Nuveen Asset Management, LLC

Nuveen Asset Management, LLC (“NAM”) provides investment advisory services to a broad range of individual and institutional clients, including open-end and closed-end investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”) and other pooled investment vehicles (each, a “Fund” and collectively, “Funds”). NAM also provides investment advisory services to institutional investors through separate account management under both direct advisory and sub-advisory mandates (“Institutional Separate Accounts”). In addition, NAM provides investment advisory services to retail separately managed account (“Retail SMA”) clients through managed account programs (wrap fee and dual contract) sponsored by broker-dealers, investment advisers and other financial intermediaries (“Program Sponsors”). Although most services are provided on a discretionary basis, NAM also provides certain services on a non-discretionary and model portfolio basis. NAM has been in business for more than 40 years. NAM is a subsidiary of Nuveen Fund Advisors, LLC (“NFAL”), which is an indirect subsidiary of Nuveen, LLC (“Nuveen”). Nuveen is a subsidiary, and represents the investment management division, of Teachers Insurance and Annuity Association of America (also known as “TIAA”), a leading financial services provider. TIAA constitutes the ultimate principal owner of NAM. See Item 10. Types of Advisory Services General NAM provides investment advisory or sub-advisory services to Funds, Institutional Separate Accounts and Retail SMAs. NAM’s investment advisory services are provided generally based on the strategy selected by the client, subject to agreed-upon account restrictions and guidelines. NAM provides its services in a broad array of fixed income, equity and other investment strategies, including in the broad categories of municipal bonds, taxable fixed income, global and international, value, growth and core equities, listed real assets, asset allocation, quantitative/enhanced, responsible investing, alternative, tax advantaged and customized strategies. Depending on the particular strategy, NAM invests in a variety of securities and other investments, including in certain cases derivatives, and employs different investment techniques. Certain strategies include an allocation to Funds, including Funds affiliated with NAM or its affiliates. Certain strategies include elements of other strategies and may be customized to meet the individualized needs of NAM’s clients. For additional information on NAM’s main strategies and principal risk factors, please see Item 8. NAM’s portfolio managers are generally responsible for the investment decisions with respect to the investment strategy selected by a client, including identification and selection of specific securities and investments to be purchased in light of current and anticipated economic and market conditions, in consideration of account guidelines, limitations and information relating to the client, legal restrictions and NAM internal strategy guidelines. NAM provides its services in single strategy accounts, and alone or together with certain affiliated and unaffiliated advisers, in combined and multi-strategy accounts. To the extent permitted by applicable law, NAM also may appoint affiliated and unaffiliated investment sub-advisers (“Subadvisers”) to provide advisory services including discretionary portfolio management to all or a portfolio of assets of one or more Funds, Institutional Separate Accounts, or Retail SMAs. Typically, a client or NAM generally may terminate its agreement at any time by providing thirty (30) days written notice. For Institutional Separate Accounts, termination provisions vary by contract and for Retail SMAs, termination provisions vary by wrap fee program. Fees paid in advance are refunded on a pro rata basis if the service is terminated within the payment period. NAM manages multiple accounts with different investment objectives, guidelines and policies, and with different fee structures. For example, certain accounts are long-only while other accounts are long-short. Further, certain accounts pay performance fees. The management of these accounts

gives rise to potential conflicts of interest because NAM has an incentive to favor one account over another. See Item 6. NAM also provides services to various accounts affiliated with TIAA, including TIAA’s General Account, and other accounts that include proprietary capital. See Item 10, 11 and 12. Clients may direct NAM to liquidate holdings to raise cash that the client will withdraw. When raising the cash in advance of the withdrawal, NAM may adjust its internal systems to reflect the designation of such cash when raised so that such cash does not reflect an impact on account performance and/or guidelines violations caused by raising such cash prior to withdrawal. In periods of market volatility, NAM may be unable to invest new money contributed to an account, or proceeds from the sale of securities, as quickly as it might have been able to do under normal market conditions. Similarly, NAM may be unable to sell securities to raise cash, or to accommodate a terminating client’s request to sell securities, as quickly, or at favorable prices, as it might have been able to do under normal market conditions. Depending on market movements, such delays could have an adverse impact on client accounts. In such periods of market volatility, NAM, when deemed advisable, also may deviate from its normal trading practices with respect to sequencing and allocation of transactions. From time to time an issuer of a portfolio security may make a distribution of a non-traditional asset, such as a digital token. The acceptance of such assets into the client’s custodial account is subject to the ability of the client’s custodian to custody such assets and the terms and conditions thereto, NAM’s good faith determination of the value of the asset, and other investment, business, legal/regulatory, operational and/or administrative considerations. To the extent that acceptance of such distribution requires NAM to take certain actions, NAM reserves the right to take action or refrain from taking action based on its consideration of the foregoing factors and its assessment of the costs and benefits of the distribution. Institutional Separate Accounts NAM provides advisory services to U.S and non-U.S. institutional clients including pension funds, profit sharing funds, charitable institutions, banks and thrift institutions, trust accounts, corporations, insurance companies, and public entities, including municipalities, states and related agencies. The fees and services for each such arrangement are individually negotiated, depending on factors such as asset class, pre-existing relationship, portfolio complexity, client type and account size or other special circumstances. See Item 5. Retail SMAs NAM provides investment advisory services to Retail SMAs through wrap fee and dual contract managed account programs. In traditional wrap fee programs, NAM provides its advisory services pursuant to an advisory agreement with the wrap fee Program Sponsor. Wrap fee programs typically include comprehensive custody, financial advisory and certain trading (provided by the Program Sponsor or a broker designated by the Program Sponsor) and investment advisory services (provided by the manager) for a bundled fee payable to the wrap fee Program Sponsor (“Wrap Fee Programs”). In a dual contract Retail SMA program, NAM provides its advisory services pursuant to an advisory agreement directly with the client or the client’s financial advisory firm. A client may separately arrange with one or more third parties for custody, financial advisory and certain trading services to be provided on a partially-bundled or unbundled basis. In a partially-bundled program, certain of such services (typically custody, financial advisory, and certain trading) are provided for a bundled fee arrangement. In an unbundled arrangement, such services are contracted, provided and paid for separately. For Retail SMAs, NAM is appointed to act as an investment adviser through a process generally administered or assisted by the Program Sponsor. Clients participating in a program, generally with assistance from the Program Sponsor, may select NAM to provide investment advisory services for their account (or a portion thereof) for a particular strategy. NAM provides investment advisory services based upon the particular needs of the program client as reflected in information provided

to NAM by the Program Sponsor, and will generally make its representatives available for communication as reasonably requested by clients and/or Program Sponsors. Clients are encouraged to consult their own financial advisors and legal and tax professionals on an initial and continuous basis in connection with selecting and engaging the services of an investment manager for a particular strategy and participating in a wrap, dual contract or other managed account program. In the course of providing services to Retail SMAs who have financial advisors, NAM generally relies on information or directions communicated by the financial advisor acting with apparent authority on behalf of its client. Executing an investment strategy for clients may entail tax consequences, which may vary by client based on client-specific factors. NAM does not provide tax or accounting advice. Clients are encouraged to consult with their own professional advisors regarding the suitability and selection of the strategy and program. NAM seeks to commence management of an account as soon as practicable after review of the account documentation in good form, acceptance of its appointment as adviser and contribution of assets to the client’s account. The time required to commence management varies depending on the time required to complete these steps, the efficiency of the Program Sponsor and/or other third parties, and the time required to establish an appropriate portfolio. The timing required to fully invest an account depends on multiple factors, including the particular strategy and guidelines; market conditions; availability of desirable securities; the amount of cash versus legacy securities used to fund a new account; and if legacy securities are used, the characteristics of such legacy securities, among others. For some strategies, such as certain municipal bond strategies where the supply of appropriate bonds is limited, it may take several weeks or longer to fully invest a client account. As a result of the foregoing, some accounts may become fully invested more quickly than other accounts, and in some cases a new account may become fully invested more quickly than an older account. The client, and not NAM, is responsible for the selection of the designated money market fund, bank deposit account or other vehicle (each, a “Designated Cash Sweep Vehicle”) into which cash and free credit balances in an account are moved pending investment by NAM. The Designated Cash Sweep Vehicle options for a particular advisory program are generally determined by the qualified custodian, sponsor or financial advisor. For certain municipal bond strategy accounts and subject to acceptance by NAM and internal procedures, NAM may accommodate directions from a client or their financial advisor to invest cash balances in an alternative(s) to the Designated Cash Sweep Vehicle during the invest up period. The alternative(s) to the Designated Cash Sweep Vehicle may include an Affiliated Fund (as defined below) that has no fund-level management fee. It is expected that such Affiliated Fund would follow an ultra short municipal bond strategy and is not a money market fund, and is therefore subject to greater risks than a money market fund. See Item 8. NAM reserves the right to determine the availability of such accommodations, including investment in such Affiliated Fund, in its discretion based on business factors it deems relevant. See Item 15 for additional information on Designated Cash Sweep Vehicles. NAM maintains procedures for executing specific transactions directed by a client or its financial advisor in a client’s account for tax reasons. Under these procedures, NAM will generally follow the directions of a client or its financial advisor regarding harvesting tax losses or gains, subject to certain scope, amount and timing limitations. Generally, the directions entail a repurchase of the sold security after the “wash sale” (thirty (30) day) period (e.g., in the case of equities), or a purchase of another appropriate security (e.g., in the case of bonds). NAM generally relies in good faith on directions communicated by a financial advisor acting with apparent authority on behalf of its client. Certain NAM strategies, such as Tax Advantaged Strategies (as defined below), incorporate tax optimization methodologies, including tax loss harvesting, as part of the investment strategy. The methodologies and processes for such strategies differ from those utilized for clientdirected transactions. In providing such directions, the client and its financial advisor are responsible for understanding the merits and consequences of their directions in light of the client’s particular tax situation. Daily market fluctuations may affect the dollar amount of gain or loss with respect to certain investment decisions. The monetary benefit derived from tax loss selling, for example, may not exceed the risk of not being fully invested during that time. Executing tax sales (and repurchases) may adversely

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NAM’s advisory fees are generally based on a percentage of assets under its management. For eligible client accounts, performance-based fees also may be negotiated in appropriate circumstances. Please see Item 6. NAM generally does not charge fixed fees except in special situations. Fees, minimum account sizes, and services may be negotiable based on factors such as client type, asset class, pre-existing relationship, portfolio complexity and account size or other special circumstances or requirements. Some existing clients pay higher or lower fees than new clients. Related accounts may be aggregated for fee calculation purposes in certain circumstances. When NAM calculates fees, valuations of account assets are determined in accordance with NAM’s valuation procedures, which generally rely on third party pricing services, but may permit the use of other valuation methodologies in certain circumstances. NAM’s determinations may differ from valuations reflected in a client’s custodial statements. Advisory Fees for Institutional Separate Accounts Advisory fees for Institutional Separate Accounts are generally determined based upon the following schedules. However, fees for certain strategies or accounts fall outside of the stated ranges or are negotiated. Breakpoints are generally applied on a blended basis, unless otherwise agreed. NAM may impose minimum annual fees for Institutional Separate Accounts as negotiated. EQUITY STRATEGIES Large Cap Core First $25 million 0.60% Next $25 million 0.50% Next $50 million 0.45% Over $100 million 0.40%

