SCHRODER INVESTMENT MANAGEMENT NORTH AMERICA INC/ DE

The Adviser is an affiliate of Schroders plc., a London Stock Exchange-listed financial services company. The Adviser is indirectly owned in its entirety by that public company. Trustees of certain settlements made by members of the Schroder family hold in excess of 25% of the voting shares of Schroders plc. Schroders has been in business since 1804. The Adviser registered with the Securities and Exchange Commission in 1980. The Adviser manages assets for domestic and foreign clients in strategies focusing on US equity, US fixed income securities, including US tax exempt securities, and securitized and asset-based finance investments. Those strategies are:

US Small Cap US Small/Mid Cap US Mid Cap US Large Cap Equity US Core Plus Municipal Bonds Intermediate and Short Term Global Credit (Corporate) US Credit (Corporate) Sustainable US Corporate US Buy & Maintain Corporate Global High Yield US High Yield Sustainable US High Yield Emerging Market Debt Multi-Sector (Relative Return) Emerging Market Debt Local Sector (Relative Return) Emerging Market Debt Hard Currency Sector (Relative Return) Emerging Market Debt (Total Return) Value Core Value Core with Labor Aware Corporates Value Short Duration Value Intermediate Duration Value Long Duration Value Long Credit Value Long Corporate Value Opportunistic Value Opportunistic Investment Grade Value Tax Aware Opportunistic Securitized Index IG Securitized Credit IG Securitized Credit Unconstrained Opportunistic Securitized Commercial Mortgage Loan ERISA Hi-Grade Flexible Securitized ERISA Flexible Secured Income Opportunistic Credit Commercial Real Estate Debt Opportunity

The Adviser also markets strategies focusing on non-US equity and fixed income securities as well as multi asset, systematic investments, quantitative and alternative strategies. For these strategies, the Adviser delegates portfolio management of the account to an affiliated adviser Schroder Investment Management North America Limited (“SIMNA Ltd”). SIMNA Ltd is regulated

by the Financial Conduct Authority in the United Kingdom and is also registered with the Securities and Exchange Commission as an investment adviser1 . Our non-US strategies include:

Global/International Equity Global/International Alpha International Alpha ADR Global/International Small Cap Emerging Markets Equity Emerging Markets Equity Alpha Frontier Markets Equity Global Emerging Markets Small Cap Global Climate Change Global Climate Leaders Global Sustainable Growth Global Innovation Global Energy Transition Global Sustainable Food & Water Healthcare Innovation Swiss Equities Asian Equities Indian Equities Global Unconstrained Fixed Income (Relative Return/Total Return)

The quantitative equity strategies are:

Global Core International (ex-US) Value Global Value Global Quality Global ESG Emerging Markets Core

The Systematic Investments strategies are: Sustainable Multi-Factor Equity Global Multi-Factor Equity All Country Quant Equity Emerging Markets Quant Equity Developed Markets Quant Equity US Quant Equity Asia Pacific ex Japan Quant Equity European Quant Equity Japanese Quant Equity UK Multi-Factor Equity / UK Yield Multi-Factor Equity Islamic Global Equity China A Quant Equity The multi-asset strategies are:

Diversified Growth Multi-Asset Retirement Target Return

The Adviser also offers alternative investment strategies including:

Commodities Total Return Commodities Enhanced Beta Active Real Return (Inflation Plus) Insurance-Linked Securities

The Adviser also offers Portfolio Solutions strategies including:

Risk-Managed US Equities Risk-Managed International Equities

The Advisor also offers the following strategy together with its sub-adviser Schroders Greencoat:

Schroders Capital US Labor Aware Infrastructure Fund

Schroders Greencoat US

Finally, the Adviser also markets strategies focusing on Japanese equities. For these strategies, the Adviser delegates portfolio management of the account to an affiliated adviser – Schroder Investment Management (Japan) Ltd (“SIM Japan”). SIM Japan is regulated by the Financial Services Agency in Japan and registered with the Securities and Exchange Commission as an investment adviser on February 20, 2020. The strategies that are marketed to US clients are:

