PICTET ASSET MANAGEMENT SA

Firm Descriptions and Ownership

Pictet Asset Management (“Pictet AM”) is the institutional asset management business line of the Pictet Group and includes the SEC Pictet AM Firms. The SEC Pictet AM Firms provide discretionary and non-discretionary investment advisory services to institutional clients. Each of the SEC Pictet AM Firms are wholly owned by Pictet Asset Management Holding SA which is in turn wholly owned by Pictet & Partners. No individual owns 25% or more of Pictet & Partners. Pictet AM SA is a Switzerland based investment adviser regulated by the Swiss Financial Market Supervisory Authority (FINMA) and has been providing discretionary or advisory investment management services on a global scale to a wide range of international institutional clients since 2006. Pictet AM Ltd is a United Kingdom based investment adviser regulated by the Financial Conduct Authority (“FCA”) and has been providing discretionary or advisory investment management services on a global scale to a wide range of international institutional clients since 1980. Pictet AM Singapore is a Singapore based investment adviser regulated by the Monetary Authority of Singapore (“MAS”) and has been providing discretionary or advisory investment management services to a wide range of international institutional clients since 2005. Pictet AM USA is a U.S. based investment adviser, registered with the SEC and has been providing discretionary or advisory investment management services to institutional clients since 2021. In addition, Pictet AM USA conducts business development, solicitation and U.S. based relationship management activities on behalf of the other SEC Pictet AM Firms, with respect to institutional investors in the United States. These institutional investors include, among others, public and corporate retirement plans, government funds, foundations, endowments and the Pictet AM US Active ETFs. Pictet AM USA markets the other SEC Pictet AM Firms’ segregated portfolio management strategies and foreign funds offered on a private placement basis. When a prospective U.S. investor expresses interest in another SEC Pictet AM Firm’s strategy, Pictet AM USA refers the prospect to the relevant SEC Pictet AM Firm. The relevant SEC Pictet AM Firm conducts due diligence, contract negotiation and all onboarding steps in relation to the prospect. Once the prospect becomes a client of the relevant SEC Pictet AM Firm, Pictet AM USA receives read only access to the client’s account information through a technological solution authorised by the relevant affiliate. This supports its business development oversight and U.S. based relationship management responsibilities. It also receives client account documents to support these responsibilities. Pictet AM USA does not have a local trading desk. It also does not handle onboarding or contracting for affiliate clients.

B.

Types of Advisory Services

The SEC Pictet AM Firms provide both non-discretionary and discretionary investment management services to institutional clients. These services include:

Assistance in determining appropriate risk and return objectives for each client. Defining the appropriate asset mix which is most likely to achieve those objectives. Selection or advice on specific markets, currencies and securities from those categories. Assuming discretionary responsibility for all aspects of day-to-day management and investment of the client’s account(s).

Pictet AM SA and Pictet AM Ltd manage a wide range of equity, fixed income and multi asset strategies including Total Return. Pictet AM Singapore manages a wide range of fixed income and equity total return strategies. Pictet AM USA manages the Emerging Markets Fixed Income strategy.

C.

Tailoring of Services and Client Restrictions

Each SEC Pictet AM Firm tailors services to institutional client needs. Clients define investment restrictions with their SEC Pictet AM Firm (as adviser) which in turn implements those restrictions throughout the mandate. Further information on account reviews and reporting appears in Item 13.

D.

Wrap Fee Programs

Investment management services for wrap fee programmes are generally the same as those offered to non-wrap clients. However, wrap accounts may face practical constraints, most often due to their smaller asset size, which can lead to slightly different returns. These differences typically stem from investment and administrative restrictions, as well as the wrap fees charged by the sponsor. Pictet AM SA

Provides model portfolios to an investment advisory group (“the sponsor”).

Performs no trade execution for wrap clients.

Receives a portion of the sponsor’s wrap fee.

Pictet AM Ltd

Acts as portfolio manager within an unaffiliated sponsor’s wrap program.

Performs trade execution for wrap clients.

Receives a portion of the sponsor’s wrap fee as management fee.

Neither Pictet AM USA nor Pictet AM Singapore participates in wrap fee programs.

E.

Client Assets Under Management (As of 31 December 2025)

The below figures are in USD and rounded to the nearest 100,000. Pictet AM SA

Discretionary: 330,703,333,875

Non-discretionary: 353,940

Pictet AM Ltd

Discretionary: 24,402,700,000

Non-discretionary: 0

Pictet AM USA

Discretionary: 382,000,000

Non-discretionary: 0

Pictet AM Singapore

Discretionary: 3,547,900,000

Non-discretionary: 380,400,000

A. Advisory Fees and Compensation Each of the SEC Pictet AM Firms charge an investment management fee expressed as a percentage of the market value of the assets that they manage. The fee is negotiated with each client. Fee schedules can include declining rates for larger portfolios and, in certain cases, performance-based fees (described in Item 6).

B. Billing Practices and Fee Payment Method Fees are payable monthly or quarterly in arrears. When an account opens or closes during a billing period, the SEC Pictet AM Firm charges a prorated fee for the portion of the period during which the account is managed. For the SEC Pictet AM Firms, fees are generally calculated based on the client’s custodian statements, and for SEC clients, 100% of fees are based on their custodian statements.

Differences between Pictet Asset Management system valuations and custodian valuations can result in differences in advisory fees.

C. Other Fees and Client-Incurred Expenses The SEC Pictet AM Firms’ advisory fees exclude all transaction-related and third-party expenses. Clients typically pay the following third-party expenses:

brokerage commissions; transaction fees; custodian charges; fund-level management fees (third-party funds and exchange-traded funds); other fund-related fees, including but not limited to servicing fees and other ancillary charges; transfer taxes; wire and electronic transfer costs; taxes and commissions related to securities transactions; and any other fees charged by third parties.

Where client assets are invested in third-party funds, those funds charge fees as described in their prospectuses. The SEC Pictet AM Firms consider these expenses when selecting funds.

Fees Related to Investment in In-House Funds In some instances, the SEC Pictet AM Firms invest client assets in Pictet AM in-house funds, subject to client investment guidelines and eligibility criteria, which also charge management fees. In addition to the advisory fee paid to the relevant SEC Pictet AM Firm, the funds in which clients participate bear “service fees” for administration and shareholder servicing, which are paid from fund assets to an affiliated management company. These fees are separate from, and in addition to, the advisory fees described above and reduce overall investment returns. For the SEC Pictet AM Firms, if an in-house fund already charges a management fee, the relevant SEC Pictet AM Firm excludes the value of the client’s investment in that fund when calculating its management fee unless otherwise agreed in writing. Where no management fee exists at the fund level, the SEC Pictet AM Firms calculates its management fee based on the total assets under management. For the US ETFs where the relevant SEC Pictet AM Firm is appointed as sub-adviser, the relevant SEC Pictet AM Firm receives management fees as disclosed in the respective ETF prospectus.

D. Termination of Advisory Agreements Each advisory agreement permits either party to terminate the agreement on written notice on a mutually acceptable period of notice, which is usually not more than 30 days.

E. Compensation for Sale of Securities or Other Investment Products The SEC Pictet AM Firms each receive the following additional compensation:

Referral compensation from Pictet AM entities that enter into agreements with clients introduced by the relevant SEC Pictet AM Firm. There are no additional fees charged to the client to remunerate the relevant SEC Pictet AM Firm.

Remuneration for distribution of Pictet AM non-US regulated funds whereby: ‒ Pictet AM SA receives such remuneration from Pictet AM Europe and Pictet AM Hong Kong, which receive the management fee directly from the funds. ‒ Pictet AM Ltd receives such remuneration from Pictet AM Europe, Pictet AM Hong Kong and Pictet AM SA, which receive the management fee directly from the funds. ‒ Pictet AM US receives such remuneration from Pictet AM Europe, Pictet AM SA, which receive the management fee directly from the funds. ‒ Pictet AM Singapore receives such remuneration from Pictet AM Europe, Pictet AM SA, Pictet AM Hong Kong, which receive the management fee directly from the funds.

Delegated investment management compensation from Pictet AM Europe or Pictet AM SA where they have partially or totally delegated to another SEC Pictet AM Firm investment management of one or more non-US regulated funds. In this context, the relevant SEC Pictet AM Firm receives a part of the management fee received directly from the fund by Pictet AM Europe or Pictet AM SA.