$5 million

Large Cap Value Opportunities First $25 million 0.60% Next $25 million 0.50% Next $50 million 0.40% Over $100 million 0.30%

$5 million

Large Cap Value Balanced First $25 million 0.60% Next $25 million 0.50% Next $50 million 0.40% Over $100 million 0.30%

$5 million

Stable Growth First $25 million 0.60% Next $25 million 0.50% Next $50 million 0.45% Over $100 million 0.40%

$5 million

Equity Long/Short First $100 million 1.10% Next $150 million 1.00% Over $250 million Negotiated

$100 million

Dividend Growth First $25 million 0.50% Next $25 million 0.45% Next $50 million 0.40% Over $100 million 0.35%

$1 million

Global Dividend Growth First $25 million 0.65% Next $25 million 0.60% Next $50 million 0.55% Over $100 million 0.50%

$5 million

Global Dividend Growth (ADR) First $25 million 0.60% Next $25 million 0.55% Next $50 million 0.50% Over $100 million 0.45%

$1 million

International Dividend Growth First $25 million 0.65% Next $25 million 0.60% Next $50 million 0.55% Over $100 million 0.50%

$5 million

International Dividend Growth (ADR) First $25 million 0.60% Next $25 million 0.55% Next $50 million 0.50% Over $100 million 0.45% $1 million Select Dividend Growth First $25 million 0.60% Next $25 million 0.55% Next $50 million 0.50% Over $100 million 0.45%

$1 million

Dividend Value First $25 million 0.60% Next $25 million 0.50% Next $50 million 0.45% Over $100 million 0.40%

$5 million

Large Cap Select First $25 million 0.60% Next $25 million 0.50% Next $50 million 0.45% Over $100 million 0.40%

$5 million

Mid Cap Growth Opportunities First $25 million 0.65% Next $25 million 0.55% Next $50 million 0.50% Over $100 million 0.45%

$5 million

Mid Cap Value First $25 million 0.65% Next $25 million 0.55% Next $50 million 0.50% Over $100 million 0.45%

$5 million

Multi Cap Value First $25 million 0.75% Next $25 million 0.70% Next $50 million 0.65% Over $100 million 0.60%

$20 million

Small Cap Growth Opportunities First $25 million 0.75% Next $25 million 0.65% Next $50 million 0.60% Over $100 million 0.55%

$5 million

Small Cap Select First $25 million 0.75% Next $25 million 0.65% Next $50 million 0.60% Over $100 million 0.55%

$5 million

Small Cap Value First $25 million 0.75% Next $25 million 0.65% Next $50 million 0.60% Over $100 million 0.55%

$5 million

Small Cap Value Opportunities First $25 million 0.75% Next $25 million 0.65% Next $50 million 0.60% Over $100 million 0.55%

$5 million

Small/Mid Cap Value First $25 million 0.70% Next $25 million 0.65% Over $50 million 0.60% Over $100 million 0.55%

$5 million

Emerging Markets (ADR) First $25 million 0.75% Next $25 million 0.70% Next $50 million 0.65% Over $100 million 0.60%

$1 million

Global Equity Income First $25 million 0.70% Next $25 million 0.65% Next $50 million 0.60% Over $100 million 0.55%

$5 million

International Opportunities First $25 million 0.75% Next $25 million 0.70% Over $50 million 0.65% Over $100 million 0.60%

$25 million

International Equity (ADR) All Assets 0.70%

$1 million

International Value First $25 million 0.70% Next $25 million 0.60% Next $50 million 0.50% Over $100 million 0.45%

$10 million

International Value (ADR) First $25 million 0.85% Next $25 million 0.75% Next $50 million 0.65% Over $100 million 0.55%

$2 million

Japan Equity First $25 million 0.70% Next $25 million 0.60% Next $50 million 0.50% Over $100 million 0.40%

$10 million

Index First $25 million 0.15% Next $25 million 0.11% Next $50 million 0.09% Next $150 million 0.05% Over $250 million Negotiated

$25 million

Enhanced Equity Index First $50 million 0.30% Next $50 million 0.25% Next $150 million 0.20% Over $250 million Negotiated New Client Minimum Account Size

$5 million

LISTED REAL ASSETS STRATEGIES U.S. Real Estate Securities First $50 million 0.50% Next $50 million 0.45% Over $100 million 0.40%

$10 million

Global Real Estate Securities First $50 million 0.60% Next $50 million 0.55% Over $100 million 0.50%

$20 million

Real Asset Income First $50 million 070% Next $50 million 0.65% Over $100 million 0.60%

$50 million

Global Infrastructure First $50 million 0.70% Next $50 million 0.65% Over $100 million 0.60%

$20 million

TAXABLE FIXED INCOME STRATEGIES Intermediate Government/Credit First $50 million 0.18% Next $50 million 0.16% Over $100 million 0.14%

$10 million

Core First $50 million 0.18% Next $50 million 0.16% Over $100 million 0.14%

$50 million

Core Plus First $50 million 0.20% Next $50 million 0.18% Over $100 million 0.16%

$20 million

Corporate Credit First $50 million 0.45% Next $50 million 0.40% Over $100 million 0.35%

$20 million

Credit Income First $50 million 0.40% Next $50 million 0.35% Over $100 million 0.30%

$50 million

Flexible Income First $50 million 0.55% Over $50 million 0.50%

$20 million

Strategic Income First $50 million 0.35% Next $50 million 0.30% Next $100 million 0.25%

$50 million

Short Duration First $50 million 0.16% Next $50 million 0.14% Over $100 million 0.12% Over $250 million Negotiated

$10 million

Long Duration First $50 million 0.25% Next $50 million 0.20% Over $100 million 0.15%

$10 million

Inflation Protected First $50 million 0.15% Next $50 million 0.10% Over $100 million 0.08%

$10 million

High Yield/Income First $200 million 0.40% Over $200 million 0.35%

$50 million

Preferred Securities and Income First $50 million 0.40% Next $50 million 0.35% Over $100 million 0.30%

$10 million

MUNICIPAL BOND FIXED INCOME STRATEGIES Municipal Bond Investment Grade First $50 million 0.30% Next $50 million 0.25% Over $100 million 0.20%

$10 million

Taxable Municipal Fixed Income First $100 million 0.35% Next $100 million 0.30% Next $300 million 0.25% Over $500 million 0.20%

$50 million

Municipal Fixed Income First $100 million 0.40% Next $100 million 0.35% Next $300 million 0.30% Over $500 million 0.25%

$50 million

Municipal Bond High Yield All Assets 0.60%

$50 million

Advisory Fees for Institutional Separate Accounts in Leveraged Finance Strategies Fees for leveraged finance strategies (Long-Short Credit, Corporate Arbitrage and Relative Value; and Long-Only Credit) are subject to negotiation based on factors including complexity. Generally, fees range from 1% to 2% per annum on accounts that employ short-selling, leverage, hedging, derivatives and/or similar investment methods, and 0.37% to 1% per annum for long only. A performance fee may also be applicable. Advisory Fees for Dual Contract Retail SMAs Advisory fees for Dual Contract Retail Separate Accounts are generally determined based upon the following schedules. However, fees for certain strategies or accounts fall outside of the stated ranges or are negotiated. NAM and Program Sponsors each charge their fees separately. Fees charged to dual contract accounts are individually contracted between NAM and the client. Breakpoints are generally applied on a blended basis, unless otherwise agreed. MUNICIPAL BOND FIXED INCOME RETAIL STRATEGIES Municipal Bond Investment Grade All Assets 0.30%

$250,000

ESG Municipal Bond Investment Grade All Assets 0.30% $250,000 High Income Municipal Bond All Assets 0.28%

$5,000,000

Municipal Bond Total Return All Assets (60/40) 0.32% All Assets (70/30) 0.21% All Assets (80/20) 0.18%

$250,000

*60/40, 70/30, and 80/20 represent the target percentage allocations to an individual municipal bonds/shares of affiliated Funds, respectively. Municipal Bond Ladder (1-7 Year; 1-10 Year; 1-15 Year; 5-15 Year; 10-25 Year; Customized) All Assets 0.10% $250,000 Municipal Income 90/10 All Assets 0.30%

$250,000

Municipal Income 80/20 All Assets 0.31%

$250,000

Custom Fixed Income Solutions All Assets 0.30%

$250,000

Tax-Aware Fixed Income All Assets 0.30%

$250,000

TAXABLE FIXED INCOME RETAIL STRATEGIES Core Plus Bond SMA All Assets 0.32%

$250,000

Core Bond All Assets 0.25%

$250,000

Core Impact Bond All Assets 0.32%

$250,000

Flexible Income All Assets 0.50%

$250,000

Preferred Securities and Income All Assets 0.30%

$50,000

Preferred Securities All Assets 0.40%

$50,000

Preferred Securities Select All Assets 0.40%

$400,000

Taxable Bond Ladder All Assets 0.10%

$250,000

EQUITY RETAIL STRATEGIES Dividend Growth All Assets 0.50%

$100,000

Global Dividend Growth (ADR) All Assets 0.60%

$100,000

International Dividend Growth (ADR) All Assets 0.65% $100,000 Emerging Markets (ADR) All Assets 0.75%

