size: $25 Million

Minimum Account Size: $25 Million Global Inflation-Linked Bonds Bloomberg World Government Inflation-Linked Bond Index Minimum Account Size: $25 Million

0.36%

Global Aggregate Fixed Income

0.32%

Bloomberg Global Aggregate Bond Index

0.28%

International Aggregate Fixed Income

0.32%

Bloomberg Global Aggregate ex-US Bond Index

0.28%

European Aggregate Fixed Income

0.32%

Bloomberg Global Aggregate ex-US Bond Index

0.28%

US Core Fixed Income

0.20%

Bloomberg US Aggregate Bond Index

0.15%

Emerging Markets Debt Local Currency

0.44%

JPMorgan GBI-EM Global Diversified

0.38%

Emerging Markets Debt Opportunities

0.44%

50% JP Morgan GBI-EM Global Diversified / 50% JP Morgan EMBI Global Diversified

0.38%

Minimum Account Size: $50 Million

Minimum Account Size: $50 Million

Minimum Account Size: $50 Million

Minimum Account Size: $5 Million

Minimum Account Size: $25 Million

Minimum Account Size: $25 Million

Investment Strategy

Asset Base (USD)

Annual Fee Rate

Rothko International Small Cap

0.85%

Minimum Account Size: $50 million

Next $50 million

0.70%

0.65%

Rothko Emerging Market All Cap

0.70%

Minimum Account Size: $50 million

Next $50 million

0.60%

0.50%

Rothko Emerging Market Small Cap

0.95%

Minimum Account Size: $50 million

0.90%

Limited Partnerships The compensation paid to Mondrian for serving as investment adviser to a limited partnership is an assetbased fee that is paid directly by each limited partner generally based on the quarter end market value of the limited partner’s capital account. Mutual Fund Fees and Expenses In a limited number of circumstances, and generally at the client’s request, Mondrian may invest in mutual funds on behalf of clients for which Mondrian acts as adviser or sub-adviser. In these instances Mondrian ensures that fees are waived at the account level (not the mutual fund level) for any client assets that are invested in one of the mutual funds managed by Mondrian. Fees for pooled vehicles are included in the offering memorandum or the fund prospectus. Managed Account Programs: SMA and Model Delivery As described above, Mondrian also provides discretionary and non-discretionary investment advisory services to certain Managed Account Programs sponsored by third parties. The underlying client will pay a fee to the Sponsor who in turn is responsible for paying the investment advisory fee to Mondrian. The Sponsor’s ADV Brochure generally contains information on minimum account sizes and fees payable to the Sponsor and participating investment managers.

Mondrian uses a fundamental value-oriented, defensive investment management style across its two principal product groups: Equity and Fixed Income. The equity product group also includes a Systematic Equity product managed under the Rothko Investment Strategies name. The discussion that follows applies to all investment vehicles offered by Mondrian and describes its investment strategies and associated risks at a general level. Specific portfolio guidelines, including diversification parameters, number of holdings, and issuer concentration limits, are set forth in the applicable investment management agreement, prospectus, or offering documents, as relevant to each vehicle. The broad investment philosophy used for the management of portfolios is outlined below: Equity Philosophy and Management Approach For Mondrian’s Equity investment advisory services, “bottom up” individual security selection is the foundation of the investment approach. Securities are analyzed using a long-term, qualitative and quantitative, dynamically integrated, discounted cash flow return to shareholder model based on a traditional dividend discount model. This security level work is complemented by top down analysis that focuses on a similar approach to aggregate market valuation to manage country and sector risk exposures by incorporating economic considerations, including inflation and currency forecasts as well as qualitative factors such as the political, regulatory and governance backdrop into portfolio construction. Mondrian also considers long-term financially material environmental, social and governance risks and opportunities as an

integrated part of the investment process. Mondrian does not apply ESG screens or filters to its investment universe unless specifically requested by a client. Mondrian believes the use of our defensive value investment approach will help us to:

• Provide a long-term rate of return meaningfully greater than the client’s domestic rate of inflation • Provide rates of return that are less variable than rates of return provided by an unmanaged index, such as the EAFE index

