SANDS CAPITAL MANAGEMENT, LLC

Sands Capital Management, LLC (“Sands Capital”) is an independent investment management firm. Sands Capital Management, LP (“Sands Capital LP”) is the principal owner of Sands Capital and is principally owned directly and indirectly by several limited liability companies and estate planning trusts as identified in Schedule B of Part 1. Sands Capital and Sands Capital LP are ultimately controlled by Frank M. Sands. Sands Capital is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). We are headquartered in Arlington, Virginia, and manage approximately $44,304.8 million in discretionary assets (Regulatory Assets Under Management) as of December 31, 2025. Sands Capital also provides portfolio recommendations for non-discretionary clients for whom we do not execute trades but for whom we provide changes to strategy models (“Model Clients”), which account for approximately $7,072.6 million in additional fee-paying assets as of December 31, 2025. Since 1992, Sands Capital has provided investment advisory and management services to taxable and tax-exempt clients, primarily on a discretionary basis, and in certain circumstances as described herein, to Model Clients. Clients include, among other types, investment companies and other pooled investment vehicles, pension and profit-sharing plans, charitable organizations, state and municipal government entities, sovereign wealth funds and foreign official institutions, corporations, non-U.S. pension funds, superannuation funds, banking or thrift institutions and individuals. Sands Capital is affiliated with other investment advisers that also operate under the name Sands Capital (“Advisory Affiliates”). Under personnel-sharing and other arrangements, Sands Capital staff members act on behalf of the Advisory Affiliates for purposes of providing services to their clients and provide other back office and administrative services to the Advisory Affiliates. Certain Sands Capital staff members are also officers of the Advisory Affiliates. Sands Capital believes that harnessing the collective capabilities of Sands Capital and the Advisory Affiliates benefits its clients. These joint teams use expanded and shared capabilities, including the sharing of research and other information by investment staff members relating to economic perspectives, market analysis and securities research. Investment Philosophy and Strategies Sands Capital embraces the fundamental investment philosophy that stock prices tend to reflect the earnings power and growth of the underlying businesses over the long term. As such, we attempt to identify and invest in high quality companies that have the capacity to generate

sustainable, above-average earnings growth over time. The strategies we offer are typified by deep, proprietary, business-focused global research, concentrated and conviction weighted portfolios and a long-term investment horizon. We invest for our clients in what we believe are the leading growth businesses that meet our six investment criteria:

Sustainable above-average earnings growth;

Leadership position in a promising business space;

Significant competitive advantages or a unique business franchise;

Clear mission and value-added focus;

Financial strength; and

Rational valuation relative to the market and business prospects.

The primary risk we seek to manage is the risk of permanent loss of capital resulting from a negative business or investment outcome. Risk management is integrated throughout our entire research and portfolio construction process. Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. The research team conducts proprietary, bottom-up, fundamental research on businesses of all market capitalizations located around the world. This analysis includes formulating a “sell case” for each investment. We typically sell when any of the following is identified:

Significant change in fundamentals;

Flaw in original investment case;

Meaningful overvaluation vs. underlying business;

Funding source for a new opportunity; or

Risk management decision.

We apply the above criteria to each of the following investment strategies, which have overlapping investments. Please refer to Item 6 – Performance-Based Fees and Side-By-Side Management and Item 12 – Brokerage Practices for additional information. Select Growth The Select Growth strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses. The portfolio normally consists of equity securities of 25 to 30 issuers.

Portfolio companies are primarily domiciled in the United States (“U.S.”) but also include the equity securities of foreign issuers traded on U.S. exchanges. Eligible securities include equity and equity-related securities, such as American depositary receipts (“ADRs”) or shares of publicly traded real estate investment trusts for U.S. or Non-U.S. tax purposes (“REITs”). The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the Russell 1000® Growth Index. Global Growth The Global Growth strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses. The portfolio normally consists of equity securities of 30 to 50 issuers. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity-related securities, such as ADRs, exchange-traded funds (“ETFs”), global depositary receipts (“GDRs”), China A-shares (whether traded cross-boundary via the Hong Kong Stock Connect or directly via exchanges in mainland China, “China A-shares”), or REITs. Low exercise price warrants (“LEPWs”), participation notes (“P-Notes”), or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World Index. Global Leaders The Global Leaders strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses. The portfolio normally consists of equity securities of 30 to 50 issuers. The strategy employs a portfolio construction approach that intends to balance growth and volatility. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World Index. International Growth The International Growth strategy is a concentrated portfolio of primarily large- and midcapitalization growth businesses. The portfolio normally consists of equity securities of 25 to 40 issuers. Generally, portfolio companies are domiciled or derive a significant portion of their revenues, profits, or productive assets outside of the United States. Eligible securities include

equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World ex USA Index. International Leaders The International Leaders strategy is a concentrated portfolio of primarily large- and midcapitalization growth businesses. The portfolio normally consists of equity securities of 25 to 40 issuers. The strategy employs a portfolio construction approach that intends to balance growth and volatility. Generally, portfolio companies are domiciled or derive a significant portion of their revenues, profits, or productive assets outside of the United States. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI EAFE Index. Emerging Markets Growth The Emerging Markets Growth strategy is a concentrated portfolio of primarily large- and midcapitalization growth businesses. The portfolio normally consists of equity securities of 30 to 50 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (e.g., substantial portion of revenues, profits, or productive assets) outside of developed markets. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI Emerging Markets Index. Emerging Markets ex China The Emerging Markets ex China strategy is a concentrated portfolio of primarily large- and midcapitalization growth businesses. The portfolio normally consists of equity securities of 25 to 45 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (e.g., substantial portion of revenues, profits, or productive assets) outside of developed markets and China. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain

foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI Emerging Markets ex China Index. Technology Innovators The Technology Innovators strategy is a concentrated portfolio of primarily large- and midcapitalization growth businesses which are publicly or privately held, with a particular emphasis placed on companies facilitating or benefitting from powerful secular shifts enabled by technologies. The portfolio normally consists of equity securities of 20 to 35 issuers. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity-related securities, such as ADRs, stock or convertible debt issued by private companies, ETFs, GDRs or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World Information Technology and Communication Services Index. Global AI Innovators The Global AI Innovators strategy is a concentrated portfolio of primarily large- and midcapitalization growth businesses which are publicly or privately held, with an emphasis on companies that enable broader adoption of artificial intelligence (“AI”), build AI into their products and services for monetization, or benefit from using AI by using it to drive efficiencies and/or generate revenue. The portfolio normally consists of equity securities of 25 to 40 issuers. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity-related securities, such as ADRs, stock or convertible debt issued by private companies, ETFs, GDRs or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World Index. Global Shariah The Global Shariah strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses that meet Islamic investment principles, as determined by Sands Capital. The portfolio normally consists of equity securities of 30 to 50 issuers. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity5

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Sands Capital earns investment management fees for separately managed accounts based upon standard fee schedules shown below. We negotiate these fees individually with clients, and not all clients pay the fee listed in the schedules below. The standard fee for investment management services varies based on the investment strategy being employed, a particular client’s profile, or as otherwise negotiated with the client or its intermediaries. These differences depend on various factors including but not limited to, the type of client, the client’s asset levels, the existence of an intermediary relationship, a pre-existing relationship, the amount of servicing required for the client’s account, and the inception date of an account, among other things. Fees are typically billed quarterly, in advance or arrears, and are calculated as a percentage of the account’s assets under management. In some cases, a performance-based fee is received. Clients with performancebased fees are likely to pay higher fees than those listed in the standard investment management fee schedule below during certain time periods. Please see Item 6 – Performance-Based Fees and Side-By-Side Management for additional information on performance-based fee arrangements. Our standard investment management fee schedules are as follows: Select Growth Assets Under Management