$100,000

Global Value All Assets 0.70%

$5 million

International Equity (ADR) All Assets 0.70%

$100,000

Multi Cap Value All Assets 0.75%

$100,000

Small Cap All Assets 0.75%

$100,000

TAX ADVANTAGED STRATEGIES Tax Advantaged Equity All Assets 0.12-0.20% (depending on the benchmark and other risk factors) $250,000 Tax Advantaged Balanced All Assets 0.20-0.25% (depending on the benchmark and other risk factors) $500,000 Tax-Advantaged Long/Short Gross Notional Value 0.17% (the effective fee rate will be higher due to leverage) As an example, for a strategy with 130%/30% long/short exposure and a fee of 17 basis points on gross notional value/exposure, the effective fee rate on actual assets would be (130% + 30%) x 17 basis points = 27 basis points. $1 million Advisory Fees for Retail SMAs Offered through Wrap Fee Programs For Retail SMAs offered through Wrap Fee Programs, NAM’s fee is determined by agreement between the Program Sponsor and NAM and may be up to 0.50%. Total annual fees charged by Program Sponsors, which include NAM’s fee, are generally up to 1.25% (in the case of fixed income) and 3.00% (in the case of equity) annually of the client’s assets in the Wrap Fee Program. Advisory Fees for Funds Fees for advisory services provided to Funds are separately negotiated between NAM and the third-party or affiliated investment adviser and/or Fund. Fees may be based on a percentage of assets under management and/or performance based. Advisory Fees for Multi-Asset Class Services Fees for Multi-Asset Class services are negotiated. Advisory Fees for Non-Discretionary Accounts and Model Portfolio Advice These services are furnished for a negotiated fee paid by the purchaser. Additional Fee Calculation Information NAM’s fees are generally payable quarterly or at such other times as agreed upon by the parties involved based upon the market value of assets in the account on the date of valuation, the average of the market value of the assets in the account during the billing period, or the calendar quarterend market value. For Institutional Separate Accounts and dual contract Retail SMAs, payment arrangements, including the timing (in advance or in arrears) and billing procedures (which may include sending an invoice and/or deduction of fees), will generally be agreed upon by NAM and the client. In the case of Wrap Fee Program clients and certain dual contract Retail SMAs, billing and payment methods generally will be determined by the Program Sponsor. For certain dual

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NAM provides its services in a broad array of fixed income, equity and other investment strategies, including in the broad categories of municipal bonds, taxable fixed income, global and international, value, growth and core equities, listed real assets, asset allocation, quantitative/enhanced, responsible investing, alternative and customized strategies. Depending on the particular strategy, NAM invests in a variety of securities and other investments, including in certain cases derivatives, and employs various methods of analysis and investment techniques. Certain strategies include an allocation to Affiliated Funds. Certain strategies include elements of other strategies and are customized to meet the individualized needs of NAM’s clients. Nuveen has adopted certain principles on responsible investing at the enterprise level. NAM generally endeavors to include material environmental, social and governance (ESG) factors as part of the investment research and/or portfolio construction process for public markets securities in active strategies to the extent relevant, as further described below. For strategies that expressly undertake to employ ESG, green, impact or other responsible investing factors, or as otherwise expressly agreed with a client, NAM's approach to ESG is subject to the guidelines and terms relating to such strategies and services. For active public markets strategies, NAM seeks to make available certain ESG research that investment research and/or portfolio managers may consider in their discretion to the extent ESG factors are deemed financially relevant from an investment perspective. NAM does not undertake to apply specific requirements in this regard, and the nature and quality of ESG research made available, if any, and whether and the degree to which ESG factors are accessed, reviewed and/or considered largely depends on the particular portfolio management team, strategy, securities, account-level guidelines and requirements, and other factors, and may vary materially. NAM's ESG research is generally not available, or is integrated to a lesser extent, in certain strategies, accounts and securities, including, for example and without limitation, distressed bonds, convertible bonds, short selling, certain fixed income holdings below certain size thresholds, as well as well as passive and quantitative public markets strategies. Unless a strategy expressly undertakes to employ ESG, green, impact or other responsible investing factors, or as otherwise agreed with a client, NAM will not necessarily include in or exclude from portfolios certain securities, industries or sectors based solely on such criteria. Clients that select strategies that expressly pursue ESG, green, impact or other responsible investing objectives should consult their own financial and other advisors and consider the suitability and risks of such strategies. See ESG Risks below. Tax Advantaged Strategies incorporate certain technology-driven tax loss harvesting and portfolio customization methodologies as part of the investment strategy. Although other strategies may consider taxation or employ tax-loss harvesting methodologies, the technology-driven methodologies employed for the Tax Advantaged Strategies are materially different than the methodologies employed for other strategies. See below for additional information on Tax Advantaged Strategies and Tax-Managed Investing Risk, and Technology and Model Risk. General descriptions of NAM’s investment strategies are included below. These descriptions are not intended to serve as applicable account guidelines. Except in limited instances (e.g., certain allocation or multi-asset class strategies), NAM’s strategies are not generally intended to provide a complete investment program for a client, and clients are responsible for appropriately diversifying their assets as appropriate. NAM reserves the right to limit the availability of any particular strategy at any given time based on factors including asset class capacity, pre-existing relationships, minimum account sizes, fees and available distribution channels. In addition, NAM develops other investment strategies from time to time and manages portfolios according to a client’s specific investment guidelines, and thus, strategies may vary by client account. Certain strategies are available only in certain channels or through investing in Funds. For Funds, the descriptions of the investment strategies below are qualified in their entirety by the information included in a Fund’s prospectus or other official offering documentation. Prior to investing in any Fund, an investor should review the relevant prospectus or offering memorandum for important information.

STRATEGIES Equity Large Cap portfolios are invested primarily in common stocks of large-capitalization U.S. and/or non-U.S. companies, including emerging markets issuers. Large Cap portfolios may reflect growth, value or core (investing in both growth and value stocks) investment approaches. Mid Cap portfolios are invested primarily in common stocks of mid-capitalization U.S. and/or nonU.S. companies, including emerging markets issuers. Mid Cap portfolios may reflect growth, value or core (investing in both growth and value stocks) investment approaches. Small Cap portfolios are invested primarily in common stocks of small-capitalization U.S. and/or non-U.S. companies, including emerging markets issuers. Small Cap portfolios may reflect growth, value or core (investing in both growth and value stocks) investment approaches. Small/Mid Cap portfolios are invested primarily in common stocks of small to mid-capitalization U.S. and/or non-U.S. companies, including emerging markets issuers. Small/Mid Cap portfolios may reflect growth, value or core (investing in both growth and value stocks) investment approaches. All Cap or Multi-Cap portfolios are primarily invested in equity securities of U.S. and/or non-U.S. companies, including emerging markets issuers, of any market capitalization. Dividend-oriented portfolios are invested primarily in equity securities of U.S. and/or non-U.S. companies, including emerging markets issuers, with an emphasis on dividends. Dividend-oriented portfolios may reflect growth, value or core (investing in both growth and value stocks), and/or U.S., global and international, investment approaches. Options Overlay (also known as Covered Call strategy) employs, to varying degrees, option overwrite strategies that seek to enhance risk-adjusted performance over time of an equity portfolio. Index portfolios generally invest a substantial amount of their assets in common stocks included in a particular broad-based securities index, such as a large cap, mid cap or small cap index. A portfolio generally does not hold all of the stocks included in a particular index, or hold them in the same weighting as the index. Enhanced Equity Index/Large Cap Core Quantitative portfolios follow an actively managed strategy that uses a proprietary quantitative process to invest in common stocks. International Equity portfolios invest primarily in non-U.S. issuers that trade in U.S. or non-U.S. markets (including emerging markets). International portfolios may reflect growth, value and core investment approaches. Certain strategies gain international investment exposure by investing in ADRs, Global Depositary Receipts (“GDRs”) and similar depositary receipts. ADRs are the receipts for the shares of a non-U.S.-based company traded on U.S. exchanges. Accounts of large institutional clients may hold ordinary non-U.S. securities (sometimes referred to as “ORDs”) directly (instead of or in addition to ADRs). GDRs typically are issued by non-U.S. banks or financial institutions and represent an interest in underlying securities issued by either a U.S. or a non-U.S. entity and deposited with the non-U.S. bank or financial institution. Emerging Markets is an emerging market-focused investment strategy. This strategy seeks longterm capital appreciation by investing in high-quality, growth-oriented emerging market companies, diversified by country, sector and market cap. Certain strategies gain investment exposure by investing in ADRs, GDRs and similar depositary receipts. ADRs are the receipts for the shares of a non-U.S.-based company traded on U.S. exchanges. Accounts of large institutional clients may hold ordinary non-U.S. securities (sometimes referred to as “ORDs”) directly (instead of or in addition to ADRs). GDRs typically are issued by non-U.S. banks or financial institutions and

represent an interest in underlying securities issued by either a U.S. or a non-U.S. entity and deposited with the non-U.S. bank or financial institution. Japan Equity portfolios seek to invest in undervalued Japanese companies with attractive absolute valuation, favorable risk/reward and identifiable catalysts and/or some element of change not understood by the market. The strategy utilizes ORDs and may also invest in GDRs or equivalent securities. Global portfolios invest primarily in U.S. and non-U.S. issuers (that trade in U.S. or non-U.S. markets) (including emerging markets). Global portfolios may reflect growth, value and core investment approaches. Certain strategies gain international investment exposure by investing in ADRs, GDRs and similar depositary receipts. ADRs are the receipts for the shares of a non-U.S.based company traded on U.S. exchanges. Accounts of large institutional clients may hold ORDs directly (instead of or in addition to ADRs). GDRs typically are issued by non-U.S. banks or financial institutions and represent an interest in underlying securities issued by either a U.S. or a non-U.S. entity and deposited with the non-U.S. bank or financial institution. Concentrated portfolios invest in a relatively small number of securities compared with nonconcentrated portfolios, thus providing greater exposure to each such security. Concentrated portfolios may relate to different asset classes (e.g., equities, preferred securities, etc.) and focus on companies of a particular capitalization (e.g., large cap, mid cap, small cap) and reflect growth, value or core (investing in both growth and value stocks) investment approaches. Long/Short portfolios establish long and short positions, typically in stocks of U.S. companies, with an objective of long-term capital appreciation. Certain long/short portfolios seek absolute returns independent of market direction (market neutral) and are not intended to outperform stocks and bonds during strong market rallies. Additional Information about Equity Strategies. Equity securities in which the portfolios invest may include common and preferred stocks, publicly-traded units of master limited partnerships (“MLPs”), REITs, ETFs and other investment companies, convertible preferred stocks and debt securities that are convertible into common stocks. Each of the equity portfolios may pursue other strategies or invest in other instruments described in this Brochure. Certain of the above equity securities portfolios may use derivatives, including options, futures contracts, options on futures contracts, and forward non-U.S. currency contracts, to manage various types of risk, enhance a portfolio’s return, equitize cash or hedge against adverse movements in currency exchange rates. In addition, certain portfolios may use derivatives such as swaps, including interest rate swaps, total return swaps, credit default swaps and non-U.S. currency swaps, as well as other derivatives, to hedge the risk of investment in securities, substitute for a position in an underlying security, reduce transaction costs, maintain full market exposure, manage cash flows and preserve capital. Certain portfolios may also use derivatives, such as participatory notes and equity-linked securities, to gain exposure to equity and other securities of certain issuers. In addition, certain portfolios may write (sell) covered call options or buy put options on an index, or on some or all of the stocks or other securities they invest in, as well as using call spreads or other types of options to generate premium income and reduce volatility on a portfolio’s return, with the intent of improving a portfolio’s risk adjusted return. Certain portfolios may invest in stock index futures contracts, options on stock indices, and options on stock index futures to maintain the liquidity needed to meet redemption requests, to increase the level of portfolio assets devoted to replicating an index, and to reduce transaction costs. In addition, certain portfolios may utilize forward contracts to enhance returns. The portfolios may also be invested in warrants and securities convertible or exchangeable for equity securities such as convertible bonds. A portion of a portfolio’s assets may be invested in non-dollar denominated equity securities of nonU.S. issuers. In addition, a portion of a portfolio’s assets may be invested in dollar-denominated equity securities of non-U.S. issuers that are either listed on a U.S. stock exchange or represented by depositary receipts that may or may not be sponsored by a domestic bank. Certain portfolios may invest primarily in ADRs and other depositary receipts.