The SEC Pictet AM Firms market advisory services through internal Sales or Business Development teams and, in some cases, through similar functions in other Pictet Group entities. Personnel in these areas receive salary, revenue-linked and qualitative bonuses, and in some instances profit share. The SEC Pictet AM Firms apply remuneration controls to ensure referral-related compensation does not incentivise behaviour inconsistent with fiduciary or regulatory obligations, including scoring mechanisms that reduce bonuses for poor compliance.

Conflicts Arising from Fee Differentials Fee levels differ among clients because fees are negotiated individually. Higher-fee accounts create an incentive to prioritise such accounts when trading or allocating investment opportunities. The SEC Pictet AM Firms address such conflicts through:

fair and consistent allocation of investment opportunities between different client accounts in the same strategy, subject to client restrictions, instructions and cash-flows; pre-allocation of all orders; pro-rata allocation based on client order size, taking into account market lot sizes and avoiding uneconomic allocations; and continuous compliance monitoring to verify consistent treatment across comparable accounts.

In managing discretionary client accounts and providing recommendations to non-discretionary clients, the SEC Pictet AM Firms use various investment strategies and methods of analysis implemented by their investment teams. Item 8 describes these methods of analysis and investment strategies together with the primary risks associated with them. However, it is not possible to identify all risks associated with investing and the particular risks applicable to a client account will depend on the nature of the account, its investment strategy or strategies and the types of securities held. While the SEC Pictet AM Firms seek to manage accounts so that risks are appropriate to the relevant strategy it is often not possible or desirable to fully mitigate risks. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. Clients and investors should understand that they could lose some or all of their investment and should be prepared to bear the risk of such losses. Clients and investors should read carefully all applicable informational materials and offering or governing documents for further information on the various risks associated with investing before retaining a SEC Pictet AM Firm to manage an account or investing in any product or vehicle it manages or advises.

A. Methods of Analysis and Investment Strategies The SEC Pictet AM Firms rely on multiple sources of information to support their investment analysis. These sources include external research providers and internally generated primary research. Information reviewed includes the financial press, meetings with company management, research received from analysts at other financial institutions (including brokers), independent research providers, conference materials, corporate rating services, timing services, annual reports, prospectuses, filings with the SEC and other regulators, company press releases and system generated information supplied through tools, such as Bloomberg Financial. Investing in securities and other financial instruments involves risk of loss of part or all of the amount invested and clients should be prepared to bear such losses. The SEC Pictet AM Firms use long only and total return investment strategies to manage client assets. These strategies apply fundamental analysis, quantitative inputs where relevant, macroeconomic assessments, sector and issuer research and security level evaluation depending on the strategy and client mandate. Different strategies may emphasise different analytical techniques and instruments so the nature and magnitude of the risks described in the “Risk of Loss and Material Risks” sub-sections will vary by strategy and client mandate. The SEC Pictet AM Firms use derivative instruments including but not limited to futures, options, swaps and forward foreign exchange contracts. Derivatives are used for investment purposes, for efficient management such as the prompt implementation of large cash flows and for hedging intended to protect client portfolios from adverse market events. Derivatives used include both exchange-traded and over-the-counter instruments. As derivatives can embed economic leverage and create additional counterparty, liquidity and operational risks, clients should read the “Derivatives, Leverage and Collateral Risks” section together with any strategy-specific disclosures in the relevant offering or governing documents. Where applicable and consistent with the fiduciary duty to act in the best interests of clients and the adherence to the Principles for Responsible Investment (PRI), the SEC Pictet AM Firms integrate material environmental, social and governance (“ESG”) criteria in their investment processes and ownership practices with a view to enhancing returns and mitigating risks over the medium to long term. ESG considerations are also applied within risk management and reporting tools to maintain high standards of transparency and accountability. As the treatment of ESG factors may differ between strategies and products so not all portfolios will be exposed to ESGrelated risks and opportunities to the same extent, clients should refer to the “ESG and Sustainability-Related Risks” disclosures and the specific documentation for the strategies in which they invest. Investment strategies are defined according to the following categories: Non-ESG Integrated, ESG Integrated, ESG Focused and Positive Impact. These categories help indicate the degree to which ESG considerations form a central component of the investment objective or process and, therefore, which ESG-related risk disclosures are most relevant for a given strategy.

Exclusions apply to actively managed funds, certificates, baskets and discretionary mandates. Exclusions do not apply to passive strategies that replicate market indices or to open-ended funds managed by third party managers. Pictet AM’s exclusions framework constitutes a minimum standard for strategies in scope and such strategies can apply more stringent exclusion criteria. Where relevant, Pictet AM retains full discretion over the implementation of exclusion criteria and can grant exemptions on a case-by-case basis in instances where issuers are on a credible pathway to improve on ESG issues that triggered the exclusion. Pictet AM relies on third party service providers, non-profit organizations and governments when determining, from an ESG perspective, which investments to exclude from the selection of securities to purchase. This process is based on the categorization by such providers of the types of companies, industries and countries that are excluded from the permissible investment universe. There is no assurance that the exclusion list determined by Pictet AM or a third-party service is complete or that all relevant securities have been restricted. The exclusion list is subject to change at any time without notice. As a result, the application of exclusions and related risks may differ across strategies and over time. Therefore, clients should review the product-level disclosures that apply to their specific investments. The following section provides a description of the investment strategies managed by the SEC Pictet AM entities. A discussion of the risks associated with these strategies appears at the end of this item.

Equities Long Only AI & Automation The investment strategy of “AI & Automation” is to invest at least 80% of its net assets (plus borrowings for investment purposes) in global equity securities of AI and automation companies and focuses on companies that have a distinct link to artificial intelligence and/or automation as measured by the proportion of the company (e.g., sales, earnings before Interest, taxes, depreciation and amortisation (“EBITDA”), enterprise value, capital expenditure (“CapEx”) or other relevant metrics) that contributes to and benefits from the value chain in artificial intelligence, robotics, cybersecurity, semiconductors and software; this includes companies that produce the essential hardware and services, as well as those providing technologies that enable robots to sense, process, communicate and act; companies that redefine, optimize and automate enterprise workflows; companies that change the way we interact with each other and consume and those that develop robotics and automation solutions aimed at consumer and service applications for everyday life. The investment strategy is expected to have significant exposure to securities of issuers in the information technology, industrials, communication services and consumer discretionary sectors. Further, AI & Automation is expected to, in the aggregate, invest more than 25% of its assets in securities of companies in the industries comprising the information technology sector.

AI Enhanced International Equity The investment strategy of “AI Enhanced International Equity” is enhanced by the use of artificial intelligence, as described below. Under normal market conditions, the investment strategy is to invest at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of International companies which are those listed within the MSCI EAFE Index (the “Index”). The investment strategy seeks to outperform the Index using an enhanced index strategy with a low tracking error to invest across the international equity market using an artificial intelligence model to identify stocks. Artificial intelligence refers, in this case, to the application of computer systems or models to perform tasks that typically require human intelligence. The artificial intelligence model uses hundreds of features engineered from a broad range of data such as fundamentals, analyst sentiment, prices and market activity, short interest and calendar effects to make relative forecasts of the stocks of the Index. These are regularly updated and combined in a proprietary optimizer with risk and control estimates and constraints on position sizing. The portfolio managers of AI Enhanced International Equity review the output of the optimizer, which drives both buy/sell recommendations during implementation of the desired portfolio. These buy/sell recommendations are then reviewed and approved by the portfolio managers before purchases and sales are executed. AI Enhanced US Equity

The investment strategy of “AI Enhanced US Equity” is to invest at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of U.S. companies. A “US Company” for this purpose are those that are listed within the S&P 500 Index (the “Index”). The investment strategy seeks to outperform (net of fees) the Index using an enhanced index strategy with a low tracking error to invest across the U.S. equity market using an artificial intelligence model to identify stocks. Artificial intelligence refers, in this case, to the application of computer systems or models to perform tasks that typically require human intelligence. The artificial intelligence model uses hundreds of features engineered from a broad range of data such as fundamentals, analyst sentiment, prices and market activity, short interest and calendar effects to make relative forecasts of the stocks of the Index. These are regularly updated and combined in a proprietary optimizer with risk and control estimates and constraints on position sizing. The portfolio managers of the Pictet AI Enhanced US Equity ETF review the output of the optimizer, which drives both buy/sell recommendations during implementation of the desired portfolio. These buy/sell recommendations are then reviewed and approved by the portfolio managers before purchases and sales are executed.