Annual Percentage

First $50 million

0.75%

All over $50 million

0.50%

Select Growth (Wealth Management) Assets Under Management

Annual Percentage

First $10 million

1.00%

Next $40 million

0.75%

All over $50 million

0.50%

Global Growth Assets Under Management

Annual Percentage

First $50 million

0.85%

Next $200 million

0.65%

All over $250 million

0.55%

Global Leaders Assets Under Management

Annual Percentage

First $250 million

0.65%

All over $250 million

0.55%

International Growth Assets Under Management

Annual Percentage

First $50 million

0.85%

Next $200 million

0.65%

All over $250 million

0.55%

International Leaders Assets Under Management

Annual Percentage

First $250 million

0.65%

All over $250 million

0.55%

Emerging Markets Growth Assets Under Management

Annual Percentage

First $50 million

0.85%

Next $200 million

0.65%

All over $250 million

0.55%

Emerging Markets ex China Assets Under Management

Annual Percentage

First $50 million

0.85%

Next $200 million

0.65%

All over $250 million

0.55%

Technology Innovators Assets Under Management

Annual Percentage

All assets

0.85%

Global AI Innovators Assets Under Management

Annual Percentage

All assets

0.65%

Global Shariah Assets Under Management

Annual Percentage

First $50 million

0.85%

Next $200 million

0.65%

All over $250 million

0.55%

Focus Strategies Assets Under Management

Annual Percentage

All assets

0.85%

The investment management fee schedules for client-tailored strategies are not standard and are negotiated on a case-by-case basis. Unless otherwise negotiated, we calculate investment management fees based upon the valuation of an account’s assets as of the last business day of each calendar quarter, generally without taking into consideration deposits or withdrawals during the quarter, as valued by our portfolio management system. The valuation on which fees are based may differ from the value reported by a client’s custodian. Please refer to “Valuation Risk”, “Private Company Risks” and “Valuation” under Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for additional risks associated with the valuation. Any unearned, prepaid fees will be returned upon termination of investment management services to a client billed in advance. If a client terminates within five business days after signing a contract, Sands Capital will fully refund all prepaid fees. Similar client accounts have different fee schedules based on the historical nature of the accounts or through negotiation with the client. Fee arrangements include performance-based fees. From time to time, and under agreed-upon specific situations, we have in the past and may in the future waive, reduce, and/or rebate all or a portion of a client’s management fee on a case-by-case basis for any period of time. For fee calculation purposes, Sands Capital has agreed to aggregate the assets of related accounts that are being managed for the same client or in connection with a common third-party relationship. In such circumstances, the aggregated accounts will receive the benefit of a lower effective fee due to the total amount of assets being managed. Any such negotiated fee arrangement is done at the sole discretion of Sands Capital and is entered into generally without notice to, or consent from, any other client.

Sands Capital has relationships with various financial intermediaries, and, in some cases, the fees assessed against the underlying clients are based on a fee schedule applicable to the relevant intermediary. Such fee schedule may or may not aggregate underlying client assets, depending on the type of relationship with the intermediary and other factors. If authorized, we will deduct our management fee directly from a client’s account, but only if such account is held with a “qualified custodian” as defined under the Advisers Act. A statement will be sent to the client or its financial intermediary detailing the portfolio’s value on which the fee is based, the agreed-upon percentage(s), the calculation of the fee, and the amount due. The accuracy of this information may or may not be verified by the client’s custodian. If direct debiting is not selected, an invoice is either sent directly to the client or to its custodian or consultant. Our fees for Model Client advisory services are negotiated on a case-by-case basis. Fees in these cases generally will be lower than our fees for providing full discretionary investment management services. When Sands Capital’s staff members or affiliates (including certain estate-planning vehicles thereof) invest in a private fund or other co-investment vehicle managed by Sands Capital, its affiliates, or the Advisory Affiliates, they generally will not be subject to a management fee or incentive allocation (or are subject to a reduced fee/allocation), at Sands Capital’s or the Advisory Affiliates’ discretion. Sands Capital has entered into agreements with the affiliated SCM Private Funds (as defined in Item 7 – Types of Clients) pursuant to which it provides various investment management and/or other services. Sands Capital receives a management fee for its investment management services performed for the SCM Private Funds (a “Management Fee”), pursuant to an investment management agreement, calculated with respect to the net asset value of the capital account of a limited partner. The Management Fee is calculated, payable, and debited monthly in arrears as of the first day of each calendar month. For each investor in the SCM Private Funds admitted to such fund after the first business day of the calendar month, the Management Fee is pro-rated based on the admission date of such limited partner. The Management Fees payable by the SCM Private Funds are generally subject to modification, waiver, or reduction by Sands Capital in its sole discretion, both voluntarily and on a negotiated basis with selected investors via side letter and other arrangements, which are not disclosed to other investors in the same SCM Private Funds. Other Fees and Expenses Our clients are responsible for negotiating cash management directly with their custodians. Sands Capital invests in ETFs for its clients when direct equity investment is not feasible. Unless otherwise negotiated, we charge our investment management fee on a client’s total account assets,

including any assets allocated to ETFs. All fees paid to us for investment advisory services are separate and in addition to the fees and expenses charged by money market funds, other cash management vehicles or ETFs to their shareholders. In addition to management fees and performance-based compensation, depending on their specific arrangements, clients pay other fees and expenses such as, custody fees, administration and subadministration expenses, mutual and UCITS fund expenses, and financial adviser/consulting fees. Furthermore, brokerage commissions, commission equivalents, markups, markdowns, any other brokerage costs, third party execution costs (if any), transaction fees, and other similar charges that are incurred in connection with transactions placed in a client’s account will be paid out of the account’s assets and are in addition to the management fee paid to Sands Capital. Please see Item 12 – Brokerage Practices for additional information on Sands Capital’s brokerage practices. With respect to the SCM Private Funds, Sands Capital or the applicable general partner will be responsible for, and will pay, or cause to be paid, all overhead expenses (except as described below or in Item 12 – Brokerage Practices), which shall include: (i) overhead expenses of an ordinarily recurring nature such as rent, utilities, supplies, secretarial expenses, stationery, charges for furniture, fixtures and equipment, staff member benefits including insurance, payroll, and other taxes and compensation (and related costs) of all staff members of Sands Capital and its affiliates; and (ii) the following investment and technology related expenses: (a) third-party and out-ofpocket research and market data expenses (including, without limitation, news, quotation, statistics and pricing services, hardware, software, databases and other technical and telecommunications services, and equipment used generally in the investment management and order management processes of Sands Capital); (b) consulting fees and travel expenses in connection with investigating and monitoring potential and existing investments; (c) fees and expenses (including travel expenses) related to the analysis, purchase or sale of securities, whether or not the investments are consummated; (d) third party and out-of-pocket fees and expenses relating to systems and software used generally in connection with Sands Capital’s operations and investment related activities; and (e) third party technology services obtained generally for the benefit of Sands Capital and its clients. All other expenses of the SCM Private Funds will be borne by the SCM Private Funds, including: (i) legal, accounting, bookkeeping, tax and regulatory compliance, both domestically and internationally (including EU Alternative Investment Fund Managers Directive for marketing to EEA investors), auditing, consulting and other professional expenses, including those of valuation firms, and expenses associated with compliance with securities regulations of the U.S., the Cayman Islands and other jurisdictions applicable to the SCM Private Funds, (including Form PF, Form ADV, Form D and all amendments thereto); (ii) administration fees and other expenses charged by or relating to the services of third-party providers of administration services (including related indemnities), including the administrator of the SCM Private Funds, (iii) third party technology services specifically for the benefit of the SCM Private Funds and its investors; (iv) bank service,