• Preserve capital during protracted market declines Mondrian invests in stocks where a dividend discount analysis isolates value in terms of the long-term flow of dividends. Dividends, and expected future dividend growth which can incorporate other forms of shareholder return, play an important role in the decision-making process. Over time, the dividend component is expected to be an important portion of expected total return. Currency analysis is also an important factor. Mondrian uses a long-term oriented “purchasing power parity” analysis in evaluating the most likely impact currency translation will have on the client’s portfolio holdings when converted back to the client’s domestic currency. Fundamental research is conducted by Mondrian’s investment staff on a worldwide basis. Portfolio managers and analysts will typically meet in-person with management of target companies and their competitors, conduct video calls, or participate in company presentations with existing or potential investment opportunities. In-house research will be augmented by use of research-oriented brokerage houses and consultants, which provide supplemental research. New ideas can also be derived from trade journals, financial newspapers, magazines and the like. Corporate annual and financial reports are the main source of financial data, supplemented by various manuals and databases published by research services. Systematic Equity Philosophy and Management Approach Mondrian’s systematic equity portfolio construction methodology isolates holdings from the investment universe that have typical Mondrian quality, earnings and value characteristics using a “Bottom Up” systematic approach by applying a different approach from the traditional Mondrian methodology. A diversified portfolio is constructed from holdings perceived to be high quality, value and defensive. It invests in a broad range of countries and sectors consistent with the core Mondrian equity philosophy. Fixed Income Philosophy and Management Approach With respect to its fixed income advisory services, Mondrian follows a broad-based approach which incorporates both a macroeconomic or “Top Down” approach, as well as an individual security selection or “Bottom Up” approach. The primary goal in the management of fixed income securities is to structure portfolios that perform better than an unmanaged index, such as the FTSE World Government Bond index. Mondrian primarily uses a value-oriented defensive management style. Mondrian’s investment philosophy is based on the belief that investments need to be evaluated in terms of their fundamental long-term value. Mondrian also considers financially material environmental, social and governance risks and opportunities as an integrated part of the investment process. Mondrian does not apply ESG screens or filters to its investment universe. In the management of fixed income securities, Mondrian invests in securities where an inflation-adjusted, discounted income stream analysis identifies value in terms of prospective real returns. This methodology is applied consistently across countries. Mondrian uses medium-term global inflation analysis to determine expected “real” returns from world bond markets. Allocations to global bond markets are made on the basis of their real return potential in U.S. dollars (or in the currency of the client’s domicile, if requested by the client). This is a single measure taking into account both Mondrian’s measure of currency value and local bond market value. In the management of globally oriented portfolios, currency analysis is often a critically important factor. Mondrian uses longterm oriented purchasing power parity analysis supplemented by real short-term interest rate analysis in determining the most likely impact currency translation will have on the client’s portfolio holdings when converted back to the client’s domestic currency. Mondrian’s Emerging Market Debt products’ investment approach is broadly similar to the general fixed income style described above. Mondrian invests both in local currency emerging market debt instruments, where it uses a risk-adjusted Prospective Real Yield methodology, and hard currency paper where it uses a Risk-Adjusted Spread methodology that compares the spread over US treasuries against Mondrian’s assessment of fundamental credit risk.

General Investment Risk This section describes the primary risks associated with the investment strategies described above in Item 8. It is not possible to identify all of the risks associated with investing and the particular risks applicable to a client account will depend on the nature of the account, its investment strategy or strategies and the types of securities held. While Mondrian seeks to manage accounts so that risks are appropriate to the strategy, it is often not possible or desirable to fully mitigate risks. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. Clients and investors should understand that they could lose some or all of their investment and should be prepared to bear the risk of such potential losses. Clients and investors should read carefully all applicable informational materials and offering/ governing documents and prospectuses for further information on the various risks associated with investing, prior to retaining Mondrian to manage an account or investing in any Mondrian product. Market Risk Mondrian is an active, long-term value-oriented investment manager. As with any investment approach, there is no guarantee of positive returns. There are numerous factors that can cause the value of an investment to increase or decrease, some of which are described in this section. International Investing Investing in securities of non-U.S. issuers, positions in which generally are denominated in foreign currencies, and utilization of forward foreign currency contracts, involve both opportunities and risks not typically associated with investing in U.S. securities. These include: fluctuations in exchange rates of foreign currencies; possible imposition of exchange control regulation or currency restrictions that would prevent cash from being brought back to the United States. The cost of investing in securities of non-U.S. issuers can be higher than the cost of investing in U.S. securities. Investments in securities denominated in foreign currencies also involve the additional cost of converting currencies upon the purchase and sale of securities. Settlement Risk Emerging and developing market countries may have different clearance and settlement procedures than in the U.S., and satisfactory custodial services for investment securities may not be available in some emerging and developing market countries, which may result in additional costs and delays in trading and settlement. In foreign countries where Mondrian may invest, there are additional risks with trade settlement where local counterparties may trade on free of payment basis instead on delivery versus payment (“DVP”). DVP is typically the standard practice found in the U.S. and Western Europe. Where securities are not traded DVP, a portfolio may not receive payment for securities it has delivered, may be subject to increased risks that the counterparty may default and may not receive the ownership rights to the shares. Emerging Markets Risk The securities markets of emerging countries are typically smaller, less developed, less liquid and more volatile than the securities markets of the U.S. and other more developed countries. Disclosure and regulatory standards in many respects are less stringent than in the U.S. and other major markets. There also may be a lower level of monitoring and regulation of the markets and the activities of investors in certain less developed countries, and enforcement of existing regulations can be extremely limited. Assets maintained in certain emerging foreign countries also may be subject to other types of risks that either are not present or less pronounced in the U.S. and other more established markets, including political and economic risks (including nationalization of foreign bank deposits or other assets, and poor political and economic infrastructure and stability), commercial and credit risks (including poorly developed and regulated banks and financial systems), liquidity risks (including restrictions on repatriation and convertibility of currencies), legal and regulatory risks (including risks relating to evolving and/or undeveloped legal systems and regulatory frameworks) and operational risks (including risks relating to maintenance of shareholder title, clearing and settlement procedures and market transparency).