Japanese Equity All Cap Japanese Equity Small Cap Japanese Equity Micro Cap

The Adviser primarily manages separate accounts on a discretionary basis for institutions, endowments, foundations, pension funds, government retirement plans, insurance companies and as sub-adviser, to registered investment companies sponsored by other advisers2 . The specific guidelines for these types of accounts are generally the subject of negotiation with clients. Clients may provide restrictions that differ from the Adviser’s usual style of managing a particular strategy. Some strategies – particularly fixed income – may have more latitude for accepting deviations from the ordinary management style of a strategy. The Adviser also serves as the manager and general partner of private investment partnerships or funds. The Adviser also subadvises funds that are registered with the SEC under the Investment Company Act of 1940. When investment management services are offered through US registered funds or private investment vehicles, any sales of those products directly to investors are conducted through an affiliated broker-dealer named Schroder Fund Advisors LLC (“SFA”). SFA is registered with the Financial Industry Regulatory Authority (”FINRA”). The FINRA license is a limited one. Other than fund sales, SFA does not execute securities transactions on behalf of clients of the Adviser. One of the registered funds for which the Adviser acts as sub-adviser specializes in private equity investments. In that case, the Adviser delegates portfolio management to its affiliate Schroders Capital Management (US) Inc., which is registered as an investment adviser with the Securities and Exchange Commission. The Adviser also manages some strategies for offshore affiliated advisers. This includes management of some offshore funds in Luxembourg. Not all of those strategies are available in the US. The Adviser has also registered as a Portfolio Manager in several Canadian provinces: Alberta, British Columbia, Manitoba, Nova Scotia, Ontario, Quebec and Saskatchewan. The Adviser does not sponsor a wrap fee program and does not actively manage accounts in wrap fee programs sponsored by others. It does provide model portfolios to wrap-fee program sponsors but all orders for the program’s accounts are raised by the wrap fee program sponsor. Each sponsor exercises investment discretion and executes each client’s portfolio transaction based on such sponsor’s own judgement. The Adviser does not provide model portfolios based on the individual needs of any one client.

Additionally, the advisor supports investment management activities provided by Schroder Investment Management (Switzerland) AG (CRD# 309892). For more details on their strategies, please refer to their brochure1As is the case with the Adviser, the mere fact that SIMNA Ltd is registered with the SEC does not imply that SIMNA Ltd personnel necessarily possess any particular level of skill or training. 2In a sub-advisory arrangement, the investment adviser appointed by the board of the fund delegates to another advisor the actual selection of securities

for the fund, typically on a discretionary basis. Other responsibilities for operation of the fund – such as pricing, marketing and preparing information for the fund board – are retained by the principal adviser.

The Adviser generally offers investment advisory services on a discretionary basis for institutions and pooled vehicles. It occasionally offers services on a non-discretionary advisory basis for certain clients. The prospectus of each registered fund advised or sub-advised by the Adviser sets forth the applicable fees and expenses. With respect to unregistered private funds managed by the Adviser, the applicable fees and expenses are set forth in the relevant offering or governing documents, or in certain cases, in a separate fee agreement between the Adviser and an investor in a private fund. The strategies available and the current standard fee structures for separate accounts are as follows: U.S. EQUITIES US Small Cap Core Management fee – 0.65% on first $50 million and 0.60% thereafter Minimum account size: $10 million US Small/Mid Cap Management fee – 0.65% on first $50 million, 0.60% on next $100 million, and 0.55% thereafter Minimum account size: $10 million US Mid Cap Management fee – 0.60% on first $50 million, 0.55% on next $100 million, and 0.50% thereafter Minimum account size: $10 million US Large Cap Equity Management fee – 0.50% on first $100 million, 0.40% on the next $100 million, and 0.35% thereafter Minimum account size: $50 million

FIXED INCOME US Core Aggregate Management fee – 0.25% on first $100 million, 0.20% on the next $100 million, and 0.15% thereafter Minimum account size: $40 million