custodial and similar fees; (v) expenses related to the purchase, monitoring, sale, settlement, custody, or transfer of SCM Private Funds assets (directly or through trading affiliates), including brokerage fees and expenses; (vi) third party and out-of-pocket fees and expenses relating to systems and software used specifically in connection with the operation of the SCM Private Funds; (vii) legal expenses (including settlement costs and costs arising in connection with a litigation or regulatory investigation instituted against the SCM Private Funds), governmental, regulatory, licensing, filing or registration fees and expenses; (viii) fees, costs, and expenses in connection with any advisory board or similar board or committee of the SCM Private Funds; (ix) any taxes, fees or other governmental charges levied against the SCM Private Funds; (x) fees and expenses relating to the offer and sale of interests in the SCM Private Funds (including, without limitation, organizational fees and expenses, as described below), and filing and legal fees; (xi) costs and expenses incurred in connection with the dissolution, winding up, or termination of the SCM Private Funds; (xii) costs and expenses incurred in connection with any meeting of the partners relating to the applicable SCM Private Fund; (xiii) expenses related to the SCM Private Funds’ indemnification obligations; (xiv) reorganizational expenses; (xv) registration, annual, and other similar fees payable by the SCM Private Funds; (xvi) such insurance, if any, as the general partners will deem necessary or appropriate for the conduct of the business of the SCM Private Funds; and (xvii) such other ordinary or extraordinary expenses associated with the operations of the SCM Private Funds as the general partners deem necessary or proper to incur. Notwithstanding the foregoing, the general partners have the ability to specially allocate the expenses described above in any other manner if a general partner reasonably determines, in its sole discretion, that it is equitable to do so. To the extent that expenses to be borne by the SCM Private Funds are paid by Sands Capital or its affiliates, the applicable SCM Private Fund will reimburse Sands Capital or its affiliates for such expenses. Our supervised persons do not receive compensation directly related to the sale of securities or other investment products, however, the sale of our advisory services or interests in the funds we manage is considered in the determination of the compensation of some staff members. This compensation is payable by Sands Capital and not by our clients or investors.

Investment Strategy Fundamental, bottom-up, company-focused research is the core of our investment process. All research analyses and conclusions are internally generated using a variety of internal and external information sources. Research activities include building proprietary financial models, scenario analyses, a written investment case relative to the business’s fit with our six investment criteria, and a hypothetical “sell case.” Environmental, social, and governance (“ESG”) factor analysis is integrated in our research activities. We focus on the ESG factors we consider most likely to have a material impact on the performance of securities in client accounts. In addition to third-party research, news articles, attendance at investment conferences, ESG research and analytics, expert research networks, annual reports, prospectuses, SEC filings, and company press releases, our investment professionals conduct on-site visits with senior management and investor relations departments of companies in which we invest or regard as potential investments. Portfolio construction and investment decisions are made by each strategy’s Portfolio Manager Decision Team (“PMDT”), determining the strategy model, including the weighting, timing, and funding source for purchases and sales. Portfolio construction and monitoring at Sands Capital are performed on an on-going basis, employing both qualitative and quantitative methodologies. Using a bottom-up research process and our investment criteria, new ideas are generally generated by the research team from an initial

universe that includes companies that are generating or are expected to generate above average earnings growth. After considerable research, creation of a formal investment case, and vetting, the PMDT makes the final decision about owning a business and its weight in the portfolio. As applicable, these decisions are team-based and reached by consensus. See additional information under Item 4 – Advisory Business. Risks of Investing – All Strategies Risk of Loss. Investing in securities involves risk of loss that clients should be prepared to bear. There may be loss or depreciation of the value of any investment due to the fluctuation of market values. The selection and execution of any investment strategy is inherently subject to a variety of risks beyond our control, including but, not limited to, risks associated with general economic conditions, the adequacy and timeliness of disclosures by issuers of securities, and market risks. Account Consent Requirements. Periodically, Sands Capital will, in its sole judgement, determine that consent from a client is necessary to make an investment or participate in a corporate event. If Sands Capital determines that consent is impractical due to timing or other considerations or consent is not received by an applicable due date, Sands Capital will not have the opportunity to make the investment for that client. Equity Securities Risk. Sands Capital’s strategies primarily focus on the purchase of equity securities. Most or all of these equity securities are common stocks. Common stocks represent a share of ownership in a company. In the event of liquidation, common stockholders have rights to a company’s assets only after bondholders, other debt holders, and preferred stockholders have been satisfied. The purchase of equity securities is subject to the risk that stock prices fall for extended periods of time. Historically, the equity markets have moved in cycles, and the value of equity securities may fluctuate drastically over various time periods. For example, individual companies report poor results or are negatively affected by industry and/or economic trends and developments. The prices of securities issued by a company may suffer a decline in response. These factors contribute to price volatility. Growth Investment Risk. We pursue a “growth style” of investing, meaning that we invest in equity securities of companies that we believe will increase their earnings at a rate that is generally higher than the rate expected for non-growth companies. If a growth company does not meet this expectation, the price of its stock may decline significantly, even if it has increased earnings. Many growth companies do not pay dividends. Concentrated Investment Risk. Sands Capital’s investment strategies are concentrated and are therefore less diversified and may experience wider fluctuations in value than if they were subject to broader diversification requirements. For example, certain investment strategies focus on a small number of issuers, industries, or regions. A decline in the market value of a particular security that is held in a higher allocation by a particular strategy is likely to affect the strategy’s

performance more than if the strategy invested in a larger number of issuers that are held in a lower allocation. Sector Focus Risk. To the extent Sands Capital’s strategies are more heavily invested in particular sectors, the value of investments could be sensitive to factors and economic risks that specifically affect those sectors. It is possible that economic, business or political developments and regulatory changes or other changes affecting one security in the sector of focus will affect other securities in that sector of focus in the same manner, thereby increasing the risk of such investments. Large Investor Risk. In certain situations, interests in an investment strategy are held by a large investor and in such an event, there is a risk that such large investors may impact Sands Capital’s investment strategy by purchasing or selling interests in large amounts. For example, when Sands Capital eliminates a large account’s interest or exits a position held in multiple accounts, the transacted shares may have an impact on the price or liquidity of the shares being sold, because there may be fewer or no willing buyers of those securities and they may have to be sold at a lower price or may not sell at all. Market Capitalization Risk. Although Sands Capital tends to invest in large companies seen as leaders in their respective business spaces, there is no limitation on the size or operating experience of the companies in which the investment strategies invest. Large-capitalization companies may lag the performance of smaller capitalization companies because large-capitalization companies may experience slower rates of growth and may not respond as quickly to market changes and opportunities. Smaller and mid-capitalization companies may be more vulnerable to adverse business or economic events than larger, more established companies. In particular, small- and midsized companies may pose additional risks, including liquidity risk, because they tend to have limited product lines, markets and financial resources, and may depend upon a relatively small management group. Therefore, small- and mid-capitalization stocks may be more volatile than those of larger companies. Management and Operational Risk. Sands Capital uses internally developed investment techniques and risk analysis to make investment decisions for the various strategies it manages. Consistent with the investment objectives, investments may be made in a broad range of issuers, securities, financial instruments, and transactions. Within these broad parameters, Sands Capital will make investment decisions for investment strategies as it deems appropriate in its sole discretion. The success of each strategy is dependent upon Sands Capital’s ability to achieve the investment objective. An investor must rely upon the ability of Sands Capital and Sands Capital’s investment professionals to identify and implement investment decisions consistent with applicable investment strategies, investment objectives, and policies. No assurance can be given that a client will be successful in obtaining suitable investments, or that if such investments are made, the objectives of the investment strategy will be achieved. A risk exists that the investment techniques will fail, thus there is no guarantee that they will produce the results desired by Sands Capital.