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Mondrian provides investment management services to a broad-based group of global institutional investors. This group includes retirement plan assets of corporate entities, retirement plan assets of government entities, trusts, foundations, endowments, charitable organizations, insurance companies and other institutional investors. Mondrian also acts as investment adviser or sub-adviser to U.S.-based investment companies and as investment adviser or sub-adviser to limited partnerships and other on- shore and offshore pooled investment vehicles and other non-U.S. clients. Clients also include wrap program Sponsors, investors in wrap programs, and clients who are Model Recipients through a non-discretionary arrangement. In addition to separately managed accounts, Mondrian acts as investment adviser to the Gallery Trust, an SEC registered investment company consisting of four Mondrian funds. Mondrian is an affiliate of Mondrian Investment Group (U.S.), Inc. which serves as the general partner for private investment funds (the “General Partner”). Mondrian serves as the appointed Investment Manager and is an affiliate of the General Partner, Mondrian Investment Group (U.S.), Inc. for private investment funds which are limited partnerships organized under the laws of the State of Delaware. These pooled investment vehicles are intended for sophisticated and institutional investors. Interests in the funds are offered to qualified investors solely on a private placement basis in accordance with Regulation D under the Securities Act of 1933. The funds are exempt from registration as an investment company in accordance with Section 3(c)(7) of the Investment Company Act of 1940. Mondrian also serves as investment adviser to each fund of Mondrian Funds PLC, an open-ended investment company registered with the Central Bank of Ireland pursuant to the European UCITS Directive. Mondrian typically requires a minimum account size of USD 25 – 100 million for separate institutional accounts, or that minimum annual fees be paid which would be equivalent to those paid on a USD 25 – 100 million account. It is expected that from time to time the minimum account size may vary depending on the type of product, or the country in which the client is located and the size, nature, circumstances and requirements of individual clients. A significant number of Mondrian’s institutional accounts are over USD 100 million. Mondrian may determine from time to time to alter the minimum account size, but any such minimum is not expected to be reduced to an amount below USD 25 million, except in exceptional circumstances, and for particular products. In connection with Mondrian’s investment management services to pooled vehicles, lower minimum account sizes apply. Additionally, Mondrian provides discretionary and non-discretionary investment advisory services to certain SMA & UMA Managed Account Programs sponsored by third parties. These services will be provided through a manager traded separately managed account or through non-discretionary model portfolio investment services where the Sponsor retains investment discretion. Sponsors of these Programs include various broker-dealers, investment advisers, consultants, or other organizations.

Mondrian generally charges fees as a proportion of assets under management. In a very limited number of situations, in addition to this fee basis, certain accounts also pay a performance-based fee. The Investment Advisers Act of 1940, as amended, restricts the payment of performance-based fees, such as the performance compensation, to investment advisers registered under such Act. However, SEC Rule 205-3 permits the payment of performance-based compensation to registered investment advisers provided that the clients meet certain financial qualifications. Where an investment firm has clients with a performance fee arrangement, there is a risk that those clients could be favored over clients without performance fees as there is the possibility that such fees may exceed the fees earned from other accounts. The potential conflict of interest arising from performance fee arrangements is addressed by Mondrian’s procedures for the allocation of aggregated trades among clients. Investment opportunities are allocated totally independently of fee arrangements. Accounts with performance-based fees also incur the costs and expenses described above in Item 5.

Mondrian Investment Partners Limited and its affiliate, Mondrian Investment Partners (U.S.), Inc. (“MIP(U.S.)”), a Pennsylvania Department of Banking and Securities registered investment advisor, are indirect whollyowned subsidiaries of Atlantic Value Investment Partnership L.P., an employee owned limited partnership. Refer to Item 4 for further details on Mondrian ownership. Mondrian Investment Partners Limited is not registered, nor does it have an application pending to register, as a broker dealer. Mondrian is affiliated with MIP(U.S.). MIP(U.S.) does not provide investment advisory services. MIP(U.S.)’s sole activity is to carry out the marketing and client services activities for Mondrian in North America. MIP(U.S.)’s sole client is Mondrian. A number of MIP(U.S.)’s personnel are registered representatives of Foreside Fund Services, LLC (“Foreside”), a third-party broker-dealer registered with the SEC and a member of the Financial Industry Regulatory Association, Inc. MIP(U.S.) has entered into an agreement with Foreside pursuant to which such registered representatives shall be permitted to offer and sell certain funds in the United States.

Mondrian Investment Partners Limited is not registered as a futures commission merchant, commodity pool operator, a commodity trading adviser. Neither does Mondrian Investment Partners Limited have an application pending to register. Mondrian is an affiliate of Mondrian Investment Group (U.S.), Inc. which serves as the general partner for private investment funds (the “General Partner”). Mondrian serves as the appointed Investment Manager and is an affiliate of the General Partner, Mondrian Investment Group (U.S.), Inc. for the following limited partnerships:

Mondrian All Countries World ex-US Equity Fund, L.P. Mondrian All Countries World ex-US, ex-China and ex-Hong Kong Equity Fund, L.P. Mondrian China Concentrated Equity Fund, L.P. Mondrian China A-share Concentrated Equity Fund, L.P. Mondrian Emerging Markets Debt Opportunities Fund, L.P. Mondrian Emerging Equity ESG Fund, L.P. Mondrian Emerging Markets Equity Fund, L.P. Mondrian Emerging Markets ex-China Equity Fund, L.P. Mondrian Emerging Markets Small Cap Equity Fund, L.P. Mondrian Global All Countries World Equity Fund, L.P. Mondrian Global Aggregate Fixed Income Fund, L.P. Mondrian Global Debt Opportunities Fund, L.P. Mondrian Global Equity Fund, L.P. Mondrian Global Equity ESG Fund, L.P. Mondrian Global Fixed Income Fund, L.P. Mondrian Global Inflation-Linked Bonds Fund, L.P. Mondrian International Aggregate Fixed Income Fund, L.P. Mondrian International Equity Focused Fund, L.P.* Mondrian International Equity Fund, L.P.* Mondrian International Equity ESG Fund, L.P. Mondrian International Small Cap Equity Fund, L.P. Mondrian Local Currency Emerging Markets Debt Fund, L.P. Mondrian QRPEY Local Currency EMD Fund, L.P. Mondrian U.S. Large Cap Equity Fund, L.P. Rothko International Small Cap Equity Fund, L.P. Rothko Emerging Markets All Cap Equity Fund, L.P. Rothko Emerging Markets Small Cap Equity Fund, L.P.

