NB Alternatives Advisers LLC

A. Description of the Firm NB Alternatives Advisers LLC (“NBAA”) is a Delaware limited liability company that was formed in 2009 and registered with the Securities and Exchange Commission (the “SEC”) as an investment adviser in 2009. NBAA is directly owned by NB Alternatives Holdings LLC and Neuberger Berman AA LLC, each of which is a subsidiary of Neuberger Berman Group LLC (“NBG”). NBAA provides alternative investment strategies directly or indirectly to, among others, large public and private pension funds; academic and charitable institutions; registered closed-end and open-end investment companies; and other sophisticated investors. NBAA’s advisory business is focused on providing services to (i) private investment funds (including both comingled funds and funds-of-one); (ii) separate accounts for third-party clients; (iii) U.S. registered funds including interval funds; (iv) NB Private Equity Partners Ltd.; (v) Sub-Funds of NB Alternative Funds SICAV S.A.; and (vi) non-discretionary investment management services to certain private funds and separate accounts, each as further described herein. On May 19, 2021, a strategic combination between Dyal Capital Partners and Owl Rock Capital Group became effective, and Dyal Capital Partners is now part of Blue Owl Capital Inc. (“Blue Owl”), a company that trades on the NYSE as “OWL.” Following the completion of the Blue Owl transaction, an entity owned by certain current and former NBG employees owned a material stake in the interests in Blue Owl’s operating entities. Neuberger’s historical relationship with Dyal Capital Partners will from time to time result in conflicts of interest, or issues that create the appearance of a conflict of interests, as described herein, including as described in Item 11. Indirect Ownership Background—Neuberger Berman Group NBG is a holding company, the subsidiaries of which (collectively referred to herein as the “Firm” or “Neuberger”) provide a broad range of global investment solutions – equity, fixed income, multi-asset class and alternatives – to institutions and individuals through products including separately managed accounts, mutual funds, and private investment vehicles. As of December 31, 2025, Neuberger had approximately $563 billion under management. 1 NBG’s voting equity is wholly owned by NBSH Acquisition, LLC (“NBSH”). NBSH is owned by current and former employees, directors and, in certain instances, their permitted transferees. Each employee that owns an equity stake has entered into an agreement that provides strong 1 Firm assets under management figures reflect the collective assets for the various subsidiaries

of NBG.

incentives to continue with the organization and has a number of restrictive covenants in the event the employee leaves the Firm. Neuberger is headquartered in New York, New York. As of December 31, 2025, Neuberger had 2,922 employees in 40 cities around the world. NBAA’s investment advisory services are further discussed below. B. Types of Advisory Services NBAA currently provides the following types of investment advisory services: Private Investment Vehicles NBAA acts as the investment manager or sub-adviser providing discretionary investment management services to privately offered investment vehicles (together with co-investment vehicles, feeder funds, aggregators and similar entities managed or sub-advised by NBAA, the “Private Funds”). The Private Funds are organized or “sponsored” by NBAA or an affiliate of NBAA, and an affiliate of NBAA generally acts as the managing member or general partner (each, a “General Partner” or “GP”) of the Private Funds. The Private Funds include commingled vehicles, evergreen open-end vehicles with periodic liquidity, including collective investment trusts, and single client limited partnerships that were organized by affiliates of NBAA for which an NBAA affiliate serves as General Partner (funds-of-one). The Private Funds also include structuring vehicles and feeder vehicles that invest exclusively or primarily in limited partnership interests of a single or multiple NBAA-managed Private Fund(s) and issue equity interests or notes to investors who, for regulatory, tax, or other reasons, elect to acquire indirect exposure to the underlying Private Fund(s) through such a vehicle rather than directly. Unlike open and closed-end mutual funds that are registered with the SEC under the Investment Company Act of 1940, as amended (the “Investment Company Act”), the Private Funds are not registered as investment companies with the SEC and are therefore not subject to various provisions of the Investment Company Act. Interests in the Private Funds are not registered for sale under the Securities Act of 1933, as amended (the “Securities Act”) and are instead sold to qualified investors on a private placement basis. The Private Funds managed by NBAA generally require that investors be (1)(a) “accredited investors” as defined under Regulation D under the Securities Act (“Accredited Investors”); and (b) “qualified purchasers” as defined in Section 2(a)(51)(A) of the Investment Company Act (“Qualified Purchasers”) or “knowledgeable employees” under Rule 3c-5 of the Investment Company Act (“knowledgeable employees”); or (2) not “U.S. persons” as defined under Regulation S of the Securities Act. For a list of the Private Funds, please reference Section 7.B(1) and (2) of Schedule D of Part 1A to NBAA’s Form ADV, which is publicly available at www.adviserinfo.sec.gov. NBAA has the overall responsibility for implementing the investment strategies of each Private Fund and has the authority to select investments within the stated investment strategies and objectives of each Private Fund. The Private Funds generally invest in private securities, such as

venture capital partnerships, special situations partnerships, buyout private equity partnerships, international private equity partnerships and real estate partnerships (collectively, “Portfolio Funds”), as well as direct/co-investments in privately held operating companies, brand royalties, income-generating instruments in the broader healthcare sector, corporate and structured credit securities and holdings, asset-backed securities, specialty finance assets, the debt of private equity-backed companies, insurance-linked securities and private investments in private and public real estate companies (collectively, including Portfolio Funds, “Private Securities”). In addition, certain Private Funds invest in public securities, including, but not limited to, fixed income, equity, catastrophe bonds and publicly traded real estate companies, including public real estate investment trusts (“REITS”) (collectively, “Public Securities” and, together with the Private Securities, the “Portfolio Investments”). Separately Managed Accounts NBAA provides ongoing discretionary investment management services to certain institutional clients in a separate account format (collectively, the “Separate Accounts”). Those investment management services include services to clients for which NBAA acts as sub-adviser. Those Separate Accounts are managed based on individual investment objectives and guidelines, including time horizon, risk tolerance, policies, and limitations of such clients. NBAA helps to establish investment objectives and monitor the achievement of such objectives through selection and management of Portfolio Investments. All Separate Account clients must qualify as (1)(a) Accredited Investors; and (b) Qualified Purchasers; or (2) non-“U.S. persons” as defined under Regulation S of the Securities Act. U.S. Registered Funds NBAA acts as a sub-adviser to affiliated registered closed-end investment companies, which include unlisted closed-end investment companies and closed-end investment companies that operate as interval funds (“Interval Funds”) (collectively, the “U.S. Registered Funds”) that provide for periodic liquidity pursuant to sub-advisory agreements entered into between NBAA and Neuberger Berman Investment Advisers LLC (“NBIA”), the investment adviser of the U.S. Registered Funds. The U.S. Registered Funds sub-advised by NBAA require that investors be (1) Accredited Investors; and (2) qualified clients as defined under Rule 205-3 of the Advisers Act (“Qualified Clients”). The U.S. Registered Funds generally invest in Private Securities, provided that the NB Private Markets Access Fund LLC and the Interval Funds also invest in Public Securities. Please refer to the respective U.S. Registered Fund offering documents for further details about the services provided with respect to the U.S. Registered Funds. NBPE NBAA acts as the investment manager providing discretionary investment management services to NB Private Equity Partners Ltd. (“NBPE”), a non-US-based closed-end investment company registered under the laws of Guernsey and listed on the London Stock Exchange. NBPE investors generally must qualify as (1)(a) Accredited Investors; and (b) Qualified Purchasers; or (2) non“U.S. persons” as defined under Regulation S of the Securities Act. For additional information