Clients have no authority or power to take part in the management of the investment strategies. The investment performance of the investment strategies depends on the skill of key staff members and investment professionals of Sands Capital. If key staff members, including key investment or key technical staff members, were to leave Sands Capital, we might not be able to find equally desirable replacements in a timely fashion and, as a result, the performance of the investment strategies could be adversely affected. In addition, the investment professionals of Sands Capital who are involved with the investment strategies perform services for other clients of Sands Capital and there is no requirement that these professionals devote any specific amount of their business time to the investment strategies. Liquidity Risk. A client may invest in assets that Sands Capital may not be able to readily sell or dispose of, including securities whose disposition is restricted by securities laws. A client’s ability to sell assets may be adversely affected by various factors, including limited trading volume, lack of a market maker, or legal restrictions including instances when Sands Capital or its affiliates come into possession of material non-public information. It is also possible that an exchange or governmental authority may suspend or restrict trading on an exchange or in particular securities or other instruments traded on the exchange. It may not always be possible to execute a buy or sell order at the desired price or to liquidate an open position, either due to market conditions on exchanges or due to the operation of daily price fluctuation limits (the maximum permitted fluctuation in the price of a futures or options contract during any trading day, also known as “circuit breakers.”) Currency Risk. Investments are generally subject to the risk that the value of a particular currency will change in relation to one or more other currencies, particularly when an investment is denominated in a currency other than a client’s home currency or when a company’s revenue or operating expenses are subject to fluctuating exchange rates. Among the factors that may affect currency values are trade balances, the level of short-term interest rates, differences in relative values of similar assets in different currencies, long-term opportunities for investment and capital appreciation and political developments. Officials in foreign countries may, from time to time, take actions with respect to their currencies that could significantly affect the value of a client’s assets denominated in those currencies or the liquidity of such investments. For example, a foreign government may unilaterally devalue its currency against other currencies, which would typically have the effect of reducing the U.S. dollar value of investments denominated in that currency. A foreign government may also limit the convertibility or repatriation of its currency or assets denominated in that currency. Valuation Risk. The process of valuing securities for which reliable market quotations are not available involves uncertainties and judgmental determinations. The resulting values may differ from values that would have been determined had readily available market quotations been available for such securities. As a result, the values placed on such securities by Sands Capital can differ from values placed on such securities by a client’s custodian or other investors as well as

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We provide investment management services to both U.S. and non-U.S. clients who have different tax statuses, often depending on the jurisdiction. Clients include, among other types, investment companies and other pooled investment vehicles, pension and profit-sharing plans, charitable organizations, state and municipal government entities, sovereign wealth funds and foreign official institutions, corporations, non-U.S. pension funds, superannuation funds, individuals, and banking or thrift institutions. Relationships with institutional and individual high net worth clients, family offices, and the financial intermediaries who represent these clients, are managed by a relationship director. The majority of these arrangements are discretionary; Sands Capital is free to select the investments and trade on the client’s behalf without prior consultation with the client. Additionally, we provide non-discretionary advisory services to Model Clients. Please refer to Item 4 – Advisory Business and Item 12 – Brokerage Practices for additional information on Model Clients.

Please refer to “Conditions for Managing Accounts” under Item 4 – Advisory Business for information on our minimum account size. Advised and Sub-Advised Pooled Vehicles We serve as investment adviser to:

Sands Capital Global Growth Fund, a separate investment series of The Advisors’ Inner Circle Fund, a U.S. registered, open-end investment company (mutual fund).

Sands Capital Funds, plc, an investment company authorized in Ireland by the Central Bank of Ireland under the Undertakings for Collective Investment in Transferable Securities (“UCITS”); which is the umbrella company for the following sub-funds: Sands Capital Global Growth Fund, Sands Capital US Select Growth Fund, Sands Capital Emerging Markets Growth Fund, Sands Capital Global Leaders Fund, Sands Capital Global Focus Fund, Sands Capital Global Shariah Fund, and Sands Capital Emerging Markets ex China Fund (“SCM UCITS Funds”).

Sands Capital Emerging Markets Growth Master Fund, L.P. a master-feeder structured private investment fund (“SCM Private Funds”). Please refer to Section 7 – Private Fund Reporting of Sands Capital’s ADV Part 1 for additional detail.

Sands Capital Collective Investment Trust which consists of the following funds: Sands Capital Emerging Markets Growth CIT, Sands Capital International Growth CIT, Sands Capital Global Growth CIT, Sands Capital Select Growth CIT, and Sands Capital Global Leaders CIT (“SCM CITs”).

Sands Capital Team Fund, L.P., a Cayman Islands exempted limited partnership (the “Proprietary Fund”). The Proprietary Fund currently offers series of limited partner interests associated with the following strategies: Select Growth, Global Growth, Global Leaders, Emerging Markets Growth, Focus, Technology Innovators, and Emerging Markets ex China. The Proprietary Fund is generally only available to Sands Capital staff members and former staff members. Please refer to Section 7 – Private Fund Reporting of Sands Capital’s ADV Part 1 for additional detail.

We also serve as investment sub-adviser to the following mutual funds and exchange traded funds:

GuideStone Growth Equity Fund

Old Westbury Large Cap Strategies Fund

Old Westbury Total Equity Fund (Model Client)

Russell Investments Emerging Markets Fund (Model Client)

Russell Investments Emerging Markets Equity ETF (Model Client)

Touchstone Sands Capital Emerging Markets ex-China Growth ETF

Touchstone Sands Capital Emerging Markets Growth Fund

Touchstone Sands Capital International Growth Equity Fund

Touchstone Sands Capital Select Growth Fund

Touchstone Sands Capital US Select Growth ETF

Transamerica International Focus

Transamerica International Focus VP

Venerable Emerging Markets Equity Fund (Model Client)

Additionally, Sands Capital serves as investment sub-adviser to various funds organized under the laws of foreign jurisdictions and offered outside of the U.S., and the firm provides investment management services to other private funds and pooled investment vehicles.

Performance-Based Fees At times, clients negotiate a performance-based fee and therefore will pay a fee based upon the performance of a client’s account versus a benchmark. Sands Capital has a limited number of these arrangements in place. Sands Capital clients who pay a performance-based fee have in the past and may in the future pay a higher fee than clients who do not pay a performance-based fee. Any performance-based fee arrangements will be consistent with the requirements of applicable

law, including the Advisers Act and, if applicable, the Employee Retirement Income Security Act of 1974. The existence of a performance-based fee arrangement creates an incentive for Sands Capital to make more speculative investments and/or pursue riskier strategies than it would otherwise do in the absence of performance-based compensation. Clients with similar investment results pay different fees due to their unique performance-based fee arrangement. This is a conflict of interest as Sands Capital has an incentive to favor those accounts for which Sands Capital receives a performance-based fee. Sands Capital has designed and implemented policies and procedures that seek to ensure that all clients are treated fairly and equally to prevent this conflict from influencing the allocation of investment opportunities among clients. Sands Capital does not consider individual client fee structures when allocating trades or investment opportunities. Please see Item 12 – Brokerage Practices for additional information. Additionally, we review performance of similarly managed accounts to monitor for performance outliers which can indicate favoritism and monitor trading activity and portfolio holdings of accounts to ensure that accounts within each strategy are managed similarly. Side-By-Side Management Sands Capital manages different types of accounts under different strategies and varying fee schedules, employing a variety of fee structures including performance-based fees in addition to asset-based management fees. Sands Capital’s portfolio managers make investment decisions for multiple strategies and portfolios including the SCM Private Funds, mutual and UCITS funds, institutional accounts, and separately managed accounts. These portfolio management responsibilities create conflicts of interest as described herein. We seek to conduct ourselves in a manner we consider to be the most fair and consistent with our fiduciary obligations to our clients. We make investment decisions based on an account’s available cash, investment objectives, restrictions, permitted investments, and other relevant considerations. Additionally, from time to time Sands Capital shares trading desk resources with the Advisory Affiliates, and such Advisory Affiliates may advise their respective clients regarding portfolio holdings that are also portfolio holdings of Sands Capital’s clients. Please refer to Item 12 – Brokerage Practices for additional information. Management of multiple portfolios can create conflicts of interest. The conflicts of interest that arise in managing multiple accounts include conflicts among investment strategies, conflicts in the allocation of investment opportunities, or conflicts due to different fees. A conflict of interest also arises where we have an incentive to favor accounts and/or investment strategies in which our staff members, the Advisory Affiliates, portfolio managers or our staff member benefit plans have a substantial interest. Conflicts of interest exist when portfolio managers manage accounts with similar investment objectives and strategies, and such accounts are managed by, one or any combination of, portfolio managers (“similar accounts”). A conflict of interest exists because of

