PRINCIPAL GLOBAL INVESTORS

Introduction Principal AM is a diversified global asset management organization providing an expanded range of diverse investment capabilities through a network of specialized investment teams and affiliates. Capabilities span all major asset classes across both public and private markets including equities, fixed income, asset allocation, and real estate, and private markets. Principal AM is an indirect wholly owned subsidiary of Principal Financial Group, Inc. (NASDAQ: PFG).

Principal AM’s Services Principal AM provides investment advisory services to institutional investors and individuals on a discretionary or non-discretionary basis. Principal AM has divided its investment management operations into several distinct investment teams across equities, fixed income, asset allocation, real estate, and private markets. Principal AM also serves as an investment adviser for Principal Funds, Inc., Principal Variable Contracts, Inc., Principal Exchange Traded Funds and, the Scholars Edge 529 plan. Principal AM also provides fund administration services for Principal Funds, Inc. and Principal Variable Contracts, Inc. Principal AM may hire affiliated or non-affiliated investment advisers to provide discretionary investment advisory services in a sub-advisory capacity. For example, Principal AM serves as a “manager of managers” on behalf of certain Principal Funds. In its capacity as a manager of managers, Principal AM recommends the hiring and firing of sub-advisory firms and provides ongoing oversight of such sub-advisory firms in connection with the services provided to the Principal Funds. Principal AM also provides additional investment services to clients as described more fully in the Investment Solutions section in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. Principal AM generally provides continuous and regular investment advice based on the defined investment strategies, objectives, and policies of its clients. These arrangements are documented through an investment management agreement, investment policy statement, or investment guidelines, which incorporate investment management restrictions and guidelines developed in consultation with each client, as well as any additional services required by the client. These restrictions and guidelines customarily impose limitations on the types of securities that may be purchased and the percentage of account assets that may be invested in certain types of securities. Clients may also choose to restrict investment in specific securities or groups of securities for social, environmental, or other reasons. Principal AM also provides certain non-discretionary services to clients such as model portfolios. Prospective clients or investors may also access our services indirectly by purchasing interests in Principal Funds or other commingled vehicles advised or sub-advised by Principal AM or an affiliate rather than establishing a direct relationship through an investment management agreement. Commingled funds managed by Principal AM include collective investment trusts, exchange4

traded funds (“ETFs”), open-end or closed-end investment companies (including Interval Funds), and privately offered funds (“Private Funds”) not registered under the Investment Company Act of 1940 as amended, (the “1940 Act”). Clients or investors should consider the features of these options and their own specific needs and circumstances when determining the most suitable investment and should carefully review the offering documents of these investment vehicles to understand the investment objectives, strategies, and risks of each vehicle. Prospective clients or investors may also purchase our services indirectly by purchasing investment management or discretionary trustee services from Principal Trust Company or Principal Bank, rather than establishing a direct relationship through an investment management agreement. For our mutual funds and other commingled vehicles, investment advice is provided directly to the fund or commingled vehicle, subject to the discretion and control of the funds’ general partners (or analogous party), and not to the underlying investors in the fund based upon their individual needs. Fund investors may have conflicting investments, taxes, and other interests with respect to their investments in the fund. As a consequence, conflicts of interest may arise in connection with decisions made by Principal AM that may be more beneficial for one investor than for another investor, especially with respect to investors’ individual tax situations. In selecting and structuring investments appropriate for a Private Fund, Principal AM and the Private Fund’s general partner (or analogous party) will consider the investment and tax objectives of the applicable Private Fund, not the investment, tax, or other objectives of any investor individually. Principal AM will, from time to time, enter into side letter arrangements with certain investors (e.g., Private Funds, commingled funds, etc.). Side letters provide such investors with different or preferential rights or terms. Such differences and preferences may include but are not limited to, different fund fee structures, and other preferential economic rights, information rights, waiver of certain confidentiality obligations, co-investment rights, redemption, certain rights or terms necessary in light of particular legal, regulatory or policy requirements of a particular investor, additional obligations and restrictions with respect to structuring particular investments in light of the legal and regulatory considerations applicable to a particular investor, or preferential liquidity or transfer rights to the extent other investors are not disadvantaged and these are allowable per regulation. Except as otherwise agreed with an investor or otherwise set out in the fund’s organization documents, Principal AM and its affiliates are not required to disclose the terms of side letter arrangements with other investors in the same fund. The organizational documents of a Private Fund establish complex arrangements among the funds, Principal AM, investors, and other relevant parties. From time to time, questions may arise regarding certain parties’ rights and obligations in certain situations, some of which may not have been contemplated upon the negotiation and execution of such documents. In some instances, the operative provisions of the organizational documents, if any, may be broad, silent on relevant provisions, conflicting, ambiguous, and vague and may allow for multiple reasonable interpretations. While Principal AM will construe the relevant provisions in good faith and in a manner consistent with its fiduciary duty to the fund and legal obligations, the interpretations used may not be the most favorable to Private Fund investors.

Services required by Principal AM’s Private Funds may, for certain reasons including efficiency and economic considerations, be outsourced in whole or in part to third parties, in each case at the discretion of Principal AM or their general partners (or analogous parties). Principal AM and its affiliates have an incentive to outsource such services at the expense of the Private Funds to, among other things, leverage the use of Principal AM’s personnel. Such services may include, without limitation, investor reporting, Private Fund administration and accounting, custodial, valuation, and legal. Outsourcing may not occur universally for all Private Funds and, accordingly, certain costs may be incurred by one Private Fund for a third-party service provider that is not incurred for comparable services by other Private Funds.

Separately Managed Accounts (“SMA”)/Wrap Programs Principal AM provides investment advisory services to a variety of managed account programs, including separately managed accounts or wrap fee programs, unified managed account programs, and model portfolio programs (collectively, “Managed Accounts”). There are several different types of Managed Account programs offered by third-party brokerdealers, banks, or other investment advisers affiliated with broker-dealers (“Program Sponsors”). In discretionary Managed Account programs, Principal AM is responsible for implementing its investment recommendations. Principal AM may handle the placement of trades for certain accounts with brokers other than the Program Sponsor or its affiliate(s) (e.g., through “step outs”), but typically the majority of trades will be directed to the Program Sponsor or its affiliate(s) for execution. In “Model-Delivery” Managed Account programs, Principal AM is retained by the Program Sponsor to provide non-discretionary research and portfolio recommendations that are not tailored to any program participant. The Program Sponsor has discretion to accept, modify, or reject Principal AM’s recommendations and assumes the responsibility to implement transactions for Managed Accounts. Principal AM generally does not have information regarding participants in Model-Delivery Managed Accounts. Generally, for Managed Accounts comprised of Employee Retirement Income Security Act of 1974 (“ERISA”) plan clients, Principal AM’s services are ordinarily described in the ERISA plan client’s contract with the Program Sponsor and/or in the Program Sponsor’s program brochure.

Asset Allocation Service Principal AM provides asset allocation advice and other investment advisory services to qualified retirement plans funded with annuity contracts purchased from Principal Life Insurance Company (“Principal Life”). These specific clients are contract holders of group variable annuity contracts issued by Principal Life. The clients, as annuity contract holders, have an option to invest in various separate accounts established by Principal Life. Principal AM acts as sub-adviser to Principal Trust Company and Principal Bank, providing asset allocation advice and other investment advisory services to institutional investors.

Services Provided to Non-U.S. Clients Principal AM may also act as an investment adviser and may conduct marketing activity with respect to clients and prospective clients domiciled in foreign jurisdictions. In some instances, Principal AM may do so without maintaining regulatory licenses or registrations in those jurisdictions, to the extent permitted by applicable law.

Clients and prospective clients in such jurisdictions should consider whether the regulatory framework of their own jurisdiction imposes restrictions upon them regarding hiring an investment adviser that does not hold local regulatory licenses or registrations. Clients and prospective clients should also consider whether the regulatory framework to which Principal AM is subject provides sufficient protection given that Principal AM may not be subject to the regulatory framework with which they are familiar in their own jurisdiction.

Global Asset Management Principal AM may utilize services from, and provide services to, our United States (U.S.). affiliates and non-U.S. affiliates. These services may include investment advisory services, client relations, investment monitoring, accounting administration, investment research, and trading. To facilitate this collaboration, Principal AM has entered into sub-advisory agreements, intercompany agreements, and “participating affiliate” arrangements with certain non-U.S. affiliates. Each U.S. affiliate is registered with the U.S. Securities and Exchange Commission (“SEC”), and each nonU.S. affiliate is registered with the appropriate respective regulators in their home jurisdictions. Under participating affiliate arrangements, certain employees of Principal AM’s non-U.S. affiliates serve as “associated persons” of Principal AM when providing certain of these services, including placing orders for clients, and in this capacity are subject to Principal AM’s oversight and supervision.

Assets Under Management Principal AM managed $419,245,584,914 in discretionary assets and $8,467,136,715 in nondiscretionary assets as of December 31, 2025.