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NAM provides investment advisory and sub-advisory services to a broad range of individual and institutional clients, including investment companies and pooled investment vehicles, pension plans, charitable organizations, state or municipal government entities, insurance companies and corporate entities. Prior to investing in any Fund, an investor should review the relevant offering materials for important information concerning the objectives, policies, strategies, risks, fees and other important information. Institutional Separate Accounts For Institutional Separate Accounts, NAM generally requires a minimum account size generally ranging from $1 to $50 million depending on the strategy. Please see the fee schedule in Item 5 above for specific minimum investment amounts. NAM may waive these minimums based on client type, asset class, pre-existing relationship with client and other factors. For certain accounts, a negotiated minimum annual fee applies. Retail SMAs For Retail SMAs, NAM typically requires a minimum account of $100,000 for equity and asset allocation strategies and $250,000 for fixed income strategies, although the specific minimum account size varies by program. NAM may waive these minimums based on client type, asset class, pre-existing relationship with client and other factors. For certain accounts, a negotiated minimum annual fee applies.

NAM offers investment advisory services to multiple accounts with different investment objectives, guidelines and policies, and with different fee structures. NAM may receive both asset-based fees and performance-based fees as compensation for its advisory services. Performance-based fees may create an incentive for NAM to make investments that are riskier or more speculative than would be the case in the absence of a performance-based fee. In these instances, NAM’s compensation may be greater than it would otherwise have been, as the fee will be based on account performance instead of, or in addition to, a percentage of assets under management. To the extent that NAM manages accounts that are charged a performance-based fee side-by-side with accounts are that not charged a performance-based fee, NAM maintains policies and procedures designed to treat all clients fairly. NAM periodically reviews allocations of investment opportunities and sequencing of transactions and compares the performance of such accounts, as well as assessing for adherence to such policies and procedures. Any exceptions or issues arising from the reviews are brought to the attention of NAM’s Chief Compliance Officer.

In addition to being registered as an investment adviser with the SEC, NAM is also registered as a commodity trading advisor (“CTA”) with the Commodity Futures Trading Commission (“CFTC”), and certain management persons and/or other personnel of NAM are registered as CTA principals or associated persons. When providing advice relating to commodity interests (e.g., futures, options on futures and swaps), depending on the particular strategy and services, NAM may be operating either under its CTA registration or under an exemption or exclusion from registration as a CTA. Certain management persons and/or other personnel of NAM are registered representatives and associated persons of Nuveen Securities, an affiliated broker-dealer. As discussed above, NAM is a subsidiary of NFAL, which is an indirect subsidiary of Nuveen. Nuveen is a subsidiary, and represents the investment management division, of TIAA, a leading financial services provider. TIAA constitutes the ultimate principal owner of NAM. For additional information on the ownership structure, please see Form ADV Part 1, Schedules A and B. TIAA’s subsidiaries include various financial industry entities, including broker-dealers, other investment advisers, commodity pool operators and/or commodity trading advisors, banking or thrift institutions, insurance companies or agencies, pension consultants, sponsors or syndicators of limited partnerships, and sponsors, general partners, or managing members of pooled investment vehicles, among other entities. For further information on these subsidiaries, please see Exhibit A. TIAA is considered a control person of NAM and TIAA’s other financial industry entities may be considered affiliates of NAM under various other regulatory regimes, including as applicable the Investment Advisers Act of 1940, as amended (the “Advisers Act”), the 1940 Act and the Employee Retirement Income Security Act of 1974 (“ERISA”). NAM is committed to putting the interests of its clients first and seeks to act in a manner consistent with its fiduciary and contractual obligations to its clients and applicable law. At times, NAM may determine, in an exercise of its discretion, to limit or refrain from entering into certain transactions, for some or all clients, in order to seek to avoid a potential conflict of interest, or where the legal, regulatory, administrative or other costs associated with entering into the transaction are deemed by NAM to outweigh the expected benefits. Further, certain regulatory and legal restrictions or limitations and internal policies (including those relating to the aggregation of different account holdings by NAM and its affiliates) may restrict certain investment or voting activities of NAM on behalf of its clients. For example, NAM’s investment and proxy voting activities with respect to certain securities, issuers, regulated industries and non-U.S. markets may be restricted where applicable laws or regulations impose limits or burdens with respect to exceeding certain investment thresholds when aggregated with its affiliates. To the extent permitted by the Advisers Act, the 1940 Act, ERISA, and other law, as applicable, NAM may give advice, take action or refrain from acting in the performance of its duties for certain client accounts that may differ from such advice or action, or the timing or nature of such advice or action, for other client accounts including, for example, for clients subject to one or more regulatory frameworks. From a business perspective within Nuveen, NAM’s business is part of a functional group that seeks to promote alignment and collaboration among certain Nuveen affiliates managing equity and fixed income asset classes.

From an investment perspective within Nuveen, NAM’s municipal fixed income, taxable fixed income, and equities investment services are part of a broader Nuveen organizational framework that seeks to promote greater collaboration among and provide leadership to the respective investment teams. NAM’s municipal bond, taxable fixed income, and equity investment teams comprise investment and trading personnel who are “multi-hatted” as employees across NAM, and certain other affiliates. These teams coordinate and share investment and certain trading processes for client accounts in municipal bond, taxable fixed income, and equity strategies. These integrated teams are sometimes referred to as Nuveen Municipals, Nuveen Fixed Income, and Nuveen Equities, respectively. Multi-hatted personnel face conflicts in providing services to various clients of multiple affiliates, such as in the areas of trade sequencing and allocating opportunities. These conflicts are similar to the conflicts they face in providing services to various clients (including affiliated and proprietary accounts) of a single investment adviser. Through its policies, procedures and practices, NAM seeks to provide for the fair and equitable treatment of its clients. See Item 12. TIAA affiliates market, distribute, make referrals of, use and/or recommend investment products and services (including funds and pooled investment vehicles, and investment advisory services) of other affiliates (including NAM), and such affiliates may pay and receive fees and compensation in connection thereto. As a result of the potential additional economic benefit to NAM and/or its affiliates resulting from such activities, there is a potential conflict of interest for NAM, which NAM seeks to mitigate in a variety of ways, depending on the nature of the conflict, such as through oversight of these activities and/or by disclosure in this Brochure. To the extent permitted by applicable law, NAM may delegate some or all of its responsibilities to one or more affiliates, including affiliated investment advisers. NAM’s affiliates may likewise delegate some or all responsibilities to NAM. Affiliated broker-dealers and their personnel act as distributors with respect to and/or promote and provide marketing support to Affiliated Funds and broker-dealer personnel are internally compensated for those activities. Such distribution activities are subject to the brokerdealer’s own procedures. For certain strategies or accounts, NAM invests in or recommends Affiliated Funds. Depending on legal requirements, NAM may waive investment advisory fees on the client assets invested in such Fund, credit the client account for the fees paid by the Fund to NAM or NAM’s affiliates, avoid or limit the payment of duplicative fees to NAM and its affiliates through other means, or charge fees both at the Fund level and client account level. Certain separate account strategies that include an allocation to Affiliated Funds are available exclusively for NAM managed accounts; termination of such separate account strategies may require a liquidation of such Funds. NAM serves as sub-adviser to several affiliated U.S. registered open and closed-end Funds, including a family of Funds branded as “Nuveen Funds” for which NFAL serves as adviser. NAM also serves as sub-adviser to other Affiliated Funds, including a series of products offered through one or more bank collective investment trusts (CITs) under the Nuveen brand, and an investment company with variable capital incorporated with limited liability in Ireland and established as an umbrella fund with segregated liability between funds pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities (“UCITS”)) Regulations, 2011, under the Nuveen brand. NAM also provides investment services (e.g., as adviser, sub-adviser or portfolio consultant) to other Funds, including Funds with the “Nuveen” or “Nuveen Asset Management” brand. NAM serves as managing member, adviser or sub-adviser to one or more private funds or other pooled investment vehicles. NAM, as successor to Symphony Asset Management, LLC, serves as collateral manager to certain CLOs, including CLOs with the “Symphony” or “Nuveen” brand. Descriptions of the Tax Advantaged Strategies generally relate to services available through NAM’s investment adviser affiliate Brooklyn. Brooklyn is expected to merge with and into NAM in the second quarter of 2026, with NAM being the surviving entity and the entity that provides the advisory services for Tax Advantaged Strategies. For certain strategies, it is expected that, with respect to all or a material portion of an account, NAM will allocate to or recommend itself, Affiliated Funds, affiliated products and/or affiliated advisers, and as a result in such case, NAM and its affiliates will retain more fees than if NAM had

allocated to or recommended an unaffiliated Fund, product or adviser. Clients should be aware of this potential conflict when engaging NAM, and should consult their own independent professional advisor(s) to determine whether the arrangement is appropriate and in their continuing best interests. NAM also provides services to various accounts affiliated with TIAA, including TIAA’s General Account, and other accounts that include proprietary capital. See Item 10, 11 and 12. As described herein, NAM provides services to multiple proprietary or Affiliated Funds or accounts of various sizes and strategies. NAM’s general policy is that proprietary or Affiliated Funds or accounts should receive neither special advantages nor disadvantages. NAM addresses the conflict associated with providing services to both affiliated and unaffiliated Funds/accounts by seeking to act in a manner consistent with its policies and procedures and its fiduciary duty to all clients. In connection with their association with Nuveen Securities, certain NAM personnel engage in marketing or selling activities with respect to shares or interests in funds and other pooled investment vehicles advised or subadvised by NAM. NAM’s affiliates or shared services units, including Nuveen Services, LLC, provide it with supplemental account administration, trading, operations, client service, sales and marketing, product development and management, risk management, information technology, legal and compliance, human resources, and other corporate, finance or administrative services. NAM may likewise provide services for its affiliates. Certain personnel perform services for both NAM and one or more NAM affiliates. The scope of certain such services and arrangements varies depending on the particular strategy, distribution channel, program, and client size and type. NAM uses its affiliated broker-dealer, Nuveen Securities, as clearing agent to facilitate the purchase and sale of certain securities for client accounts in accordance with its policies and procedures. For additional information about NAM’s use of its affiliated broker-dealer, see Item 12. In providing investment advisory services to accounts in certain strategies, NAM uses portfolio management, research, trading and other resources of one or more non-US affiliates, including Nuveen Hong Kong Limited, Nuveen Singapore Private Limited, Nuveen Investment Management International Limited, Nuveen Japan Co. Ltd, and/or others, that are not registered with the SEC. Certain of such services are provided through a “participating affiliate” arrangement, as that term is used in relief granted by the SEC staff allowing U.S. registered investment advisers such as NAM to use portfolio management resources of advisory affiliates subject to the regulatory supervision of the registered investment adviser.