*Effective January 1, 2026, Mondrian International Equity Fund, L.P. was renamed Mondrian International Equity Value Opportunities Fund, L.P., and Mondrian International Equity Focused Fund, L.P. was renamed Mondrian International Equity Value Fund, L.P. Mondrian Investment Partners Singapore Private Limited provides client servicing and institutional marketing services in Asia. Mondrian Investment Partners Singapore Private Limited is an indirectly owned subsidiary of Atlantic Value Investment Partnership LP. Mondrian Investment Partners Singapore Private Limited does not engage in the execution of securities transactions.

Trading Mondrian has a written Code of Ethics (“Code”) and Market Abuse Policy which all Mondrian staff are required to adhere to. The Code sets standards that should ensure ethical behavior where Mondrian staff have potential conflicts of interest in relation to their duty to Mondrian’s clients e.g. where Mondrian staff engage in personal account trading activity, are offered gifts or entertainment from business contacts, have outside business interests or directorships and make personal political contributions. The Code is designed to adhere to the standards of ethical conduct set by both of Mondrian’s regulators, the SEC and FCA, and

specifically, Rule 17j-1 under the U.S. Investment Company Act of 1940 and Rule 204A-1 of the U.S. Investment Advisers Act of 1940. As an Investment Manager Mondrian may come in to contact with information about a company that is not generally available to the investing public. Mondrian’s policy and procedures for handling any conflicts of interest arising from access to non-public information are set out in the Mondrian’s Market Abuse Policy. All Mondrian staff are required to comply with the Code and Market Abuse Policy. Mondrian’s Compliance and Risk team is responsible for monitoring compliance with both policies. Additionally, in the course of its normal investment management business activities, and as stated above, there are other conflicts of interest that can arise that Mondrian needs to manage in order to ensure that all clients are treated fairly and equitably. The following is a list of some of these potential conflicts and a summary of Mondrian’s policy for managing the conflict. These conflicts are not specifically addressed in the Code but are dealt with in other policies and procedures which all staff are required to comply with, including Mondrian’s Conflict of Interest Policy. Mondrian has a fiduciary duty to its clients and as such must identify and take steps to mitigate potential conflicts of interest. This is outlined in Mondrian’s Conflict of Interest Policy. Some of the key conflicts are set out below. Mondrian will provide a copy of the Code, Market Abuse Policy and Conflict of Interest Policy to any client or potential client upon request. Dealing in Investments as Principal in Connection with the Provision of Seed Capital A conflict of interest exists when a portfolio management firm manages its own money alongside client money. Mondrian generally does not trade for its own account. However, Mondrian and its affiliates have provided the seed capital to certain investment vehicles that have been established by Mondrian group entities. Mondrian serves as the investment manager to these investment vehicles. Mondrian operates dealing policies designed to ensure the fair and equal treatment of all clients e.g. the allocation of aggregated trades among clients and products with different strategies that may be trading in opposing directions. These policies ensure that any portfolios in which Mondrian has an investment interest do not receive favorable treatment relative to other client portfolios. Client Order Priority – Advisory Mondrian’s objective is to manage similar mandates and different mandates with overlapping securities trading in the same direction in a manner that is fair and equitable to all clients. Mondrian provides this service to both Directly Managed and Managed Account Programs: SMA and Model Delivery clients. Mondrian has a process in place to control how investment opportunities are allocated between participating clients in these different client types. Client Order Priority – Trading Across Mandates Clients could be advantaged or disadvantaged relative to other clients by the priority the execution of their trade is given in the sequence of trades to implement an investment decision. Whilst Mondrian will endeavor to aggregate all client orders in the same security across all mandates, situations can arise where mandate specific factors may affect the timing of the implementation of investment opportunities for different mandates e.g. cash availability, different investment committees, or contingent trades. So that all clients are treated equitably in these situations, Mondrian has developed procedures to ensure that when clients from different mandates join existing orders, all clients are handled fairly based on order priority. Allocation of Investment Opportunities Mondrian is an investment manager of multiple client portfolios. As such, it has to ensure that investment opportunities are allocated fairly between clients. There is a potential risk that Mondrian may favor one client over another client in making allocations of investment opportunities. Mondrian makes security selection decisions at committee level. Those securities identified as investment opportunities are added to a list of approved securities; portfolios will hold only such approved securities. All portfolios governed by the same or a similar mandate will be structured similarly (that is, will hold the same or comparable stocks), and will exhibit similar characteristics. Sale and purchase opportunities identified at regular investment meetings will be applied to portfolios across the board, subject to the requirements of individual client mandates.