Principal AM’s fees generally depend on the services being provided. Principal AM offers its services for compensation based primarily on a percentage of assets under management or on a fixed fee basis. Principal AM may negotiate and charge different fees for different accounts. For example, Principal AM may consider a variety of factors when offering discounted fee schedules to certain clients, including but not limited to the totality of the client’s (and/or their affiliates’) relationship with Principal AM or its affiliates, the number of accounts managed, the size or asset level of the account(s), the nature of services rendered, the country of domicile, and any special requirements of the account(s) managed. For clients with whom Principal AM has agreed to provide the lowest fee rate charged to any other similarly situated client, all these factors, including the totality of Principal AM’s relationship with a client and/or its affiliates, may be taken into consideration in determining whether a client is similarly situated to another. Principal AM may also consider the impact such arrangements could have on agreements that have previously been entered into with other clients. In addition, fees and allocations are often fixed, fixed plus performance, or performance only. Certain fixed fees are required to be paid up front. For an additional discussion of performancebased fees and allocations, please refer to Item 6 (“Performance-Based Compensation and Sideby-Side Management”) of this Brochure. When deciding whether to negotiate a particular fee, Principal AM may also consider its capacity to manage assets in a particular strategy. In addition, Principal AM may offer or make available to certain clients a specified asset level or capacity maximum that Principal AM will allow them to

invest in a given strategy. The amount of capacity offered may impact fee negotiations. The negotiation of fees may result in similarly situated clients paying different fees for comparable advisory services. Clients may invest in a variety of U.S. and non-U.S. commingled vehicles, including private commingled vehicles. Information regarding advisory fees charged by Principal AM and other expenses payable by investors is set forth in the offering documents for the applicable commingled vehicle.

Fees for Institutional Clients Accounts Equities Fee Schedules: Principal AM’s standard annual fees for investment management services are based on the fair market value of assets under management as outlined in the table below. Published fee schedules shown reflect unaffiliated client portfolios which are individually managed (segregated and discretionary) and subject to the stated minimum accounts sizes. Fees and minimum investment amounts in all categories and ranges can be subject to negotiation as appropriate and may be higher or lower than those described below. International Equity International Equity Diversified International Equity

Fee Schedule 0.60% on the first $50 million 0.55% on the next $50 million 0.50% thereafter Minimum Account Size: $50 million

International Developed Equity

0.55% on the first $50 million 0.50% on the next $50 million 0.45% thereafter Minimum Account Size: $25 million

Global Emerging Markets Equity Emerging Markets Ex-China

0.75% on the first $50 million 0.70% on the next $50 million 0.60% thereafter Minimum Account Size: $50 million

Asia Pacific ex Japan Equity Asia Ex Japan Equity

0.65% on the first $50 million 0.60% on the next $50 million 0.50% thereafter Minimum Account Size: $25 million

European Equity

0.50% on the first $50 million 0.40% on the next $50 million 0.30% thereafter Minimum Account Size: $25 million

European Responsible Equity

0.55% on the first $50 million 0.50% on the next $50 million 0.45% thereafter

International Small Cap Equity

0.80% on the first $50 million 0.75% on the next $50 million 0.70% thereafter Minimum Account Size: $25 million

Global Equity Global Opportunities Equity Global Sustainable Equity

0.55% on the first $50 million 0.50% on the next $50 million 0.45% thereafter Minimum Account Size: $25 million

Principal Equities U.S. Small Cap Equity U.S. Small Cap Select Equity U.S. Small Cap Select Value Equity U.S. SMID Equity

Fee Schedule 0.60% on the first $50 million 0.55% on the next $50 million 0.45% thereafter Minimum Account Size: $10 million

Capital Appreciation U.S. Core Equity Income Equity Income Concentrated Capital Appreciation

0.50% on the first $50 million 0.45% on the next $50 million 0.40% on the next $100 million Negotiable on all thereafter Minimum Account Size: $25 million

Concentrated Mid Cap

0.60% on the first $50 million 0.55% on the next $50 million 0.50% on the next $100 million Negotiable on all thereafter Minimum Account Size: $25 million

SMID Equity Income

0.70% on the first $50 million 0.65% on the next $50 million 0.60% on the next $100 million Negotiable on all thereafter Minimum Account Size: $25 million

Mid-Cap Growth

0.75% on the first $100 million 0.50% above $100 million

SMID Growth

0.85% on the first $50 million 0.75% above $50 million

Small-Cap Growth

0.85% on the first $50 million 0.75% above $50 million

Principal Aligned Blue Chip Equity Mid Cap Equity Mid Cap Constrained

Fee Schedule 0.60% on the first $50 million 0.55% on the next $50 million 0.45% thereafter Minimum Account Size: $25 million

Focused Blue Chip Equity

0.70% on the first $50 million 0.65% on the next $50 million 0.55% thereafter Minimum Account Size: $25 million

Public Infrastructure Equity Global Listed Infrastructure Securities

Fee Schedule 0.75% on the first $25 mm 0.65% on the next $25 mm 0.60% on all thereafter Minimum account size: $25 mm

Fixed Income Fee Schedules: Principal AM’s standard annual fees for investment management services are based on the fair market value (unless book value is specified in the negotiated contract) of assets under management as outlined in the tables below. Published fee schedules are shown for unaffiliated client portfolios which are individually managed (segregated and discretionary) and subject to the stated minimum accounts sizes. Fees and minimum investment amounts in all categories and ranges can be subject to negotiation as appropriate and higher or lower than those described below. Multi-Sector Fixed Income Aggregate Passive

Fee Schedule 0.08% on the first $250 million 0.06% on the next $250 million 0.04% on all thereafter Minimum Account Size: $50 million

Short Term Income

0.20% on the first $150 million 0.15% on the next $150 million 0.10% thereafter Minimum Account Size: $50 million

Core Fixed Income Core Plus - Intermediate

0.25% on the first $50 million 0.20% on the next $50 million 0.15% thereafter Minimum Account Size: $50 million

Core Plus Bond

0.30% on the first $100 million 0.25% on the next $100 million 0.20% thereafter Minimum Account Size: $50 million

U.S. Multi-Sector Fixed Income

0.45% on the first $50 million 0.40% on the next $100 million 0.35% thereafter Minimum Account Sized: $50 million

Multi-Sector Credit

0.50% on the first $100 million 0.45% on the next $100 million 0.40% thereafter Minimum Account Size: $50 million

Global Fixed Income

0.35% on the first $50 million 0.30% on the next $50 million 0.25% on the next $50 million 0.20% thereafter Minimum Account Size: $50 million

Global Multi-Sector Fixed Income

0.45% on the first $50 million 0.40% on the next $100 million 0.35% thereafter Minimum Account Sized: $50 million

Investment Grade Investment Grade Corporate Long Duration Credit

Fee Schedule 0.30% on the first $100 million 0.25% on the next $100 million 0.20% thereafter Minimum Account Size: $50 million

High Yield/Bank Loans Short Duration High Yield High Yield High Yield Opportunistic Global High Yield Bank Loans

Fee Schedule 0.50% on the first $50 million 0.45% on the next $50 million 0.40% thereafter Minimum Account Size: $50 million

Asia Fixed Income Asia Credit Strategy

Fee Schedule 0.40% on the first $50 million 0.35% on the next $50 million 0.30% thereafter Minimum Account Size: $50 million

Asia Investment Grade Credit

0.35% on the first $100 million 0.30% on the next $100 million 0.25% thereafter Minimum Account Size: $50 million

Emerging Market Debt Finisterre Emerging Market Debt

Fee Schedule 0.22% on the first $50 million 0.20% on the next $50 million 0.16% thereafter Minimum Account Size: $50 million

Securitized Debt / Cash Mortgage-Backed Securities

Fee Schedule 0.22% on the first $50 million 0.20% on the next $50 million 0.16% thereafter Minimum Account Size: $50 million

Government & High-Quality Fixed Income

0.25% on the first $100 million 0.20% on the next $100 million 0.15% on the next $100 million Negotiable on all thereafter Minimum Account Size: $50 million

Balanced CMBS Yield Oriented

0.35% on the first $50 million 0.25% on the next $50 million 0.20% thereafter

CMBS Opportunistic Value

0.55% on the first $50 million 0.50% on the next $50 million 0.40% thereafter Minimum Account Size: $50 million

High Yield CMBS Yield Oriented Return

0.40% on the first $50 million 0.30% on the next $50 million 0.25% thereafter Minimum Account Size: $50 million

CMBS Total Return Investment Grade CMBS Yield Oriented

0.30% on the first $50 million 0.25% on the next $50 million 0.20% thereafter Minimum Account Size: $50 million

Money Market

0.12% on the first $100 million 0.11% on the next $100 million 0.10% thereafter Minimum Account Size: $50 million

Ultra Short High Quality

0.15% on the first $100 million 0.13% on the next $100 million 0.10% thereafter Minimum Account Size: $50 million

Municipal Opportunistic Municipal Taxable Municipal Long Fixed Income

Fee Schedule 0.30% on the first $50 million 0.25% on the next $50 million 0.20% thereafter Minimum Account Size: $50 million

Municipal California Fixed Income

0.25% on the first $100 million 0.20% on the next $100 million 0.15% thereafter Minimum Account Size: $50 million

National Municipal

0.28% on the first $100 million 0.20% on the next $100 million 0.15% thereafter Minimum Account Size: $50 million

Stable Value Morley Stable Value Account

Fee Schedule 0.15% on the first $100 million 0.12% on the next $100 million Minimum Account Size: $50 million

Principal Alternative Credit Private Investment Grade Credit

Fee Schedule 0.25% on the first $100 million 0.20% on the next $100 million 0.15% thereafter Minimum Account Size: $50 million

Lower and Core Middle Market Direct Lending

Base Management Fee: 1% Performance Fee: 15% with a 6% hurdle Minimum Accounts Size: $50 million