concerning this entity, please see the fund’s formation and other offering documents, which eligible investors can find at www.nbprivateequitypartners.com. Sub-Funds of NB Alternative Funds SICAV S.A. NBAA acts as a portfolio manager to the sub-funds (the “Sub-Funds”) of an authorised Luxembourg alternative investment fund for which certain Sub-Funds have adopted the status of European Long Term Investment Funds as defined in the Regulation (EU) 2015/760 of 29 April 2015 as amended (collectively, the “ELTIFs”). NBAA entered into a portfolio management delegation agreement with Neuberger Berman AIFM S.à.r.l (“NB Lux”), an affiliate of NBAA and the alternative investment fund manager of the Sub-Funds. The Sub Funds are regulated by the Commission de Surveillance du Secteur Financier of Luxembourg (“CSSF”). The Sub-Funds generally invest in Private Securities. Please refer to the respective offering documents for further details about the services provided with respect to the Sub-Funds. Non-Discretionary Services NBAA provides non-discretionary investment management services to certain Private Funds and Separate Accounts (collectively, the “Non-Discretionary Accounts”) where it is required to consult with the client before effecting any transaction for the client’s account. For those NonDiscretionary Client Accounts, NBAA’s services generally include periodic or ongoing responsibility to make recommendations as to investment policy statement design and specific investments to be purchased, sold or held, and, if NBAA’s recommendations are accepted by the client, to arrange or effect the implementation of any accepted recommendations. With respect to the provision of those non-discretionary services, Client Accounts generally have sole discretion and final responsibility for investment decisions. The Private Funds, the Separate Accounts, the U.S. Registered Funds, NBPE, Sub-Funds, and Non-Discretionary Accounts are collectively referred to herein as the “Client Accounts.” Additional Services Finally, from time to time, NBAA provides additional services to certain Client Accounts and investors, including the review of non-NBAA managed investments as well as portfolio modeling and reporting, which can include non-binding investment advice in the form of written investment analyses. In addition, those additional services can include training and knowledge transfer that can range broadly by function – for example, risk management, portfolio management and investment due diligence - as well as by asset class and strategies. Those activities include, among others, sessions to review investment opportunities alongside deal teams, or review existing or legacy portfolios; teaching sessions about the private equity asset class, the market and the investment strategies; introductions to private equity firms; and diverse other activities tailored to help investors get a greater insight into these areas. Unless specifically provided in such Client Account’s Offering Documents (as defined below), NBAA is not specifically compensated for the provision of additional services, though the provision

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A. Fee Schedule I. PRIVATE FUNDS NBAA is typically compensated for its advisory services to the Private Funds based on a percentage of assets under management (e.g., commitments, invested capital, or net asset value (“NAV”)) and also can receive performance-based compensation from a Private Fund, as described below and in more detail in the Private Fund Offering Documents. Each Private Fund generally pays to NBAA (or its affiliate) semi-annual, quarterly or monthly advisory or management fees (“Management Fees”) equal to a certain percentage of (i) the total capital commitments (regardless of whether such capital has been invested) of the investors in the applicable Private Fund; (ii) the total invested capital of the applicable Private Fund; or (iii) the NAV (as defined in the applicable Private Fund Offering Documents). Management Fees can be negotiable under certain circumstances. NBAA, or its affiliate acting as General Partner of a Private Fund, in its discretion, is permitted to waive or reduce the Management Fee applicable to all or any of the investors in each Private Fund or agree with an investor to waive or alter the Management Fee as to that investor. Each Private Fund also typically charges performance-based fees or makes performance-based allocations of income. Those are typically in the form of carried interest distributions (“Carried Interest” and, collectively with incentive allocations and any performance-based fees, “Performance-based Compensation”) based on the net cash proceeds attributable to Private Fund investments. Performance-based Compensation can be negotiable under certain circumstances and is often subject to high water provisions or preferred returns, whereby NBAA or an affiliate receives Performance-based Compensation only on increases in the NAV in excess of the highest NAV the Client Account has previously achieved. Performance-based Compensation generally is apportioned to the General Partners or special limited partners of the Private Funds, which are affiliates of NBAA.2 NBAA or its affiliate, acting as the General Partner of a Private Fund,

In the case of certain legacy funds managed by Almanac Realty Investors and Insurance-Linked Strategies, the Performance-based Compensation is apportioned to special limited partners or general

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in its discretion, is permitted to waive or reduce the Performance-based Compensation applicable to all or any of the investors in each Private Fund or agree with an investor to waive or alter the Performance-based Compensation as to that investor. The Performance-based Compensation for certain Private Funds is subject to a “clawback,” in each case in accordance with such Private Fund’s Offering Documents. Additionally, for a limited number of Private Funds, a portion of the Management Fees or the Performance-based Compensation, or both, will be paid to one or more anchor investors. As a result, NBAA may not have the same alignment of interests with the investors of those Private Fund as they would have in the absence of the revenue share with those anchor investors. See Item 6 for more information about Performance-based Compensation. For certain Private Funds, in addition to management fees and Performance Fees, Neuberger Wealth Account clients will be subject to a fee paid to Neuberger Berman BD LLC (“NBBD”) for placement and onboarding services (“PW Access Fee”). The PW Access Fee is described in the Offering Documents of the applicable Private Funds. Management Fees and Performance-based Compensation will generally be waived or partially waived in connection with capital commitments and contributions made by the General Partners or related persons, such as Neuberger employees, senior advisors, and their families who, directly or indirectly, invest, or have invested, in the Private Funds as well as certain Dyal Capital Partnersmanaged private funds (each, a “Dyal Fund”) now managed by Blue Owl, including pursuant to the Firm’s employee investment program. Lower fees and expenses for comparable services are available from unaffiliated managers. The fees and expenses of a Private Fund, including the Management Fee and Performance-based Compensation, could constitute a higher percentage of average net assets than would be found in other investment vehicles not managed by NBAA. Management Fees, Performance-based Compensation, and PW Access Fees (where applicable) for Private Funds are negotiable under certain circumstances. Investors should refer to the respective Private Fund Offering Documents for additional or supplementary information regarding the Private Fund, including the fees and expenses paid by such Private Fund. II. SEPARATE ACCOUNTS Separate Accounts pay a Management Fee equal to a certain percentage of the Separate Account’s (i) total capital commitment (regardless of whether such capital has been invested); (ii) total invested capital; or (iii) NAV (as defined in the relevant Separate Account Offering Documents). Certain Separate Accounts also pay Performance-based Compensation. Fees are negotiable and set forth in the relevant Separate Account Offering Documents. All U.S. Separate Account clients of NBAA are Qualified Purchasers and those charged Performance-based Compensation must be eligible to enter into such an arrangement under the Advisers Act.

partners that include members currently or previously not affiliated with NBAA (for example, former Almanac employees and senior advisors).

Fees will vary depending on a variety of factors including, but not limited to, the identity of the portfolio manager or group managing the account, account size and investment objectives. Investors should refer to the respective Separate Account Offering Documents for additional or supplementary information regarding the Separate Account, including the fees and expenses paid by such Separate Account. III. U.S REGISTERED FUNDS NBAA’s fees with respect to its services as sub-adviser to the U.S. Registered Funds is set forth in the respective U.S. Registered Fund Offering Documents. Each U.S. Registered Fund pays a Management Fee as well as Performance-based Compensation. The annual advisory fee or Management Fee rate for each U.S. Registered Fund is negotiated with and approved by the U.S. Registered Fund’s Board of Managers/Directors. Investors should refer to the respective U.S. Registered Fund Offering Documents for additional or supplementary information regarding the U.S. Registered Fund, including the fees and expenses paid by such U.S. Registered Fund. Each Interval Fund pays NBIA a Management Fee at a specified rate equal to a percentage of the average daily value of the Interval Fund’s net assets. NBIA is also entitled to receive an incentive fee based on income received by the Interval Fund that is equal to a percentage of the Pre-Incentive Fee Net Investment Income for each calendar quarter, subject to a hurdle rate and a “catch-up” feature. For the calculation, “Pre-Incentive Fee Net Investment Income” means, interest income, dividend income and any other income (including any other fees (other than fees for providing managerial assistance), such as commitment, origination, structuring, diligence and consulting fees or other fees that the Interval Fund (or its wholly-owned subsidiaries)) accrued during the calendar quarter, minus the Interval Fund’s operating expenses accrued for the quarter (including the advisory fee, expenses payable under the administration agreement, and any interest expense or fees on any credit facilities or outstanding debt and dividends paid on any issued and outstanding preferred shares, but excluding the incentive fee and any distribution or shareholder servicing fees). Pre-Incentive Fee Net Investment Income includes, in the case of investments with a deferred interest feature (such as original issue discount, debt instruments with PIK interest and zero-coupon securities), accrued income that the Interval Fund has not yet received in cash. PreIncentive Fee Net Investment Income does not include any realized capital gains, realized capital losses or unrealized capital appreciation or depreciation. The annual Management Fee rate for each Interval Fund is negotiated with, and approved by, the fund’s Board of Trustees. IV. NBPE NBAA’s fees with respect to its services to NBPE are set forth in the NBPE Offering Documents. NBPE generally pays NBAA a Management Fee as well as Performance-based Compensation. Investors should refer to the NBPE Offering Documents for additional or supplementary information regarding NBPE, including the fees and expenses paid by NBPE.

V. Sub-Funds of NB Alternative Funds SICAV S.A. NBAA’s fees with respect to its services to the Sub-Funds are paid by NB Lux pursuant to each SubFunds’ portfolio management agreement and internal transfer pricing policies between NB Lux and NBAA. Each Sub-Fund pays NB Lux a Management Fee as well as Performance-based Compensation. Investors should refer to the respective Sub-Fund’s Offering Documents for additional or supplementary information regarding the Sub-Funds, including the fees and expenses paid by such Sub-Fund. The differing fee structures among the Client Accounts described in this Item 5.B results in certain conflicts of interest and issues that present the appearance of a conflict of interest. See Item 6, Item 10 and Item 11.D. VI. NON-DISCRETIONARY ACCOUNTS NBAA’s fees with respect to its services to Non-Discretionary Accounts are set forth in Items 5.A.I. and 5.A.II.