US Core Plus Management fee – 0.30% on the first $100 million, 0.25% on the next $100 million, and 0.20% thereafter Minimum account size: $40 million Municipal Bonds: Intermediate & Short-Term Management fee – 0.292575% on first $50 million, 0.225% on the next $50 million, 0.1125% on the next $400 million, 0.09% for the next $500 million, and .072% thereafter Minimum account size: $50 million Global Credit (Corporate) Management fee – 0.35% on first $100 million, 0.25% on the next $100 million, and 0.20% thereafter Minimum account size: $100 million US Credit (Corporate) and Sustainable US Corporate Management fee – 0.30% on first $100 million, 0.25% on the next $100 million, and 0.20% thereafter Minimum account size: $100 million US Buy & Maintain Corporate Management fee – 0.14% on first $100 million, 0.13% on the next $150 million, 0.12% on the next $250 million, 0.10% on the next $500 million, 0.08% thereafter Minimum account size: $100 million High Yield: Global Management fee – 0.50% on first $100 million, 0.45% on the next $100 million, and 0.40% thereafter Minimum account size: $100 million High Yield: US and Sustainable US High Yield Management fee – 0.50% on first $100 million, 0.45% on the next $100 million, and 0.40% thereafter Minimum account size: $100 million Emerging Market Debt Multi-Sector (Relative Return) Management fee – 0.60% on first $100 million, 0.50% on the next $100 million, 0.40% on the next $300 million, and 0.35% thereafter Minimum account size: $100 million Emerging Market Debt Local Sector (Relative Return) Management fee – 0.60% on first $100 million, 0.50% on the next $100 million, 0.40% on the next $300 million, and 0.35% thereafter Minimum account size: $100 million Emerging Market Debt Hard Currency Management fee – 0.40% on first $100 million, 0.30% on the next $100 million, 0.20% on the next $300 million, and 0.15% thereafter Minimum account size: $100 million

Emerging Market Debt Hard Currency Sector (Relative Return) Management fee – 0.60% on first $100 million, 0.50% on the next $100 million, 0.40% on the next $300 million, and 0.35% thereafter Minimum account size: $100 million Emerging Market Debt (Total Return) Management fee: 0.70% on the first $100 million; 0.60% on the next $100 million; and 0.50% thereafter. Minimum account size: $100 million Value Core, Value Core with Labor Aware Corporates, Value Short Duration, , Value Intermediate Duration, Value Long Duration, Value Long Credit, Value Long Corporate, Value Opportunistic, Value Opportunistic Investment Grade, Management fee – 0.325% on first $50 million, 0.25% on the next $50 million, 0.125% on the next $400 million, 0.1% for the next $500 million, and .08% thereafter Minimum account size: $50 million Value Tax-Aware, Value Tax Aware Opportunistic Management fee – 0.2925% on first $50 million, 0.225% on the next $50 million, 0.1125% on the next $400 million, 0.09% for the next $500 million, and .072% thereafter Minimum account size: $50 million SECURITIZED PRODUCTS & ASSET-BASED FINANCE Securitized Index IG Management fee – 0.30% on first $250 million, 0.25% on the next $250 million, 0.175% on the next $500 million, and 0.15% thereafter Minimum account size: $250 million Securitized Credit IG Management fee – 0.375% on first $250 million, 0.325% on the next $250 million, 0.25% on the next $500 million, and 0.20% thereafter Minimum account size: $250 million Securitized Credit Unconstrained Management fee – 0.55% on first $250 million, 0.50% on the next $250 million, 0.45% on the next $500 million, and 0.40% thereafter Minimum account size: $250 million Opportunistic Securitized Management fee – 0.65% on first $350 million, 0.60% on the next $250 million, 0.55% on the next $200 million, and 0.50% thereafter Minimum account size: $350 million Commercial Mortgage Loan Management fee – 0.40% base fee Minimum account size: $300 million

ERISA Hi-Grade Flexible Securitized This strategy is available only through a pooled investment vehicle. ERISA Flexible Secured Income This strategy is available only through a pooled investment vehicle. Opportunistic Credit This strategy is available only through a pooled investment vehicle. Commercial Real Estate Debt Opportunity This strategy is available only through a pooled investment vehicle. NON-U.S. EQUITIES & FIXED INCOME Global/International Equity Management fee – 0.50% on first $100 million, 0.40% on next $100 million, and 0.35% thereafter Minimum account size: $50 million Global/International Alpha Management fee – 0.60% on first $100 million, 0.50% on next $100 million, and 0.45% thereafter Minimum account size: $50 million International Alpha ADR Offered only through model delivery to wrap-fee program sponsors Global/International Small Cap Management fee – 0.80% on first $100 million, 0.70% on next $100 million, and 0.60% thereafter Minimum account size: $100 million Emerging Markets Equity Management fee – .90% on first $100 million, 0.80% on the next $100 million, and 0.65% thereafter Minimum account size: $100 million Frontier Markets Equity Management fee – 1.20% on first $100 million and 1.00% thereafter Minimum account size: $75 million Emerging Markets Equity Alpha Management fee – .90% on first $100 million, 0.80% on the next $100 million, and 0.65% thereafter Minimum account size: $100 million Global Emerging Markets Small Cap Management fee – 1.20% on first $100 million and 1.00% thereafter Minimum account size: $75 million