Fees for Private Funds The fees for a private fund (“Private Fund”) are called out more fully in its offering documents and may be negotiable based on the agreements between an underlying Private Fund investor and Principal AM. Typically, Principal AM Private Fund investments have annual investment management fees up to 1.5% (calculated either as a percentage of the investor’s account value or as percentage of their invested capital in the Private Fund) which typically decline based on the amount of assets invested. In addition, Private Funds incur organizational and start-up expenses, general partner/management expenses, and expenses, fees and costs connected with a Private Fund’s operations. The Private Funds incur these fees and expenses in addition to the investment advisory fees charged by Principal AM. The fees and expenses are paid by the Private Fund and can be substantial. Investors in the Private Funds indirectly bear these expenses as these are paid out of the profits of the Private Fund. Fees from Private Funds deducted from fund assets may reduce investor returns. Principal AM and the General Partners/Managers of the Private Funds generally have complete control and discretion over the organizational and start-up expenses, general partner and management expenses, and expenses, fees and costs connected with the Private Funds they sponsor and organize, as well as their payment. Private Fund organizational and start-up expenses, general partner/management expenses, and expenses, fees and costs connected with the Private Fund’s operations vary widely across the Private Funds sponsored and organized by Principal AM. Some of the more common types of organizational and start-up expenses include legal, accounting, tax, regulatory filing and compliance, initial capital raising, printing, and other similar fees, costs, and expenses connected to the Private Fund’s formation and launch of operations. Some of the more common general partner and management company expenses include expenses for ongoing legal, accounting, tax advice, compliance, anti-money laundering, and administration services, including expenses associated with the preparation of the General Partner’s financial statements and tax returns; placement agent fees and expenses; costs and expenses of any Fund advisory board (including travel and all other out-of-pocket costs incurred in connection with any advisory board meetings); fees, costs, and expenses incurred in connection with distributions to the Private Fund investors; and in respect of reporting to and communicating to the Private Fund’s investors.

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Risk of Loss

Investing in securities involves risk of loss that clients should be prepared to bear. Each of the investment strategies listed below is subject to certain risks. There is no guarantee that any investment strategy will meet its investment objective.

Equities Principal AM has various equity teams offering a number of actively managed and systematic strategies, all utilizing equity securities to help meet its clients’ investment objectives and goals. Principal AM is generally a long-only manager. The vast majority of the portfolios are discretionary. Please refer below to “Item 16 – Investment Discretion” regarding discretion over client accounts. Equity teams provide client-focused investment solutions spanning equity markets worldwide. This process generally utilizes internally generated fundamental research that focuses on bottom-up stock selection within a sophisticated comparative framework. The entire scope of research encompasses companies, large and small, in emerging and developed markets, although the universe of companies relevant to any single investment strategy will typically be smaller. The use of technical methods of analysis can also be used within the research. The proprietary systems include some data sourced from outside investment research specialists. Principal AM maintains a global equity research platform in which teams of investment analysts—organized by region, sector, and thematic expertise—support multiple investment teams and portfolio managers across the Firm. These analysts operate within a shared resource model, meaning their research, insights, and company coverage may be utilized by more than one portfolio management team. While individual investment strategies may rely on specific subsets of the global research platform, the shared analyst structure enhances idea generation, facilitates consistency of research views, and allows for efficient coverage of global markets. Portfolio managers retain full discretion over how analyst research is incorporated into security selection for their respective strategies. Research teams reference many sources when analyzing a company, including but not

limited to investment publications on general economic conditions, financial publications from the investment banking industry, corporate annual reports and regulatory filings, and meetings with senior management of companies whose stocks in which the specialized investment teams have invested or are considering for investment when deemed appropriate or as necessary, in the teams’ judgment. The types of equity securities typically utilized for these strategies include common stock (exchange traded, over the counter and initial or follow-on offerings) issued by U.S. and non-U.S. corporations or other issuers. The specialized investment teams can utilize different instruments, at their preference, to fulfill their selection including but not limited to: (1) American Depositary Receipts and Global Depositary Receipts, if liquidity is suitable; (2) open-end funds and ETFs for cash equitization purposes and to gain exposure to certain markets; (3) closed-end funds, participation notes, private placement securities and rights and warrants on equity securities (although rare); and (4) forward currency contracts to hedge the exposure of foreign currency fluctuations in the equity portfolios. Principal AM’s philosophy is that equity markets are not perfectly efficient and therefore provide opportunities to add value through fundamental research and active risk management. Our strategies are built on the belief that bottom-up stock selection is the most reliable and repeatable source of consistent competitive performance over time. To that end, the lead portfolio manager for each strategy collaborates directly with the investment analysts regarding the output of their analysis and is ultimately responsible for security selection and for the individual weighting of each portfolio holding. Risk management is embedded in the investment processes of each distinct investment team. The portfolio managers have a number of risk management systems/tools at their disposal, each serving a different purpose within the portfolio construction process. These systems monitor risk and guidelines (in terms of region, country, currency, sector, industry, market capitalization distribution, style factor distribution, beta sensitivity and individual position weights) in each client’s portfolio. Generally, the portfolio management teams monitor portfolio risk exposures through a series of weighting constraints relative to each portfolio’s benchmark and each portfolio’s overall characteristics and individual security holdings. Furthermore, the risk management tools allow Senior Management of the specialized investment teams to view portfolio positioning for their respective strategies at any time. The Chief Investment Officers for equity are charged with supporting risk management efforts that quantify the portfolio managers’ success in achieving risk and return objectives for the accounts they manage. Prospective clients should be aware that no risk management system is fail-safe, and no assurance can be given that risk frameworks employed by the specialized investment teams will achieve their objectives and prevent or otherwise limit substantial losses. There is also the risk that the investment approach taken will be out of favor at times, causing strategies to underperform other strategies or funds that also seek capital appreciation but use different approaches to the stock selection and portfolio construction process. A further discussion of the risks inherent in our equity strategies is provided below. Principal AM offers a broad range of global and regional equity strategies across developed and emerging markets, specified market segments and style preferences, which include, but are not limited to:

International Equity Strategies

Diversified International Equity, International Equity These strategies offer a broad exposure to equity investment opportunities outside the U.S. They are active core strategies including moderate strategic allocations to emerging markets.

International Developed Equity These strategies can provide broad exposure to selected equity investment opportunities in developed markets outside of the U.S. utilizing a disciplined active approach.

International Small Cap These strategies provide diversified exposure among selected smaller capitalization companies in developed regions outside the U.S. utilizing a disciplined active core approach.

European Equity These strategies offer a broad exposure to European equity investment opportunities (inclusive of the United Kingdom, and excluding European emerging markets), utilizing a disciplined active core approach.

Emerging Markets Equity Strategy Global Emerging Markets Equity, Emerging Markets Ex-China These strategies can provide diversified exposure among companies within growing segments of the economy in emerging markets countries and focus on delivering growth without excessive valuation premiums.

Global Equity Strategies Global Equity, Global Opportunities Equity, Global Responsible Equity These strategies invest in companies domiciled in the United States, developed international and emerging market countries, with broad latitude to focus on our highest conviction investment opportunities across the world. The “Responsible” designated strategy also incorporates certain specific industry exclusions and carbon related ESG enhanced features.

Domestic Equity Strategies U.S. Small Cap, U.S. Small Cap Select, U.S. SMID The objectives of these strategies are to provide a diversified exposure among selected smaller capitalization U.S. companies. The U.S. Small Cap, U.S. Small Cap Select, and U.S. SMID strategies are core offerings while the U.S. Small Cap Select Value strategy has value- oriented characteristics.

Small Cap Growth, SMID Cap Growth, and Mid Cap Growth The growth strategies focus primarily on stocks within the market capitalization ranges of the Russell Mid Cap Growth Index, Russell 2500 Growth Index and Russell 2000 Growth Index, respectively. The strategies focus on leading indicators of fundamental business improvement and investor expectations. Each strategy seeks long-term growth of capital.

Mid Cap, Blue Chip, Focused Equity The Mid Cap, Blue Chip, and Focused Equity strategies are designed for investors seeking equity investment opportunities irrespective of benchmark orientation. The strategy focuses primarily on long-term ownership of high-quality businesses with sustainable competitive advantages, owner-operator management, and discounted valuations.

Capital Appreciation The Capital Appreciation strategy seeks long-term growth of capital by investing in common stocks of companies across the capitalization spectrum.

Equity Income The Equity Income strategy seeks a relatively high level of current income and long-term growth of income and capital by investing primarily in the common stocks of U.S. large- cap companies.

SMID Equity Income The objective of the SMID Equity Income strategy is to seek a relatively high level of current income and long-term growth of income and capital by investing primarily in common stocks of small and mid-cap U.S. companies.

Passive & Systematic Equity Strategies In addition to actively managed strategies, Principal AM also manages passive index replication strategies, as well as various quantitatively managed systematic and “smart beta” strategies. Fee schedules for these strategies are available upon request.

Infrastructure Equity Securities Principal AM offers an actively managed global listed infrastructure securities strategy to help meet its clients’ investment objectives, needs, and goals. Please refer to Item 16 regarding discretion over the clients’ accounts. The types of equity securities that can be utilized for this strategy or any related listed infrastructure strategies include common stock (exchange traded, over the counter, and initial public offerings) issued by U.S. and foreign corporations, issuers defined as a listed infrastructure company, or real estate investment trusts. Principal AM can also invest client assets in the following securities, subject to client guidelines: preferred securities, American Depositary Receipts, Global Depositary Receipts, Exchange Traded Funds (“ETFs”), participation notes, private placement securities, and rights and warrants on equity securities.