B. Payment Method Calculation and Payment of Management Fees and Performance-based Compensation: Private Funds—The Management Fee generally will be paid by and deducted from the assets of each Private Fund quarterly (and in some cases, semi-annually or monthly) in advance or arrears and will generally be prorated for partial periods with regard to each Management Fee period. Private Fund investors should refer to the Fund’s offering documents. Commitments will periodically be called to satisfy Management Fees and may be reduced by distributions. Performance-based Compensation for each Private Fund is generally paid out as a distribution of the net cash proceeds attributable to Portfolio Investments of such Private Fund. Investors should refer to the respective Private Fund Offering Documents for additional or supplementary information regarding the calculation and payment of fees. Separate Accounts—Management Fees are generally charged quarterly or monthly, in arrears, based on the market value of the Client Account’s capital commitment on an annual tranche basis. Performance-based Compensation is generally charged on each annual tranche of commitment as a distribution of the net cash proceeds attributable to distributions related to Portfolio Investments of such Separate Account annual tranche. Payment of fees for Separate Accounts will generally be made upon invoice. Investors should refer to the respective Separate Account Offering Documents for additional or supplementary information regarding the calculation and payment of fees. U.S. Registered Funds (except the Interval Funds)—The Management Fee and Performancebased Compensation paid by NBIA to NBAA as sub-adviser in accordance with the sub-advisory

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A. Methods of Analysis Security Analysis NBAA’s investment teams for the various strategies described in Item 8.B below employ distinct investment processes that include methods of analyses, including one or more of the following: Fundamental analysis – involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Statistical analysis – involves the examination of data to draw conclusions or insights and determine cause-and-effect patterns between events. Technical analysis – involves the analysis of past market data, primarily price and volume. Cyclical analysis – involves the analysis of business and market cycles to find favorable conditions for buying and/or selling a security or other investment. Analysis of financially material environmental, social, and governance considerations - involves the analysis of factors that are expected to have a material impact on the performance of the relevant investments and is as part of NBAA’s holistic investment analysis. These additional financially material considerations are analyzed alongside the other diligence information and do

not require a particular investment or sponsor to meet a minimum score or criteria in order for the Investment Committee to approve the investments. The additional financially material considerations may also be used by Program Managers of certain funds or accounts that are required, pursuant to their contractual terms, to establish whether an investment satisfies certain legal or regulatory requirements and their implications on valuation, risk and growth potential. While that analysis is inherently subjective and may be informed by both information provided by private equity GPs and other third-party diligence resources, NBAA believes that the consideration of financially material environmental, social and corporate governance factors, alongside traditional financial metrics, enhances its overall investment process, and is designed to have a positive effect on the risk return profile of client portfolios. The consideration of financially material environmental, social, governance factors as part of an integrated investment process does not mean that NBAA pursues a specific “impact” or “sustainable” investment strategy for any particular Client Account, other than as described in Offering Documents or other documents to those particular Client Accounts. Contrarian and Opportunistic analysis – involve the analysis of market data for potential buying and selling strength by gauging investor expectations. Qualitative analysis – involves the subjective evaluation of non-quantifiable factors such as the quality of management, labor relations, and strength of research and development, factors not readily subject to measurement, in an attempt to predict changes to share price based on that data. Quantitative analysis – uses computer, mathematical, or other types of models to capture and process data, including market data, industry information, and financial data for companies, in an attempt to forecast price activity or other market activity that is affected by that data. Operational due diligence – involves an independent due diligence review of asset managers, to identify operational risks and evaluate the effectiveness of the control environment in place at a given organization. Investment Team due diligence – involves the Investment Team’s due diligence review of certain potential Portfolio Investments to identify operational risks and evaluate the effectiveness of the control environment in place at a given organization. Real Estate due diligence – involves extensive due diligence of a company’s management team, business plan, internal controls, assets and corporate structure, as well as informed assessments of real estate opportunities and business strategies. With respect to the Private Funds, NBAA evaluates investments based on a variety of factors that are typically described in the Private Fund Offering Documents. Sources of Information In conducting security analysis on behalf of the Client Accounts, NBAA typically utilizes a broad spectrum of information sources, including, but not limited to:

reviews of private corporate documents (including business plans, financial records and projections); legal documents and customer agreements, and industry research and reviews; interviews with key officers, customers, suppliers and competitors; site visits to portfolio companies to examine operations, technologies, products and market opportunities; expert networks, and outside consultants and advisors having special expertise in relevant fields.

NBAA compiles the foregoing information and typically employs a variety of financial analysis tools and methodologies in valuing and evaluating potential investments. Following an investment, NBAA will continue to monitor the progress and suitability of the Portfolio Investment as well as market and economic outlook, although certain investments made by the Client Accounts in Private Securities will be illiquid investments that will be difficult or impossible to sell. Although the foregoing represents the principal methods of analysis and sources of information that NBAA uses, NBAA could, where appropriate, employ other methods of analysis and consider other sources of information. B. Investment Strategies The following is a summary of the principal investment strategies employed by NBAA. The material risks associated with certain of these strategies are set forth in Item 8.C below. This is a summary only. Investors and potential investors should look to the applicable Offering Documents and other investor materials for a more complete description of each strategy. Investors and potential investors should not rely solely on the descriptions provided below. NBAA can employ other strategies where appropriate and likely will offer additional or different strategies in the future. Private Equity Investment Portfolios and Co-investment Platform NBAA’s Private Investment Portfolios platform seeks to identify and select top performing managers and diversify appropriately across asset classes, vintage years and pace of capital deployment, maturity and stage of companies, geographies, industries and generalist versus industry specific funds. The team also invests opportunistically into co-investments and secondaries. In addition, when determining proper diversification, NBAA analyzes the private equity marketplace and seeks to appropriately weight capital allocations to those sectors with the most promising opportunities. The team manages portfolios in various formats, including commingled funds, custom funds, evergreen funds, separate accounts, and registered funds, as well as European vehicles such as Sub Funds. This strategy may be diversified or focus on a particular area, including, but not limited to, emerging managers; real assets and infrastructure; impact investing; and certain geographies. NBAA’s Co-investment platform’s investment strategy is to directly invest in companies alongside leading private equity firms by (i) partnering with premier private equity firms in their core areas

of expertise; (ii) leveraging the global platform at Neuberger to source, evaluate and execute coinvestment opportunities; (iii) investing on favorable terms alongside lead financial sponsors; (iv) maintaining a disciplined investment philosophy; and (v) building a diversified portfolio of coinvestments. The Private Equity Investment Portfolio and Private Equity Co-Investment platform are integrated together under a single investment committee. Private Equity Secondary Platform NBAA’s Secondary platform’s strategy is to acquire seasoned private equity investments through secondary market transactions, both traditional LP and GP-led, at attractive valuations from investors desiring liquidity or through GP-led transactions. This strategy includes (i) leveraging the Neuberger global network of relationships with private equity firms, corporations, endowments and foundations, institutional investors and high net worth individuals to source proprietary investment opportunities; (ii) capitalizing on secondary market inefficiencies to invest at attractive valuations; (iii) leveraging access to private equity firms and the broader Neuberger platform to support the team’s evaluation of investments; and (iv) actively managing investments post-acquisition. Almanac Realty Investors Platform NBAA’s Almanac Realty Investors is the Firm’s private real estate investment unit. The Almanac Realty Securities strategy seeks to provide growth capital investments into private and public real estate companies in the form of debt, preferred equity or common equity. Almanac’s Investment Manager Solutions strategy seeks to acquire minority equity interests in real estate investment managers or real estate fund sponsors. Athyrium Opportunities Platform The Athyrium Opportunities platform seeks to make income-generating investments in the broader healthcare sector. The strategy focuses on small to mid-size healthcare companies with relatively high costs of capital and substantial intellectual property and other assets, lending to them using various credit-oriented structures designed to enhance downside protection while creating yield for investors, as well as upside opportunity (e.g., warrants). A representative of NBAA sits on the investment committees of certain of the Athyrium funds, and NBAA acts as subadvisor to certain of the Athyrium funds and provides certain support services to those such funds pursuant to a master services agreement between NBAA and Athyrium Capital Management, LP (“ACM”). As partial consideration for its services, ACM has agreed to pay NBAA or its affiliates a portion of the carried interest distributions made by certain Athyrium funds to the applicable Athyrium general partners. NBG is also a minority owner of ACM. Private Debt Platform NBAA’s Private Debt team makes investments in sponsor-backed companies. The Private Debt business is focused on new issuances of first lien and unitranche loans. The Private Debt business may also make investments in second lien loans and equity investment opportunities.