Cleaner Planet The investment strategy of “Cleaner Planet” is to invest at least 80% of its net assets (plus borrowings for investment purposes) in securities of “Cleaner Planet” companies. Cleaner Planet companies are global companies that contribute and benefit from the structural change towards a more sustainable economy including companies that have a distinct environmental and/or social impact objective, measured by the proportion of the company (e.g. sales, EBITDA, enterprise value, CapEx or other relevant metrics) that contributes positively to activities such as energy efficiency, renewable energy, pollution control, water supply & technology, sustainable buildings, waste management & recycling, sustainable agriculture & forestry, circular economy, dematerialized economy or enabling technologies and infrastructure that support the aforementioned activities. The investment strategy is also expected to have significant exposure to securities of issuers in the information technology, industrials and utilities sectors. Further, Cleaner Planet is expected to, in the aggregate, invest more than 25% of its assets in securities of companies in the industries comprising the information technology sector.

Emerging Markets Rising Economies The Emerging Markets Rising Economies strategy invests in equities within emerging markets and frontier countries where there is active working population growth. The strategy is actively managed and is implemented through an exchange traded fund structure. The investment process combines both a quantitative and fundamental approach to select companies for inclusion within the portfolio. The quantitative element focuses on companies with cheap relative valuations which are exhibiting positive change, and the fundamental analysis undertaken emphasises dividend as a strand of overall value and similarly involves looking for companies that are seeing an improvement in fundamentals. Investing in this strategy involves risk of loss. Principal risks are described under Risk of Loss and Material Risks.

Family The Family strategy is an active, large cap, global equity portfolio that invests in family and founder-owned, publicly listed companies. The strategy seeks to outperform global equity markets through a full business cycle. We believe that owner-managed businesses are managed differently, allocating capital with a long-term vision that can create sustainable competitive advantages. The Family universe is dynamic and renewed annually. Our Family portfolio is built by selecting the best opportunities within the investment universe based on fundamental analysis complemented by top down risk control. To help select the best long-term investments and mitigate risk, ESG is integrated into every step of the active investment process, with a focus on the governance factors that influence the performance of family-owned businesses.

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The SEC Pictet AM Firms provide advisory and discretionary portfolio‑management services exclusively to institutional clients, including pension and profit‑sharing plans, registered mutual funds, private investment funds, sovereign wealth funds, regulated and unregulated foreign funds (such as UCITS), U.S. pooled investment vehicles such as LLCs and Collective Investment Trusts and other international institutional investors. The SEC Pictet AM Firms do not provide advisory services to retail clients.

Pictet Asset Management SA Pictet AM SA primarily provides portfolio management services to the following types of institutional clients:

pension and profit‑sharing plans charitable organisations insurance companies registered mutual funds private investment funds sovereign wealth funds regulated and unregulated funds U.S. pooled investment vehicles such as LLCs and Collective Investment Trusts other U.S. and international institutions

Pictet Asset Management Ltd Pictet AM Ltd primarily provides portfolio management services to the following types of institutional clients:

pension and profit‑sharing plans registered mutual funds private investment funds sovereign wealth funds regulated and unregulated funds other U.S. and international institutional clients

Pictet Asset Management (USA) Corp. Pictet AM USA primarily provides portfolio management services to the following types of institutional clients:

pension and profit‑sharing plans registered mutual funds unregulated funds

Pictet Asset Management Singapore Pte. Ltd. Pictet AM Singapore primarily provides discretionary investment management services to the following types of institutional clients:

corporate pension and profit‑sharing plans registered mutual funds private investment funds sovereign wealth funds regulated and unregulated funds other international institutions

The SEC Pictet AM Firms have established minimum account requirements for certain client accounts, which can vary based on the investment vehicle (separate account or fund), investment strategy and asset class. For

separately managed accounts, the SEC Pictet AM Firms generally require a minimum of US$ 50 million; however, in its discretion and in special circumstances, the SEC Pictet AM Firms can accept accounts of lesser amounts. Minimums applicable to pooled vehicles (including non-U.S. regulated funds) are set forth in the applicable governing or offering documents. Minimums are subject to waiver in the SEC Pictet AM Firms’ discretion and may be waived from time to time. To open or maintain a separate account, clients are required to sign an investment management agreement with the SEC Pictet AM Firms that stipulate the terms under which the SEC Pictet AM Firms are authorized to act on behalf of the client to manage the assets listed in the agreement. In certain instances, the SEC Pictet AM Firms may also manage assets for clients of its affiliates and will receive from the affiliate a portion of the fee or other compensation paid by the end client for such services. Under these circumstances, the client enters into an investment management agreement with the affiliate and, in turn, the affiliate delegates authority to the SEC Pictet AM Firms. For example, Pictet Asset Management (Europe) SA may delegate investment management of non-U.S. regulated funds to the SEC Pictet AM Firms and the SEC Pictet AM Firms receive a portion of the management fee paid by the fund. For wrap programs in which the SEC Pictet AM Firms either serve as portfolio manager or acts solely as a model portfolio provider, account size requirements for the underlying sponsor accounts are established by the program sponsor and can differ from the SEC Pictet AM Firms’ separate account minimum. In these programs when acting solely as a model portfolio provider, the SEC Pictet AM Firms do not implement trades for sponsor- managed accounts.

A. Performance‑Based Fees The SEC Pictet AM Firms can enter into performance‑fee arrangements with “qualified clients,” as defined under the Advisers Act, using the qualification criteria determined as of the last trading day of each quarter or another date agreed with the client. Performance‑fee terms are negotiated individually with each qualified client. All performance‑fee arrangements comply with Section 205(a)(1) of the Investment Advisers Act of 1940 and Rule 205‑3. When performance‑based fees are calculated, realized and unrealized capital gains and losses are included. Performance‑fee arrangements create conflicts of interest. These arrangements can incentivise an SEC Pictet AM Firm to favour performance‑fee clients over other clients. This incentive can influence the timing or selection of securities transactions or allocation of limited opportunities. Performance‑fee arrangements can encourage selection of investments that carry higher risk because these investments can generate higher returns and therefore higher performance fees. For the Pictet total return funds that are managed, the performance‑fee structure is not negotiated at arm’s length. The conflicts associated with performance‑based fees are addressed through our side‑by‑side management processes described below.

B. Side‑By‑Side Management The SEC Pictet AM Firms manage multiple accounts that follow substantially similar investment strategies. This structure creates conflicts of interest. These conflicts arise from the possibility of preferential treatment among accounts, differences in fee structures, differences in performance‑related compensation to portfolio managers and differences in timing and size of transactions. Conflicts also arise when investment opportunities have limited availability, including initial public offerings. Fund managers who receive higher performance‑related compensation from managing certain strategies, such as total‑return funds, can have incentives that influence investment decisions. Accounts paying higher fees can also create incentives for preferential treatment. These conflicts are addressed using the following measures:

Investment opportunities are allocated on a pro‑rata basis, taking into account market conventions such as standard lot sizes and avoidance of uneconomic allocations.

Regular compliance monitoring is conducted to ensure that investment opportunities are allocated fairly across similar accounts and that investment risks remain consistent.

New products launched or seeded by affiliates of the SEC Pictet AM Firms can initially be owned predominantly by those affiliates or their clients. These accounts are monitored carefully to mitigate preferential treatment.

Discretionary authority is exercised in a manner consistent with client objectives, which can result in different timing and nature of actions taken across accounts.

Information access across investment teams is controlled through information barriers.

Investment results differ across accounts because of factors including cash availability, timing of account openings, client contributions or withdrawals and client‑specific restrictions. Some clients cannot participate in certain investments or can participate only partially or at different times, including where minimum IPO or fixed‑income investment thresholds would produce uneconomic allocations. The SEC Pictet AM Firms ensure that investment decisions focus on their respective fiduciary duties and not on their financial interests. Across comparable strategies and circumstances, the SEC Pictet AM Firms provide fair and equitable access to investment opportunities.

In addition, the SEC Pictet AM Firms’ policies deal with information barriers among investment teams, ensuring that our investment teams can access only those accounts necessary for them to carry out their roles and responsibilities.