Forward currency contracts could be used to hedge the exposure to foreign currency fluctuations in the equity portfolios.

Global Listed Infrastructure Strategy The Global Listed Infrastructure Securities strategy is designed to provide investors with access to the infrastructure asset class by investing in listed securities issued by companies engaged in the infrastructure industry around the world. The strategy’s investment objective is to provide excess total returns relative to an index.

Philosophy and Risk Management Principal AM’s philosophy is that equity markets are not perfectly efficient and therefore provide opportunities to add value through fundamental research and active risk management. Principal AM’s strategies are built on the belief that bottom-up stock selection is designed to be a reliable and repeatable source of consistent competitive performance over time. The portfolio management team believes mispricing occurs in listed infrastructure markets, often as a result of the mismatch between the shorter-term focus of the market and the long duration of infrastructure assets and investment cycles. The team also believes seeking to avoid the big losers is more important than identifying big winners. To that end, the portfolio management team collaborates directly with analysts regarding the output of their analysis and is ultimately responsible for security selection and for the individual weighting of each portfolio holding. Risk management is embedded in the investment process. Principal AM’s portfolio managers have a number of risk management systems/tools at their disposal, each designed to serve a different purpose within the portfolio construction process. Generally, the portfolio management teams monitor portfolio risk exposures through a series of weighting constraints relative to each portfolio’s benchmark, each portfolio’s overall characteristics, and individual security holdings. Prospective clients should be aware that no risk management system is fail-safe, and no assurance can be given that risk frameworks employed by Principal AM and the portfolio managers will achieve their objectives and prevent or otherwise limit substantial losses. There is the risk that Principal AM’s investment approach could be out of favor at times, causing strategies to underperform other strategies or funds that also seek capital appreciation but use different approaches to the stock selection and portfolio construction process.

Risks associated with investing in Infrastructure Securities All Principal AM’s infrastructure equity securities strategies entail market risk, liquidity risk, and operational risk. Past performance does not necessarily predict future returns. Clients are subject to the risk that stock prices will fall over short or extended periods of time, and clients could lose all, or a substantial portion, of the value of their investments. Historically, the equity markets have moved in cycles, and the value of equity securities can fluctuate significantly from day to day. Individual companies could report poor results or be negatively affected by industry and/or economic trends and developments. The prices of these companies’ securities could decline in response. These factors contribute to price volatility, which is a principal risk of equity investing. These strategies utilize, to a significant extent, securities issued by listed infrastructure

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Principal AM provides portfolio management services to individuals, high net worth individuals, corporate pension and profit–sharing plans, Taft-Hartley plans, charitable institutions, foundations, endowments, municipalities, registered mutual funds, private investment funds, ETFs, trusts, sovereign wealth funds, foreign funds, supranational, central banks, collective investment trusts, wrap programs, insurance separate accounts, life insurance company general accounts, fund of funds, 529 plans, real estate, listed infrastructure, interval funds and other U.S. and international institutions. Some of Principal AM’s clients are affiliates. Principal AM is a subadviser to Principal Trust Company and Principal Bank providing asset allocation advice and other investment advisory services to institutional investors. Principal AM provides investment advisory services both directly to clients and as a sub‑adviser to investment products (e.g., ETF, CIT, model portfolios) sponsored or advised by other registered investment advisers or financial institutions. Principal AM also provides asset allocation and other investment advisory services to qualified retirement plans funded with group annuity contracts purchased from Principal Life.

Generally, the minimum account size for opening and maintaining an individually managed equity portfolio/account is $10-50 million and is based on the type of strategy used for the client’s portfolio. Generally, the minimum account size for opening and maintaining an individually managed fixed income portfolio/account is $25-50 million and is based on the type of strategy used for the client’s portfolio. Principal AM reserves the right in its sole discretion to accept client accounts with fewer initial assets. The minimum account size for all Separately Managed Accounts in which Principal AM participates is generally $100,000. Although investment minimums differ from program to program and are determined by the Program Sponsor, Principal AM may elect to waive or negotiate other minimum account sizes.

Management Performance fee arrangements create an incentive for Principal AM to recommend or select investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. This creates potential conflicts of interest, which Principal AM seeks to address through policies and procedures. Such fee arrangements also create an incentive for Principal AM to favor client accounts that pay performance-based fees over other accounts in the allocation of investment opportunities, and to aggregate or sequence trades in favor of such accounts. Principal AM believes it has procedures reasonably designed and implemented to treat clients fairly and equitably, and to prevent this conflict from influencing the allocation of investment opportunities among clients. Certain Principal AM accounts are charged performance fees in accordance with the conditions and requirements of Rule 205-3 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Any such performance fees will be negotiated on an individual basis with the client. Principal AM is willing to consider incentive fees in appropriate circumstances. In measuring client assets for the calculation of performance-based fees, realized and unrealized capital gains and losses are included depending upon contractual provisions. Principal AM manages investments for a variety of clients including pension funds, retirement plans, mutual funds, ETFs, large institutional clients, 529 plans, real estate, listed infrastructure, interval funds, Managed Accounts, and Private Funds. Potential conflicts of interest can arise from the side-by-side management of these clients based on different fee structures. Principal AM seeks to mitigate these conflicts by managing accounts in accordance with applicable laws and its policies and procedures, which are designed to ensure all clients are treated fairly, and to prevent any client or group of clients from being systematically favored or disadvantaged in the allocation of investment opportunities. Principal AM’s policies and procedures regarding allocation of investment opportunities and trade executions are described below in “Item 12 - Brokerage Practices.”

Fee and Cost Allocation

Principal AM provides investment services to multiple clients who can have substantial overlap in investment strategies and who may compete for potentially limited investment opportunities. The Firm offers investment opportunities to each client in accordance with the applicable provisions of each client’s constituent documents including allocation into investment vehicles by the Firm and its affiliates. Principal AM may form employee alignment vehicles to enable certain investment professionals and other employees of Principal AM and its affiliates to participate in the Private Fund. Principal AM may waive carried interest, management fees, and financing fees for any such employees investing directly or indirectly into a Private Fund. Co-investments can be offered by Principal AM or its affiliates in their discretion to the extent that: (i) the size of an investment opportunity exceeds the aggregate desired allocation to the Client(s) for which the opportunity would be appropriate; and/or (ii) there is adequate interest from prospective Investors, including co-investors. Co-investments can be structured through investment vehicles or similar arrangements organized to facilitate such investments for legal, tax, regulatory, or other purposes (each, a “Co-Investment Vehicle”). A Co-investment Vehicle could include an entity that invests side-by-side with a Private Fund Client or into which a Private Fund Client invests together with other co-investors, each entity and/or co-investor which could be managed by, or otherwise affiliated with, Principal AM or its affiliates. Certain investors may receive different and/or more favorable terms when compared to such Private Fund Client, and could have interests or requirements that conflict with, and adversely impact, such Private Fund Client. Principal AM will generally seek to cause such Private Fund Client, and other Principal AM related investors, to participate in any investments and any related transaction on comparable economic terms vis-a-vis the underlying opportunity to the extent Principal AM deems appropriate, subject to legal, tax, regulatory, and other similar considerations. Such comparable participation is not necessarily appropriate in all circumstances. The Private Fund Client could participate in such investment on different and potentially less favorable economic and/or non-economic terms than such parties (or that the Private Fund Client would participate in, if such parties were not co-investors) if Principal AM deems such participation as being otherwise in the Private Fund Client’s best interests.

Affiliations Principal AM provides global investment solutions to institutional, retirement, retail and high net worth investors in the U.S. and select emerging markets. Principal AM is organized into Investment Management, which provides public, multi-asset and private market capabilities across all asset classes, including equity, fixed income, real estate and alternatives, to serve a breadth of client investment objectives; and International Pension, which provides long-term savings and retirement solutions through pension accumulation and income annuities in Asia and Latin America.

Affiliated Entities Principal AM utilizes personnel or other resources or services of its non-U.S. affiliates, Principal Global Investors (Europe) Ltd., Principal Global Investors (EU) Ltd., Principal Global Investors (Singapore) Ltd., Principal Global Investors (Australia) Ltd., Principal Global Investors (Ireland) Ltd., Principal Global Investors (Switzerland) Ltd., Principal Asset Management Company (Asia) Ltd., Principal Global Investors (Japan) Ltd., and any other affiliated entities that Principal AM contracts with as appropriate to assist Principal AM in the performance of investment advisory services. Those advisory affiliates recommend to their clients or invest on behalf of their clients in securities that are the subject of recommendations to, or discretionary trading on behalf of, Principal AM’s clients. Investment professionals from the advisory affiliates render portfolio management, research, or trading services to Principal AM’s clients, including registered investment companies.

Affiliated Investment Advisers Principal Real Estate Investors, LLC (“Principal Real Estate”) is an investment adviser registered with the SEC. Principal Real Estate offers portfolio management and investment advisory and sub-advisory services for public and private real estate products to affiliated (including Principal AM) and non-affiliated persons. Principal Asset Management Company (Asia) Limited (“PAM Asia”) is an investment adviser registered in Hong Kong with the Securities Futures Commission (SFC), and with the SEC in the US. that offers specialized investment teams to invest funds distributed primarily in Asia. Principal Advised Services, LLC (“PAS”) is an investment adviser registered with the SEC. PAS provides asset allocation advice implemented with assistance of proprietary algorithms. Principal Securities, Inc. (“PSI”), is an investment adviser registered with the SEC and a FINRAregistered broker-dealer that markets a variety of proprietary and non- proprietary mutual funds, unit investment trusts and limited partnerships. Principal AM does not execute security transactions with PSI. PSI is an introducing broker-dealer for retail funds business. Spectrum Asset Management, Inc. (“Spectrum”) is an investment adviser registered with the SEC. Spectrum offers services managing client funds invested in preferred securities. Spectrum is also a member of the National Futures Association and registered with the Commodity Futures Trading

Commission.