Allocation of Aggregated Trades Mondrian may from time to time aggregate trades for a number of its clients. In the vast majority of situations a trade will be prorated across all participating accounts. There are a small number of situations where a different allocation model is applied. For example, for equities when the amounts involved are too small to be evenly proportioned in a cost-efficient manner; for bonds where a minimum lot size and/ or a minimum trading size do not permit a pro rata allocation. For these situations Mondrian applies an allocation model that takes account of the size of the individual orders. Mondrian’s policy requires that all allocations of aggregated trades must be fair between clients. Mondrian monitors the effectiveness of its allocation process to ensure that clients are being treated fairly over a given period (usually annually) and to remain satisfied that the process is fair. In addition Mondrian performs periodic reviews of portfolio performance dispersion to confirm that clients with the same or similar investment mandates have been fairly treated. Allocation of New Issue Opportunities New issues, including “IPO’s” present a potential conflict of interest when they are priced at a discount to the anticipated secondary market price and the issuer has restricted or scaled back its allocation due to market demand. In such instances, the new issue allocation could be allocated to selected clients with others not receiving the allocation they would otherwise be entitled to. Mondrian clients with relevant mandates are given an equal opportunity, proportionate to the size of their portfolio, to participate in new issue trades. All new issue purchases are allocated on a strict pro-rata basis. Dual Agency Dual Agency (also known as Cross Trading) concerns those transactions where Mondrian may act as agent for both the buyer and seller. In such circumstances there is a potential conflict of interest as it may be possible to favor one client over another when establishing the execution price and/or commission rate. Although it rarely does so, Mondrian may act as agent for both buying and selling parties with respect to transactions in investments. If Mondrian proposes to act in such capacity, the Portfolio Manager will first obtain approval from the Chief Compliance Officer. The CCO has an obligation to ensure that both parties are treated fairly in any such trade. Investment in Shares Issued by Companies Who are Clients of Mondrian Mondrian has client relationships with a number of entities which are associated with companies that issue securities in which Mondrian could invest client assets. This results in a potential conflict of interest. Mondrian makes stock selection decisions at a committee level. If a security is identified as offering a good investment opportunity it is added to Mondrian’s list of approved securities. All portfolios governed by the same or a similar mandate are structured similarly, that is, will hold the same or comparable securities. Mondrian would not consider client relationships when analyzing securities and would not add a holding to, or remove one from, the approved list because of a client relationship. Dealing in Investments as Agent for More Than One Party Conflicts of interest exist when a portfolio management firm manages multiple client portfolios. Mondrian addresses these potential conflicts through the operation of dealing policies designed to ensure the fair and equal treatment of all clients e.g. the allocation of aggregated trades among clients. If Mondrian’s arrangements are not sufficient to ensure with reasonable confidence that the risks of damage to the interests of a client will be prevented, Mondrian will clearly disclose with sufficient details the nature and sources of the conflict to the client. The disclosure will be made prior to the conclusion of a contract, and in a durable medium to the client. It will include sufficient detail of the conflict and the steps undertaken to mitigate these risks in order to enable the client to take an informed decision.

Best Execution It is Mondrian’s policy to take all sufficient steps to achieve on a consistent basis the best possible result for clients when executing trades (“Best Execution”). Best Execution refers to many factors, including the following:

Price Cost Size Liquidity Speed Likelihood of execution and settlement Nature Any other consideration relevant to the execution of the order

For each trade, Mondrian will appraise the most effective execution method and venue with the objective of achieving Best Execution as outlined above. The relative importance of each of the above factors will differ depending on the characteristics of the order, the financial instrument and the characteristics of the execution venue to which the trade may be directed. The choice of the venue for execution will also be dependent upon the characteristics of the financial instrument underlying the order and the functional capabilities of the broker/dealer or venue. In most circumstances, price will be the most important execution factor; however in some circumstances Mondrian may determine that other execution factors, for example liquidity, have greater importance in achieving the best possible result for clients. Mondrian’s policy with regard to Best Execution is to endeavor to exercise the same standards and operate the same processes across all the different markets and financial instruments. However, the diversity in markets, size of trade orders and the viability of trading platforms for certain trades and financial instruments may mean that different factors will have to be taken into account in the context of specific trades. For example, in some markets, price volatility may mean that the timeliness of execution is a priority, whereas, in other markets that have low liquidity, the fact of execution may itself constitute best execution. In other cases, the choice of venue or execution method may be limited because of the nature of the order. For example, in the case of a large equity trade or a program trade across a number of markets, it may not be practical to use a direct market access venue or a multilateral trading facility. Timeliness together with depth of liquidity may be the overriding factors in such cases and therefore Mondrian may select a broker/dealer to execute such trades either on a principal or agency basis. Mondrian itself does not engage in principal trades. Security Trading Methods Mondrian uses a range of execution methods and venues to execute equity trades which may include:

• Broker/dealer execution on an agency basis • Broker/dealer execution on a principal basis • Execution through broker/dealers that trade on an organized frequent and systematic basis buying and

selling off their own books outside a regulated market but for which continuous quotes must be provided. Firms that provide this category of trading are known under the MiFID (the Markets in Financial Instruments Directive) regulations as “systematic internalisers”.

• Algorithmic trading where we give brokers specific instructions to execute orders in line with certain parameters e.g. a percentage of daily volume

• Direct market access • Multilateral trading facilities (“MTFs”) e.g. crossing networks or matching engines Broker/dealers may execute trades on an agency or principal basis and they may also act as a systematic internaliser, as described above, where they are, in effect, acting as the execution venue. Mondrian is not always notified of the capacity that the broker/dealer is acting in when it trades. Mondrian has selected venues based on their ability to offer the best possible execution result for each instrument being traded. Fixed Income Fixed income orders are traded by the Trading Desk by either placement with broker/dealers for execution or executed directly on a MTF.