A. Broker-Dealer Registration SEC Pictet AM Firms and Management Persons None of the SEC Pictet AM Firms, nor any of their management persons, is registered or has an application pending to register as a broker-dealer or as a registered representative of a broker-dealer. Pictet AM USA Distribution Staff Whilst Pictet AM USA is not a broker-dealer, certain distribution staff of Pictet AM USA, including its Chief Executive Officer, are registered representatives of Foreside Fund Services LLC, a FINRA-registered broker-dealer, solely to distribute Pictet Group funds to U.S. institutional and intermediary clients. Neither Pictet AM USA nor any other Pictet AM entity has a trading, investment advisory or investment research relationship with Foreside Fund Services LLC or its affiliates.

B. Futures / Commodities Registration CFTC Registration Status None of the SEC Pictet AM Firms is registered with the CFTC as a Futures Commission Merchant, Commodity Pool Operator or Commodity Trading Advisor or as an associated person of any of these categories. NFA Exemptions Each of the below SEC Pictet AM Firms is recorded with the National Futures Association in the following exempt categories:

Pictet AM SA: Exempt Commodity Pool Operator and Exempt Commodity Trading Advisor.

Pictet AM Ltd: Exempt Commodity Pool Operator and Exempt Commodity Trading Advisor.

Pictet AM Singapore: Exempt Commodity Pool Operator and Exempt Commodity Trading Advisor.

C. Material Relationships or Arrangements with Related Persons Below is the description of any relationship or arrangement that is material to the SEC Pictet AM Firms’ advisory business or to their clients and that the SEC Pictet AM Firms have with any related affiliates listed below. Where such relationship or arrangement creates a material conflict of interest with clients, the nature of the conflict and the related controls are set out either in:

For the Investment Company / Other Pooled Investment Vehicles within their description in point 2 below. For all the other relationships and arrangements, at the end of this item.

1.

Broker-Dealer Affiliates

Banque Pictet & Cie SA (“Banque Pictet SA”) Banque Pictet SA is a Switzerland based licensed bank and broker-dealer with FINMA and is a related person of each of the SEC Pictet AM Firms. Activities include:

Asset management and custodial services.

Broker-dealer services for non-U.S. client accounts on a limited basis when instructed by the SEC Pictet AM Firms (clients may request not to use Banque Pictet SA).

Referrals or delegations of clients to the SEC Pictet AM Firms.

Provision of general research information and certain administrative, support and IT services to the SEC Pictet AM Firms.

Joint ESG engagement with Pictet Wealth Management for a limited number of companies (holdings shared only between relevant ESG teams).

Bank Pictet & Cie (Europe) AG (“BPAG”) BPAG is a Germany based BAFIN-licensed bank and is a related person of the SEC Pictet AM Firms. BPAG acts as custodian for Luxembourg UCITS funds managed by the SEC Pictet AM Firms and as a broker for the SEC Pictet AM Firms.

2.

Investment Company / Other Pooled Investment Vehicles

U.S. ETFs advised by Pictet AM SA, Pictet AM Ltd and Pictet AM USA(“U.S. ETFs”) Pictet AM SA, Pictet AM Ltd and Pictet AM USA are investment advisers to the U.S. ETFs which are registered investment companies. The U.S. ETFs are the only in-house funds offered to U.S. investors where the relevant SEC Pictet AM Firm, acts as manager. The relevant SEC Pictet AM Firm receives a management fee from each U.S. ETFs. This relationship creates a material conflict with clients whereby there are side-by-side management conflicts between the U.S. ETFs and other relevant SEC Pictet AM Firm clients (such as allocation of investment ideas and trades). The controls in place to address this conflict are:

The side-by-side management controls described in Item 6.

The application of the same due diligence, fairness and conflict management standards to the U.S. ETFs as to other clients.

Luxembourg mutual funds where Pictet Asset Management (Europe) SA (“Pictet AM Europe”) is the Management Company Pictet AM Europe is the Management Company of Pictet AM Luxembourg mutual funds, which are not marketed or targeted to U.S. clients (except to U.S. based intermediaries and wealth managers for distribution to offshore clients). Pictet AM Europe delegates investment management of several Pictet Group Luxembourg mutual funds to the SEC Pictet AM Firms. This relationship creates a material conflict with clients whereby there are incentives to favour these funds when allocating opportunities. The controls in place to address this conflict are:

Delegation arrangements are subject to regulatory and internal oversight.

The side-by-side management controls described in Item 6.

The application of the same due diligence, fairness and conflict management standards to the Pictet Group Luxembourg mutual funds as to other clients.

Swiss mutual funds where Pictet AM SA is the Management Company Pictet AM SA is the Management Company of Pictet AM Swiss mutual funds, which are neither marketed nor targeted to U.S. clients. Pictet AM SA delegates investment management of several Swiss funds to Pictet AM Ltd. This relationship creates a material conflict with clients whereby there are incentives to favour these funds when allocating opportunities. The controls in place to address this conflict are:

Delegation arrangements are subject to regulatory and internal oversight.

The side-by-side management controls described in Item 6.

The application of the same due diligence, fairness and conflict management standards to the Pictet Group Luxembourg mutual funds as to other clients.

3.

Other Investment Adviser affiliates

Pictet Alternative Advisors SA (“PAA SA”) Pictet Alternative Advisors (“PAA”) is the dedicated alternative investment advisory division of the Pictet Group. PAA SA is an authorised asset manager under FINMA in Switzerland and an exempt reporting adviser with the SEC. PAA SA is an affiliate of the SEC Pictet AM Firms. PAA SA undertakes the following activities:

Permitting SEC Pictet AM Firms to promote certain PAA SA-managed private funds on a private offering basis to accredited investors as defined in Rule 501(a) of Regulation D promulgated under the Securities Act. Structuring and oversight of alternative investment vehicles. Operation of a Thematic Expert Board for certain thematic private equity co-investment and multi-strategy funds which are not offered to US investors and on which selected Pictet AM SA’s Thematic Strategies team serve.

Pictet Alternative Advisors (UK) Ltd (“PAA UK”) PAA UK is United Kingdom based and authorised and regulated by the FCA and is registered as an exempt reporting adviser with the SEC. PAA UK is an affiliate of the SEC Pictet AM Firms. PAA UK undertakes the following activity:

Permitting SEC Pictet AM Firms to promote certain PAA UK-managed private funds on a private offering basis to accredited investors as defined in Rule 501(a) of Regulation D promulgated under the Securities Act.

Pictet North America Advisors SA (“PNAA”) PNAA is Swiss based and regulated by FINMA and registered as an investment adviser with the SEC. PNAA is an affiliate of Pictet AM SA, Pictet AM Ltd and Pictet AM USA. PNAA undertakes the following activities:

Receipt and use of generic thematic portfolio models from Pictet AM SA in the discretionary management of segregated accounts for U.S. clients. Leverages the U.S. ETFs managed by Pictet AM SA, Pictet AM Ltd and Pictet AM USA that PNAA can place in the discretionary portfolio management of its clients or propose to clients with advisory mandate.

Pictet AM Ltd Pictet AM Ltd is a United Kingdom based investment adviser authorised and regulated by the FCA and is registered as an investment adviser with the SEC. Pictet AM Ltd is an affiliate of the other SEC Pictet AM Firms. Pictet AM Ltd undertakes the following activities:

Management of a broad range of equity, fixed income and multi-asset strategies, including total return strategies for institutional clients and pooled vehicles. Delegation of all or part of client accounts to and from other Pictet AM entities. Non-U.S. client referrals to and from the Pictet Group to access specific strategies. U.S. client referrals from Pictet AM USA. Promotion of certain PAA private funds on a private placement basis. Joint business development (including with Pictet AM USA in the U.S.). Provision of centralised trading desk services for non-Asian markets. Offering of U.S. ETFs for discretionary and advisory mandates. Sharing of internally produced investment research. Receipt of investment advisory services for Japanese Equities.

Pictet AM SA Pictet AM SA is a Swiss based investment adviser regulated by FINMA and is registered as an investment adviser with the SEC. Pictet AM SA is an affiliate of the other SEC Pictet AM Firms. Pictet AM SA undertakes the following activities:

Management of a broad range of equity, fixed income and multi asset strategies, including total return strategies for institutional clients and pooled vehicles. Shared management of certain equity, fixed income and multi asset strategies with other Pictet AM entities. Non-U.S. client referrals to and from the Pictet Group to access specific strategies. U.S. client referrals from Pictet AM USA. Promotion of certain PAA private funds on a private placement basis. Delegation of portfolio management to and from other Pictet AM entities. Provision of trading desk services for non-Asian total return equity and fixed income strategies. Provision of model portfolios for use by PNAA. Offering of U.S. ETFs for discretionary and advisory mandates. Sharing of internally produced investment research.