Capital Solutions Platform NBAA’s Capital Solutions business is a strategy that seeks to directly originate financing solutions to premier sponsor-backed companies. The strategy seeks to structure investments (e.g., preferred stock, hybrid notes, structured equity) into high quality, stable businesses with meaningful sponsor equity cushions, targeting equity-like returns in instruments with credit-like protections. Marquee Brands Partners Platform NBAA’s Marquee Brands platform seeks to make income-generating investments through brand acquisitions or acquisitions of organizations with minimal hard or physical assets in the broader consumer and retail sectors, and capitalizes on royalties, partnerships and other monetization strategies. Marquee Brands portfolio includes brands across Home, Culinary, Motherhood, Active & Outdoor, and Fashion. NB ILS Platform NBAA’s Insurance-Linked Strategies (“NB ILS”) investing platform seeks to achieve risk-adjusted returns that are uncorrelated with traditional asset classes. The platform invests in a diversified portfolio of insurance-linked securities that focus on natural and non-natural catastrophe risks. The strategy may utilize other forms of investments to achieve its objectives including, but not limited to, derivatives such as swaps, options and other instruments. Multi Sector Private Credit Platform The Multi Sector Private Credit (“MSPC”) investing platform seeks to generate attractive riskadjusted returns by investing opportunistically across private, public and alternative credit sectors, leveraging internal and external origination channels. Depending on client objectives and guidelines, MSPC builds customized portfolios and other client-specific structures, with a core focus on differentiated opportunities that have historically exhibited relatively low sensitivity to traditional corporate credit risk. The platform emphasizes disciplined underwriting, rigorous due diligence, and thoughtful structuring and diversification across collateral types, obligors, and investment structures. Tactical Alternative Credit Platform NBAA’s Tactical Alternative Credit (“TAC”) investing platform is a multi-sector private credit strategy that deploys capital opportunistically across alternative credit sectors, targeting recurring income with an emphasis on principal protection through disciplined underwriting, collateral- and structure-focused investing, and diversified portfolio construction. The strategy applies a relative value framework and may allocate across hard-asset lending, contractual cash flow lending, and other niche or dislocated credit opportunities as market conditions evolve.

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NBAA’s clients include the Private Funds, the Separate Accounts, the U.S. Registered Funds, NBPE, and the Sub-Funds of NB Alternative Funds SICAV S.A. Separate Account clients include U.S. and non-U.S. institutional investors, including public and private pension plans. Set forth below are the minimum account requirements for NBAA’s accounts: Private Funds Investors in the Private Funds generally must qualify as (1)(a) Accredited Investors; and (b) Qualified Purchasers or knowledgeable employees; or (2) non-“U.S. persons” as defined under Regulation S of the Securities Act. The minimum investment required by an investor varies depending on the Private Fund and in each case is subject to waiver by NBAA or the Private Fund’s General Partner. Potential investors should review the applicable Private Fund Offering Documents for further information with respect to minimum requirements for investment. Separate Accounts NBAA generally creates Separate Accounts for accounts in excess of $100 million but can consider accounts with lesser commitment amounts in its sole discretion. These customized portfolios are designed to meet the specific risk and return goals, liquidity restraints, factor sensitivity targets and other requirements of its clients. Separate Account investors generally must qualify as (1)(a) Accredited Investors and (b) Qualified Purchasers; or (2) non-“U.S. persons” as defined under Regulation S of the Securities Act.

U.S. Registered Funds Investors in the U.S. Registered Funds (except the Interval Funds) generally must be Qualified Clients eligible to be charged Performance-based Compensation under the Advisers Act. Certain of the U.S. Registered Funds also require investors to be Accredited Investors. Please refer to the U.S. Registered Fund Offering Documents for information pertaining to the U.S. Registered Funds. NBPE Investors in NBPE generally must qualify as (1)(a) Accredited Investors; and (b) Qualified Purchasers or knowledgeable employees; or (2) non-“U.S. persons” as defined under Regulation S of the Securities Act. Sub-Funds of NB Alternative Funds SICAV S.A. Investors in the Sub-Funds must be eligible investors as set out in the Sub-Fund Offering Documents pertaining to each Sub-Fund.

For certain Client Accounts, NBAA or its affiliates (such as the General Partners to Private Funds or special limited partners) will receive Performance-based Compensation that is based on a share of one or more of the distributions or (realized or unrealized) capital gains, income or capital appreciation of the assets of an account. Examples of Performance-based Compensation include, but is not necessarily limited to:

a distribution based on the net cash proceeds attributable to the investments; and

an incentive fee or incentive allocation where the fee or allocation is calculated as a percentage of distributions or (realized or unrealized) capital gains or capital appreciation profits (sometimes referred to as incentive allocation or Carried Interest).

Certain Client Accounts’ Performance-based Compensation is subject to, or otherwise impacted by: (a) catch-up provisions; (b) high water mark provisions, whereby NBAA or an affiliate receives Performance-based Compensation only on increases in the NAV in excess of the highest NAV the Client Account has previously achieved; (c) hurdle rate or preferred return provisions, whereby NBAA or an affiliate does not receive Performance-based Compensation until the Client Account’s annualized performance exceeds a benchmark rate, such as T-bill yield, LIBOR or a fixed percentage; and/or (d) clawback provisions which may be net of taxes. As discussed in Item 5.A, NBAA generally receives Performance-based Compensation in connection with the management of Client Accounts. Investors should look to the applicable Offering Documents for a more complete description of Performance-based Compensation. To the extent that portfolio managers of NBAA manage Client Accounts that charge only Management Fees as well as Client Accounts that charge Management Fees and Performancebased Compensation, those portfolio managers have a conflict of interest, or the appearance of a conflict of interest, that an account with a Performance-based Compensation arrangement will offer the potential for higher profitability when compared to an account with only a Management Fee. Performance-based Compensation arrangements create an incentive for NBAA and its portfolio managers to recommend Portfolio Investments that are riskier or more speculative than those which would be recommended under a different fee arrangement. Different compensation arrangements also create an incentive to favor higher fee-paying Client Accounts over other Client Accounts in the devotion of time and resources and the allocation of investment opportunities.

Similar issues exist when NBAA or its personnel and affiliates have differential investments (or other pecuniary interests) in certain Client Accounts. To manage conflicts of interest, and issues that present the appearance of a conflict of interest, NBAA has adopted a number of compliance policies and procedures. Those policies and procedures include (i) the Neuberger Berman Code of Ethics (see Item 11.A) and Code of Conduct; (ii) the NBAA Compliance Manual; (iii) investment allocation policies and procedures that provide that investment opportunities be allocated fairly among Client Accounts and that Client Accounts are managed in accordance with their investment mandates; (iv) policies and procedures that address when a proposed or actual Client Account Portfolio Investment presents a conflict of interest, or the appearance of a conflict of interest; and (v) the NBAA Conflicts Committee. In addition, NBAA’s policies and procedures prohibit personnel from considering fee structures in allocating investment opportunities. NBAA reserves the right to amend its policies and procedures from time to time without notice to, or the consent of, the investors in the Client Accounts, or any other person.

A. Registration as a Broker-Dealer or Registered Representative NBAA is not a registered broker or dealer. Most NBAA personnel are registered representatives with FINRA through their affiliation with NBAA’s registered broker-dealer affiliate, NBBD. In such capacity, subject to applicable law, they are permitted to receive sales commissions in connection with the sale of interests in certain Client Accounts. See Items 5.E and 10.C.1. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor or Associated Person NBAA is exempt from registration as a commodity pool operator (“CPO”) or a commodity trading advisor (“CTA”) with the CFTC. NBAA manages its accounts and pools as an exempt CPO, generally in reliance on available exemptions under CFTC Rules 4.13(a)(3) and CFTC No Action Letter 1238. C. Material Relationships NBAA currently has certain relationships or arrangements with related persons that are material to its investment management business and the Client Accounts. Below is a discussion of such relationships/arrangements and any conflicts of interest, or issues that present the appearance of a conflict of interest, which arise therefrom. 1. Broker-dealer, municipal securities dealer, or government securities dealer or broker NBAA is affiliated with NBBD, a U.S. registered broker-dealer. In addition, most NBAA advisory personnel are registered representatives with FINRA through their affiliation with NBBD. Registered representatives of NBBD and unaffiliated broker-dealers solicit certain investors for NBAA and its affiliates. Subject to applicable law, NBBD receives sales commissions in connection with the sale of interests in certain Client Accounts. Some sales commissions will be a portion of, or calculated from, NBAA’s Management Fee with respect to such interests. From time to time, certain Client Accounts pay commissions, expenses, finder’s fees or other compensation to (i) third parties and (ii) certain employees of Neuberger and its affiliates for identifying Portfolio Investments. See Item 5.E and Item 14.B. In providing investment management services to the Client Accounts, NBAA draws upon the trading, operational, administrative and research resources of NBBD and other affiliates. NBAA utilizes Anti Money Laundering services provided by NBBD.