Code of Ethics NAM has adopted a Code of Ethics, as supplemented (the “Code of Ethics”) The Code of Ethics is designed to detect and prevent conflicts of interest relating to personal trading by its employees, and to ensure that NAM effects transactions for clients in a manner that is consistent with its fiduciary duty to its clients and in accordance with applicable law. NAM’s employees who wish to purchase or sell most types of securities in their personal accounts may do so only in compliance with certain procedures outlined in the Code of Ethics, such as preapproval of non-exempted securities by compliance personnel and periodic holdings and transaction reporting. Employees are required, with limited exceptions, to maintain brokerage accounts with select broker-dealers who provide automated, electronic reporting of transactions and account information to assist the Nuveen Ethics Office in monitoring employee transactions. The Code of Ethics also prohibits the misuse of material nonpublic information and confidential information. A copy of the Code of Ethics will be provided upon request of any client or prospective client. Please see the cover page to this Brochure for contact information.

Certain employees have been designated as NAM Investment Persons, as that term is defined in the Code of Ethics. An Investment Person is prohibited from transacting in securities during the period starting 7 calendar days before, and ending 7 calendar days after, any trade in an Affiliated Fund, or any portfolio or client account advised or sub-advised by Nuveen for which he/she has responsibility. NAM and its Related Persons may invest in securities for their personal accounts that are also recommended to NAM clients. Potential conflicts arise in this situation because NAM or its Related Persons may have a material interest in or relationship with the issuer of a security, or may use knowledge about pending or currently considered securities transactions for clients to profit personally. To address these potential conflicts, employees are required to review and certify securities trading activity quarterly and to provide securities holding reports upon commencement of employment and to review and certify securities holdings thereafter on an annual basis. In addition, employee transactions are subject to limitations regarding the type and timing of transactions, including certain trading prohibitions, and pre-approval and monitoring by compliance professionals and/or certain Related Persons. NAM, its employees and its affiliates may give advice and take action in the performance of their duties for some clients that may differ from advice given, or the timing or nature of actions taken, for other clients or for their proprietary or personal accounts. NAM employees and others related to NAM employees and its affiliates can be clients of NAM (collectively, “employee accounts”). NAM has a potential conflict of interest because it could seek to favor employee accounts over its other clients in the management of employee accounts. Additionally, NAM can provide special services and/or provide services at no or reduced fees for employee accounts. NAM manages employee accounts in a manner consistent with NAM’s fiduciary duty to its other clients. It is NAM’s policy that employee accounts should not receive special trading advantages or disadvantages, and employee accounts are subject to the firm’s trading policies. Subject to the restrictions described above, NAM and employee accounts may at any time hold, acquire, increase, decrease, dispose of or otherwise deal with positions in investments in which a client account may have an interest from time to time. NAM has no obligation to acquire for a client account a position in any investment which it, acting on behalf of another client, or an employee, may acquire, and the client accounts shall not have first refusal, co-investment or other rights in respect of any such investment. Subject to certain exceptions (e.g., multi-hatted personnel), NAM and its advisory affiliates maintain procedures (including certain information barriers) designed generally to provide for independent exercise of investment and voting power. To the extent the Nuveen Ethics Office determines that there is no material conflict of interest, certain employees of NAM from time to time may engage in outside business activities, including serving on boards of unaffiliated entities. Employees may be offered or receive business gifts, meals, and entertainment from parties with whom NAM conducts business. Receipt of business gifts, meals, and entertainment may inappropriately influence investment or trading decisions. Similarly, the giving of business gifts, meals, and entertainment could inappropriately influence a person or entity in an effort to gain an unfair advantage in acquiring or retaining clients. Employees are subject to certain limitations and reporting obligations regarding the receipt/giving of business gifts, meals, and other benefits in the form of entertainment from parties with whom NAM conducts business. For a discussion of conflicts related to gifts and entertainment, please refer to Item 14, Payments to Others – General. Similarly, employees may from time to time provide or solicit political contributions to certain candidates, officeholders, political organizations, or trade associations. Utilizing political contributions inappropriately to gain an unfair advantage in acquiring or retaining clients creates a conflict of interest. NAM has established procedures designed to comply with applicable federal law. In addition, applicable contributions require preclearance and employees are required to certify on a quarterly basis that they have reported all applicable political contributions.

Participation or Interest in Client Transactions Proprietary Accounts NAM, its employees and its affiliates (including TIAA) invest in Affiliated Funds or separate accounts managed by NAM or its affiliates from time to time. Generally, to the extent that NAM or NAM affiliates have funded a separately managed account or have made a significant investment in an Affiliated Fund (e.g., generally greater than 25% of the affiliated Fund’s assets), such separately managed account or Affiliated Fund will be considered a proprietary account for certain regulatory purposes. This creates a conflict if NAM were to favor such accounts such as in the allocation of investment opportunities. NAM seeks to manage such accounts in a manner consistent with NAM’s fiduciary duty to its other clients to address the potential conflicts of interest resulting from NAM or a NAM affiliate’s economic interest in a proprietary account. NAM’s general policy provides that proprietary accounts (separately managed accounts and Affiliated Funds) should receive neither special advantages nor disadvantages relative to other client accounts and NAM addresses this conflict by periodically reviewing allocations of investment opportunities across client accounts. Material Non-Public Information From time to time, NAM receives material non-public information (“MNPI”) and becomes subject to limitations on its investment activities relating to the possession of MNPI. Under applicable law, NAM and its employees are prohibited from improperly disclosing or using MNPI for its own benefit or the benefit of its clients. Possession of MNPI could limit NAM’s ability to transact in affected investments, which could be detrimental to client accounts. NAM, in its discretion, seeks to employ the use of certain approaches or procedures in an effort to minimize such limitations, but there is no assurance that NAM will employ such procedures or that such procedures will be effective in alleviating the limitations associated with possessing MNPI. Cross Trades A cross trade occurs when an adviser effects a trade between two or more of its advisory clients’ accounts and does not charge a fee for effecting the transaction. Subject to applicable law, NAM causes a client account to enter into a cross trade only in cases where it believes that the cross trade would be in the best interests of both selling and buying accounts. Given the fiduciary duty owed to both accounts when effecting such trade, the use of cross trades raises potential conflicts of interest. While raising a potential conflict, NAM believes that cross trading can be beneficial for advisory accounts managed by NAM where appropriate. Among accounts in municipal bond strategies, cross trading can also be especially beneficial for Retail SMAs. Although individual Retail SMAs are not generally large enough for a single institutional block of bonds within a diversified portfolio, when NAM exercises investment control over an institutional block of bonds that is allocated and held among multiple Retail SMAs, participating Retail SMAs can collectively benefit in large part from institutional pricing and execution. Employing cross trading for Retail SMAs where appropriate can further support this objective because it permits NAM to preserve the integrity of the institutional block while at the same time meeting the needs of both selling and buying accounts. Cross trades enable the participating accounts to engage in a transaction that seeks to more closely replicate an institutional block transaction and avoid the execution and pricing disadvantages associated with odd lot trading. Given these potential benefits, NAM exercises discretion to engage in cross transactions to the extent that (i) a Retail SMA owns a portion of an institutional size block of bonds over which NAM exercises investment control and has a need to sell all or a portion of such bonds; (ii) there is also an account with a need to buy such bonds; and (iii) NAM determines that the cross trade would be in the best interests of both accounts. Cross trades for municipal bonds in Retail SMAs generally use Nuveen’s Affiliated Broker-Dealer in an administrative capacity to clear the transaction. See Use of Affiliated Broker-Dealer in Item 12. The price of a cross trade is set according to one of the following methodologies, the goal of which is to seek a fair price for both sides of the cross trade. For Retail SMAs, under normal market conditions, especially when NAM exercises investment control over an institutional block of bonds, municipal bonds are generally crossed at an independent evaluation price of a third party pricing service (e.g., ICE) minus a price adjustment (typically equivalent to 3-8 basis points in yield, subject to adjustment based on market conditions) that is designed to replicate a typical dealer bid/ask

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Broker-Dealer Selection In most arrangements, NAM has the authority to make all determinations as to which securities are to be bought or sold, the amounts of the securities to be bought or sold, the broker-dealer to be used and commissions, dealer spreads and other fees to be paid. In executing trades on behalf of clients, NAM seeks best execution under the circumstances of each trade. NAM considers a variety of factors when adding a broker to its list of approved broker-dealers including, but not limited to, the broker’s trading capabilities, ability to provide market intelligence, knowledge and understanding of NAM’s trading activities, syndicate capabilities, participation in commission sharing arrangements for equities trading through which NAM is able to pay for research products and services, and their clearance and settlement capabilities. In addition, NAM considers electronic trading venues and algorithmic trading systems when it believes they can offer efficient execution and benefit to clients. When selecting broker-dealers to execute transactions in equity securities, NAM takes into consideration best price and additional factors including, but not limited to, the value, nature and quality of the broker-dealer’s services, the broker’s participation in commission sharing arrangements through which NAM is able to pay for research products and services, execution capability, commission rate, financial responsibility (including willingness to commit capital), the likelihood of price improvement, the speed of execution and likelihood of execution for limit orders, the ability to minimize market impact, the maintenance of the confidentiality of orders, and responsiveness of the broker-dealer. For equity transactions, the determinative factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution under the circumstances. Subject to the satisfaction of its obligation to seek best