Pictet AM Singapore Pictet AM Singapore is a Singapore based investment adviser regulated by MAS and is registered as an investment adviser with the SEC. Pictet AM Singapore is an affiliate of the other SEC Pictet AM Firms. Pictet AM Singapore undertakes the following activities:

Management of emerging markets fixed income and equity total return strategies for institutional clients and pooled vehicles. Operation of an Asia-focused trading desk executing or placing orders in Asian fixed income markets. Referrals of clients to PAA entities for access to alternative strategies. Promotion of certain PAA private funds on a private placement basis. Provision of investment advisory services within Pictet AM’s Emerging Market Fixed Income platform. Receipt of delegated portfolio management from other Pictet AM entities. Use of Pictet AM Ltd and Pictet AM SA trading desks for non-Asian securities. Sharing of internally produced investment research.

Pictet Asset Management (Hong Kong) Ltd (“Pictet AM Hong Kong”) Pictet AM Hong Kong is Hong Kong based and regulated by the Securities & Futures Commission. Pictet AM Hong Kong is an affiliate of the SEC Pictet AM Firms. Pictet AM Hong Kong undertakes the following activities:

Provision of investment advisory and portfolio management services in Asian and emerging market equity and fixed income strategies for non-U.S. institutional clients and pooled vehicles. Management of Hong Kong-domiciled funds and offshore hedge funds not offered to U.S. investors. Receipt and provision of delegated portfolio management for hedge fund and long-only strategies within Pictet AM. Operation of an Asia equity trading desk placing orders for Pictet AM entities. Sharing of internally produced investment research.

Pictet Asset Management (Japan) Ltd (“Pictet AM Japan”) Pictet AM Japan is a Japan based and regulated by Financial Services Agency. Pictet AM Japan is an affiliate of the SEC Pictet AM Firms.

Pictet AM Japan undertakes the following activities:

Management and distribution of Japanese domestic funds for local investors. Provision of an Asia equity trading desk placing orders in Japanese and certain regional equity instruments for other Pictet AM entities. Provision of investment advisory services for Japanese Equities to Pictet AM Ltd. Sharing of internally produced investment research. Receipt and referral of clients for strategies managed by Pictet AM SA and Pictet AM Ltd.

Pictet AM Europe Pictet AM Europe is Luxembourg based and regulated by the Commission de Surveillance du Secteur Financier (“CSSF”) and exempt registered adviser with the SEC. Pictet AM Europe is an affiliate of the SEC Pictet AM Firms. Pictet AM Europe undertakes the following activities:

Acting as management company for Pictet AM Luxembourg mutual funds (including oversight of governance, risk management and distribution arrangements). Delegation of investment management of several funds to SEC Pictet AM Firms and other Pictet AM entities. Provision of private assets and hedge fund solutions aimed at U.S.-based intermediaries and institutional investors.

Pictet AM USA Pictet AM USA is a U.S. based investment advisor and registered with the SEC Pictet AM USA is an affiliate of the other SEC Pictet AM Firms. Pictet AM USA undertakes the following activities:

4.

Business development and marketing of Pictet AM strategies to U.S. institutional and intermediary clients. Client servicing and relationship management for U.S. clients primarily managed by Pictet AM SA. Provision of investment advisory services within the Emerging Market Fixed Income platform. Referrals of potential investors to PAA entities for alternative strategies. Offering of U.S. ETFs for discretionary and advisory mandates. Promotion of certain PAA private funds on a private offering basis to eligible U.S. investors.

Futures Commission Merchant (“FCM”) / Commodity Pool Operator (“CPO”) / Commodity Trading Adviser (“CTA”)

There are no SEC Pictet AM Firm affiliates that act as an FCM, CPO or CTA beyond the exempt status of Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore, as disclosed above.

5.

Banking or Thrift Institution

Read the rest in the brochure

A. Code of Ethics The SEC Pictet AM Firms adopted a Code of Ethics (the “Code”) pursuant to SEC Rule 204A 1 under the Investment Advisers Act of 1940 that sets forth the standards of business conduct expected of all supervised persons, based on professionalism, integrity, honesty and trust, and is designed to help manage conflicts of interest. The Code addresses:

personal account dealing rules;

gifts and entertainment;

protection of confidential client information;

dealing with personal conflicts of interest; and

respecting confidential information of Pictet AM and the Pictet Group.

Officers, directors and employees within SEC Pictet AM Firms are permitted, subject to the Code and applicable law, to trade for their own accounts in securities that the SEC Pictet AM Firms recommend to and/or purchases for clients. These situations create potential conflicts of interest because employees could have the opportunity or incentive to benefit from knowledge of client orders, to trade ahead of client transactions or otherwise to obtain more favourable terms than clients. The Code is designed to mitigate these conflicts and to ensure that such personal activity does not interfere with making or implementing decisions in the best interests of clients. Clients and prospective clients can obtain a copy of the Code by contacting Robert Henderson, Global Pictet AM Chief Compliance Officer, at +44 207 847 5000 or pam_core_compliance@pictet.com.

B. Personal Securities Transactions Employee personal trading is subject to preclearance for most transactions and restrictions on trading in close proximity to client trading activity. Personal trading is monitored on a daily basis by the Pictet AM Business Ethics team to manage potential conflicts between the SEC Pictet AM Firms, their staff and clients. Without appropriate controls, personal trading in the same or related securities as clients could result in front running, trading ahead of clients or unequal treatment between employee and client accounts. The preclearance requirements, trading window restrictions, reporting obligations and daily monitoring are designed to mitigate these conflicts and to help ensure that client interests are placed ahead of officers, directors and employees’ personal interests. In addition, employees must report all brokerage and trading accounts to the Pictet AM Business Ethics team upon joining and must provide:

an annual report of holdings; and

a quarterly report of trading activity.

C. Insider Trading Policy and Information Barriers The SEC Pictet AM Firms maintain policies, procedures and controls to prevent misuse of material non-public information. These include: • physical access controls; • system entitlements that restrict access to sensitive investment management and trading information to the

relevant teams; • separate portfolio management, trading and investment accounting systems within SEC Pictet AM Firms; and

• the absence of shared employees performing portfolio management, operations or trading across SEC Pictet

AM Firms and other Pictet Group entities. Trading in securities issued by clients or their affiliates is subject to monitoring to help ensure consistency with procedures for the management of inside information. Additional details in relation to the management of conflicts related to information barriers are set out in Item 10.

D. Participation in Client Transactions SEC Pictet AM Firms do not undertake proprietary investment and other Pictet Group entities do not conduct proprietary investment on behalf of any SEC Pictet AM Firms. Certain Pictet Group entities outside SEC Pictet AM Firms can trade for their own accounts in securities that SEC Pictet AM Firms can buy or sell for clients. These arrangements create potential conflicts of interest, including incentives to favour securities or investment vehicles in which SEC Pictet AM Firms or their affiliates have an interest or to allocate investment opportunities unevenly between proprietary and client accounts. SEC Pictet AM Firms’ information barriers are designed to prevent access by those entities to SEC Pictet AM Firm clients’ orders, transactions or positions. The SEC Pictet AM Firms are permitted to recommend or purchase, for client accounts, securities or investment products in which the SEC Pictet AM Firms, their affiliates or other related persons have a financial interest (for example, as investment manager, general partner or co-investor) but only if authorised by the client. These arrangements present conflicts of interest, including an incentive to favour affiliated products or positions over comparable third party alternatives. The SEC Pictet AM Firms address these conflicts through client authorisation requirements, product approval and due diligence processes, information barrier arrangements, allocation and best execution policies and ongoing compliance monitoring. Where permitted by applicable regulation and when in the best interests of both clients, the SEC Pictet AM Firms can facilitate the crossing of securities between client accounts via external brokers at an independently determined market price, usually at lower-than-normal broker commissions. The SEC Pictet AM Firms receive no fees for such cross transactions. ERISA plan clients and U.S. registered investment companies under the Investment Company Act of 1940 cannot participate in cross trades.

A. Brokerage Selection, Use of Brokers and Related Conflicts Discretionary Brokerage Authority The SEC Pictet AM Firms exercise discretionary authority to select the securities to be bought or sold for client accounts and to select the brokers, dealers or banks that execute client transactions, consistent with each client’s investment objectives and guidelines. Broker Approval Process The SEC Pictet AM Firms execute transactions only through brokers that the Pictet Group Counterparty Risk Committee approves. The Committee performs a risk-based assessment that includes:

financial strength;

credit risk metrics;

regulatory status;

behaviour of market indicators; and

the nature and complexity of expected transaction types.