The existence of these relationships will from time to time cause a conflict of interest, or the appearance of a conflict of interest. See Item 11.B.6 and 11.D.1. The Firm has established policies and procedures reasonably designed to prevent the misuse by the Firm and its personnel of material information regarding issuers of securities that has not been publicly disseminated. See Item 11.D.1. 2.

Investment Company or other pooled investment vehicle

NBAA acts as the adviser to NBPE; the sub-adviser to the U.S. Registered Funds, advised by an affiliate of NBAA; and a portfolio manager to the Sub-Funds. NBAA also acts as adviser to NB Private Funds where an affiliate acts as General Partner. Affiliates of NBAA act as General Partners to other pooled investment vehicles (collectively, the “Affiliated Funds”). Certain management persons of NBAA act as directors or officers of Affiliated Funds. 3.

Other investment adviser or financial planner

NBAA has relationships that are material to its investment advisory business with the following affiliated investment advisers (collectively, the “Advisory Affiliates”). SEC Registered Affiliated Advisers: Neuberger Berman BD LLC3 Neuberger Berman Investment Advisers LLC Neuberger Berman Asia Limited Neuberger Berman Europe Limited Neuberger Berman Singapore Pte. Limited Neuberger Berman Loan Advisers LLC Neuberger Berman Loan Advisers II LLC Neuberger Berman Loan Advisers IV LLC Neuberger Berman Loan Advisers Europe II LP Neuberger Berman Canada ULC Neuberger Berman AIFM S.à.r.l (Exempt Reporting Adviser) Neuberger Berman Asset Management Ireland Limited (Exempt Reporting Adviser) Non-SEC-Registered Advisers: Neuberger Berman East Asia Limited Neuberger Berman Australia Ltd Neuberger Berman Information Consulting (Shanghai) Limited Neuberger Berman Korea Limited Neuberger Berman Taiwan (SITE) Limited

While NBBD is also registered with the SEC as an investment adviser, it does not currently provide advisory services to any clients.

Where required, personnel of non-SEC-registered Affiliated Advisers are considered “access persons” of NBAA and are subject to certain NBAA policies and procedures as well as supervision and periodic monitoring. In providing investment management services to the Client Accounts, NBAA draws upon the resources of certain of the Advisory Affiliates. For example, and subject to the Information Barrier Procedures (defined below), NBAA employees speak with employees of NBIA’s dedicated research department. Where required, personnel of the non-SEC-registered advisers involved in NBAA’s advisory activities are deemed “associated persons” of NBAA and are subject to certain NBAA policies and procedures as well as supervision and periodic monitoring. Certain NBAA portfolio management personnel are also officers or otherwise affiliated with some of these Advisory Affiliates but are not engaged in providing investment management services to the clients of such Advisory Affiliates. NBAA acts as sub-adviser to certain Separate Account clients of third-party advisers and Advisory Affiliates. In addition, NBAA serves as sub-adviser to certain Client Accounts, including those advised by Advisory Affiliates. Neither NBAA nor its related persons are obligated to allocate any specific amount of time or investment opportunities to a particular Client Account. See Item 6 and Item 11.B.8 with respect to side-by-side management. The views and opinions of NBAA, and those of the Advisory Affiliates and their research departments, will, from time to time, differ from one another. As a result, Client Accounts managed by NBAA, or its Advisory Affiliates can be expected to hold securities or pursue strategies that reflect differing investment opinions or outlooks at the time of their acquisition or subsequent thereto. See Item 11.B.7 and Item11.D.6. The Firm has adopted policies and procedures reasonably designed to prevent the misuse by the Firm and its personnel of material non-public information (“MNPI”). See Item 11.D.1. 4. Futures commission merchant, commodity pool operator, or commodity trading advisor NBBD is registered with the CFTC as a CTA and introducing broker and is a member of the NFA. In addition, NBIA is registered as a CTA and CPO and Neuberger Berman Canada ULC is registered as a CPO and CTA. NBAA does not have a material relationship with these entities in such capacities. 5.

Banking or thrift institution

None. 6.

Accountant or accounting firm

None.

7.

Lawyer or law firm

None. 8.

Insurance company or agency

Certain Neuberger personnel currently provide ongoing consulting, advice and other support to NB Reinsurance Ltd., a company formed under the laws of Bermuda (“NB Re”), which holds a Class 3 exempted insurance license in Bermuda. Such services include participation on and advice to NB Re’s board of directors and underwriting committee and certain other matters in connection with NB Re’s entry into reinsurance contracts or insurance-linked agreements with third parties, primarily through collateralized industry loss warranties as well as catastrophe bonds. The NB ILS funds will invest substantially all of their assets in NB Re. Neuberger controls NB Re. 9.

Pension consultant

None. 10.

Real estate broker or dealer

None. 11.

Sponsor or syndicator of limited partnerships

The Private Funds are generally organized or “sponsored” by NBAA, and an affiliate of NBAA acts as the General Partner of the Private Funds, where applicable. See Item 10.C.2. Further information about the partnerships for which affiliates of NBAA serve as the General Partner is available in Section 7.B.(1) of Schedule D of Part 1A of NBAA and its affiliated SEC-registered investment advisers’ Form ADVs. See Item 10.C.3. 12.

Administrator

None. D. Selection of Other Investment Advisers NBAA invests certain Client Accounts in Portfolio Funds for which a third-party acts as the Underlying Manager. NBAA maintains an extensive due diligence process for the selection of Underlying Managers, which it has developed throughout 30 years of private equity investing (including predecessor firms). The following items are examples of the qualitative and quantitative analyses that may be conducted during due diligence of the Underlying Managers, to the extent determined by NBAA to be appropriate: •

Track Record o Commentary on performance o Relevance of track record to current team o Assessment of unrealized value

• • • •

• • • • • • • • • • • • • • • •

Item 11:

Strategy, Portfolio Construction & Value Creation Funded Primary Analysis (if applicable) Fund Size Investment Team o Size and stability of team o Partner Attribution o Board Seat Activity Investment Committee / Decision Making Capital Efficiency o Recycling Analysis Co-Investment Opportunities Operating Capabilities & Other Team Resources Analysis of Additional Financially Material Factors Firm Governance & Culture Legal / Compliance Valuation NAV Cash Management IT / Disaster Recovery / Cybersecurity Counterparties / Service Providers Economics Terms Relevant litigation, reputational issues, legal/structuring, etc. Reference Calls

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

A. Code of Ethics In order to address conflicts of interest, and issues that present the appearance of a conflict of interest, NBAA has adopted a Compliance Manual and additional policies and procedures as well as the Neuberger Berman Code of Ethics and Code of Conduct (collectively, the “Conflicts Procedures”). The Conflicts Procedures are applicable to all of NBAA’s officers, members, and employees (collectively, the “Employees”). The Conflicts Procedures generally set the standard of ethical and professional business conduct that the Firm and NBAA requires of the Employees. The Conflicts Procedures consist of certain core principles requiring, among other things, that Employees: (1) at all times place the interests of clients first; (2) conduct all personal securities transactions in such a manner as to avoid any conflicts of interest, and issues that present the appearance of a conflict of interest, and to avoid any abuse of an individual’s position of trust and responsibility; (3) refrain from taking advantage of their positions inappropriately; and (4) at all

times conduct themselves in a manner that is beyond reproach and that complies with all applicable laws and regulations. As discussed further below, the Conflicts Procedures include provisions relating to the confidentiality of client information; a prohibition on insider trading; approval and disclosure requirements related to gifts and entertainment items; and personal securities trading procedures, among other topics. All Employees must acknowledge the terms of the Code of Ethics at least annually, or when it is materially amended. In addition, the Conflicts Procedures impose certain additional requirements on Access Persons (as defined in the Conflicts Procedures) who are advisory persons. It also requires Access Persons to report personal securities transactions on at least a quarterly basis or as otherwise required and provide the Firm with a detailed summary of certain holdings (initially upon becoming an Access Person and annually thereafter) over which such Access Persons have control or a direct or indirect beneficial interest. NBAA reserves the right to amend its policies and procedures from time to time without notice to, or the consent of, the investors in the Client Accounts, or any other person. Investors or prospective investors may obtain a copy of the Code of Ethics by contacting their Client Service Representative. B. Participation or Interest in Client Transactions From time to time, NBAA will participate or have a direct or indirect interest in Client Account transactions as described below. NBAA’s policies and procedures provide that NBAA make all investment management decisions in its Client Accounts’ best interests. 1.