When placing orders, Mondrian will typically ask three relevant broker/dealers to quote before executing at the best price. For less liquid or larger orders where market impact or certainty of execution is deemed more important, we may only ask one broker/dealer to price the trade, subject to portfolio manager approval. Where liquidity, size or market coverage is not an issue, Mondrian will typically execute orders over an MTF after requesting quotes from the relevant broker/dealers on Mondrian’s Approved Counterparty List. Derivative Trading Mondrian’s derivatives exposure within portfolios consists almost entirely of defensive forward currency contracts and non-deliverable forwards (“NDF’s”) used in an unleveraged and fully covered manner. Currency forwards and NDF’s are traded using currency venues and trading approaches as outlined below. Derivative securities, such as futures and options may be used if client guidelines permit. Mondrian has the ability to collateralize derivative broker/dealer exposure where appropriate e.g. to comply with regulatory requirements. In such circumstances, Mondrian will ensure that the appropriate legal broker/dealer documentation is in place prior to executing any relevant trades. Foreign Exchange Trading The foreign exchange trading market is generally large, highly efficient and very liquid. There is normally only a small difference between the quality of service and execution received from different counterparties (note that certain emerging markets currencies are quite different, as described below). Mondrian has the system capability to execute foreign exchange with counterparties other than the client’s custodian. It can be difficult to determine whether it is better to trade foreign exchange competitively, which could potentially marginally improve the price achieved or with the client’s custodian which minimizes counterparty risk, improves availability of funds and reduces transaction fees. However, in order to ensure that competitive rates of execution are achieved, foreign exchange trade execution with all approved counterparties is actively managed by Mondrian’s Trading Desk and execution quality is monitored by the Best Execution and Trading Oversight Committee on a post trade basis. Mondrian’s Traders monitor market rates using live data sources (e.g. Reuters) and target execution as close to the market as possible taking into account size of order, liquidity of the currency pair reflected in bid-offer spread and other variables. The Traders will challenge counterparty prices on individual trades if they are not satisfied with the rate on offer. Trading in foreign exchange markets is generally executed competitively after requesting multiple quotes via an MTF (FX Connect). The Trader may transmit a request for a quote via an MTF or directly to a single broker/dealer based on the size of the order, market data or where the Trader deems it appropriate to do so. In order to help reduce settlement risk when executing FX away from the client’s own custodian, Mondrian’s panel of FX counterparties typically use the Continuous Linked Settlement (“CLS”) system where available for that particular currency pair and where the client has signed the relevant paperwork. The CLS system aims to eliminate settlement risk and is run by CLS Bank International (“CLS Bank”), a special purpose bank owned by approximately 70 financial institutions and dedicated to settling foreign exchange trades. All eligible FX transactions for clients that allow the use of CLS settle through CLS Bank on a payment versus payment basis. Certain emerging market currencies have restrictions and controls over pricing and how they can be traded. These restrictions and controls may be put in place by the government of the relevant country however may also result from the trading processes of custodians (and their sub-custodians) which can make it, on a practical level, very difficult to trade with anyone other than the custodian. Restricted currency trades are therefore normally managed through the client’s custodian and are sometimes executed through a subcustodian based in the relevant country. The exchange rates are generally not negotiable so there is no flexibility in the rates achieved for trades in restricted market currencies and they are more costly than for non-restricted currencies. Mondrian continues to investigate the services of certain third-party execution platforms to assess whether they can improve transparency and reduce execution costs in certain restricted currency trades. Mondrian takes into consideration the cost saving benefits and relative risks when determining if and where it is appropriate to use these services. Where it is deemed favorable to execute trades through a third-party platform, Mondrian will typically discuss the risks and seek client approval prior to onboarding accounts to the third-party platform, unless it is considered that the client would prefer Mondrian to make these decisions on their behalf. Mondrian continues to monitor and analyze execution rates in these restricted markets to ensure that we achieve competitive rates on a risk-assessed basis.

Broker Selection Establishing and Maintaining Mondrian Approved Counterparty List Mondrian selects broker/dealers to execute transactions based upon a judgment of their professional capability to provide the service. Mondrian maintains an Approved Counterparty List of broker/dealers and other counterparties. In order to add a broker/dealer to the Approved Counterparty List, an approval and due diligence process needs to be completed. All new broker/dealers require the approval by the Chairman of the Best Execution and Trading Oversight Committee and the Chief Compliance Officer. The Approved Counterparty List is subject to continual review, and broker/dealers on the list will be either suspended or removed from the list if Mondrian feels that they are not providing a good service or if Mondrian believes that they represent an increased level of counterparty risk. This review process takes a number of forms:

• Mondrian monitors credit ratings for those derivative counterparties where this market information is

available. Mondrian identifies whether the credit rating may indicate an unacceptable risk threshold. If a counterparty breaches one of these tolerances, Mondrian will consider reducing exposure to the counterparty or suspending trading, depending on the threshold reached, until the risk level has reduced.

• A regular Trading Desk meeting will review broker/dealer performance and other broker/dealer service level factors.

• Mondrian’s Compliance and Risk team performs ongoing due diligence reviews of the Approved

Counterparty List to ensure that the approved broker/dealers continue to meet Mondrian’s standards.

• Credit analysts in Mondrian’s Global Fixed Income and Currency team perform reviews of the credit

worthiness of companies as part of their investment research. These reviews include a number of the key counterparties used by Mondrian.