execution, NAM may also consider the broker-dealer’s access to new issues or initial public offerings (“IPOs”). NAM and certain affiliates generally utilize a shared centralized equity trading desk for trading equities for Funds and Institutional Separate Accounts, and a separate shared centralized trading desk for trading equities for Retail SMAs. For fixed income transactions, NAM takes into consideration best price and execution quality under the circumstances in order to seek best execution. NAM and certain affiliates utilize one or more shared centralized trading desks for trading certain fixed income strategies for Funds and Institutional Separate Accounts, depending on the specific strategy, dollar amount, operational connectivity, and other factors. Other trades for Funds and Institutional Separate Accounts are generally executed independently by NAM investment and trading personnel for a particular strategy. Additionally, NAM generally uses separate trading personnel and desks for Retail SMA trades. When NAM personnel or desks trade accounts independently, they could be buying or selling a given security at the same time that another, similar account or strategy, is also buying or selling the same security. Best execution is not evaluated on a transaction-by-transaction basis, but on an overall basis over an extended period of time For certain accounts in Leveraged Finance strategies, NAM has retained certain broker/dealers to act as prime broker and execute trades for such accounts subject to best execution, and provide other services. NAM exercises oversight and policy making responsibility for NAM’s equity and fixed brokerage practices through one or more committees that meet periodically. For municipal bond strategies, NAM periodically ranks broker-dealers on the basis of best execution criteria and other factors, including incidental proprietary research services. In purchasing new issues of municipal securities for client accounts, NAM may designate a portion of the selling concession to certain broker-dealers on the basis of such ranking. The ability to select among multiple dealers is generally extremely limited in cases where there is a limited supply of municipal bonds with specified desired characteristics (e.g., a certain credit quality, maturity, duration and/or particular state of issue). For taxable fixed income strategies, NAM seeks best execution based on its consideration of a broker-dealer’s services, including the ability to obtain a competitive bid or offer price. NAM generally does not employ the practice of ranking broker-dealers for purposes of selecting a particular broker-dealer for trade execution for taxable fixed income securities. NAM executes securities and investment transactions through financial firms that use, offer or include products or services of NAM or its affiliates in a particular program or preferred list. NAM does not take into account such business arrangements when selecting firms for securities and investment transactions. Taxable fixed income trades concerning securities and loans are typically executed on a net yield basis in which the security price includes certain undisclosed compensation to the dealer. Transactions placed through dealers serving as primary market-makers generally reflect the spread between the bid and asked prices, or in some cases, reflect a pre-negotiated spread or concession for riskless principal trades. Securities also may be purchased from underwriters at prices that include underwriting fees. NAM expects that substantially all portfolio transactions for fixed income securities will be effected on a principal (as opposed to an agency) basis and accordingly, does not expect to pay significant amounts of brokerage commissions. Depending on the terms of the client arrangement, NAM also has the authority to negotiate and enter into investment arrangements with respect to derivatives, including swaps, futures, options and other types of exchange-traded or over-the-counter (OTC) arrangements on behalf of its client accounts. NAM enters into derivatives transactions for a variety of purposes relating to a client’s objectives, including to seek an investment opportunity, to hedge a risk (e.g., interest rate risk) or for other investment purposes. Counterparties to these derivatives transactions are selected based on a number of factors, including a pre-existing relationship with NAM or the client, credit rating,

execution prices, execution capability with respect to complex derivative structures, reputation, responsiveness and/or other criteria relevant to a particular transaction. Certain Retail SMA programs impose policies and restrictions that limit the trading and investment options in Retail SMAs that would otherwise be available for Institutional Separate Accounts and Funds. As a result, Retail SMAs may be excluded from potentially attractive trading and investment opportunities. Clients should consult with their financial advisors regarding the terms and features of their Retail SMA program. Use of Affiliated Broker-Dealer NAM uses Nuveen Securities to clear certain securities (e.g., municipal bond) transactions for separate account clients (including Retail SMAs and Institutional Separate Accounts) where NAM believes that such use does not create a conflict of interest. In such transactions, there will be no change in the security price Nuveen Securities pays or receives and the price NAM’s clients pay or receive for the same securities when Nuveen Securities provides the clearing services. Nuveen Securities will not receive any spread, mark-up, mark-down or transaction fee from the client in connection with such service. NAM may reimburse the actual or estimated expenses of Nuveen Securities for providing such services out of its own resources. NAM believes that there are significant advantages for its clients in using Nuveen Securities as a clearing agent for securities transactions (including cross trades for municipal bonds in Retail SMAs), which may include minimizing the chance of error otherwise associated with a large number of individual purchases and delivery instructions, a greater ability to purchase and allocate institutionalized blocks of municipal bonds or other securities to NAM separate accounts, and the potential for price improvements on securities transactions for the benefit of clients. When selling securities for NAM accounts, NAM is similarly able to aggregate all or a portion of the block at Nuveen Securities prior to selling them to a dealer. This practice also has the potential to minimize the opportunity for third party errors, increase overall speed and efficiency, and result in price improvements. See also Cross Trades in Item 11. Execution Practices for Legacy Securities NAM reserves the right to establish policies that limit acceptance of a client’s previously acquired securities (“legacy” positions or securities) for account funding or contribution purposes. Where accepted, NAM generally evaluates legacy positions and generally sells all or a portion of such securities to the extent that such securities would not be included in NAM’s normal portfolio holdings for such account or otherwise conflict with applicable guidelines (unless such securities are subject to another express arrangement). Depending on the size and characteristics of the legacy position and the then-prevailing markets and other factors, the client may receive a sale price that is less favorable than if the transaction involved a more marketable or liquid position. The client will be responsible for all tax liabilities that result from any sale transactions. As discussed above in Items 4 and 10, for certain programs, NAM utilizes the shared services of Nuveen to perform certain functions, including trading for certain Retail SMAs based on NAM’s directions. For Retail SMAs, NAM generally determines the timing and manner of disposition of legacy securities used to fund new Retail SMAs, or contributed to existing Retail SMAs, that are incompatible with NAM’s long-term investment view or otherwise conflict with applicable guidelines. NAM may sell all or a portion of such securities promptly, or may sell certain legacy securities promptly (e.g., those that are below certain quality thresholds or maturity requirements) and sell other legacy securities more gradually and/or opportunistically over the invest-up or other period. As a result of time constraints and lot sizes that may be applicable to sales of legacy securities, and the general unavailability of the full range of trading techniques including aggregation, the prices received in legacy securities transactions may be more or less favorable than the prices that could be attained for sales of securities selected by NAM as part of ongoing management. Generally, a sale of an odd-lot of legacy securities and/or lower quality securities (especially, in the case of municipal bonds) will receive a less favorable price than a sale of a larger round lot and/or higher quality securities. Clients may always sell legacy securities on their own with the assistance of their financial advisor and without reliance on NAM, and use cash to fund a new account or make a contribution to the account. Because these execution practices for legacy securities are generally not part of Nuveen’s normal management of client accounts, Nuveen’s execution practices, and its

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In the ordinary course of business, NAM or a Related Person provides business gifts, meals and entertainment such as tickets to cultural and sporting events to personnel of firms that do business with NAM or its affiliates. Such gifts, meals and entertainment provided by NAM or a related person generate a conflict of interest to the extent that they create an incentive for the recipient or beneficiary to use, recommend, offer or include products or services of NAM in a particular program, include NAM in a preferred list of advisers, or refer clients to NAM. In the ordinary course of business NAM employees also are the recipients of business gifts, meals and entertainment. NAM’s receipt of gifts, meals and entertainment generates a conflict of interest to the extent that they create an incentive for the recipient or beneficiary to use the services of the provider (e.g., in the case of a broker-dealer, brokerage services) of the gifts, meals and entertainment. The giving and receipt of gifts and other benefits are subject to reporting and limitations under internal policies and procedures. NAM pays fees to consultants for their advice and services, industry information or data, or conference attendance. NAM also pays for certain marketing activities. If a particular payment constitutes, in NAM’s judgment, an arrangement subject to requirements under the Advisers Act, NAM will seek to comply with such requirements. The payment of fees to consultants and marketing entities generates a conflict of interest to the extent that such payment creates an incentive for the recipient or beneficiary to use, recommend, offer or include products or services of NAM in a particular program, include NAM in a preferred list of advisers, or refer clients to NAM. NAM and/or its affiliates provide free general educational services to financial intermediaries who typically offer or use products or services of NAM and/or its advisory affiliates. NAM and/or its affiliates may make available various financial and educational tools, reports, materials and presentations on current industry topics relevant to a financial advisor. Certain financial tools and illustrations may use data provided by a financial advisor. Materials and services provided by NAM and/or its affiliates are not intended to constitute financial planning, tax, legal, or investment advice

and are for educational purposes only. The provision of such services and materials generates a conflict of interest to the extent that such provision creates an incentive for the recipient or beneficiary to use, recommend, offer or include products or services of NAM in a particular program, include NAM in a preferred list of advisers, or refer clients to NAM. In appropriate instances, NAM and its Related Persons refer business to each other with respect to each other’s products and services. Prospects and clients to whom such referrals have been made should be aware of the conflict inherent in such referral as a result of the common control of such parties. See Item 10. From time to time and accordance with applicable law, NAM enters into arrangements to compensate third parties for introducing prospective clients to NAM or its Affiliates. Such third parties engage in referral and other promotional activity for advisory services and investment vehicles of NAM and its Affiliates. Compensation for such promotional activity is generally paid either as a flat fee calculated and paid on a periodic basis or a fee based on a percentage of the fees NAM or its Affiliates receives from clients. Such arrangements create conflicts of interest because the party engaging in promotional activity has a financial incentive to refer clients to NAM and its Affiliates. In addition, certain promotional arrangements may incentivize a client to maintain a certain level of assets managed by NAM if doing so would result in eligibility to receive additional compensation or benefits. Lastly, certain promoter arrangements may be with index providers for Tax Advantages strategies where the compensation arrangements may create financial incentives for NAM or its Affiliate to use the certain direct indexing strategies in client accounts. In the ordinary course of business, NAM (or an affiliate) makes payments to firms or persons that use, recommend, offer or include products or services of NAM (and its affiliates) in a particular program, include NAM (and its affiliates) in a preferred list of advisers, or refer clients to NAM (or its affiliates). The types of payments include, without limitation, conference, program or event attendance, participation or exhibition sponsorship fees; educational and training fees; license, data access, operational or administrative fees; or fees linked to program participation or specific marketing initiatives within an existing program or new program. The amounts of such payments, which are generally made on an enterprise-wide basis, can be significant for certain SMA Program Sponsor or financial intermediary firm recipients (e.g., up to or in excess of $1 million annually). NAM (or an affiliate on NAM’s behalf) sometimes pays travel, meal and entertainment expenses for a firm’s representatives and others who visit NAM’s offices or other locations (including hotels and conference centers) to learn about its products and services. The foregoing payments generate a conflict to the extent that they create an incentive for the recipient or beneficiary of the payment to use, recommend, offer or include products or services of NAM in a particular program, include NAM in a preferred list of advisers, or refer clients to NAM. NAM also makes charitable contributions or underwrites or sponsors charitable events at the request of others. Payments described above vary significantly from firm to firm depending on the nature of NAM’s and its affiliated investment advisers’ separate account activities with the firm and the amount of the firm’s separate account client assets under NAM’s and its affiliated investment advisers’ management. Such contributions generate a conflict to the extent that they create an incentive for the recipient or beneficiary of the payment to use, recommend, offer or include products or services of NAM in a particular program, include NAM in a preferred list of advisers, or refer clients to NAM. Payments are subject to NAM or a Related Person’s internal review and approval procedures. Retail SMA clients are encouraged to request and review materials from Program Sponsors (such as a Program Sponsor’s brochure) describing business and financial terms and arrangements between Program Sponsors and investment advisers. All clients are encouraged to make relevant inquiries of their financial advisory firms and financial advisors, consultants and other intermediaries regarding the arrangements and practices described above. In addition to the foregoing, with respect to Funds, NAM or an affiliate makes payments to firms or individuals that use, offer or sell shares of the Funds advised by NAM, or place the Funds on a recommended or preferred list. Such Fund-related payments generate a conflict to the extent that they create an incentive for the recipient or beneficiary of the payment to use, offer or sell shares of the Funds advised by NAM, or place the Funds on a recommended or preferred list. Fund

investors should review a Fund’s prospectus and statement of additional information for important information about such Fund-related payments.