Principal and Agency-Cross Transactions:

Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account, buys from, or sells any security to, an advisory client. A principal transaction would occur if NBAA bought securities for its own inventory from a Client Account or sold securities from its inventory to a Client Account. In certain instances, it would also occur if an affiliate of NBAA bought or sold securities from or to a Client Account. If NBAA, its affiliates or their respective principals own a substantial equity interest in an account managed by the adviser, a transaction involving that account and another client could be characterized as a principal transaction. For example, if NBAA, its affiliates or their respective principals have a substantial equity interest in an Affiliated Fund, the transfer of securities from such Affiliated Fund’s account to an NBAA-managed Separate Account or another Affiliated Fund could be deemed a principal transaction. A principal transaction presents conflicts of interest that include the adviser or affiliate earning a fee or earning (or losing) money as a result of the transaction.

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Moreover, from time to time and subject to legal, tax, regulatory and other considerations, NBAA permits certain parties to participate, on a preferred basis, in investment opportunities alongside certain Client Accounts. To mitigate these conflicts of interest, and issues that present the appearance of a conflict of interest, NBAA’s Conflicts Procedures provide that investment decisions be made in accordance with the fiduciary duties owed to Client Accounts and to require that NBAA (or such personnel) not place their pecuniary, investment or other financial interests ahead of our Clients Accounts’ interests. For example, NBAA has adopted policies and procedures reasonably designed to allocate investment opportunities in a fair and equitable manner among Client Accounts. See Item 12.B and Item 11.D.1 regarding investment allocation procedures.

Item 12:

Brokerage Practices

A. Criteria for Selection of Broker-Dealers Brokerage Selection NBAA generally invests Client Accounts in Private Securities that are investments directly with the issuers. Such trades are generally not placed through a broker-dealer. Accordingly, NBAA does not generally engage directly in soft dollar arrangements with respect to Private Securities, enter into agreements with, or make commitments to, any broker-dealer that would bind NBAA to compensate that broker-dealer, directly or indirectly, for client referrals (or sale of fund interests) through the placement of brokerage transactions, or have any clients that direct brokerage to certain brokers. As described in Item 5.E NBAA will from time to time utilize the Firm’s central trading desk to execute Public Securities transactions with third-party brokers for certain Client Accounts. Accordingly, where appropriate, references to NBAA in connection with trade execution in this

If NBAA trades Public Securities or other securities (e.g., foreign currency forwards and hedges, etc.) through a broker-dealer (and subject to the paragraph below), NBAA generally looks to the overall quality of service provided by the broker and will consider many factors when making a selection for execution. NBAA has discretion to utilize soft dollars in connection with brokerage trades for certain Client Accounts in Public Securities to obtain research and/or brokerage services used for the benefit of clients, although it only does so within the safe harbor provided in Section 28(e) of the Exchange Act. Subject to the foregoing, it is NBAA’s policy to seek to obtain the best price on every trade given all the relevant circumstances, and NBAA monitors and regularly evaluates the execution quality it receives from every broker with which it trades. However, in addition to price, traders are also permitted to consider the size and potential market impact of the transaction, liquidity of both the security and the market, the broker’s ability to provide or find liquidity, time limitations, and confidentiality of the transaction. In addition, NBAA is permitted to consider research and other services in making brokerage decisions. (See “Research and Other Soft

Dollar Benefits” in this Item 12.A). Accordingly, Client Accounts will from time to time be able to obtain more favorable brokerage commission rates elsewhere. NBAA will also utilize electronic trading networks when they can provide liquidity and price improvement over and above what is available through traditional methods for execution. In the event Public Securities are distributed to certain Client Accounts, NBAA generally expects that it will rely on the broker-dealer with whom the securities account for such Client Account is held, which will from to time include an affiliate of NBAA, for trade execution. NBAA has selected one or more firms to serve as prime broker (“Prime Broker”) to hold the funds and securities of certain Client Accounts. The Prime Broker also executes transactions on behalf of certain Client Accounts, consistent with the principles of best execution. Specific trades can be “traded away,” (i.e., executed through brokers other than the Prime Broker) where NBAA believes that doing so could provide access to greater inventory or better price or execution. NBAA has selected Prime Brokers it believes will provide specific services beneficial to certain Client Accounts, allowing the Client Account to operate more effectively and efficiently by, for example, providing NBAA with electronic access to account information and trade confirmations and bulk mailing of statements to investors. Research and Other Soft Dollar Benefits Soft dollars refer to the practice of using a portion of the commissions generated when executing client transactions to acquire research and brokerage services from broker-dealers. In general, this discussion relates to equity trading; NBAA does not generally pay additional commissions to obtain soft dollars for fixed income transactions to brokers or dealers on behalf Client Accounts. Use of Soft Dollars: NBAA is permitted to consider research and other services as a factor in making brokerage decisions for certain Client Accounts and, as it deems appropriate, use a portion of the commissions generated when executing certain Client Account transactions (commonly referred to as “soft dollars”) to acquire research and brokerage services (“soft dollar benefits”) in a manner consistent with the “safe harbor” provided by Section 28(e) of the Exchange Act. Under the safe harbor, as it has been interpreted by the SEC, NBAA is permitted to use soft dollars to pay for soft dollar benefits, even where such benefits are also be available for cash, to the extent appropriate and permitted by law and other global jurisdictional requirements, when such benefits assist NBAA in meeting Client Accounts’ investment objectives or in managing the Client Accounts. As described in Item 5.E, NBAA will from time to time utilize the Firm’s central trading desk to execute transactions with third-party brokers for certain Client Accounts. In addition, NBAA participates in the Firm’s soft dollar program for certain Client Accounts and, where appropriate, this discussion concerns those Client Account’s use of soft dollars and participation in the Firm’s soft dollar program. The use of soft dollars to receive research and services benefits NBAA by allowing NBAA, at no cost to it, to (i) supplement and enhance its own research and analysis activities; (ii) receive the views and information of individuals and research staff of other securities firms; and (iii) gain access to persons having special expertise on certain companies, industries, areas of the economy and market factors. Subject to the Firm’s policies and procedures, NBAA is permitted to take into

account the value of permissible soft dollar benefits provided by a broker-dealer, as long as such consideration is not inconsistent with the objective of seeking best execution for Client Account transactions. Certain Client Accounts are permitted to pay a higher commission rate than the rate that would be charged solely for execution to a broker-dealer in recognition of such soft dollar benefits. When appropriate under its discretionary authority and consistent with the duty to seek best execution, NBAA is permitted to select broker-dealers who provide NBAA with useful soft dollar benefits and pay to those broker-dealers an amount or rate of commission that is higher than might have been paid absent the receipt of soft dollar benefits. NBAA is permitted to select brokerdealers based on its assessment of each broker-dealer’s ability to provide quality executions and its belief that the research, information and other services provided by such broker-dealer could benefit Client Accounts. Often, it is not possible to place a dollar value on the quality of executions or on the soft dollar benefits from broker-dealers effecting transactions in portfolio securities. Accordingly, broker-dealers selected by NBAA could be paid commissions for effecting portfolio transactions for Client Accounts in excess of amounts other broker-dealers would have charged for effecting similar transactions, if NBAA determines in good faith that such amounts are reasonable in relation to the value of the soft dollar benefits provided by those broker-dealers, viewed either in terms of a particular transaction or NBAA’s overall duty to discretionary accounts. NBAA is permitted to use “step outs” or “commission sharing arrangements” to obtain soft dollar benefits for certain Client Accounts. A step out would occur if NBAA directs a broker-dealer, who executes a trade, to allocate (or “step out”) a portion of the trade to another broker-dealer for clearance and settlement. NBAA primarily expects to use step outs for block trades and believes that this practice assists in seeking best execution. In commission sharing arrangements, NBAA is permitted to effect transactions, subject to best execution, through a broker with a request that the broker allocate a portion of the commission or commission credits to a segregated “research pool” maintained by the broker. NBAA is permitted to then direct such broker to pay for eligible products and services directly or transfer the credits to a commission credit aggregator for future payment to a research provider. Participating in commission sharing arrangements enables NBAA to (1) strengthen its key brokerage relationships; (2) consolidate payments for eligible products and services; and (3) receive a variety of high-quality eligible products and services while facilitating best execution in the trading process. NBAA also is permitted, in its discretion, to elect to pay cash for soft dollar items. Allocation of Soft Dollar Research: Research obtained with soft dollars will not always be utilized by the Firm for the specific Client Account or Client Accounts that generated the soft dollars and, in fact, will also be used for NBIA-managed clients. It should be noted that the value of many soft dollar benefits cannot be measured precisely, and commissions paid for such services cannot always be allocated to Client Accounts in direct proportion to the value of the services to each Client Account. Because, as discussed in Item 12.B, NBAA will aggregate or “bunch” certain Client Account transactions, brokerage commissions attributable to one or more Client Accounts are