the similar, different, or overlapping investment objectives and strategies, whereby the portfolio managers could favor one account over another. Due to their position with such accounts, the portfolio managers’ knowledge about the size, timing, and possible market impact of an account’s trades, could be used to benefit other accounts managed by them. Other conflicts include, for example, conflicts in the allocation of investment opportunities for similar accounts when there are limited investment opportunities. In such events, investment decisions are made by Sands Capital in its sole discretion, using its best judgment, and taking into account those factors it deems to be relevant. Such factors include one or more of the following: investment objectives, availability of cash, size of investments, or other restrictions or limitations imposed by law, regulation, or contract with respect to a client’s account. Sands Capital has established policies and procedures intended to result in the fair and equitable allocation of investment opportunities among Sands Capital’s clients over time. Please refer to Item 12 – Brokerage Practices for more information. Allocation of aggregated trades, particularly trade orders that were only partially completed due to limited availability and allocation of investment opportunities, generally, are conflicts of interest, as we have an incentive to allocate securities that are expected to increase in value to favored accounts. A conflict of interest arises if transactions in one account closely follow related transactions in a different account, such as when a purchase increases the value of securities previously purchased by another account or when a sale in one account decreases the sale price received by another account. Decisions to buy or sell a particular security for each client advised by Sands Capital are made by each strategy’s Portfolio Manager or team of Portfolio Managers, and as a result, a particular investment can be bought or sold for one client in different amounts, or at different times, than it is bought or sold for a different client. Similarly, an investment can be purchased for one client at the same time as it is sold for a different client. A conflict arises because actions with respect to one client are adverse to the interests of another client. Conflicts like those described above arise where clients are invested in different strategies or in different parts of an issuer’s capital structure, also including instances where one or more client (or a client of the Advisory Affiliates) owns private securities of an issuer and another client (or a client of the Advisory Affiliates) owns public securities of the same issuer. Actions by one client in one part of the capital structure can have an adverse consequence on clients in another part of the capital structure. We have a conflict of interest with respect to proprietary investments held in client accounts while the same investment is held in certain accounts related to Sands Capital. Such accounts would include a portfolio manager’s personal account, our staff member benefit plan, or funds in which our staff members invest and accounts owned by Sands Capital. We have adopted a Code of Ethics that governs a number of conflicts of interest we have when providing our advisory services to clients. Please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading for additional information.

Differences develop between the holdings and performance of accounts in the same investment strategy due to a variety of factors, including but not limited to, differences in account size, account restrictions or limitations, regulatory restrictions, registration in non-U.S. jurisdictions, cash flows, tax status, the timing and terms of execution of trades, and individual client needs. Sands Capital exercises limited discretion over the timing and order of registrations to trade in non-U.S. jurisdictions, which could result in certain client accounts’ availability to trade in such non-U.S. jurisdictions prior to others. We have established policies and procedures designed to manage the potential conflicts described above. We monitor a variety of areas, including compliance with account guidelines, review of allocations, compliance with our Code of Ethics, and any material discrepancies in the performance of similar accounts. As described under Item 12 – Brokerage Practices, we have policies and procedures designed to achieve fair and equitable allocation of investment opportunities among our clients over time. Certain Advisory Affiliates employ strategies that differ materially from Sands Capital's long-only equity approach but involve the same issuers or securities as those held in Sands Capital’s client accounts. Advisory Affiliates may engage in short selling, use over-the-counter (“OTC”) derivatives, employ leverage, and invest in or through pooled investment vehicles managed by unaffiliated third parties. The differing strategies employed by the Advisory Affiliates create potential conflicts, including opposite trading positions and competition for liquidity. For a detailed description of these conflicts and mitigation procedures, see Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading.

Sands Capital LP is the sole member of the Advisory Affiliates, and Sands Family Trust, LLC is the manager of the Advisory Affiliates. Other Affiliates of Sands Capital serve as general partners of private funds advised by the Advisory Affiliates. Sands Capital has entered into a services agreement with the Advisory Affiliates. Pursuant to this shared services arrangement, Sands Capital provides certain resources (e.g., including trading, investment research, marketing, compliance, human resources and other finance or administrative services) in order for the Advisory Affiliates to conduct their business. As part of this shared services arrangement, Sands Capital's trading desk executes securities transactions on behalf of the Advisory Affiliates' clients, including but not limited to short sales and OTC derivative transactions. Such transactions may involve heightened risk characteristics and potential conflicts of interest. See Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss and Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading. Sands Capital shares proprietary research and other information with the Advisory Affiliates and the Advisory Affiliates share similar information with Sands Capital from time to time. Certain clients of Sands Capital are also clients or investors of the Advisory Affiliates. The Advisory Affiliates and Sands Capital refer clients or investors to each other from time to time. Client participation, if any, in investment opportunities identified by the Advisory Affiliates is made through investments in pooled investment vehicles, which purchase and hold the securities of the underlying portfolio companies, through separately managed accounts, or through direct investments by such clients. Officers, staff members, and affiliates of Sands Capital invest in these opportunities alongside clients of the Advisory Affiliates or on a side-by-side basis through separate investment vehicles and invest in opportunities that are not presented to clients. Additionally, in the event the securities issued by a portfolio company in which the Advisory Affiliates’ clients, officers, staff members, or affiliates have indirectly invested become listed on

a national securities exchange and if the listed company meets the criteria for one of Sands Capital’s strategies, we may invest, and have invested, in such securities for our client accounts. For a description of potential conflicts of interest created by the relationship among Sands Capital and its affiliates, including its Advisory Affiliates, as well as a description of how such potential conflicts are addressed, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading. Sands Capital Emerging Markets Growth Fund-GP, LLC, a Delaware limited liability company, serves as general partner of Sands Capital Emerging Markets Growth Feeder Fund (DE), L.P., a Delaware limited partnership. Sands Capital Emerging Markets Growth Fund-GP Limited, a Cayman Islands exempted limited company, serves as general partner of Sands Capital Emerging Markets Growth Master Fund, L.P., a Cayman Islands exempted limited partnership (see Item 7 – Types of Clients for additional information). Sands Capital Team Fund-GP, LLC, a Delaware limited liability company, serves as general partner of Sands Capital Team Fund, L.P., a Cayman Islands exempted limited partnership (see Item 7 – Types of Clients for additional information). Please refer to Item 7 – Types of Clients for information regarding our mutual fund advisory and sub-advisory relationships.

Trading Sands Capital has adopted a Code of Ethics in compliance with the Advisers Act and the Investment Company Act of 1940, as amended. Sands Capital has designed the Code of Ethics to help ensure it meets its fiduciary obligations to its clients as well as to emphasize a culture of compliance at the firm. Conflicts of interest arise in connection with Sands Capital staff members having knowledge about the timing of transactions, opportunities, and/or broker selections and, therefore, have information about the implications of such transactions. As a result, Sands Capital’s staff members are in a position to use such information to their advantage and/or to the possible disadvantage of the clients. Additionally, staff members of Sands Capital and its affiliates provide advice and take action in connection with their investment advisory duties for some clients that differ from advice given, or the timing of actions taken, for other clients or with respect to their personal accounts. Therefore, while our staff members are permitted to buy or sell securities, or increase or decrease positions in securities for their own accounts that we also purchase or sell for our clients, including the purchase of private companies that they recommend to clients at or after initial public offering (“IPO”), these transactions must be in accordance with our Code of Ethics (which includes our personal trading policy) and our Insider Trading Policy. The Code of Ethics permits trading in