In addition to this counterparty risk assessment, when selecting or recommending broker-dealers for client transactions, the SEC Pictet AM Firms consider a range of execution-related factors including but not limited to the broker’s:

commission rates and spreads

execution price and overall cost of the transaction

ability to handle the size, type and complexity of the order

speed and likelihood of execution and settlement

responsiveness and quality of order handling

provision of research and other services (where permitted by law and regulation)

The SEC Pictet AM Firms seek to obtain over time and on a consistent basis the best overall result for clients which is not necessarily the lowest possible commission rate for each individual transaction. In assessing the reasonableness of a broker’s compensation (such as commissions or spreads), the SEC Pictet AM Firms consider the totality of the services and execution quality provided to client accounts. Use of Affiliated Brokers The SEC Pictet AM Firms use affiliated brokers on a limited basis. Affiliates are not paid more than standard commission rates or standard spreads for securities executed net of commission. Clients can instruct an SEC Pictet AM Firm not to use affiliates to execute orders for their accounts. Where affiliated brokers are part of the Pictet Group, the SEC Pictet AM Firms have an economic interest in their success. This creates a conflict of interest as the SEC Pictet AM Firms have an incentive to route client orders to affiliated brokers rather than to unaffiliated brokers that might otherwise be available. The SEC Pictet AM Firms seek to manage this conflict through their best execution processes and oversight, including monitoring execution quality and pricing for affiliated brokers against comparable unaffiliated brokers and permitting clients to opt out of the use of affiliated brokers. Best Execution The SEC Pictet AM Firms follow their Best Execution Policy to ensure that client trades achieve the best possible result on a consistent basis. The effectiveness of the policy and execution arrangements are reviewed, including assessment of whether execution venues continue to produce the best results for clients. The policy is reviewed at least annually and upon material changes. Oversight is performed by the Pictet AM Trade Execution Committees for Equities and Fixed Income and monitored by traders and Compliance.

1.

Research and Other Soft Dollar Benefits a.

Use of client commissions for research and who pays for research

All research used for the benefit of multi-asset and fixed income strategies managed by the SEC Pictet AM Firms is paid for from the relevant SEC Pictet AM Firm’s own profit and loss account. For equity strategies, the SEC Pictet AM Firms consume research received from a variety of external sources including brokers and third-party independent research providers (“external research”). In accordance with applicable laws and its fiduciary obligations, the SEC Pictet AM Firms can use a percentage of client dealing commissions to pay for external equity research where it assists in the investment decision-making process of its investment managers. b. Benefit to the firm and conflict of interest When the SEC Pictet AM Firms use client brokerage commissions to obtain research or other eligible services, the SEC Pictet AM Firms receive a benefit because they do not have to produce or pay for this research or these services from their own resources. This creates a conflict of interest because the SEC Pictet AM Firms have an incentive to select or recommend brokers based in part on the research or other services they provide rather than solely on clients’ interest in receiving the most favourable execution of their transactions. c.

Paying-up (higher commissions or spreads)

The SEC Pictet AM Firms’ equity trades are unbundled. Where permitted by law and the client, research commission is collected alongside the cost of execution via Commission Sharing Agreement (“CSA”) or Research Payment Account (“RPA”) brokers and trades with non-CSA/ non-RPA brokers are on execution-only rates. In all cases, the provision of external research will be dependent on the ability of the SEC Pictet AM Firms to fulfil their best execution obligations to clients as well as their obligations under section 28(e) of the Securities and Exchange Act of 1934 (“Section 28(e)”) and internal criteria. In certain circumstances, the SEC Pictet AM Firms can cause clients to pay commissions or spreads that are higher than those that might otherwise be available from other brokers in recognition of the value of research or other eligible services provided consistent with Section 28(e) and applicable law. d. Which accounts benefit and allocation of research and soft dollar benefits Soft dollar benefits funded by client dealing commissions are generally used to support the investment decision making of the relevant equity investment teams and not all client accounts that generate research commissions will necessarily benefit to the same extent from the research obtained. The SEC Pictet AM Firms do not seek to allocate soft dollar benefits strictly in proportion to the commissions generated by each individual client account. This creates a potential conflict of interest that the SEC Pictet AM Firms seek to manage through their governance, budgeting and oversight processes including the Pictet AM Research Committee. e.

Types of products and services obtained

Examples of the research services that the SEC Pictet AM Firms use are: • Macroeconomic forecasting • Market analysis and forecasting • Sector analysis • Stock analysis • Quantitative research • Thematic research

f.

Governance, budgeting and procedures for research and other soft dollar use

External research is obtained from brokers and independent research providers and can be funded by client commissions on condition that the material or services provided they are “eligible research” meaning such research: • concerns one or several financial instruments or other assets;

• concerns the issuers or potential issuers of financial instruments; or • is closely related to a specific industry or market such that it informs views on financial instruments, assets or

issuers within that sector, and which explicitly or implicitly recommends or suggests an investment strategy and provides a substantiated opinion as to the present or future value or price of such instruments or assets or otherwise contains analysis and original insights and reach conclusions based on new or existing information that could be used to inform an investment strategy and be relevant and capable of adding value to the SEC Pictet AM Firm’s decisions on behalf of clients. Research is bought for the benefit of clients of the SEC Pictet AM Firms by the managers and analysts responsible for a defined set of products and portfolios. A budget is calculated for each team using the Pictet AM approach and parameters as described within the Pictet AM Research Policy. This budget is calculated by the desk head, reviewed by the Chief Investment Officer and finally ratified by the Pictet AM Research Committee. This budget is reviewed on a quarterly basis by the Pictet AM Research Committee. Where an RPA is used, the relevant SEC Pictet AM Firm uses a segregated research account controlled by the relevant firm or an approved affiliate to pay for external research. RPA-funded research must be used exclusively to support client portfolio investment decisions. In some cases, an external RPA administrator oversees the collection, budgeting and quality review of RPA-funded research. The relevant SEC Pictet AM Firm enters into CSAs to fund external research using a portion of client dealing commissions on the following conditions:

The service (which can include research and advisory services, economic and political analysis or software incidental to such goods and services) assists the team in meeting mandated investment objectives.

The goods and services do not include market data, travel, accommodation, entertainment, general administrative goods or services, general office equipment or premises, membership fees, employee salaries or direct money payments.

The service has been reviewed for quality by the recipient.

CSA brokers provide execution-only rates for all transactions outside of the research-funding component. The SEC Pictet AM Firms will ensure that the use of client dealing commissions for the purchase of research has been conducted in accordance with the relevant principles and regulations and in accordance with our policies and procedures. 2.

Brokerage for Client Referrals a.

Whether brokerage is used to obtain client referrals and related conflict

The SEC Pictet AM Firms do not receive client referrals from brokers. Accordingly, the SEC Pictet AM Firms do not select or recommend brokers based on any arrangements to receive client referrals from such brokers. b. Procedures regarding brokerage for referrals Not applicable 3.

Directed Brokerage a.

Practice and policy on directed brokerage and conflicts / costs

If a client instructs an SEC Pictet AM Firm to use a specific broker, the client’s instructions are followed. Directed brokerage restricts our ability to:

negotiate commission rates;

select brokers able to execute difficult trades efficiently;

aggregate orders to achieve lower costs;

obtain optimal execution prices for directed accounts; and

use brokers vetted by the Counterparty Risk Committee.

As a result, directing brokerage can result in higher overall transaction costs or less favourable execution outcomes than might otherwise be achieved. b. Clients permitted to direct brokerage and potential impact Clients can choose to direct the SEC Pictet AM Firms to a specified broker. However, doing so can limit the SEC Pictet AM Firms’ ability to achieve most favourable execution of their transactions and can result in higher commissions or less favourable prices compared to accounts where the SEC Pictet AM Firms are free to select brokers.

B. Aggregation and Allocation of Client Transactions a.

Aggregation practices and condition

Transactions for multiple clients are generally aggregated to provide fair and efficient execution. Aggregated orders execute at an average price, with costs allocated pro-rata subject to market conventions and to avoid uneconomic allocations. Some clients can trade after aggregated orders if aggregation is not feasible, which can affect execution prices. Client orders are not aggregated with orders of other Pictet Group entities or employees. Compliance monitors trade allocations. b. Trade Reallocations Trades are only reallocated to correct errors in initial order entry or allocation. Procedures and Compliance monitoring is maintained to ensure reallocations are fair and consistent with fiduciary duties. c.