There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of or the integrity of NAM or its management persons.

General Description NAM provides continuous monitoring and oversight of the discretionary accounts it manages, and accounts are reviewed on an exception basis. Accounts are reviewed by the relevant portfolio manager (or overlay portfolio manager in the case of Retail SMA MSAs) and/or other NAM or Nuveen employees to seek to ensure that each account is managed consistent with the strategy and investment criteria applicable to the account in terms of: (i) allocation of portfolio assets; (ii) diversification of portfolio assets; (iii) duration and maturity, for fixed income accounts; and (iv) compliance with any specific restrictions applicable to the account. The composition and number of reviewers vary depending in part on the type of account, amount of assets and nature of investment goals and objectives of client. For Funds, reviews also may include analysis of security performance, account diversification and cash flow. In addition to the regular reviews, NAM may also consider the following additional factors, depending on the strategy and account: (i) performance of individual securities or asset classes; (ii) material economic and market events; (iii) changes in a separate account client’s financial profile as communicated to NAM; and (iv) changes recommended in overall investment policy or strategy by NAM’s portfolio managers. The number of accounts for which a reviewer is responsible will vary. Client Reports Separate Accounts (Retail SMA and Institutional) NAM provides portfolio reports to the extent agreed with the client, upon reasonable request, or specified under the Retail SMA program agreement. Portfolio reports generally include portfolio holdings and may include performance information. Such reports are not intended to replace a client’s custodial account statements as records for official or tax reporting purposes. Retail SMA Clients generally receive reports from the Program Sponsor or the custodian, and not from NAM.

Clients are encouraged to request and review monthly or quarterly account statements (including holdings, asset amounts and transactions during the period) sent directly to a client from their custodian (e.g., broker-dealer, bank or trust company). NAM’s portfolio reports reflect valuations of account assets determined in accordance with NAM’s valuation procedures, which generally rely on third party pricing services. In the event that the third party pricing vendor’s price is unavailable or other observable inputs are unavailable or deemed unreliable, NAM will make a reasonable determination of a security’s fair value. NAM’s valuations may differ from valuations reflected in a client’s custodial statements. Further, certain securities or investments may be valued differently based on factors such as the type of account, operational systems, and/or client instructions. NAM also may distribute economic commentaries and other materials periodically. Special reports may be prepared to meet specific client requirements. NAM may provide reports to Program Sponsors, financial intermediaries and certain institutional clients that are not regularly sent to clients regarding performance, portfolio holdings and other portfolio information. Where NAM serves as a sub-adviser to an affiliated adviser, the affiliated adviser would provide any such reports. See Item 4 regarding other reports and materials. Funds NAM provides Fund clients (manager or board) with periodic reports that may include, among other information, holdings and transaction information, performance and attribution analysis, brokerage allocation, soft dollar information, accounting data, portfolio reviews, reviews of diversification, and distribution information, as well as additional information or reports as requested by the Fund manager or board. Fund investors receive shareholder or investor reports in accordance with the terms, conditions and regulatory requirements applicable to the particular Fund. See also Item 15.

Clients should receive quarterly or monthly account statements from the broker-dealer, bank or other financial services firm that serves as qualified custodian to their account(s), and clients should carefully review those statements. Clients who do not receive such account statements are encouraged to follow up directly with their qualified custodian and request such statements. Clients who receive additional reports from NAM are urged to compare these reports to the account statements they receive from the qualified custodian. NAM’s reports are generally preliminary and may vary from custodial statements based on accounting procedures, reporting dates, valuation methodologies and other factors. They are not intended to be a substitute for account statements provided by a qualified custodian, and should not be used for official purposes. In the event of an inadvertent receipt of a check or other financial instrument payable to a client, NAM reserves the right to send the check or instrument to the client or its custodian rather than back to the original sender when it believes that such procedure provides the best overall protection for the underlying assets. Clients who seek to direct transfers or payments from their separate account to third parties (e.g., to pay bills or transfer funds) should directly contact and instruct the account’s qualified custodian and/or primary financial advisor. It is generally outside the scope of NAM’s authority and services to process or intermediate such instructions. Clients typically select qualified custodians and negotiate and enter into custody agreements with custodians without NAM’s involvement. NAM does not seek to hold client assets or have broad authority to withdraw client assets upon instruction to qualified custodians, and NAM disclaims authority attributed to NAM in custody agreements between clients and qualified custodians to withdraw client assets upon instruction to the custodian. NAM’s authority as it relates to custody is generally limited in the ordinary course to customary trading and settlement of securities and investment transactions in the client’s account (typically on a “delivery vs payment” basis for registered securities transactions) and other authorized trading as well as deductions for NAM’s advisory fee deductions in certain cases, as applicable. NAM maintains policies and procedures with respect to arrangements whereby NAM is deemed to have technical custody, such as resulting from certain authorizations to withdraw client assets or capacity with respect to a pooled investment vehicle. Clients, and not NAM, are responsible for the selection of the Designated Cash Sweep Vehicle into which cash and free credit balances in a client account are moved pending investment by NAM. Notwithstanding any requirements of the qualified custodian, any financial advisor or other financial intermediary for NAM to confirm, acknowledge or otherwise select the Designated Cash Sweep Vehicle, NAM does not exercise any investment discretion with respect to the selection of the Designated Cash Sweep Vehicle. In confirming, acknowledging or selecting the Designated Cash Sweep Vehicle in accordance with any such requirements of the qualified custodian, financial advisor or other financial intermediary, NAM is doing so at the direction of and on behalf of the client and unless NAM is otherwise specifically instructed by the client to select a specific Designated Cash Sweep Vehicle, the default Designated Cash Sweep Vehicle shall be selected for the client account. NAM is not responsible if the Designated Cash Sweep Vehicle is not competitive in terms of yield, fees, protection of principal balance or other features as compared to any other Designated Cash Sweep Vehicle options. Clients should review and discuss the Designated Cash Sweep Vehicle options, including the default option, with their financial advisor, consultant or the qualified custodian.

NAM is generally granted discretionary authority to manage securities accounts on behalf of clients. For Institutional Separate Accounts and Retail SMAs through dual contract programs, NAM generally obtains a client’s written consent to its discretionary authority with respect to the client’s assets in the form of an executed investment management agreement or other comparable services agreement prior to providing discretionary advisory services. For Retail SMAs through Wrap Fee Programs, NAM is appointed to act as an investment adviser through a process generally documented and administered by the Program Sponsor. Clients participating in a program, generally with assistance from the Program Sponsor, may select NAM to provide investment advisory services for their account (or a portion thereof) in a particular strategy. NAM provides investment advisory services based upon the particular needs of the client as reflected in information provided to NAM by the Program Sponsor, and will generally make itself available for direct consultations as reasonably requested by clients and/or Program Sponsors. Clients are encouraged to consult their own financial advisors and legal and tax professionals on an initial and continuous basis in connection with selecting and engaging the services of an investment manager in a particular strategy and participating in a wrap or other program. In the course of providing services to program clients who have financial advisors, NAM generally relies on information or directions communicated by the financial advisor acting with apparent authority on behalf of its client. NAM’s discretionary authority over an account is generally subject to directions, guidelines and limitations imposed by the client and, in the case of a Wrap Fee Program client, the Program Sponsor. NAM will endeavor to follow reasonable directions, investment guidelines and limitations. Although NAM seeks to provide individualized investment advice to its discretionary client accounts, NAM will not be able to accommodate investment restrictions that are unduly burdensome or materially incompatible with NAM’s investment approach (including restrictions affecting more than a stated percentage of the account), and reserves the right to decline to accept, or terminate, client accounts with such restrictions. See Item 4. In addition to the foregoing, NAM provides its services on a non-discretionary and model portfolio basis. From time to time, with NAM’s consent, clients may include certain securities in accounts for which NAM provides no investment advisory services (“unsupervised securities”). Unsupervised securities are not subject to NAM’s services. From time to time, NAM also provides certain services on a consulting basis. For additional information about NAM’s investment advisory services and investment restrictions, see Item 4.

Except as otherwise directed by a client, NAM is generally authorized to vote proxies for its clients, which may include Funds, as part of its duties as a discretionary investment adviser. NAM does not vote proxies where a client withholds proxy voting authority, or in certain non-discretionary and model portfolio programs, and certain other circumstances summarized below. NAM votes proxies in accordance with its policies and procedures in effect from time to time. Nuveen’s Proxy Voting Committee (“PVC”) provides an administrative framework to facilitate and monitor NAM’s exercise of proxy voting, and to fulfill obligations of reporting and recordkeeping under the federal securities laws. NAM has adopted proxy voting policies which are reasonably designed to ensure NAM votes proxies in the best interests of its clients. NAM leverages the expertise and services of an internal group within Nuveen ("Nuveen Stewardship Group") to provide proxy voting recommendations and administer NAM’s proxy voting