Affiliated Broker Dealers SAMI Brokerage, LLC (“SAMI”), is a registered broker-dealer and a FINRA (Financial Industry Regulatory Authority) member. Principal AM executes securities transactions for clients through SAMI in certain circumstances, but only in compliance with applicable rules. Principal Securities, Inc. (“PSI”), is an investment adviser registered with the SEC and a FINRAregistered broker-dealer that markets a variety of proprietary and non- proprietary mutual funds, unit investment trusts and limited partnerships. Principal AM does not execute security transactions with PSI. PSI is an introducing broker-dealer for retail funds business. Principal Funds Distributor, Inc. (“PFD”) is a FINRA registered broker-dealer. PFD serves as a principal underwriter for Principal Funds, Inc. and Principal Variable Contracts, Inc, provides marketing support for Principal Exchange-Traded Funds, and acts as a non-exclusive placement agent for Principal AM’s private funds in the US and Canada. Principal AM acts as sub-adviser to certain Principal Funds. Principal AM does not execute security transactions with PFD.

Other Principal Financial Group Affiliated Entities The Principal Real Estate Europe Group (“the PrinREE Group”), which was acquired by Principal in April 2018, manages alternative investment funds and separate account mandates investing in European real estate on behalf of investors and clients. The PrinREE Group includes 5 authorized Alternative Investment Fund Managers (“AIFMs”): Principal Real Estate Limited - authorized in the UK by the FCA; Principal Asset Management SAS - authorized in France by the AMF; Principal Real Estate S.À R.L. - authorized in Luxembourg by the CSSF; Principal Real Estate Spezialfondsgesellschaft mbH - each of which are registered in Germany by BaFin. Principal Real Estate has a Participating Affiliate Arrangement with the PrinREE Group that allows the PrinREE Group to provide advisory services to Principal Real Estate clients. Principal Asset Management Ltda., an investment adviser in Brazil, specializes in alternative investments and hedge funds in local markets and abroad. Principal Global Investors Trust Company (“PGI Trust”) is an Oregon banking corporation and a trustee of collective investment trusts. PGI Trust, as trustee, retains Principal AM as investment adviser for one or more bank collective investment trusts. For some of the bank collective investment trusts, Principal AM is granted discretion or mandated to retain one or more affiliated investment advisory firms as sub-adviser. Principal Trust Company is a Delaware trust company providing trust, custodial and administrative services. Additionally, Principal Trust Company serves as a discretionary trustee over a group of accounts where they delegate investment advisory services to Principal AM. Principal Bank is an FDIC-insured bank that offers a variety of products and services, including Individual Retirement Accounts. Principal Bank is a federal savings association, and Principal Trust Company is a Delaware trust

company. Principal Bank and Principal Trust do business under the name Principal Custody Solutions (“PCS”). In some situations, PCS serves as discretionary trustee to accounts for which PCS delegates investment advisory services to Principal AM. Principal Bank also serves as an affiliated qualified custodian to some of these accounts as well as to other accounts for which Principal AM serves as investment manager. Principal Life Insurance Company (“Principal Life”) is a licensed insurance company in all 50 states and the District of Columbia. Principal AM manages the Principal Total Market Stock Index Separate Account of Principal Life. Principal AM provides asset allocation advice and other investment advisory services to qualified retirement plans funded with group annuity contracts purchased from Principal Life. Principal AM also has other affiliated entities that are listed in Form ADV Part 1A Item 7A.

Other Financial Industry Activities Principal AM’s legal entity (PGI) is registered with the Commodity Futures Trading Commission (CFTC) as a Commodity Trading Advisor (“CTA”) and as a Commodity Pool Operator (“CPO”). PGI operates one or more controlled foreign corporations (“CFC”) of the registered fund for which it acts as a registered CPO and is a member of the National Futures Association (“NFA”). PGI advises qualified eligible persons (“QEPs”) under CFTC Regulation 4.7. Principal AM is the investment adviser to the Principal Funds, which includes three registered open-end management investment companies – Principal Funds, Inc.; Principal Variable Contracts Funds, Inc.; and Principal Exchange-Traded Funds – as well as two registered closed-end management investment companies operated as Principal-advised closed-end interval funds. Some of Principal AM’s staff are registered representatives of PFD or both PFD and PSI. The staff, in their capacity as registered representatives of PFD and PSI, solicit investment in Principal Funds or in unregistered private investment funds which are sponsored or managed by Principal AM or its affiliates. Only the registered representatives on Principal AM’s distribution staff are eligible to receive sales compensation for any sales of shares of the Principal Funds or interests in unregistered private investment funds. In addition to the sales compensation paid to Principal AM’s distribution staff, Principal Funds and unregistered private investment funds pay advisory fees that are received by Principal AM or its affiliated advisers. As such, there is a conflict of interest when funds that are paying advisory fees to Principal AM or its affiliated advisers are recommended by the sales staff. Some Separately Managed Account/Wrap fee programs (“SMA Programs”) include investment styles with respect to which one or more of Principal AM’s affiliated investment advisory firms have expertise and experience. Where that is the case, both Principal AM and the affiliated advisory firm(s) will be involved in the provision of investment advisory services to program participants electing the investment style, with the affiliated advisory firm responsible for providing model portfolio creation and maintenance services for the style, and Principal AM responsible for placing client account trades, proxy voting (for those clients electing to authorize the investment adviser to vote proxies), implementing reasonable client-imposed investment restrictions, establishing and implementing procedures used to select securities to be liquidated

when a client requests partial liquidation of the client’s account, and all other responsibilities imposed upon the investment adviser in the particular wrap fee program. In some wrap fee programs, the affiliated advisory firm is also granted authority to handle larger trades, typically those associated with changes to the model portfolio, where appropriate, in order to seek best execution. In those situations, in which one of Principal AM’s affiliated advisory firms provides model portfolio creation and maintenance services, the affiliated advisory firm ordinarily provides those services as a sub-adviser to Principal AM, and the client’s direct agreement ordinarily is with Principal AM as the investment adviser. In those situations, Principal AM is responsible to the client for the actions and decisions of Principal AM’s affiliated sub-adviser and Principal AM is responsible for paying its affiliated sub-adviser out of the fees Principal AM receives as the client’s investment adviser. In the event that Principal AM uses SAMI as a broker on trades for accounts in wrap fee programs, no brokerage commissions will be paid to SAMI in connection with those trades. Principal AM is part of a diversified, global financial services organization with many types of affiliated financial services providers, including but not limited to broker- dealers, insurance companies, and other investment advisers. Principal AM enters into arrangements, as needed, to provide services or otherwise enter into some form of business relationship with these foreign and/or domestic affiliates. Additional disclosure of these relationships will be provided upon request. Principal AM acts as investment adviser to certain index ETFs for which the NASDAQ Stock Market LLC (“NASDAQ”) serves as index service provider. While Principal AM retains certain intellectual property rights with respect to such indices, there is no expectation that NASDAQ will consult with Principal AM or its affiliates with respect to possible changes to the indices. Neither Principal AM nor any of its affiliates are expected to be in possession of or have access to any nonpublic information concerning the index methodologies or screening criteria of each index, although the possibility may occur. To the extent separate accounts, mutual funds, ETFs, or other products seek to track the performance of any of the proprietary indexes, or in instances where Principal AM or an affiliate becomes aware of non-public information concerning the NASDAQ indices, there is a potential for conflicts of interest. Potential conflicts include the possibility of misuse or improper dissemination of non-public information about contemplated changes to the composition of an index, such as using information about changes to the index to trade in a personal account, unauthorized access to index information, and allowing index or methodology changes in order to benefit Principal AM or other accounts managed by it. However, Principal AM believes it has adopted policies and procedures to help protect against these conflicts, including documentation of index changes, restrictions on personal trading, and implementation of certain information barriers.

Transactions and Personal Trading Code of Ethics Principal AM has adopted a Code of Ethics (the “Code”). The principal purposes of the Code are to provide policies and procedures consistent with applicable laws and regulations, including Rule

204A-1 under the Advisers Act, to prevent conflicts of interests or the appearance of such conflicts when Principal AM’s officers, directors, employees, and certain non-employees of Principal AM with access to client and trading information of Principal AM (“Access Persons”) own or engage in their own personal transactions involving securities or when members of the person’s immediate family, domestic partner, or family members of domestic partners sharing the same household engage in securities transactions. Clients of Principal AM can obtain a summary of the Code of Ethics by contacting the Chief Compliance Officer at 800-787-1621.