Errors and Breaches

Account errors, trade errors and other operational mistakes can occasionally occur in connection with the management of client accounts by the SEC Pictet AM Firms. The SEC Pictet AM Firms have established policies and procedures to address the identification and correction of such errors, which generally require that errors caused by the SEC Pictet AM Firms and affecting a client’s account be resolved promptly and fairly. The SEC Pictet AM Firms are committed to ensuring that clients do not experience financial loss as a result of errors for which the SEC Pictet AM Firms are responsible. Errors can arise from a variety of situations including portfolio management (such as inadvertent violation of investment restrictions), trading, processing or other functions (for example, miscommunication of information, incorrect number of shares, wrong price, wrong account or placing a buy order instead of a sell order and vice versa). The intent of these policies and procedures is to restore a client account to the appropriate financial position as determined in good faith by the SEC Pictet AM Firms based on what is reasonable in light of all relevant facts and circumstances surrounding the error. Consistent with the applicable standard of care, the SEC Pictet AM Firms’ policies, procedures and client agreements generally do not require perfect implementation of investment management decisions, trading, processing or other functions. Therefore, not all mistakes will be considered compensable to the client. Imperfections (including but not limited to the implementation of investment decisions, quantitative strategies, financial modelling, trade execution, cash movements, portfolio rebalancing, processing instructions or facilitation of securities settlement as well as imperfections in processing corporate actions or generating reports) would not constitute compensable errors depending on the materiality and other relevant facts and circumstances.

A. Compensation for Client Referrals The SEC Pictet AM Firms market advisory services through internal Sales or Business Development departments and, in some instances, through similar departments of other Pictet Group entities. Personnel in these functions receive a salary, a bonus determined by revenue metrics and qualitative factors and, in some instances, a profit-share based on Pictet Group results. The SEC Pictet AM Firms maintain remuneration policies and procedures that ensure referral-related compensation does not encourage conduct contrary to fiduciary responsibilities or regulatory requirements. This includes a scoring mechanism to reduce a bonus score in the event of poor compliance with policies or procedures. Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore can receive institutional client referrals from Pictet AM US. The receiving SEC Pictet AM Firm remunerates Pictet AM US for the referral. No additional cost is charged to the client in connection with this arrangement. The relevant SEC Pictet AM Firm can also pay compensation to external introducers or Pictet Group entities for referred clients. This compensation is typically a percentage of the annual management fee paid by the referred client. These costs are fully borne by the relevant SEC Pictet AM Firm and do not increase the fees charged to clients. The SEC Pictet AM Firms do not receive compensation for referring clients to non-Pictet AM entities, except for distribution fees associated with investor referrals into non-US mutual funds and Pictet AM USA for the U.S. ETFs. A conflict of interest may arise because referral arrangements could create an incentive for the SEC Pictet AM Firms to favour referred clients or to promote products or strategies that generate referral‑related payments. This conflict is mitigated by the fact that the clients concerned are institutional investors that set their own investment objectives, strategies and restrictions and retain full discretion over portfolio construction as set out in the investment management agreement. Discretionary authority is exercised only within client‑defined mandates, and sales or referral personnel are organisationally separate from portfolio management. The SEC Pictet AM Firms maintain a Code of Ethics, compliance oversight of referral arrangements and remuneration controls designed to prevent preferential treatment, and clients receive clear disclosures enabling them to assess any potential conflicts.

B. Other Compensation (including Third-Party Economic Benefits) A group of senior managers of the SEC Pictet AM Firms can receive additional remuneration via the Pictet AM Long Term Incentive Plan, based on profitability metrics and subject to a three year deferral. Pictet AM SA, Pictet AM Ltd and Pictet AM Singapore receive economic benefits from third parties in the form of external research, which is funded through client dealing commissions or Commission Sharing Agreements (please refer to Item 12). These arrangements involve a defined set of eligibility criteria and oversight mechanisms including quality review, compliance with Section 28(e) of the Securities Exchange Act of 1934 and monitoring by the Pictet AM Research Committee. Research benefits are used solely to support investment decision-making in the best interests of clients. SEC Pictet AM Firms engage a third-party media and communications firm to support media appearances and promotional activities, including placements on financial news platforms such as Bloomberg TV and NYSE TV. The media firm may also coordinate advertising initiatives and may collaborate with other external service providers in connection with these activities. The SEC Pictet AM Firms do not pay this media firm directly. Instead, the costs are paid by an affiliate within the Pictet Group that is not a registered investment adviser. As a result, the SEC Pictet AM Firms receive an economic benefit in the form of increased marketing exposure and brand visibility. These costs are not charged to advisory clients, are not included in advisory fees and are not reported as client expenses. This arrangement creates a conflict of interest because the SEC Pictet AM Firms have an incentive to participate in media and promotional activities that enhance their public profile. Media appearances, interviews and related content are designed for general informational and marketing purposes and are not intended as personalised

investment advice. Because the affiliate, rather than the SEC Pictet AM Firms, pays for these services, the SEC Pictet AM Firms receive marketing benefits without bearing the associated costs, which may incentivise continuation or expansion of the arrangement. The conflict of interest is addressed through the following measures:

Media and advertising content is reviewed to ensure compliance with applicable securities laws and advertising rules.

Investment advice is based solely on each client’s objectives, restrictions, risk tolerance and financial circumstances, and is not influenced by media or marketing activity.

Neither the SEC Pictet AM Firms nor their personnel receive compensation tied to referrals, asset gathering or investment recommendations arising from media arrangements.

The SEC Pictet AM Firms clearly distinguish marketing and informational content from personalised investment advice.

A. Criminal and Civil Actions The SEC Pictet AM Firms do not have any material criminal or civil actions to disclose.

B. Administrative Proceedings Before Regulatory Authorities The SEC Pictet AM Firms do not have any material administrative proceedings before regulatory authorities to disclose.

C. Self‑Regulatory Organisation (SRO) Proceedings The SEC Pictet AM Firms do not have any material disciplinary proceedings before any self-regulatory organisation.

D. Overall Assessment of Material Disciplinary Events Based on the information provided for this Item, there are no disciplinary events that are material to a client’s evaluation of the SEC Pictet AM Firms or the integrity of their management personnel.

A. Periodic Reviews Ongoing Supervision of Client Accounts After a client’s onboarding, the primary portfolio manager or the alternate portfolio manager in their absence, assumes responsibility for the daily supervision of the client’s account. This supervision includes verifying that the account complies with all applicable investment restrictions. The Investment Controlling department independently monitors investment restrictions every day. Investment Controlling ensures that corrective actions are completed promptly and that any breaches are reported to the client. Periodic Risk and Performance Reviews Periodic formal reviews of the risk and performance characteristics of all products is conducted. These reviews are performed before a committee that usually includes the following individuals:

the Head of Investment;

the Chief Investment Officer of the team under review;

the Chief Investment Risk & Data Officer;

the Head of the investment team under review and senior portfolio managers;

the Head of the Investment Risk Department; and

the Risk Manager or deputy for the relevant investment team.

The Chief Risk Officer can attend these meetings on an ad hoc basis, particularly for significant strategies.

B. Other-Than-Periodic Reviews In addition to periodic reviews, additional reviews are performed whenever this is appropriate or required. Triggering events include client requests, compliance or guideline monitoring results, industry developments, market events, regulatory or statutory changes and any issues identified within a client account. These matters are directed to the investment professionals and business management responsible for the relevant areas.

C. Client Reports The standard reporting package for segregated clients includes monthly and/or quarterly reports with valuation information, a performance summary, performance attribution and manager commentary describing portfolio activity, performance drivers, market developments and outlook. Valuations are broken down by asset type, currency, geography and sector. Please note valuations are generated by Pictet AM’s investment accounting and portfolio management systems. Therefore, as custodians and the Pictet AM systems use different accounting methods, reporting dates and valuation methodologies, there is a risk that differences in valuations can occur. Alternative reporting formats are also provided when clients have specific reporting requirements. After formal reviews, supplementary information is prepared when appropriate.