activities. Depending on the issue, the Nuveen Stewardship Group considers the research and recommendations of one or more proxy advisors to help formulate its substantive positions on recurring proxy issues and criteria for addressing non-recurring issues. NAM maintains the fiduciary responsibility for all of its proxy voting decisions. From time to time, a NAM portfolio manager may initiate action to override the Nuveen Stewardship Group’s recommendation for a particular vote. Any such override will be reviewed for material conflicts. NAM’s policy permits it to refrain from voting in certain circumstances, including where it determines that it would be in the client’s overall best interest not to vote (e.g., where proxy voting would result in a financial, legal, regulatory, or operational encumbrance or burden that outweighs the potential benefit to the client of voting); with respect to securities on loan through a securities lending program; and with respect to legacy securities and securities in accounts where NAM’s advisory services have been terminated. In special circumstances, NAM may vote a proxy based on the instructions of the client or its representative. NAM’s ability to vote proxies is subject to timely receipt of the proxy from the client’s proxy advisory firm, custodian or other party, and, in the case of proxies relating to certain nonU.S. securities, subject to the establishment by applicable parties of any necessary local documentation (e.g., power of attorney). Equity Securities - With respect to equity securities, NAM will vote equity securities in accordance with its policies and procedures discussed above. Fixed Income Securities - A client may indirectly acquire equity securities that issue proxies. For example, a client may acquire, directly or through a special purpose vehicle, equity securities of a bond obligor whose bonds are already held in a client’s account when such bonds have deteriorated or are expected shortly to deteriorate significantly in credit quality. The purpose of acquiring equity securities generally will be to seek to prevent the credit deterioration or facilitate the liquidation or other workout of the distressed issuer’s credit problem. In the course of exercising control of a distressed issuer, NAM may pursue the client’s interests in a variety of ways, which may entail negotiating and executing consents, agreements and other arrangements and/or otherwise influencing the management of the issuer. NAM does not consider such activities proxy voting for purposes of Rule 206(4)-6 under the Advisers Act. In the rare event that a fixed income issuer were to issue a proxy, NAM would generally vote in accordance with its policies and procedures. NAM recognizes that there are circumstances where it has a perceived or real material conflict of interest in voting the proxies of issuers. NAM seeks to vote proxies in the best interest of its clients regardless of such real or perceived material conflicts of interest and attempts to minimize this risk by establishing reasonable procedures to identify and monitor such conflicts of interest. If it is concluded that a material conflict exists, the Nuveen Stewardship Group will normally vote the proxy in accordance with a proxy advisory firm’s benchmark recommendation. To the extent the Nuveen Stewardship Group believes there is a justification to vote contrary to the proxy advisory firm’s benchmark recommendation, such requests are escalated to the PVC for evaluation and mitigation. NAM’s clients may contact their relationship manager for a copy of NAM’s proxy voting policies and procedures or more information about the proxy voting record for their account. Legal Proceedings NAM is under no obligation to advise or act for clients in legal proceedings including bankruptcies and class actions involving securities purchased or held in client accounts. NAM generally notifies or transmits copies of legal materials it receives to the client, Program Sponsor, client custodian or other client representative. NAM encourages clients to consult their custodian for additional information pertaining to class action notifications. Clients that have Retail SMAs managed by NAM through a Retail SMA program will have claims

attributable to their accounts processed in accordance with the policies and practices of the Retail SMA program or referring Program Sponsor elected by the client. In addition, claims on behalf of the Funds will be processed in accordance with the policies of the relevant Fund. In special situations primarily relating to distressed or defaulted bonds held by certain institutional or Fund accounts, NAM may engage in reorganization and workout arrangements and other legal matters in order to maximize the value of the particular portfolio holding.

NAM does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance and, thus, has not included a balance sheet of its most recent fiscal year. NAM is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has NAM been the subject of a bankruptcy petition at any time during the past ten years.

ADDITIONAL INFORMATION

Notice to Canadian Clients NAM is exempt from registration as an adviser in Alberta, British Columbia, and Ontario, as it meets all of the conditions of an “exempt international adviser.” NAM is required to take certain steps to rely on that exemption, one of which is to provide its clients with notice of certain matters. Notice is hereby given that: 1. NAM is not registered as a “portfolio manager” in any province or territory of Canada. 2. NAM has its head office at 333 West Wacker Drive, Chicago IL, 60606, U.S.A. 3. The local address for service of process against NAM in Alberta is: Torys LLP 525 – 8th Avenue S.W., 46th Floor Eighth Avenue Place East Calgary, Alberta, Canada, T2P 1G1 The local address for service of process against NAM in British Columbia is: Lawdell Corporate Services Limited Suite 1600 Cathedral Place, 925 West Georgia Street Vancouver, British Columbia, Canada, V6C 3L2 *For British Columbia, Lawson Lundell LLP provides agency services through Lawdell Corporate Services Limited

The local address for service of process against NAM in Ontario is: Torys LLP 79 Wellington St. West Toronto, Ontario, Canada, M5K IN2 4. There may be difficulty enforcing legal rights against NAM because it is resident outside Canada and all or substantially all of its assets may be situated outside of Canada. Any nonpublic personal information NAM receives from Canadian clients will be stored in the U.S. and, as a consequence, may become subject to disclosure in accordance with U.S. laws.

EXHIBIT A Primary Financial Industry Subsidiaries under Nuveen, LLC, the investment management division of TIAA Entity Name Primary Financial Industry or Related Affiliation* U.S. Registered Investment Advisers & Broker Dealers Brooklyn Investment Group, LLC Registered Investment Adviser Churchill Asset Management LLC Registered Investment Adviser Churchill DLC Advisor LLC Registered Investment Adviser Churchill NCPE Advisor LLC Registered Investment Adviser Churchill PCIF Advisor LLC Registered Investment Adviser Registered Investment Adviser CFTC Registered Commodity Pool Operator Gresham Investment Management LLC CFTC Registered Commodity Trading Adviser Nuveen Alternatives Advisors, LLC Registered Investment Adviser Registered Investment Adviser Nuveen Asset Management, LLC CFTC Registered Commodity Trading Adviser Nuveen Fund Advisors, LLC Registered Investment Adviser Snowhawk LP Registered Investment Adviser Teachers Advisors, LLC Registered Investment Adviser TIAA-CREF Investment Management, LLC Registered Investment Adviser Winslow Capital Management, LLC Registered Investment Adviser Nuveen Securities, LLC Registered Broker Dealer Non-U.S. Investment Affiliates Arcmont Asset Management Limited UK FCA Registered Entity Clean Energy Partners LLP UK FCA Registered Entity Glennmont Asset Management Limited UK FCA Registered Entity Glennmont Partners I Limited UK FCA Registered Entity Nuveen Alternatives Europe SARL Luxembourg CSSF Registered Entity Nuveen Asset Management Europe SARL Luxembourg CSSF Registered Entity Nuveen Australia Limited Australian ASIC Registered Entity Nuveen Canada Company Canadian Exempt Market Dealer Nuveen Hong Kong Limited HK SC Registered Entity Nuveen Investment Management International Limited UK FCA Registered Entity Nuveen Japan Co. Ltd Japan FSA Registered Entity Nuveen Management AIFM Limited UK FCA Registered Entity Nuveen Middle East Limited ADGM FSRA Registered Entity Nuveen Singapore Private Ltd Singapore MAS Registered Entity Other Nuveen Affiliates Greenworks Lending LLC Relying Adviser GreenWood Resources Capital Management LLC Forestry Management Nuveen Natural Capital, LLC Forestry, Farmland, Real Estate Management Nuveen Services, LLC Shared Services Entity Symphony Alternative Asset Management LLC Relying Adviser Westchester Group Investment Management, LLC Farmland Management Westchester Group Real Estate, LLC Real Estate Broker or Dealer Other Primary Financial Industry Subsidiaries of TIAA TIAA-CREF Individual & Institutional Services, LLC Registered Investment Adviser (aka Advice and Planning Services) Registered Broker Dealer TIAA-CREF Tuition Financing, Inc. Registered Investment Adviser Registered Municipal Advisor TIAA Kaspick, LLC Registered Investment Adviser TIAA Wealth Investment Management LLC Registered Investment Adviser Teachers Insurance and Annuity Association of America Insurance Company or Agency Seven30 Re (Bermuda) Co. Limited Insurance Company or Agency Seven30 Insurance (Bermuda) Co. Limited Insurance Company or Agency TIAA-CREF Insurance Agency, LLC Insurance Company or Agency TIAA Trust, N.A. Banking or Thrift Institution

*The list above refers to TIAA subsidiaries in financial industry affiliation categories referenced in Form ADV, Part 2A, Item 10.C, excluding numerous entities organized primarily to serve as sponsor, general partner, managing member (or equivalent) or syndicator of one or more pooled investment vehicles or limited partnerships (or equivalent). For a list of such entities that have material arrangements with the registrant, please see the registrant’s Form ADV, Part 1, Section 7.A. of Schedule D. The list above refers to the primary financial industry affiliation category and certain TIAA subsidiaries listed above may have additional financial industry affiliations, as further described in its respective disclosure documents (Form ADV, in the case of a registered investment adviser).

PRIVACY STATEMENT Nuveen Asset Management, LLC, a subsidiary of Nuveen, considers your privacy to be a fundamental aspect of our relationship with you. In order to provide you with individualized service, we and certain of our service providers collect certain nonpublic personal information from or about you, including when you provide information to us on applications or other forms (such as your address or social security number), and when we process information about your account transactions with us (such as purchases, sales and account balances). We may also collect such nonpublic personal information through your account inquiries by mail, email, telephone or our website or when you otherwise communicate with us. This privacy notice should not be construed as establishing a contractual relationship. We do not disclose any nonpublic personal information about you to unaffiliated third parties, except as permitted or required by law or for our everyday business purposes, such as to process transactions or service a client account. For example, in connection with offering you Nuveen products and services that meet your investing needs, and to effect transactions that you request or authorize, we may disclose the nonpublic personal information we collect, as described above, to companies that perform administrative or marketing services on our behalf, such as transfer agents, custodians, printers and mailers that assist us in the distribution of investor materials. These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purposes. We also reserve the right to disclose or report nonpublic personal or account information to nonaffiliated third parties in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, or to protect our rights or property. We may also disclose nonpublic personal information about you or your accounts to non-affiliated third parties at their request or where you consent in writing to such disclosure. We may also share information about you with our affiliates in connection with servicing your account, and subject to applicable law may provide you with information about products and services that we or our affiliates believe may be of interest to you. The information that we may share may include, for example, information about our experiences and transactions with you, your participation in funds or investment products or programs we offer, your ownership of certain types of accounts, information or other data about your accounts, subject to applicable law. Our affiliates, in turn, are not permitted to share your information with non-affiliated entities, except as required or permitted by law. If you decide at some point either to close your account(s) or to become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice. With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that are designed to protect your nonpublic personal information. A copy of our privacy notice is also posted at https://www.nuveen.com/privacy. If you have any questions about our policy or would like additional copies of this notice, please call us toll free at (800) 257-8787 or send us an email through our website www.nuveen.com or write to us at Nuveen at 333 West Wacker Drive, Chicago, IL 60606. For California residents, please visit the following link for more information: https://www.nuveen.com/privacy-ccpa For EEA and UK residents, please visit the following link for more information: https://www.nuveen.com/en-us/resources/nuveen-european-union-united-kingdom-privacy-notice For information on our use of personal data in accordance with the Data Protection Law of the Cayman Islands, please visit the following link for more information: https://www.nuveen.com/en-us/resources/cayman-islands-privacy-notice For individuals located in Brazil, please visit the following link for more information: https://www.nuveen.com/en-us/resources/Brazil-privacy-notice