permitted to be allocated to brokers who provide statistical data and research used by the Firm in managing other clients’ accounts. A factor in the allocation of brokerage is the Firm’s evaluation of the quality of the brokers’ research, meaning the extent to which such brokerage benefits some or all Firm clients. For purposes of evaluating such research, points are awarded in several categories and the allocation to brokerage business is made based upon the number of points each broker receives. Research is often received on an unrequested basis from brokers who are not awarded points. Often research received from others is not used. Brokers who are not being awarded points for research are nonetheless sometimes used in the interest of securing best execution. Commissions paid by one Client Account would, in effect, subsidize services that benefit another Client Account or NBIA-managed clients. However, any distortions should balance out over time as NBAA believes that its various sources of research and brokerage services enable NBAA to make better investment decisions and execute more effective trades. Therefore, the Firm does not usually attempt to allocate the relative costs or benefits of research or brokerage services among clients. Certain Client Accounts’ ability to pay for expenses through soft dollars will be limited by laws or regulations such as the restrictions under MiFID II or by client restrictions. Although the Firm makes efforts to ensure that clients are treated equally when it comes to bearing these expenses, these legal or client restrictions could result in Client Accounts who are not subject to the legal restrictions paying more commissions for soft dollars than similarly situated clients who are subject to such legal restrictions. Additionally, those restrictions on paying soft dollar commissions could impact the ability to aggregate the orders of clients with restrictions on soft dollars with the orders of clients who do not have such soft dollar restrictions, which could impact the execution received by one or both groups of clients. As part of the efforts to fairly distribute soft dollar expenses, NBAA works with other parts of the Firm to set a budget estimating the spending on research over the upcoming quarter that is monitored against the research commissions generated by the Firm’s clients. NBAA believes that, in the aggregate, the services it receives benefit Client Accounts and assists NBAA in fulfilling its overall fiduciary duty to Client Accounts. NBAA is permitted to receive directives from certain Client Accounts to make a “best effort” attempt to transact business with a client-designated broker in consideration of services received solely by that client from the broker. In such instances, only the particular Client Account’s own soft dollars would be used. Unless contrary written instructions are provided by the client, primary consideration would be still given to seeking best execution of such transactions. Types of Soft-Dollar Products and Services: Research services provided by a broker-dealer can be either proprietary (created and provided by the broker-dealer, including tangible research products as well as access to analysts and traders) or third-party (created by a third-party but provided by the broker-dealer). NBAA is permitted to use soft dollars to acquire either type of research or any permissible brokerage services. The Firm has received the following soft-dollar products and services during the last fiscal year: current and historical data concerning particular companies, industries and the financial economy as a whole, as well as information and analysis thereof, technical and statistical studies and data dealing with various investment opportunities, risks and trends, and analysis involving special situations.

Trade Errors Trade errors can result from a variety of situations involving portfolio management (e.g., inadvertent violation of investment restrictions) and trading (e.g., miscommunication of information, such as wrong number of shares, wrong price, wrong account, calling the transaction a buy rather than a sell and vice versa, etc.) (collectively, “Trade Errors”). In situations where correcting a Trade Error would result in NBAA bearing financial losses, NBAA has an incentive to ignore or understate the Trade Error. However, the Firm has adopted policies and procedures for correcting Trade Errors. The policies and procedures require that all Trade Errors affecting a Client Account be resolved promptly and fairly. Under certain circumstances, the policy provides that trades can, where appropriate, be cancelled or modified prior to settlement. The intent of the policy is to reasonably assure that, if a Trade Error results in a Client Account being in a worse financial position, the Client Account is restored to the appropriate financial position considering all relevant circumstances surrounding the error.

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A. Compensation by Non-Clients Not applicable. B. Compensation for Client Referrals Subject to applicable law, certain employees of NBAA and its affiliates are eligible to earn an account referral commission for referring a potential investor to NBAA that engages NBAA to provide investment advisory services. In addition, from time to time, in accordance with applicable law, NBAA retains and compensates financial intermediaries and other third parties for introducing new clients to NBAA for NBAA’s advisory services. Those third parties are retained as independent contractors to refer clients and engage in other promotional activity for NBAA and its advisory services. In that capacity, the third-party promoter is authorized to recommend, solicit, approve, support, discuss or describe experiences, or engage in other promotional activity related to NBAA, its investment advisory services and personnel that constitutes an “endorsement” or “testimonial” of NBAA, as such terms are defined under Rule 206(4)-1 under the Advisers Act. See Item 5.E. Referral arrangements give rise to conflicts of interest, and issues presenting the appearance of a conflict of interest, given that the referring party has a financial incentive to introduce new investors to NBAA. In certain cases, other conflicts of interest exist. In those cases, the referring party is required to disclose the specific conflict to the potential client prior to, or at the time of, the referral. NBAA’s participation in the referral arrangements does not diminish its fiduciary obligations to its clients. Consistent with its obligations under the Advisers Act, NBAA provides disclosures for the referral parties to distribute to potential clients relating to the applicable referral arrangement. Consultants NBAA actively seeks to educate consultants, broker-dealers, and other financial intermediaries (jointly referred to in this section as “Consultants”) about its advisory services. NBAA sponsors educational events where its representatives meet with Consultants and/or their clients. NBAA will from time to time pay some of the costs associated with educational events, which provide NBAA’s representatives with an opportunity to meet with Consultants and/or clients. These fees are paid by NBAA from its own resources, which include the Management Fees received from the investors. Investors should confer with their Consultant regarding the details of the payments they receive from NBAA. NBAA benefits from such activity as it advises Client Accounts.

On December 17, 2018, the SEC announced the issuance of an Order (the “Order”) concerning expense allocations by the former Dyal Capital Division of NBAA relating to the Business Services Platform (the “BSP”), a team within Dyal focused on providing client development, talent management, operational advisory and other services to the partner managers in which the Dyal Funds invest. Without admitting or denying any wrongdoing, NBAA consented to the entry of the Order. Following the completion of the Blue Owl transaction in May 2021, in which the Dyal Capital Partners Division ceased to be a division of NBAA, no businesses of NBAA utilize the BSP and allocates the expense associated with the BSP to an NBAA-advised fund. The SEC Order had no finding of intentional wrongdoing or fraud and found that the issues relating to the BSP expenses ceased in 2017. According to the Order, with respect to certain of the Dyal Funds, the Dyal Funds’ manager did not appropriately allocate a portion of the BSP expenses to certain Dyal Funds and did not have proper policies and procedures in place to ensure that all allocations were related to the utilization of the BSP. The Order required NBAA to cease and desist from committing or causing any violations and future violations of Sections 206(2) and 206(4) of the Advisers Act, as amended, and Rules 206(4)-7 and 206(4)-8 thereunder. NBAA agreed as part of the settlement to pay disgorgement of $2,073,988 (plus prejudgment interest of $284,620) to certain Dyal Funds covering 2012-2016, and pay a civil monetary penalty of $375,000 to the SEC. The civil monetary penalty was satisfied on January 3, 2019. The disgorgement and prejudgment interest was satisfied on June 7, 2019.

A. Periodic Reviews NBAA generally reviews the accounts of the Client Accounts on a periodic basis, consistent with the Client Account’s needs, including, without limitation, in connection with investor reporting. In reviewing Client Accounts, NBAA is permitted to take into consideration a variety of factors, including the investment strategies set forth in the Offering Documents. B. Non-Periodic Reviews Other than the periodic review of accounts described above, certain account anomalies could trigger non-periodic reviews of Client Accounts.