securities, including securities held by clients, subject to certain restrictions. Pre-clearance of equity transactions is required. Our staff members are generally prohibited from purchasing or selling securities that are part of an Investment Action (defined as a change in the holdings or weights of a model portfolio) for a designated time period (a “blackout period”) before and after the security has been purchased or sold for clients. However, staff members are permitted to trade in the same securities as clients during client cash flow transactions and in some cases get better market prices on their executions than clients receive on their cash flow transactions. Staff members are not required to take the same action for their personal account as they recommend for a client account and conversely, staff members are not required to take the same action for a client account as they would for their personal account. Please refer to “Trading Procedures – Cash Transactions” under Item 12 – Brokerage Practices for additional information covering these types of transactions. Certain personal securities transactions must receive written approval from the Chief Compliance Officer or her designee before the transaction can be initiated. The Code of Ethics requires periodic reporting of personal securities transactions and holdings reports upon hire and annually thereafter. Each calendar quarter, our staff members are required to provide all transactions in reportable securities to the Compliance Team. All Sands Capital staff members must also comply with all applicable federal securities laws. On a periodic basis, Sands Capital staff members are required to certify that they have read, understand, and have complied with the Code of Ethics and Insider Trading Policy. A copy of our Code of Ethics is available upon request. Please contact the Compliance Team at (703) 562-4000, writing to 1000 Wilson Blvd., Suite 3000, Arlington, VA 22209, or emailing complianceteam@sandscap.com. Sands Capital reserves the right to refine and modify the Code of Ethics and its other policies and procedures over time. No investor or prospective investor should invest with Sands Capital on the basis of, or otherwise rely on, the provisions thereof, and any such refinements or modifications have the potential to materially affect the investments available to the clients or the expenses borne thereby. Inside Information At times, officers and/or staff members of Sands Capital or its affiliates come into possession of material non-public information. Sands Capital and its affiliates generally operate without ethical screens or information barriers. As a result, Sands Capital and its affiliates generally impute material non-public information received by one to all investment professionals, however such information may not be imputed to all investment professionals, depending on specific facts and circumstances, including the potential use of a temporary information barrier. We have adopted an Insider Trading Policy applicable to Sands Capital, its affiliates, and their respective staff members to address trading (either personally or on behalf of others) using material non-public

information. In compliance with our policies and procedures and applicable securities laws, Sands Capital or its affiliates, and their staff members are prohibited from using or sharing such information to buy or sell securities for clients and in their personal accounts, until the information has been disclosed to the public, or is no longer material. Consequently, a client may be restricted from initiating a transaction or selling an investment which, if such information has not been known to it, may have been undertaken on account of applicable securities laws. Due to these restrictions, a client may not be able to make an investment that it otherwise might have made or sell an investment that it otherwise may have sold. The inability to buy or sell securities could adversely affect the client’s liquidity (ability to raise or invest cash), guidelines or restrictions and investment results. In the event Sands Capital receives material non-public information in connection with its investment advisory activities and services, Sands Capital may at times be restricted from disclosing such information to its clients or to use such information to effect transactions for its clients. In certain circumstances, Sands Capital is prohibited from disclosing or using such information to benefit a client. Additionally, Sands Capital or its affiliates or their respective staff members could be independent directors or insiders of public companies in which Sands Capital is invested or seeks to invest, and as a result Sands Capital’s trading in such securities may be restricted. From time to time, Sands Capital staff members: (i) serve on boards of directors and/or investment committees of other organizations that currently are, or may in the future become, clients of Sands Capital or its affiliates; (ii) in connection with the Advisory Affiliates, serve on the board of directors of a private company or have access to such a board through contractual rights of board observership; or (iii) be members of the boards of directors of publicly or privately held companies. This presents a conflict of interest if Sands Capital staff members become aware of material nonpublic information. Sands Capital may be unable to engage in transactions on behalf of clients while in possession of such information and place the security in question on a “restricted” list. At times, we intentionally obtain material, nonpublic information in order to assess an opportunity to participate in a transaction for certain client accounts. We maintain procedures and controls designed to segregate the information and limit its distribution to a small group of restricted staff members when practical. Those controls include a temporary restriction on trading in the issuer’s securities across all client accounts, including accounts that will not benefit from the transaction being considered. Before we take any steps that will result in a broad restriction on trading, we consider a variety of factors including the expected impact on any affected client accounts, the general merits of the investment opportunity and the expected duration of the trading restriction. When a temporary restriction on trading in a security is imposed, a portfolio manager may be required to forgo an investment decision he or she would otherwise make in client accounts, which could cause those accounts to experience a loss or be otherwise disadvantaged.

Restricted List In certain circumstances, particular securities are placed on a “restricted” or “blackout” list. While a security is on this list, purchases, sales, or other transactions in the security are prohibited. The reasons for placing a security on the restricted list include, but are not limited to, preventing: (i) the appearance of impropriety in connection with trading decisions; (ii) the use, or appearance of the use, of inside information; (iii) regulatory investment limitations from being exceeded; and (iv) concentration in a particular security. Side Letters; Most Favored Nation Provisions Sands Capital enters into certain investment advisory contracts with clients which include different or preferential rights or terms, including, but not limited to, different fee structures or information rights. Certain investment advisory contracts also have “most favored nation” provisions, which allow clients that meet certain criteria and characterizations (including, among other things, type of client, timing and size of investment made, and legacy status of client) to elect similar terms or rights. Sands Capital, in its sole discretion, shall determine whether a client meets the necessary criteria and characterization to elect terms or rights under any “most favored nation” provision. Except as otherwise agreed with a client, Sands Capital is not required to disclose the terms of investment advisory contracts with other clients. Additionally, Sands Capital entered into certain side letter arrangements with certain investors in the SCM UCITS Funds or SCM Private Funds providing such investors with different or preferential rights or terms, including, but not limited to, different Management Fees, waiver of minimum contributions and interest charges, agreeing to different admission dates, withdrawal dates, lock-up periods, notice periods, other restrictions, and permitting the revocation of withdrawal notices. Except as otherwise agreed with an investor or required by applicable regulation, Sands Capital is not required to disclose the terms of side letter arrangements with other investors in the same SCM Private Funds. Securities in which Sands Capital has a Financial Interest Sands Capital, on behalf of its clients, purchase or sell securities of companies in which Sands Capital or its affiliates (or their respective officers and staff members) have interests that were acquired in connection with the activities of the Advisory Affiliates. This creates a conflict of interest because it produces incentives to promote these securities over others. From time to time, Sands Capital will establish Seeded Accounts (proprietary accounts that are generally established for the purpose of developing new investment strategies and products). This creates a conflict of interest with our client accounts as our portfolio managers may be incentivized to focus extra attention on or allocate select investment opportunities to these accounts. To manage this conflict, we require that trades for Seeded Accounts be executed after the trades of all other

client accounts. Please refer to “Seeded Accounts” under Item 12 – Brokerage Practices for additional information. Investment opportunities may, from time to time, be appropriate for Sands Capital and may, from time to time, be appropriate for clients of an affiliate at the same, different, or overlapping levels of a portfolio company’s capital structure. Sands Capital may invest, and has invested for its client accounts, in securities of companies in which the Advisory Affiliates had invested prior to the company being listed on a national security exchange. In such cases, our affiliates (and our respective officers and staff members) will have a financial interest in the listed company. This creates a conflict because we have an incentive to promote these securities over others. To help manage these conflicts, we rely on various compliance controls including but not limited to the following:

We maintain a Code of Ethics, which reinforces our fiduciary duty to clients and, to address this specific conflict, prescribes additional restrictions regarding such financial interest;

We maintain written policies and procedures that describe the trade allocation and trade order practices of Sands Capital, and contain requirements related to marketing and advertising of Sands Capital’s services;

We have a Conflicts of Interest Board made up of senior executives of Sands Capital and its affiliates that will assess, and make recommendations with respect to, conflicts of interest and related policies and procedures;

We employ technological trading and compliance tools to monitor portfolio activities;

We review portfolios to ensure investments are consistent with clients’ guidelines and restrictions; and

We have procedures in place to limit the communication of confidential information between Sands Capital and our affiliates.

Valuation of Private Securities Sands Capital utilizes the valuation committee of the Advisory Affiliates, as appropriate, to conduct the valuation of private securities held in client accounts, which inherently involves some degree of discretion (please see “Private Company Risks” and “Valuation” under Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for additional detail). The exercise of valuation discretion by Sands Capital’s affiliate gives rise to conflicts of interest because valuations ultimately impact Sands Capital’s track record and the calculation of client fees.