None of the SEC Pictet AM Firms have direct custody of client assets. Every US client receives account statements directly from the qualified custodian, such as a broker-dealer, bank or other regulated custodian, that safeguards the client’s assets. https://pictetmy.sharepoint.com/personal/vstrande_pictet_com/_layouts/15/Doc.aspx?sourcedoc=%7B0E3AA51F-93A6-4AD89E56F6B819F606F5%7D&file=Item%2015%20original%20text%20extracted%2020260218.docx&action=default&mobilere direct=true Clients are instructed to review these custodial statements carefully. Clients are also asked to compare the custodian’s official records with the account statements provided by the SEC Pictet AM Firms. Differences in figures can appear due to custodians and the SEC Pictet AM Firms internal reporting systems applying different accounting methods, reporting timelines or valuation methodologies for certain securities.

Discretionary Authority The SEC Pictet AM Firms generally provide portfolio management services on a discretionary basis. Under a discretionary mandate, the SEC Pictet AM Firm has authority to:

determine the securities to be purchased or sold for a client’s account;

the amount of securities to be bought or sold; and

the timing of such transactions,

without obtaining the client’s prior consent for each trade. This authority is exercised within the scope of the client’s investment guidelines and restrictions and in accordance with the client’s stated investment objectives. Before assuming discretionary authority, the relevant SEC Pictet AM Firm and the client enter into a written investment management agreement (or, for pooled vehicles, the applicable governing or offering documents). These documents describe the nature and extent of the SEC Pictet AM Firm’s discretionary powers and the types of investments that may be made. Where required, the client also grants the relevant SEC Pictet AM Firm trading authority to place orders or a power of attorney with the client’s custodian to permit the relevant SEC Pictet AM Firm to implement investment decisions directly in the client’s account.

Client Investment Guidelines and Restrictions Each client is responsible for establishing its investment objectives, risk tolerance, benchmark (if any) and any investment guidelines and restrictions that will govern the management of its account. Institutional clients typically determine their investment constraints in consultation with the relevant SEC Pictet AM Firm. These guidelines and restrictions must be provided in writing (usually in the investment management agreement, investment policy statement or similar document) before the SEC Pictet AM Firm begins managing the account. The SEC Pictet AM Firms are required to manage client accounts in accordance with these investment guidelines and restrictions. Examples of such limitations can include constraints on specific issuers or sectors, concentrations, geographic or currency exposures, use of derivatives or leverage or ESG-related exclusions. If a client modifies its guidelines or restrictions after the mandate has begun, the changes must be agreed in writing and will apply on a forward-looking basis.

Consistent Management of Similar Accounts The SEC Pictet AM Firms seek to manage client accounts that pursue the same investment strategy in a consistent manner. In practice, this means that accounts invested in the same product or strategy are generally managed using the same investment process and model portfolio, subject to client-specific guidelines, restrictions, tax considerations and legal or regulatory constraints. As clients can impose different investment restrictions or have different objectives or operational requirements, accounts invested in the same strategy may not hold identical positions or weightings and their performance may differ over time. The SEC Pictet AM Firms will not implement an investment decision for a particular account if doing so would be inconsistent with that account’s written investment guidelines or restrictions.

Legal and Regulatory Limits on Discretion In addition to client-imposed guidelines and restrictions, the SEC Pictet AM Firms’ discretionary authority is subject to applicable laws, regulations and tax rules in the jurisdictions in which they and the relevant portfolios operate. For both regulated and unregulated funds, as well as for segregated mandates where applicable, these requirements may include, among other things, portfolio diversification standards, investment concentration limits, borrowing or leverage limits, restrictions on investments in affiliated entities and other regulatory constraints on portfolio composition and investment practices.

The SEC Pictet AM Firms monitor compliance with these regulatory limits as part of their overall compliance and investment-risk frameworks and adjust portfolio management as necessary to remain within applicable legal and regulatory requirements, while continuing to manage accounts in line with clients’ stated objectives and guidelines.

A. Authority to Vote Client Securities Proxy-Voting Policies and Procedures The SEC Pictet AM Firms maintain a proxy voting policy based on widely accepted best practice in corporate governance standards including board composition, executive remuneration, risk management and shareholder rights. Where clients delegate proxy voting authority to a SEC Pictet AM Firm, the relevant SEC Pictet AM Firm votes proxies on behalf of such clients in accordance with the policies and procedures described below. The SEC Pictet AM Firms act in the long-term interests of shareholders and do not automatically support the management of companies. The SEC Pictet AM Firms vote against management when this aligns with client interests. The relevant SEC Pictet AM Firm may also depart from its voting policy when company-specific circumstances warrant such action.

Agreements with Clients About Voting Authority In accordance with SEC guidance on proxy voting responsibilities, a client and the relevant SEC Pictet AM Firm, as investment advisor, can agree to limit the exercise of voting authority. These agreements can specify that:

the SEC Pictet AM Firm will not exercise voting authority if doing so imposes costs on the client (for example, restricting securities lending);

the SEC Pictet AM Firm will vote only on selected proposal types defined by client preference (for example, contested elections for directors);

the SEC Pictet AM Firm will not vote on matters where the cost of voting is high or the expected benefit is low; and

votes will not be cast where voting is not reasonably expected to affect the value of the client’s investment.

Furthermore, in considering whether the proxy voting policy and procedures are reasonably designed to ensure compliance with SEC Rule 206(4)-6 and to fulfil fiduciary duties to multiple clients, the SEC Pictet AM Firms also consider whether a uniform voting approach serves the best interests of each individual client.

Circumstances Where the SEC Pictet AM Firms Do Not Vote The SEC Pictet AM Firms are not required to vote every proxy. The SEC Pictet AM Firms refrain from voting when pre-agreed limitations apply or when abstaining better serves the client’s interests including situations where costs exceed benefits. Additional circumstances include:

absence of an executed Power of Attorney;

incomplete voting recommendations;

newly established accounts not yet fully set up; or

legal or operational restrictions on voting certain securities (e.g., embargoed holdings).

Use of Third-Party Proxy Advisors The SEC Pictet AM Firms use the services of third-party proxy-voting service providers whose expertise and global coverage support informed and consistent voting across all relevant company meetings worldwide.

Scope of Voting Activities The SEC Pictet AM Firms apply the following principles to determine the scope of proxy-voting activities:

For actively managed funds, the SEC Pictet AM Firms aim to vote on 100 percent of equity holdings.

For passive strategies, the SEC Pictet AM Firms aim to vote on companies representing 80 percent of the relevant benchmark weight, subject to upward or downward adjustments depending on strategy characteristics (such as portfolio size, geography or market capitalization).

For segregated accounts, including mandates and third-party (i.e. sub-advisory) mutual funds managed by Pictet AM, clients delegating voting authority can apply the SEC Pictet AM Firms’ proxy voting policy or adopt their own.

Conflicts of Interest Conflicts of interest related to proxy voting are identified within the SEC Pictet AM Firms’ policies, procedures and systems. The SEC Pictet AM Firms may face a conflict of interest if voting rights are exercised in a way that is influenced by client relationships, employee affiliations or personal investments rather than acting in clients’ best interests. Such conflicts are mitigated by requiring personnel to disclose and seek prior approval for outside business interests and investment professionals are prohibited from holding securities in funds they manage, with annual attestations required. In addition, there are communication barriers in place to prevent information sharing in relation to proxy voting. These controls undergo regular review to support effective oversight.

Availability of Proxy-Voting Records The SEC Pictet AM Firms publish complete proxy voting records on their website as part of their responsible investment policy. Clients may request portfolio-level proxy voting information for open-ended funds and segregated accounts. Clients may also obtain a copy of the SEC Pictet AM Firms’ proxy voting policies and procedures upon request.

B. Clients Retaining Voting Authority When a client elects not to delegate proxy voting authority to the relevant SEC Pictet AM Firm, the client (or the client’s designated representative) retains exclusive responsibility for voting. In such cases, proxies and voting materials are sent directly to the client by custodians or transfer agents. The SEC Pictet AM Firms do not provide voting recommendations to such clients and do not share intended votes for any accounts where they hold proxy voting authority.

The SEC Pictet AM Firms do not have any financial condition that impairs their ability to meet their contractual or fiduciary commitments to clients. The SEC Pictet AM Firms have not been the subject of bankruptcy proceedings. The SEC Pictet AM Firms do not require or solicit the prepayment of advisory fees. For these reasons, Item 18 is not applicable.

PRIVACY NOTICE The SEC Pictet AM Firms’ Group privacy notice has not been amended since August 2023, please click here to view the privacy notice.