Where any of the above reviews identify a weakness that may impact Mondrian’s counterparty risk exposure, this is highlighted to the Chairman of the Best Execution and Trading Oversight Committee and the Chief Compliance Officer who will consider if it is appropriate to suspend trading with that broker/ dealer. Best Execution and Trading Oversight Committee (the “Committee”) Senior investment staff, the Chief Operating Officer, the Chief Compliance Officer and Head of Trading meet formally to review Mondrian’s best execution arrangements. The Committee is responsible for identifying any enhancements or correcting potential weaknesses in Mondrian’s trading arrangements. Equity commission rates are set by product and market. Mondrian generally negotiates competitive execution-only commission rates in advance. As part of the Committee’s responsibility, commission rates are reviewed periodically and compared to industry averages. By concentrating business through a limited number of broker/dealers and taking account of the size of Mondrian’s trading volumes, Mondrian believes it is able to negotiate competitive commission terms. Allocation of Trades to Broker/Dealers The primary consideration of the Trading Desk is to execute all transactions at Best Execution. Working with the approved list of counterparties and within the guidelines set out by the Best Execution and Trading Oversight Committee and any client-specific requirements, the Trading Desk will select, in its opinion, the most appropriate trading venue, trading strategy and counterparty to execute each trade. The final decision regarding trading venue and executing broker/dealer (if applicable) is the responsibility of the Trading Desk. The Trading Desk is very aware that there is an impact on each client portfolio’s ability to achieve its return objective every time a trade is made. Therefore, every effort is made by the Trading Desk to minimize the cost of each trade. In considering the unit cost of any trades, the Trading Desk assesses the rate of commission paid as well as the market ‘spread’ and any market impact. Mondrian will disclose to clients annually information on costs and charges, including management fees, brokerage commission and implicit trading costs.

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Mondrian does not receive any economic benefits from parties other than clients, to whom Mondrian provides investment advice or other advisory services. Mondrian may pay solicitation fees for client referrals. In order to receive a referral fee from Mondrian, solicitors must comply with the requirements of the jurisdictions in which they operate. Specifically, with respect to soliciting US-domiciled prospective clients, any cash referral fee paid to an unaffiliated solicitor will be pursuant to applicable rules and regulations and to a written agreement between the solicitor and Mondrian. The written agreement will be structured to comply with relevant rules under the Investment Advisors Act, and will include a description of the activities the solicitor will perform on behalf of Mondrian and any compensation payable. If clients are referred to Mondrian by a solicitor, Mondrian will require the solicitor to provide an appropriate disclosure statement to the client regarding that arrangement at the time of the referral. Investment consultants typically provide advisory services to Mondrian’s clients and Mondrian occasionally purchases services from these consultants. However, Mondrian will take care to ensure that any services it purchases from such firms are appropriate and would not reasonably be considered to be an inducement to that firm. Where such a conflict is identified, Mondrian documents the relevant action undertaken to resolve the conflict. Mondrian can enter into arrangements with, and/or make payments from its own assets to certain intermediaries to enable access to Mondrian’s funds including Managed Account Programs (SMA and Model Delivery) on platforms made available by such intermediaries. Certain of those parties are engaged in, or have affiliates engaged in, the business of providing investment consulting services. These fee arrangements may create an incentive for such parties to promote or recommend Mondrian’s services.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Mondrian or the integrity of Mondrian’s management. Mondrian has no information applicable to this Item.

Portfolios are reviewed on a regular basis by the Implementation team and the relevant portfolio management team for price movements and changes in fundamentals, for compliance with investment guidelines, and to seek to ensure consistency across similar mandates. Each investment product has a relevant strategy committee which typically meets at least monthly and determines the investment strategy. Allocation decisions are implemented for the relevant client groupings by a dedicated Portfolio Management team. Target weights are typically achieved over several trading cycles in accordance with Mondrian’s Trade Sequencing practices, described in Item 12 above. Each Portfolio Management team is overseen by the relevant Chief Investment Officer of the strategy. Each Portfolio Management team considers numerous factors in selecting a particular issuer or security, including, but not limited to: available universe, trading and operational costs, client specific expected returns, cashflows, liquidity needs, client-imposed investment guidelines, and the ability to establish a material position or place a material trade. In the absence of client-imposed restrictions, all client portfolios within the same product are managed to be as similar as possible. Reviews are performed periodically to ensure that the portfolios for the same product exhibit similar performance returns and are included for eligible trades. Mondrian’s clients are normally supplied with a written monthly or quarterly statement (as determined by the clients’ needs) which includes a listing of holdings together with the amount, cost, market price and market value for equity accounts of each holding and, upon request, the current dividend yield. A performance page highlights the performance of the account for the latest month, the last three months (on request), the year-to-date and since account inception. These performance results are compared to the results for the same periods for relevant indices. Bond reports are issued which are similar in nature but which also provide a maturity breakdown and, upon request, a quality breakdown. In addition, each client is furnished with a complete listing of the past month’s or quarter’s trading activities (as appropriate) and, if requested for an equity account, a commission report which lists the broker’s name and amount of commission received by each broker receiving business in the past month. Once a quarter, the client report will be expanded to include written remarks covering Mondrian’s economic views and investment strategy and a detailed report supplementing the country-by-country investment inventory. This typically includes an industry breakdown but with the same general data as provided in the geographical listing. There may be other special reports prepared to individual client specifications.

Mondrian does not act as custodian of clients’ assets. Client assets managed by Mondrian shall be held at a third-party custodian under the client’s name pursuant to an agreement between the client and the thirdparty custodian. Mondrian does not appoint or recommend the appointment of custodians to hold custody assets for separate account clients. The separate account clients will appoint their own custodian. Whilst Mondrian may provide its clients with periodic statements at a pre-agreed frequency as described above, as the client appointed custodian is the official book of records, any statement received from Mondrian should be reconciled to that of the qualified custodian. Please also see Item 5 for a description of the fees and costs. Note that with respect to commingled vehicles sponsored by an affiliate of Mondrian, the affiliate does appoint the custodian for the commingled vehicle with Mondrian input. The custodian for such commingled vehicles is a third party to Mondrian and its affiliates.

Mondrian will accept discretionary authority from a client via execution of a written agreement at the outset of an advisory relationship. This discretionary authority allows Mondrian to select the amount and identity of securities to be bought or sold for that client account. In all cases, Mondrian will exercise discretion in a manner consistent with the investment advisory agreement and stated investment objectives. When selecting securities and determining amounts, Mondrian observes the investment policies, limitations and restrictions of the clients for which it advises. For registered investment companies, Mondrian’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. Investment guidelines and restrictions must be provided to Mondrian in writing.