Employee Personal Trading The Code requires all Access Persons to adhere to high standards of honest and ethical conduct, and the interests of our advisory clients must be placed first at all times. All Access Persons of the Firm are required to certify upon association/employment and annually thereafter that they have read, understood, and complied with the Code. This includes that they have complied with the requirements and disclosed covered accounts, reportable securities, and pre-cleared transactions as required by the Code. Access Persons are permitted to personally buy and sell securities of issuers that Principal AM also trades for its clients, so long as those buy and sell transactions are conducted in accordance with the Code. As such, there are procedures in place to prevent instances where potential conflicts of interest arise between the personal securities transactions of the Access Persons and the securities transactions that Principal AM conducts for the accounts of clients. Compliance monitors personal trading via an online pre-clearance system, ACA ComplianceAlpha Employee Compliance module “ACA.” The procedures provide for the maintenance of a master securities list that includes all securities traded by Principal AM for purchase or sale on behalf of clients. All Access Persons are required to obtain pre-clearance approval to buy and sell reportable securities (excluding exempt securities and transactions) through ACA, before executing a personal security transaction to make sure the proposed transaction conforms to our Code provisions. There is also a quarterly review of reportable transactions, as well as an annual certification of accounts and holdings by Access Persons.

Principal AM Interests in Client Transactions Principal AM will invest its own financial assets primarily in U.S. Treasury securities that it also recommends to clients. It also invests its own financial assets in a short-term investment pool of its indirect parent company, PFSI, or in a checking account in the name of Principal AM. From time to time, Principal AM may invest seed money in an account (e.g., a private fund or separately managed account) for the purposes of creating or maintaining a track record that will later be used to market an investment strategy. When seed money is no longer deemed necessary, the seed money may be withdrawn. Principal AM will attempt to do so without impairing its ability to manage the investment strategy or causing harm to any clients or shareholders. Principal AM furnishes investment advice with respect to various portfolios of its affiliate

company, Principal Life. In fulfilling its responsibilities, Principal AM buys and/or sells Principal Life securities or other investment products that it also recommends to its clients who are not related persons of Principal AM. Also, Principal AM provides investment advisory services to qualified retirement plans funded through Principal Life group annuity contracts. The investment options offered to these clients include primarily a recommendation to invest in Principal Life separate accounts. Principal AM is the investment manager of various securities portfolios of Principal Life and other related persons. Principal AM is the adviser to a number of the Principal Funds, a family of mutual funds organized by Principal Life and distributed by PFD. Related persons of Principal AM include, but are not limited to, Principal Life, PSI, and PFD. In carrying out its responsibilities in each of these arrangements, Principal AM buys or sells for related persons securities that it also recommends to its clients who are not related persons of Principal AM. From time to time, Principal AM advises clients to purchase securities which could coincide with other client purchases, or when one or more affiliates of Principal AM could also (1) be purchasing or selling and/or (2) holding such securities. Such situations are subject to procedures designed to ensure fair allocation of available transactions. Principal AM also advises clients to participate in investment vehicles with other participants (e.g., a Principal Collective Investment Trust), and which potentially include one or more affiliates of Principal AM. Principal AM recommends to its clients the purchase, sale or holding of shares of affiliated mutual funds and/or ETFs for which Principal AM and its affiliates also provide advisory services while considering suitability. Principal AM has policies and procedures that address trading and potential conflicts of interest. These conflicts, along with all potential conflicts of interest, are overseen according to our relevant policies and procedures.

Outside Activities Principal AM employees have a duty to act solely in the interest of our clients. As such, Principal AM’s Outside Business Activity procedures require that employees obtain approval from their manager and Compliance before engaging in any outside activities. This allows Principal AM the opportunity to consider whether such activities create actual or potential conflicts of interest prior to approving such activity.

Political Contributions Principal AM’s Political Contribution Policy establishes the requirements that apply when covered associates make or solicit U.S. political contributions or engage in political activities in the U.S. The policy prohibits Principal AM’s employees from making or soliciting U.S. political contributions for the purpose of obtaining or retaining business. The policy requires employees to pre-clear U.S. political contributions before the employee, spouse, domestic partner, or dependent children ages 17/18 or older residing in the same household who will be able to vote at the time of the election make any contributions to a political candidate, government official, political party, or political action committee (“PAC”) in the U.S.

When acting as a discretionary adviser, Principal AM determines which securities or other instruments are bought or sold for an account, the amount of such securities or other instruments and the timing of the purchases and sales, the broker, dealer, underwriter (and in the case of the currency services, the foreign exchange dealer) through which transactions are effected and the commission rates or spreads paid, except as specifically directed by the client. Our discretion in these matters is governed by our responsibility to act in the best interest of our clients in fulfilling their investment objectives.

Selection of Brokers and Dealers Principal AM’s principal objective in selecting broker-dealers and entering client trades is to seek best execution for client transactions. In general, best execution means executing trades at the best net price considering all relevant circumstances. While best execution is our objective for all transactions, it can be evaluated over time through several transactions rather than through a single transaction. In seeking best execution, the key factor is not necessarily the highest bid or the lowest offer, but whether the transaction represents the best qualitative execution for the client. This assessment will be influenced by many factors including current market conditions and the type of instrument in question and the markets in which it trades. In selecting brokers and dealers, Principal AM considers a variety of factors including, but not limited to: • Financial strength and stability • Best price for the trade • Reasonableness of the commission, spreads, or markups • Ability to execute and clear a trade in a prompt and orderly manner • Quality of executions in the past and existing relationship to date • Confidentiality provided by the broker or dealer • Execution capabilities and any related risks in trading a block of securities • Broad market coverage resulting in a continuous flow of information concerning bids and offers • Consistent quality of service, including the quality of any investment-related services provided • Recordkeeping practices (e.g., timely and accurate confirmations) and • Cooperation in resolving differences. Principal AM reviews a variety of internal and external trading reports and other information to evaluate the quality of execution of certain transactions over time. In some instances, Principal AM will pay broker commissions that are higher than the commissions another broker might have charged for the same transaction. Please see the section on Soft Dollar Practices below for additional information about brokerage and research services received by Principal AM. Principal AM maintains an approved list of brokers and dealers; our traders are required to direct trades only through these approved counterparties. New counterparty arrangements must be reviewed and approved by Principal AM’s counterparty review process before trading can begin through the new counterparty. Alternative trading systems that meet the Counterparty Team’s guidelines are also eligible for consideration. Once a broker or dealer is approved, it is added to the Approved Counterparty List and communicated to traders. Counterparties are regularly

monitored by the Counterparty Team for signs of deterioration in business operations, creditworthiness, and rating changes. Principal AM generally does not intend to place portfolio trades for any of its equity or fixed income clients with an affiliated broker-dealer. To best support client trading outcomes, Principal AM has developed a “Focus Broker” list, which is comprised of a subset of brokers from the Approved Counterparty List that Principal AM believes offer consistent execution quality, access to research, strong overall service and responsiveness, and support enhanced trade oversight of trading outcomes. The Focus Broker list constituents are discussed on a periodic basis (e.g., during Trading Committee meetings) and reviewed on an annual basis (or more frequently as deemed necessary) and are regularly monitored to ensure execution quality is not subordinated to research or other benefits. Principal AM believes that the Focus Broker constituents offer efficient trade communication and provide Principal AM with reduced operational complexity and improved execution quality monitoring ability. The complete Approved Counterparty List, of which the Focus Broker list is a part, is comprised of a wide group of brokers available to investment personnel for execution and research, including, but not limited to, hard-to-source securities, liquidity needs, and specific expertise. The Approved Counterparty List is similarly reviewed no less than annually. Notwithstanding the above, Principal AM’s principal objective is to seek best execution for client transactions.

Broker Review Principal AM conducts a broker review that gathers input from key investment staff. Portfolio managers, research analysts and traders rate brokers and dealers based on the value they believe they receive from the broker or dealer through reports, meetings, conference calls, management visits and other research. Traders rate brokers and dealers based on factors that include, but are not limited to, execution quality, information flow, volume of trading in Principal AM’s orders, willingness to take the other side of the trade in a principal transaction, bids and offers and the broker’s execution cost history. Based on their responses, an aggregate score will be calculated for each broker and dealer and a relative ranking determined. In addition to ratings, feedback is gathered on the strengths and weaknesses of each broker and dealer (e.g., research sales, strategy, and trading).

Brokerage Commissions Transactions on stock exchanges and other agency transactions, as applicable, involve payment by the client of negotiated brokerage commissions. Such commissions vary between different brokers and dealers, and a particular broker or dealer often charges different commissions based on the difficulty and size of the transaction or the means of execution (i.e., program, algorithmic or sales trader), among other things. Although commission rates are considered by Principal AM in our brokerage selection process and are reasonable in relation to the value of the services provided, our clients may not realize the lowest possible commission rates as our determination process considers the additional factors outlined above.

Cross Trades Principal AM may arrange for one client to purchase or sell securities to another client (i.e., a “cross trade”), provided the clients in question have consented to cross trades and the regulatory authority governing the client accounts clearly permits the cross trade to occur. Principal AM has implemented policies and procedures regarding the execution of cross trades when appropriate for both clients and permissible under applicable law. Cross trades are only considered in circumstances where the transaction is in the best interests of both parties, the purchase and sale of the security satisfies the investment guidelines for each of the portfolios involved, and all applicable regulatory requirements are satisfied (e.g., for mutual funds, the cross trade is consistent with Rule 17a-7 procedures). When entering into cross trades, Principal AM takes steps to obtain a price determined by reference to independent market indicators and which Principal AM believes is consistent with its duty to seek best execution for each party. Because Principal AM manages different styles of accounts with different portfolio managers, it sometimes happens that two or more portfolio managers initiate orders to buy or sell the same equity security at the same time. If one portfolio manager has entered a buy order for a stock while another portfolio manager has a sell order, the orders will be worked separately to ensure that one account does not buy from the other.