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accounts that direct brokerage, including Directed Accounts and Trade Away Accounts, may be constrained from participating in these offerings. These accounts will purchase securities in the secondary market. The price received by these clients may be higher or lower than that of clients participating in the syndicated offering. Sands Capital’s Seeded Accounts, Proprietary Fund and non-discretionary Model Clients will not participate in syndicated offerings but will typically purchase these securities in the secondary market. Directed Brokerage Arrangements We normally select the broker-dealers that execute securities transactions for the accounts we manage. In certain instances where clients select the broker-dealers (known as “directed brokerage”), orders for those accounts will not be aggregated with orders for other managed

accounts and will be executed at different prices and commission rates than other client orders for the same security with the same broker-dealer. When a client instructs us to direct a portion of the transactions for its account to a specific broker-dealer, we will treat the clients direction as a decision by the client to withhold, to the extent of the direction, the discretion that we would otherwise have in selecting broker-dealers to affect transactions and in negotiating commissions for the client’s account. Although we will attempt to affect directed brokerage transactions in a manner consistent with our policy to seek prompt execution of orders in an efficient manner at a favorable price, we may not be able to obtain such execution for all of these transactions. Some of our clients have selected a broker-dealer to act as custodian for their assets and will direct us to execute transactions through that broker-dealer. It is not our practice to negotiate commission rates with such broker-dealers, even if we recommended the broker-dealer to the client. Clients directing brokerage may pay higher brokerage commissions than would be paid when we are free to determine the best available broker. In addition, we will not be able to aggregate directed brokerage orders with orders for other client accounts. We will typically affect directed brokerage transactions after those for client accounts for which we have full discretion. Please refer to “Trading for Discretionary Clients” under Item 12 – Brokerage Practices for additional information about the sequencing of client trades. Clients directing brokerage to a particular broker-dealer should consider whether the commissions, executions, clearance and settlement capabilities, and fees for custodial or other services provided to the client by that broker-dealer, if applicable, will be comparable to those otherwise obtainable. We expect custodial and brokerage firms to meet minimum requirements for operational efficiency and therefore not all custodians and brokerage firms will be acceptable to us. We also reserve the right to not accept a designated broker-dealer with whom we do not already have a working relationship. Certain clients hire us based on the recommendation of an investment consultant or other third party. We may execute these clients’ securities transactions through their consultant or its affiliate. We have a conflict of interest in using such brokers because it promotes additional client referrals from the consultant. Cross Trades and Principal Transactions When permitted by applicable law, we will, on infrequent occasions and subject to client consent, “cross” securities between client accounts. In such transactions, one client will purchase securities held by another client. As described in Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading, cross trades create a conflict of interest because Sands Capital acts as investment adviser to both the buying and selling client, whose interests with respect to the pricing and timing of the transaction may be adverse. Cross transactions are affected when we consider the transaction to be in the best interests of both clients and at a price determined by

reference to independent market indicators. Neither Sands Capital nor any related party receives any compensation in connection with such transactions. We maintain a record of each cross trade and the client accounts involved. Cross trades with a registered investment company are affected in compliance with all applicable requirements of the Investment Company Act of 1940, as amended. Please refer to “Best Execution” under Item 12 – Brokerage Practices for information about principal transactions. Seeded Accounts We have established “Seeded Accounts” for the purpose of developing new investment strategies and products. These accounts are typically in the form of separate accounts and are initially funded by Sands Capital or its affiliates. As many of our strategies have overlapping securities, it is likely that Seeded Accounts will invest in some of the same securities as client accounts. It is our policy to trade Seeded Accounts after all other accounts. In cases where the rotation consists only of Free Block Accounts and Seeded Accounts, there will be no blocking between the two accounts, and, in such cases, Seeded Accounts will transact only after the Free Block Accounts have received their full allocation. As Seeded Accounts are not normally included in Investment Action block trades to the same extent as client accounts, the price they receive may be better or worse than the price received by client accounts. Please refer to “Trading Procedures for Investment Actions” under Item 12 – Brokerage Practices for additional information. Trade Errors “Trade errors” are errors by Sands Capital when executing a client trade that are discovered preor post-settlement and that have had a financial impact in a client’s account. In this regard, a Trade Error Committee has been established, comprised of experienced staff members representing relevant functional groups within the firm to address the resolution of trade errors that may arise, from time to time. We attempt to resolve trade errors caused by Sands Capital as soon as reasonably practicable after discovery so that the affected clients will not suffer a loss. Trades will be adjusted as needed in order to put the client in such a position, as reasonably practical, as if the error had never occurred. If we are at fault for the trade error, the client will retain any profit when the trade is reversed. If we are at fault for a trade error and it is at a loss, Sands Capital reimburses the client for that loss. We will not use one client’s account to correct a trade error in another client’s account and we will not use future trade commissions to compensate a broker either directly or indirectly for absorbing the cost of correcting a trade error in an earlier transaction. When a trade error involves more than a single buy or sell, gains/losses owed to a client from an error will typically be determined on a net basis. When a third party is at fault for a mistake that caused negative financial impact, Sands Capital may, in its sole discretion, assist to facilitate the reimbursement on behalf of the impacted client. We do not use soft dollars to resolve trade errors.

Sands Capital relies primarily on the business development activities of our staff members to solicit new business. Some of Sands Capital’s clients use consultants to evaluate and recommend investment advisers and their services, including Sands Capital. Sands Capital is not affiliated with any consultant. These consultant firms represent multiple clients and prospects and, therefore, have frequent

interactions with Sands Capital and its affiliates. In addition, Sands Capital and its affiliates may engage and pay fees to consultants to attend consultant sponsored conferences or purchase analytical services and other research offered by them. Sands Capital pays nominal fees to be listed and include information about our investment strategies in consultant registries or databases that describe services provided by investment managers including Sands Capital. Sands Capital pays third-party platforms to make Sands Capital Global Growth Fund (for additional information please see Item 7 - Types of Clients Advised and Sub-Advised Pooled Vehicles) and SCM UCITS Funds (for additional information please see Item 7 - Types of Clients Advised and Sub-Advised Pooled Vehicles) available on their platforms. From time to time, Sands Capital enters into written referral agreements that involve the payment of a fee for introductions to prospective clients that lead to an investment mandate. In the event Sands Capital enters into such an arrangement terms, including the fee structure, will be disclosed to all affected prospective clients prior to the execution of an investment management agreement and in accordance with applicable law.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary event that would be material to an evaluation of their advisory business or the integrity of their management. Sands Capital has no such events and, therefore no information to disclose pursuant to this Item.

Account Review Sands Capital’s staff members review (at least quarterly) all client accounts on a regular basis. Most accounts will be reviewed more often, for example when cash flows or Investment Actions occur. Reviewers will evaluate the composition of a client’s account to that of the appropriate strategy model, taking into consideration any client specific restrictions or prohibitions, investment objectives, types of securities owned, investment process, performance, and similar matters. Accounts are under continuous review as far as examining the fundamentals of each security owned in an account. Accounts are reviewed after initial setup. Additional account reviews are conducted periodically by various teams within Sands Capital for compliance, cash flows, security weightings, and restrictions to ensure adherence to client guidelines, restrictions, or limitations. Accounts are also reviewed upon the occurrence of certain circumstances necessitating a review, including changes in economic or market conditions, changes in information about a specific issuer, purchases or sales of securities, or changes in staff members at Sands Capital. At any time, a client is able request a review of its account. Client Reporting Clients or their designated intermediaries typically receive a quarterly report of their accounts showing each asset and its cost, market value, and percent of total portfolio along with the total market value. Sands Capital’s year-end record of gains and losses may or may not agree with the client’s custodian statement. Upon request, we will provide commentary about the investment strategy and additional details related to transactions, performance, attribution, or other information on a monthly or other interim basis. In addition to the reporting provided to all investors, Sands Capital expects to provide certain investors with additional or more frequent information that other investors will not receive (e.g. under a side letter, investment management agreement, or in response to diligence or other requests).