Clients may obtain a copy of Mondrian’s Proxy Voting Policies and Procedures upon request. Clients may also request that Mondrian provide information as to how Mondrian voted any proxies on behalf of their account(s).

Application of Proxy Voting Guidelines Mondrian’s client agreements define the scope of its authority and responsibilities to vote proxies on behalf of each client. These typically fall into four categories: 1. Clients that delegate full discretion to Mondrian to vote proxies on their behalf 2. Clients that vary the scope of Mondrian’s voting authority by imposing specific guidelines 3. Clients that receive proxy voting advice from Mondrian in specific circumstances but undertake voting themselves 4. Clients that undertake to vote proxies themselves Mondrian’s proxy voting procedures apply to all clients who grant discretion to vote proxies on their behalf. Where clients have adopted specific proxy voting policies, Mondrian will assess the extent to which they are consistent with its adopted guidelines. Where a client’s own proxy voting policy diverges significantly from Mondrian’s own guidelines, that client’s policy will be considered separately. Mondrian is committed to voting all proxies where possible. Mondrian’s Policy is to vote in the best interests of all clients, providing overall value to clients by focusing on risk-adjusted returns and maximizing the value of the underlying company shares. Recognizing that proposals may be unique to a specific company’s circumstances, Mondrian does not have a default voting position. It votes proposals based on the merit of the proposal itself on a case-by-case basis. Each motion is reviewed by a portfolio manager from the investment team responsible for research coverage of that stock. This includes matters to be voted on related to social and environmental items, including climate change. Mondrian will typically support management for shareholder proposals but will still review each proposal on a case-by-case basis. Mondrian has appointed Institutional Shareholder Services (“ISS”) as its Proxy Voting Adviser in 2026. Details of the Proxy Adviser’s voting guidelines are published on their website. Mondrian has procedures in place to monitor and evaluate the performance of its Proxy Voting Adviser to ensure Mondrian’s ongoing ability to casts votes in the best interest of its clients. For active equity products, proxy voting items are forwarded to the investment teams when they are received. The portfolio manager will consider the relevant facts and circumstances of that particular company, the Proxy Voting Adviser’s recommendations and any conflicts of interest that may exist. Where Mondrian’s analysis indicates that it is in the client’s best interests to vote contrary to the Proxy Adviser’s recommendation, Mondrian aims to ensure that the vote is exercised in accordance with our Proxy Voting Policy and is uninfluenced by considerations other than the best interests of our portfolios. In such circumstances, it is the responsibility of the product’s Chief Investment Officer (“CIO”) to ensure the vote is consistent with Mondrian’s Policy. Mondrian’s systematic equity portfolios will generally follow the Proxy Voting Adviser’s recommendation. Periodic sampling of their recommendations is conducted to ensure the recommendations are based on accurate information and are in clients’ best interests. Exceptions to Proxy Voting Procedure Mondrian will attempt to vote every proxy which we or our agents receive, where we have authority to do so. However, there are situations in which Mondrian may not be able to directly process a proxy, for example, where we may have received a proxy statement in an untimely manner. Use of a proxy voting service and relationships with multiple custodians, helps to mitigate these risks and avoid situations where Mondrian is unable to vote a proxy. Shareblocking In some countries where Mondrian invests client assets, local laws impose a trading block on shareholders after they vote their proxies, usually lasting several weeks. Mondrian believes that, in certain situations, clients may benefit more by keeping the option to sell shares instead of voting. If the criteria below are met, the portfolio manager would not need to register for a specific proxy vote or get approval from the Proxy Voting Committee for a “no vote.” Criteria for a “no vote” decision:

The proxy items are not considered material by the Mondrian portfolio manager A “no vote” is unlikely to affect the vote's outcome The Mondrian portfolio manager is not aware of conflicts of interest regarding the decision not to vote Mondrian may want to sell the shares soon

• Clients will not be disadvantaged by not voting compared to the risk of not selling during the trading block

• A record is kept to justify the decision Qatar Qatar’s commercial code now states that voting must be done in person at the AGM. This may limit Mondrian’s ability to vote in this region. Conflicts of Interest There are several oversight and compliance monitoring functions incorporated into Mondrian’s firm-level procedures to ensure material conflicts of interests are disclosed and monitored, including those arising from proxy voting issues. Where Mondrian is considering voting a proxy contrary to the Proxy Adviser’s recommendation and a conflict of interest has been identified, it will be referred to the Committee. Any members from investment teams that are invested in that stock will be recused from the Committee for that decision and alternates appointed in their place. The Committee will assess the issue and ensure the decision is uninfluenced by considerations other than the best interests of all relevant portfolios and is consistent with Mondrian’s Policy. Availability of Proxy Voting Information and Recordkeeping In accordance with the FCA Shareholder Rights Directive, Mondrian will disclose annually on its website how it has cast votes in general meetings during the reporting period. Clients may request information on how their proxies were voted from Mondrian at any time. As a 13(f) filer, Mondrian also submits an annual Form N-PX, disclosing its votes on executive compensation (“say-on-pay”) matters for relevant securities as mandated by SEC Rule 14Ad-1. These proxy voting records are filed on or before August 31st each year and are publicly accessible on the SEC’s website. Additionally, the Form N-PX proxy voting records for Mondrian’s mutual funds are made available on the Mondrian website.

Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about their financial condition. Mondrian 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.