Principal Transactions Principal AM does not generally engage in principal transactions, as defined by Section 206(3) under the Advisers Act, as part of its trading processes for clients. In the event that Principal AM engages in a principal transaction, Principal AM will take action to ensure compliance with the relevant requirements of the Advisers Act. Section 206(3) prohibits any investment adviser from engaging in or effecting a transaction on behalf of a client while acting either as principal for its own account, or as broker for a person other than the client, without disclosing in writing to the client, before the completion of the transaction, the adviser's role in the transaction and obtaining the client’s consent. An investment adviser is not "acting as broker" if the adviser receives no compensation (other than its advisory fee) for affecting a particular agency transaction between advisory clients.

New Issues Newly issued securities (including new securities sold in reliance on Rule 144A) will normally be purchased directly from the issuer or from an underwriter for the securities. Such transactions involve no brokerage commissions. Purchases from underwriters will typically involve a commission or concession paid by the issuer (and not by clients of Principal AM) to the underwriter. Secondary purchases from and sales to dealers will include the spread between the bid and asked prices. In general, Principal AM’s primary objective in exercising any available authority concerning the selection of an underwriter, broker, or dealer is to obtain the best overall terms for Principal AM’s clients. In pursuing this objective, Principal AM considers all matters it deems relevant (both for the specific transaction and on a continuing basis), including the breadth of the market in the security, the price of the security, the financial condition and executing capability of the broker or dealer and the reasonableness of the compensation, if any, received by the underwriter, broker, or dealer.

Foreign Exchange Transactions It is the responsibility of a client’s custodian to handle foreign exchange transactions (“FX Transactions”) for client accounts, to settle trades and to repatriate dividends, interest, and other income payments received into the client account to the account’s base currency when necessary. However, Principal AM will, when requested by the client and where Principal AM determines that it is cost effective or efficient, arrange for its trade desk or a third party to handle trade settlement related FX Transactions in unrestricted currencies. Under this type of arrangement, should a client request, the trade desk is responsible for seeking best execution for FX Transactions, either with the client’s custodian or with third parties. Unless otherwise agreed to, Principal AM will continue to issue standing instructions to each client’s custodian for all other types of FX Transactions in unrestricted currencies, such as those related to dividend and interest repatriation. Because of various limitations regarding transactions in restricted currencies, (generally in jurisdictions where all FX Transactions must be done by the client’s custodian) all FX Transactions in restricted currencies will continue to be affected by each client’s custodian pursuant to standing instructions and Principal AM will not be in a position to seek best execution. In cases where a client has not requested that Principal AM handle arrangements for trade settlement related FX Transactions in non-U.S. securities, and/or Principal AM has deemed that it is not cost effective to do so, Principal AM will instruct the client's custodian to execute the necessary FX Transactions. This is done either through standing instructions communicated to the custodian when the account is established, or at the time settlement instructions are sent to the custodian for a particular transaction. The custodian is responsible for executing FX Transactions, including the timing and applicable rate of such execution pursuant to its own internal processes. As clients generally have arrangements with their custodian regarding the execution of FX Transactions, such arrangements impact the fees and expenses charged to the client by the custodian. The principles described above apply both to separately managed client accounts and to commingled investment vehicles (including registered funds, collective investment trusts, and similar pooled vehicles) and private funds managed by Principal AM. In the case of commingled vehicles and private funds, FX Transactions are generally effected through the fund’s custodian, prime broker, Principal AM’s internal trading desk, or other designated service provider, subject to the same limitations and considerations described above. In certain cases, investors in commingled vehicles and private funds may provide direction regarding the execution of FX Transactions in accordance with the applicable governing documents.

Trade Errors Principal AM maintains a system of checks and balances designed to limit the errors it makes in placing trades for client accounts. It is Principal AM’s policy that the utmost care is taken in making and implementing investment decisions on behalf of our funds and our client accounts. Nonetheless, Principal AM will, from time to time, make such errors. It is Principal AM’s policy to absorb all losses on trades it places in error. In rectifying erroneous trades, Principal AM distinguishes between errors it identifies prior to the time a client’s custodian settles the erroneous trade and posts it to the client’s custodial statement ("Time of Settlement") and those it identifies after the Time of Settlement. With respect to equity securities, Principal AM maintains

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Principal AM will enter into compensation arrangements with related parties. Currently on select accounts where Principal Securities, Inc. introduces relationships to Principal AM, Principal AM pays compensation to Principal Securities, Inc. in the form of an annual percentage of the management fee in the amount of 0.20% (or 20 basis points) of asset balances of applicable accounts. Principal AM may also from time to time enter into relationships with Principal Securities or other related entities. Principal AM may also enter into promoter arrangements with unrelated person(s) when it appears that a promoter could provide access to clients Principal AM might not otherwise have. Prior to doing so, Principal AM will make all applicable regulatory filings and ensure that such arrangements are maintained in compliance with applicable regulations including Rule 206(4)-1 and any relevant supporting regulatory guidance. This compensation may include paying the promoter (a) a salary; (b) a percentage of the management fee Principal AM has earned that the promoter has introduced; (c) a one-time fee; or (d) any combination of (a), (b), and/or (c).

Other Compensation Placement Arrangements Certain Principal AM affiliates, such as Principal Funds Distributor in the U.S., serve as the appointed distributor to many of the registered and unregistered investment products. In this capacity, the Principal AM affiliates contract with authorized participants. In the U.S., these activities may be deemed participation in a distribution of an investment product for statutory purposes, and an affiliate may receive additional compensation.

Promotional and Educational Cost Reimbursements From time to time and consistent with Principal AM’s policy and applicable regulation, Principal AM also pays for, or reimburses broker-dealers or other financial intermediaries, various costs arising from, or activities that may result in, the sale of advisory products or services, including: (i) client and prospective client meetings and entertainment; (ii) sales and marketing materials; (iii) educational and training meetings or entertainment activities with the registered representatives of such broker-dealers and other personnel from entities that distribute Principal AM’s products and/or services; and (iv) charitable donations in connection with events involving personnel or clients of entities that distribute Principal AM’s products and/or services.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of the Firm or the integrity of the Firm’s management. To the best of Principal AM’s knowledge, Principal AM has no information applicable to this item that is not otherwise disclosed in Form ADV Part 1A.

Review of All Accounts Principal AM reviews each client account to monitor portfolio performance and to ensure that each portfolio conforms to guidelines established by Principal AM and the client. Separately negotiated contracts with each client contain the precise nature of the advisory services to be furnished to that client. These contracts can specify the criteria and process for the account review furnished by the client. In addition, Principal AM uses its own review processes and procedures during the ongoing management of the client’s portfolio. Principal AM generally sends reports to clients on the investment status of their portfolios quarterly, or more frequently if required under the terms of the client contract. Principal AM utilizes a compliance system to assist in the automated review and monitoring of portfolios. Many client account investment guidelines can be input into this compliance system. Each equity trade order is submitted into the system and reviewed electronically for compliance with the account’s investment guidelines. This is done prior to the trade order being submitted to Principal AM’s trade desk. The system blocks trades that would cause an explicit breach of client guidelines. Principal AM generates daily reports identifying exceptions for further analysis.

Reviews by Strategy Equities Equity portfolios receive ongoing review during the trading process. The portfolio managers utilize proprietary and third-party portfolio construction tools to monitor pre-trade and post-trade risks before trade orders are sent to the trading desk. These systems allow the team to evaluate the impact of potential trades on the overall portfolio exposures which cannot be monitored through the automated compliance system yet are a client objective or guideline. Certain members of the specialized investment teams can monitor portfolios on an ongoing basis. Daily performance reports on representative samples of client portfolios are compared to relative benchmarks. Principal AM runs monthly risk analysis and exception reports on a representative sample of portfolios relative to benchmarks, and in addition, portfolio managers formally review a representative group of client portfolios each month.

Fixed Income Each fixed income portfolio is reviewed daily by its portfolio manager and team members assigned to that portfolio. Principal AM runs daily reports on a sampling of accounts indicating performance of each portfolio, market value and cash for each account included in the sampling. Principal AM has an oversight process to monitor portfolios. Principal AM runs monthly performance reports on all accounts, which are provided to the members who have oversight authority. Risk management reports showing error (tracking error) and characteristics are run at least quarterly. Each portfolio manager meets quarterly to review the activity in the portfolio(s) for which the portfolio manager is responsible.

Asset Allocation Principal Asset Allocation reviews fund positioning and performance daily. Sector, risk factor, and issuer concentrations are monitored through third-party tools. Investment guidelines are established and monitored for each sub-adviser within a Fund, setting parameters for individual security weightings, sector allocation ranges, tracking error relative to the benchmark, etc. Quarterly monitoring calls are conducted with each sub-adviser. These calls are supplemented by reviews of each manager’s monthly and quarterly attribution and risk management materials, annual in-person meetings, and an annual re-underwriting of the investment and operations due diligence. Sub-advisers may be removed or replaced as deemed appropriate. The Investment Solutions team reviews the asset allocation process used to develop its market outlook, as well as the portfolios constructed for its strategies, on a quarterly basis. Asset allocation strategies are customized for each client based on their specific goals and objectives. In certain cases, asset allocation reviews are conducted quarterly, while others may be reviewed annually. The frequency of the review depends on the time horizon and investment strategy applicable to each account.

Reviewers Principal AM has several committees and other internal groups that help Portfolio Managers in their review of objectives and constraints of the client, investment activity, operational activity, and client relations. The number and type of accounts reviewed, frequency of meetings, and output of each group vary by focus.

Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) defines “custody” to include a situation in which an adviser or a related person holds, directly or indirectly, client funds or securities or has any authority to obtain possession of them, in connection with advisory services provided by the adviser. For example, for purposes of the Custody Rule, we may be “deemed” to have custody of certain client assets because we have the ability to deduct fees from client custodial accounts. If Principal AM is deemed to have “custody” solely as a consequence of its authority to deduct its fees from client accounts, however, it will not be required to obtain a surprise examination under the Custody Rule. Principal AM urges careful review of account statements and a comparison of official custodial records against any Principal AM-provided account statements. Principal AM does not hold client assets but has an affiliate which provides custody services for certain Principal AM clients. In these circumstances, Principal AM will receive an Internal Control Report from the affiliate no less frequently than once each year. The internal control report must include the opinion of an independent public accountant as to whether controls have been placed in operation and are suitably designed and operating effectively to meet control objectives relating to custodial services. Generally, in circumstances where Principal AM is deemed to have “custody,” (1) Principal AM will have a reasonable basis, after due inquiry, for believing that the client’s custodian sends an account statement, at least quarterly, to such client; and (2) a surprise examination will be conducted annually to verify the existence of assets in the client’s account.

Principal AM generally receives discretionary authority from the client at the outset of an advisory relationship to select the identity and number of securities to be bought or sold. Principal AM retains limited discretion from clients to allocate retirement plan assets within the group variable annuity contracts issued by Principal Life. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives, guidelines and restrictions for the particular client account memorialized in a written agreement. When selecting securities and determining amounts, Principal AM observes the investment policies, limitations, and restrictions of the clients for which it advises. Principal AM may accept accounts for which it has discretionary authority to purchase securities for the account, but not to select broker-dealers for transactions. These are commonly known as “client directed brokerage relationships” and are described in “Item 12 – Brokerage Practices.” Principal AM may also accept non-discretionary arrangements, such as providing a series of securities recommendations by periodically updating a model portfolio, or where clients retain investment discretion with respect to transactions in the account. In these situations, Principal AM’s lack of investment discretion may cause the client to lose possible advantages that our discretionary clients may derive from our ability to act for those discretionary clients in a moretimely fashion, such as the aggregation of orders for several clients as a single transaction.

Principal AM has adopted and implemented written Proxy Voting Policies and Procedures which are designed to reasonably ensure that Principal AM satisfies its fiduciary obligation with respect to voting proxies for clients which have authorized Principal AM to vote proxies. Clients can choose to retain the right to vote proxies. Principal AM’s guiding principles in performing proxy voting are to make decisions that (i) are in its clients’ best interests (ii) favor proposal that tend to maximize a company’s shareholder value and (iii) are not influenced by conflicts of interest. Principal AM’s Proxy Voting Committee (the “Proxy Voting Committee”) shall (i) oversee the voting of proxies and the Proxy Advisory Firm, (ii) where necessary, make determinations as to how to instruct the vote on certain specific proxies, (iii) verify ongoing compliance with the Policy, (iv) review the business practices of the Proxy Advisory Firm and (v) evaluate, maintain, and review the Policy on an annual basis. The Proxy Voting Committee, on an annual basis, or more frequently as needed, will direct each investment team to review draft proxy voting guidelines recommended by the Committee (“Draft Guidelines”). Where an investment team has a position which deviates from the Draft Guidelines, an alternative set of guidelines for that investment team may be created. Collectively, these guidelines will constitute Principal AM’s current Proxy Voting Guidelines and may change from time to time (the “Guidelines”). The Proxy Voting Committee has the obligation to determine that, in general, voting proxies pursuant to the Guidelines is in the best interests of clients. While the Proxy Voting Committee establishes the Guidelines and Procedures, the Proxy Voting Committee does not direct votes for any client except in certain cases where a conflict of interest

exists. Each investment team is responsible for determining how to vote proxies for those securities held in the portfolios their team manages. While investment teams generally vote consistently with the Guidelines, there may be instances where their vote deviates from the Guidelines. Clients may instruct Principal AM to utilize a different set of guidelines, request specific deviations, or directly assume responsibility for the voting of proxies. In addition, Principal AM may deviate from the Guidelines on an exception basis if the investment team or Principal AM determines that it is the best interest of clients in a particular strategy to do so, or where the Guidelines do not direct a particular response and instead list relevant factors. Principal AM believes a company’s positive environmental and social practices may reduce risk and, in turn, influence the value of the company, with a goal of leading to long-term shareholder value. Where Principal AM is vested with proxy voting authority, it is Principal AM’s policy to attempt to vote all proxies on behalf of the client, unless Principal AM determines in accordance with its policies to refrain from voting. Because of the volume and complexity of the proxy voting process, including inherent inefficiencies in the process that are outside Principal AM’s control (e.g., delays or incomplete information from intermediaries such as custodians, proxy agents or parties involved in Wrap Fee Programs), not all proxies may be voted. With respect to non-U.S. companies, Principal AM makes reasonable efforts to vote most proxies and follow a similar process to those in the U.S. However, in some cases it may be both difficult and costly to vote proxies due to local regulations, customs or other requirements or restrictions, and such circumstances and expected costs may outweigh any anticipated economic benefit of voting. The major difficulties and costs may include: (i) appointing a proxy; (ii) obtaining reliable information about the time and location of a meeting; (iii) obtaining relevant information about voting procedures for foreign shareholders; (iv) restrictions on trading securities that are subject to proxy votes (share-blocking periods); (v) arranging for a proxy to vote locally in person; (vi) fees charged by custody banks for providing certain services with regard to voting proxies; and (vii) foregone income from securities lending programs. In certain instances, it may be determined by Principal AM that the anticipated economic benefit outweighs the expected cost of voting. Principal AM intends to make its determination on whether to vote proxies of non-U.S. companies on a case-bycase basis. Some clients may have entered into securities lending arrangements with agent lenders to generate additional revenue. If a client participates in such lending, the client will need to inform Principal AM as part of their contract with Principal AM if they require Principal AM to take actions in regard to voting securities that have been lent. If not commemorated in such agreement, Principal AM will not recall securities and as such, they will not have an obligation to direct the proxy voting of lent securities. In the case of lending, Principal AM maintains one share of each company security out on loan from the client. Principal AM will vote the remaining share in these circumstances. PrinAM Proxy Voting Philosophy emphasizes long-term shareholder value through responsible corporate governance. While boards and management lead corporate policy, shareholders play a vital oversight role. The Firm’s global policy is guided by four themes: board structure, risk and strategy oversight, executive leadership and compensation, and shareholder rights. It supports independent, skilled, and accountable boards, transparent executive pay aligned with performance, and the protection of shareholder rights. Many voting decisions are made case-by-case, especially for shareholder proposals, with passive strategies generally aligning with management unless directed otherwise.

Conflicts of interest may arise within a large, complex financial organization. To address this, the Firm adheres to a strict Code of Ethics and Conduct and complies with all relevant regulations. Investment personnel must act in clients’ best interests and report any potential or actual conflicts to Legal or Compliance. Conflicts may stem from internal or external relationships, excluding standard issuer communications or internal investment discussions. The Firm’s procedures ensure proxy voting and investment decisions are made independently and solely to maximize shareholder value, maintaining transparency and regulatory compliance. PrinAM allows investment teams to pursue distinct strategies, which may occasionally result in differing proxy votes across teams. This divergence is not considered a conflict of interest but reflects the autonomy of investment philosophies. To manage exceptions—such as votes that deviate from established guidelines or involve potential conflicts—the Firm enforces a formal Exception Process. Certain votes, such as those involving Principal Financial Group stock or proprietary funds, are excluded from this process and follow predefined rules like echo voting or abstention. If a proxy advisory firm faces a conflict, alternative independent recommendations may be used, or the Exception Process is triggered to ensure decisions remain in clients’ best interests. Principal has retained one or more third-party proxy service provider(s) (the “Proxy Advisory Firm”) to provide recommendations for proxy voting guidelines, information on shareholder meeting dates and proxy materials, translate proxy materials printed in a foreign language, provide research on proxy proposals, operationally process votes in accordance with the Guidelines on behalf of the clients for whom Principal AM has proxy voting responsibility, and provide reports concerning the proxies voted (“Proxy Voting Services”). Although Principal AM has retained the Proxy Advisory Firm for Proxy Voting Services, Principal AM remains responsible for proxy voting decisions. Principal AM maintains proxy voting records and related records designed to meet its obligations under applicable law. Where permitted by and in accordance with applicable law, Principal AM may rely on third parties to make and retain, on our behalf, a copy of the relevant records. Clients may obtain a complete copy of our proxy voting policies and other information regarding how their proxies were voted upon request. In the rare event that a proxy ballot is received for a fixed income account, the relevant portfolio manager will be responsible for voting the ballot. Principal AM complies with applicable reporting requirements under Form N-PX. Principal AM is subject to Section 13(f) of the Securities Exchange Act of 1934 and exercises voting power over equity securities, it files an annual Form N-PX report disclosing proxy votes relating to executive compensation matters, including “say-on-pay,” “say-on-frequency,” and “golden parachute” proposals, as required by Exchange Act Rule 14Ad-1 when as the adviser Principal AM has the power, direct, or influence a proxy vote on behalf of a client.

Registered investment advisers are required in this Item to provide clients with certain financial information or disclosures about the Firm’s financial condition. Principal AM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of bankruptcy proceedings.