Sands Capital does not act as custodian of any client account and does not have physical possession of any client’s funds or securities. Clients with separately managed accounts engage custodians directly to maintain custody of their funds and securities. Sands Capital is neither party to, nor responsible for the terms of any contract between a client and their custodian. Except as mentioned below, Sands Capital does not have custody of client assets. By virtue of its relationship with the SCM Private Funds, Sands Capital is deemed to have custody of the funds and securities of the SCM Private Funds. The SCM Private Funds’ cash and securities are held with one or more “qualified custodians” as defined under the Advisers Act, (generally a bank or broker dealer) independent of Sands Capital. Investors in the SCM Private Funds receive custodial statements from these “qualified custodians”. Furthermore, the SCM Private Funds are subject to annual audits in accordance with generally accepted accounting principles by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board and the audited financial statements are distributed to investors within 120 days of the end of the applicable fund’s fiscal year. In limited circumstances, Sands Capital is deemed to have custody of clients’ assets who invest directly in a private company or in investment vehicles (“Private Investment Funds”) sponsored and/or managed by Sands Capital or its affiliates. Clients investing in Private Investment Funds will receive quarterly statements directly from the custodian of the Private Investment Fund or, if such fund is subject to annual audit, audited financial statements prepared in accordance with

generally accepted accounting principles. In cases of direct private company investments, the relevant securities will be held at the client’s qualified custodian. These client accounts are required to undergo surprise examinations by an independent public accountant. Sands Capital has been deemed to have custody of certain other client assets by virtue of having been granted the authority to directly debit Sands Capital’s investment management fees from such clients’ accounts. In these arrangements, a client expressly authorizes Sands Capital to instruct the client’s custodian to periodically deduct the agreed investment management fees directly from the client’s account and to pay the fees to Sands Capital. Sands Capital seeks to confirm annually with its separately managed account clients’ custodians that clients are receiving custodial statements directly from their custodians for accounts in which authority has been granted to debit Sands Capital’s investment management fees. Clients should receive, at least quarterly, statements from the broker-dealer, bank, or other qualified custodian that holds and maintains their investment assets. We urge clients to carefully review their statements and compare official custodial records to the account statements that we provide. Our statements could vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Please refer to Item 13 – Review of Accounts for additional information.

We typically accept accounts where we are given full investment discretion (permission to make investment decisions for the account without prior consultation with the client). In certain cases, our discretionary authority regarding investments is subject to certain client limitations. These limitations are recognized as the individual investment policies and restrictions placed by the client on investments in certain businesses, industries, and/or securities. All such limitations are to be agreed upon in writing. Client accounts that are subject to limitations, or have temporarily or partially removed Sands Capital’s discretionary authority, may not be able to participate in aggregated trades as transactions for these accounts may be effected only after compliance with applicable limitations has been established. As a result, these accounts may receive a less favorable execution on portfolio transactions. Please refer to Item 12 – Brokerage Practices for additional information.

We have adopted policies and procedures with respect to the voting of proxies relating to securities held in client accounts. When a client has delegated responsibility for voting proxies to us, we evaluate and vote proxies in a manner consistent with the client’s best interests and in a manner that is consistent with our fiduciary duties. We may consider certain environmental, social and

governance factors when evaluating proxy matters so that all financial and non-financial risks and opportunities that may materially impact the outcome of an investment are appropriately considered. Before voting a particular proxy, our policy is to conduct a reasonable investigation of the associated matter(s), including, where appropriate, by considering our proxy voting guidelines to ensure that our voting determination is in the best interests of the relevant clients and is not based on materially inaccurate or incomplete information. We do not automatically support management; however, we believe that the recommendation of management on any issue should be given substantial weight in determining how proxy issues are resolved. Furthermore, there can be times when we determine that refraining from voting a proxy is in a client’s best interest, such as when the cost of voting exceeds the expected benefit to the client. For routine matters (e.g., those matters that are not expected to measurably change the structure, management, control or operation of the company and are consistent with customary industry standards and practices, and the laws of the state of incorporation of the applicable company), Sands Capital will vote in accordance with the recommendation of management, unless, in Sands Capital’s opinion, such recommendation is not conducive to long term value creation or otherwise in the best interest of its clients. Non-routine matters (e.g., those matters relating to directors’ liability and indemnity proposals; executive compensation plans; mergers, acquisitions, and other restructurings submitted to a shareholder vote; anti-takeover and related provisions; and shareholder proposals) require company-specific and a case-by-case review and analysis. Sands Capital’s staff members are responsible for notifying the Director of Stewardship or the Chief Compliance Officer of any potential conflict of interest that may impair Sands Capital’s ability to vote proxies in an objective manner. The Director of Stewardship and the Chief Compliance Officer will review each potential conflict and notify the Proxy Committee if they determine there is a conflict of interest with respect to the proxy vote. The Proxy Committee will determine whether the conflict is material to that proposal. If the Proxy Committee determines that a conflict is not material, then Sands Capital may vote the proxy. If the Proxy Committee determines that it is material, Sands Capital will vote or abstain from voting per the determination of the Proxy Committee. Prior to voting, Sands Capital may: (i) contact an independent third party for its recommendation on how to vote and consider voting in accordance with that recommendation; or (ii) fully disclose the nature of the conflict to clients and obtain their consent as to how we intend to vote. If a client participates in a securities lending program, Sands Capital will not be able to vote the proxy for shares out on loan. Sands Capital will generally not seek to recall for voting the client shares on loan. However, under rare circumstances, for voting issues that may have a particularly significant impact on the investment, Sands Capital may request a client to recall securities that are on loan if Sands Capital determines that the benefit of voting outweighs the costs and lost revenue to the client and the administrative burden of retrieving the securities.

Voting proxies of issuers may give rise to a number of administrative or operational issues that may cause Sands Capital to determine that voting such proxies are not in the best interest of its clients or that it is not reasonably possible to determine whether voting such proxies will be in the best interests of its clients. While not exhaustive, the following list of considerations highlights some potential instances in which a proxy vote might not be entered.

Sands Capital may receive meeting notices without enough time to fully consider the proxy or after the cut-off date for voting. Sands Capital may be unable to enter an informed vote in certain circumstances due to the lack of information provided in the proxy statement or by the issuer or other resolution sponsor. A market may require Sands Capital to provide local agents with a power of attorney or consularization prior to implementing Sands Capital’s voting instructions. Proxy materials may not be available in English and require a translator or may require traveling to a foreign country to vote the security in person. Proxy voting in certain countries may require “share blocking.” In such cases, shareholders wishing to vote their proxies must deposit their shares shortly before the date of the meeting with a designated depositary. During this blocking period, shares that will be voted at the meeting cannot be sold until the meeting has taken place and the shares are returned to the client’s custodian banks. Absent compelling reasons to the contrary, Sands Capital believes that the benefit to the client of exercising the vote is outweighed by the cost of voting (i.e., not being able to sell the shares during this period). Accordingly, if share blocking is required, Sands Capital generally elects not to vote those shares. The applicable Research Team member, in conjunction with the Proxy Committee, retains the final authority to determine whether to block the shares in the client’s portfolio.

We utilize a third-party service platform that provides vote execution, reporting, and recordkeeping services. We also engage independent proxy research providers that specialize in providing a variety of fiduciary-level proxy-related services that include in-depth research, global issuer analysis, and voting recommendations. While we review these providers’ recommendations, we vote all proxies based on our own proxy voting policies and in the best interests of clients. Clients can obtain information regarding how we voted proxies relating to securities held in their accounts, and/or request a copy of our proxy voting policies and procedures, by contacting the Compliance Team at (703) 562-4000, writing to 1000 Wilson Blvd., Suite 3000, Arlington, VA 22209, visiting our website at www.sandscapital.com or emailing to complianceteam@sandscap.com. Certain voting records are also available on our website. Class Actions and Other Litigation Matters In the event a class action is brought to the attention of Sands Capital, and such action may have a material impact on the financial position of a fund sponsored and advised by Sands Capital, Sands

Capital will use reasonable efforts to timely complete administrative class-action processes necessary to allow participation. For all other clients, Sands Capital will gather and provide any requisite information it has regarding class action matters at the client’s request, to enable the client to file the class action. Sands Capital does not take proactive measures to monitor for class actions in which its clients may be able to participate. All attorneys’ fees, third-party fees, and expenses related to the class action will be borne by the respective client, including any fund advised by Sands Capital if applicable.

Registered investment advisers with discretionary authority are required to disclose any financial commitment that is reasonably likely to impair their ability to meet contractual commitments to clients. We have no such commitments or any other information to disclose pursuant to this item.