C. Client Reports On a quarterly, monthly, or semi-annual basis, depending on the Client Account, schedules of purchases and sales, and statement of changes in net assets, and schedules of investments and cash are generally provided to each Client Account. A client may request a reasonable number of additional reports at no extra charge. Private Funds. Investors in Private Funds receive such reports as described in the Private Fund’s Offering Documents (or as otherwise negotiated with NBAA). To comply with Rule 206(4)-2 under the Advisers Act (the “Custody Rule”), when NBAA is deemed to have custody of a Private Fund’s assets, Private Fund financial statements are prepared in accordance with Generally Accepted Accounting Principles (or “GAAP”) (or International Financial Reporting Standards (“IFRS”) reconciled with GAAP for certain Private Funds) and distributed to investors within 120 days after the end of the fund’s fiscal year for its direct investing accounts and 180 days of the fund’s fiscal year for its fund of funds accounts. Generally, investors also receive at least quarterly reports containing information on the Private Fund’s portfolio holdings, valuation of their interests in the Private Fund and cash distributions. These reports may include or be accompanied by information with respect to the performance of the Private Fund, other information about the investor’s capital account and certain tax-reporting information (e.g., Schedule K-1). Separate Accounts. Please refer to the Separate Account Offering Documents for information pertaining to the Separate Accounts. U.S. Registered Funds. U.S. Registered Fund (including Interval Funds) investors receive such reports as described in the applicable U.S. Registered Fund Offering Documents and annual and semi-annual reports as required by the Investment Company Act or other applicable laws and regulations. In addition, NBAA provides reports to each U.S. Registered Fund’s Board of Directors/Managers, as they request and as required by the Investment Company Act. Sub-Advised Accounts. NBAA coordinates with Sub-Advised Account clients or their permitted designees to provide periodic reviews and reporting to the client or investors as required. Clients and investors in a sub-advised fund receive such reports as required by the investment adviser as provided in the applicable sub-advisory agreement and as required by applicable law or regulation. NBPE. NBPE investors receive such reports as are described in the NBPE Offering Materials. In addition, NBAA provides reports to NBPE’s Board of Directors, as they request and as required by applicable law. Sub-Funds. Sub-Fund investors receive such reports as are described in the Sub-Fund Offering Materials.

Private Funds With the exception of certain Private Securities, none of NBAA or its affiliates will maintain physical custody of the funds or securities of any Private Fund. Custody of the assets of a Private Fund generally will be maintained with a qualified custodian selected by NBAA or its affiliate, in its exclusive discretion, which selection may change from time to time generally without the consent of investors in the Private Fund. Although NBAA or its affiliates generally will not have physical custody of Private Fund assets, under the Custody Rule, an adviser has “constructive” custody if it or an affiliate has the authority to possess client assets by withdrawing funds on a client’s behalf. NBAA or its affiliates, by virtue of acting as adviser and/or General Partner of each Private Fund, has the authority to withdraw funds or securities from the Private Fund. Accordingly, NBAA is deemed to have “constructive” custody over the assets in each Private Fund. In order to comply with the Custody Rule, these Private Funds undergo an annual audit performed by an independent accounting firm registered with, and subject to inspection by, the Public Company Accounting Oversight Board (PCAOB). The audited financial statements, prepared in accordance with GAAP (or IFRS reconciled with GAAP for certain Private Funds), are distributed to all Private Fund investors within 120 days of the end of the fund’s fiscal year for its direct investing accounts and 180 days of the fund’s fiscal year for its fund of funds accounts. Separate Accounts Generally, none of NBAA nor its affiliates will be deemed to have custody of the assets of the Separate Accounts. The assets in a Separate Account typically are deposited with a qualified custodian selected by the client. Under each investment management agreement, NBAA generally invoices the Separate Account client, and the client directs its custodian to pay NBAA. U.S. Registered Funds Please refer to the Offering Documents for information pertaining to the U.S. Registered Funds (including Interval Funds). None of NBAA nor its affiliates maintain physical possession of the assets of any Registered Fund, including any securities. The assets of each U.S. Registered Fund are held in an account of a qualified custodian in accordance with the requirements of the Investment Company Act. Sub-Advised Accounts Sub-Advised Accounts are custodied in accordance with the particular type of client (e.g., Separate Accounts, Private Funds, and Non-U.S. Registered Funds).

NBPE Please refer to the NBPE Offering Documents for information pertaining to NBPE. Sub-Funds Please refer to the Sub-Fund Offering Documents for information pertaining to the Sub-Funds.

Discretionary Accounts NBAA generally has the authority to determine, for the Client Accounts, without obtaining specific client consent, the Portfolio Investments to be bought or sold; the amount to be bought or sold; and, if applicable, the broker dealer to be used and commission rates paid. In limited circumstances, certain Client Accounts are permitted to request exclusion from participating in certain Portfolio Investments pursuant to the terms of their agreement with NBAA. In addition, certain third-party sponsors will from time to time direct Portfolio Investments, in whole or in part, to certain Clients Accounts, or request that other Client Accounts not participate in a potential Portfolio Investment. NBAA’s discretionary authority is derived from an express grant of authority under each Client Account’s investment advisory agreement or investment management agreement with NBAA or pursuant to a sub-advisory agreement, as applicable. Purchases and sales must be suitable for the particular Client Account and limitations may be imposed as a result of instructions from the Client Account or as set forth in the Offering Documents. From time to time, the Firm itself places restrictions on trading in certain securities or other assets in Client Accounts. Legal or regulatory considerations or Firm risk management policies and procedures will necessitate that the Firm restrict trading in certain issuers. Limitations will also be imposed if the purchase of a security, when aggregated with positions in such security held by NBAA and its affiliates, and by the Client Accounts or other Firm clients, would exceed applicable law or NBAA’s self-imposed rules with regard to maximum size of positions in a security. NBAA will not be able to trade in any securities on the Firm restricted list on behalf of any Client Accounts, except with approval by the Firm’s Legal and Compliance Department. For example, pursuant to the Firm’s MNPI Procedures, when NBAA is in possession of MNPI related to the issuer of any security, whether acquired unintentionally or otherwise, NBAA is not permitted to render investment advice as to, or otherwise trade or recommend a trade in, the securities of such issuer until such time as the information that NBAA has is no longer deemed to be MNPI. As such, there are circumstances which will prevent the purchase or sale of securities for Client Accounts for a period of time. See Item 11.D.1.

Non-Discretionary Accounts For certain accounts, NBAA provides non-discretionary investment management services where it is required to consult with the Client Account before effecting any transactions on behalf of the Client Account. In each such case, the investor is the final decision maker on all buy, sell and hold decisions with respect to those transactions and holdings. Please refer to “Non-Discretionary Services” in Item 4.B for a discussion of Non-Discretionary Accounts.

With certain exceptions, Client Accounts are typically invested in Private Securities. Due to the nature of these investments, NBAA does not typically anticipate having authority to vote proxies since it does not make direct investments in Public Securities. However, in the event Public Securities are distributed to a Client Account, NBAA will vote proxies for such securities in accordance with the best interest of such Client Account (and as described further below). In particular, with respect to those Client Accounts that will make direct investment in Portfolio Funds, NBAA will not exercise voting authority with respect to any Private Securities held by such Portfolio Fund; instead, such voting authority is expected to be exercised by the general partner of such Portfolio Fund. In addition, NBAA generally does not take any action with respect to shareholder actions (including those relating to class actions, bankruptcy or reorganizations) that may be required or solicited with respect to portfolio securities held by a Client Account; instead, such actions with respect to shareholder actions are expected to be taken by the Underlying Manager of each Portfolio Fund. NBAA has implemented written Proxy Voting Policies and Procedures (the “Proxy Voting Policy”) that provide that NBAA will vote proxies in the best interest of the Client Accounts for whom NBAA has voting authority. The Proxy Voting Policy also provides for the process by which proxy voting decisions are made; the handling of material conflicts; the disclosure of the Proxy Voting Policy to investors; the maintenance of appropriate books and records relating to proxies; and proxy voting guidelines for common proxy proposals. For certain Client Accounts that own public equities, Neuberger has engaged Glass, Lewis & Co. (“Glass Lewis”) as its advisor and voting agent to: (1) provide research on proxy matters; (2) vote proxies in accordance with Neuberger’s Governance and Proxy Voting Guidelines or as otherwise instructed and submit such proxies in a timely manner; (3) handle other administrative functions of proxy voting; (4) maintain records of proxy statements received in connection with proxy votes and provide copies of such proxy statements promptly upon request; and (5) maintain records of votes cast. For public equities, if there is a material conflict of interest, the proxy will be voted as Glass Lewis recommends. NBAA believes that this process is reasonably designed to address conflicts of interest and issues presenting the appearance of a conflict of interest that arise in conjunction with proxy voting decisions. Investors may obtain a copy of the Proxy Voting Policy or obtain information about how NBAA voted their specific proxies upon request.

A. Prepayment of Fees (Six or more months in advance) Not applicable. B. Impairment of Contractual Commitments NBAA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients. C. Bankruptcy Petitions NBAA has not been the subject of a bankruptcy proceeding.