Global Climate Change Management fee – 0.65% on first $100 million, 0.55% on the next $100 million, and 0.50% thereafter Minimum account size: $100 million Global Climate Leaders Management fee – 0.65% on first $100 million, 0.55% on the next $100 million, and 0.50% thereafter Minimum account size: $50 million Global Sustainable Growth Management fee – 0.65% on first $100 million, 0.55% on the next $100 million, and 0.50% thereafter Minimum account size: $50 million Global Innovation Management fee – 0.70% on first $100 million, 0.60% on the next $100 million, and 0.55% thereafter Minimum account size: $50 million Global Energy Transition Management fee – 0.65% on first $100 million, 0.60% on the next $100 million, and 0.55% thereafter Minimum account size: $100 million Global Sustainable Food and Water Management fee – 0.65% on first $100 million, 0.60% on the next $100 million, and 0.55% thereafter Minimum account size: $100 million Healthcare Innovation Management fee – 0.70% on first $100 million, 0.60% on the next $100 million, and 0.55% thereafter Minimum account size: $50 million Swiss Equities This strategy is available only through a pooled investment vehicle. Asian Equities Management fee – 0.90% on first $100 million, 0.80% on the next $100 million, and 0.75% thereafter Minimum account size: $100 million Indian Equities Management fee – 0.75% on first $100 million, 0.65% on the next $100 million, and 0.60% thereafter Minimum account size: $50 million Japanese Equities Management fee – 0.70% on first $100 million, 0.60% on the next $100 million, and 0.55% thereafter Minimum account size: $50 million

Global Unconstrained Fixed Income (Total Return) Management Fee –0.55% on first $100 million, 0.50% on the next $100 million, and 0.45% thereafter Minimum account size: Typically $100 million Global Unconstrained Fixed Income (Relative Return) Management fee – 0.40% on first $100 million, 0.35% on the next $100 million, and 0.30% thereafter Minimum account size: $50 million QUANTITATIVE EQUITY PRODUCTS (QEP) Global Core Management fee: 0.27% on the first $50 million, 0.22% from $50 million - $100 million, 0.19% from $100 million - $250 million, 0.16% from $250 million - $500 million, 0.14% thereafter Minimum account size: Typically $200 million International (ex-US) Value Management fee: 0.65% on first $100million, 0.55% on the next $100 million, and 0.40% thereafter Minimum account size: Typically $100 million Global Value Management fee: 0.65% on first $50 million, 0.55% on the next $100 million, 0.45% on the next $100 million and 0.40% thereafter Minimum account size: Typically $100 million Global Quality Management fee: 0.65% on first $50 million, 0.55% on the next $100 million, 0.45% on the next $100 million and 0.40% thereafter Minimum account size: Typically $100 million Global / ESG Management fee: 0.65% on first $50 million, 0.55% on the next $100 million, 0.45% on the next $100 million and 0.40% thereafter Minimum account size: Typically $100 million Emerging Markets Core Management fee: 0.35% on first $50 million, 0.32% $50m- $100m, 0.29% $100m - $250m, 0.26% $250m - $500m, and 0.24% thereafter Minimum account size: Typically $100 million

SYSTEMATIC INVESTMENTS Sustainable Multi-Factor Equity Management fee – 0.30% Minimum account size: Typically $100 million

Global Multi-Factor Equity Management fee – 0.30% Minimum account size: Typically $100 million All Country Quant Equity Management fee – 0.40% Minimum account size: Typically $100 million Emerging Markets Quant Equity Management fee – 0.4% Minimum account size: Typically $100 million Developed Markets Quant Equity Management fee – 0.30% Minimum account size: Typically $100 million US Quant Equity Management fee – 0.30% Minimum account size: Typically $100 million Asia Pacific ex Japan Quant Equity Management fee – 0.30 % Minimum account size: Typically $100 million European Quant Equity Management fee – 0.30% Minimum account size: Typically $100 million Japan Quant Equity Management fee – 0.30% Minimum account size: Typically $100 million UK Multi-Factor Equity / UK Yield Multi-Factor Equity Management fee – 0.30% Minimum account size: Typically $100 million Islamic Global Equity Management fee – 0605% Minimum account size: Typically $100 million China A Quant Equity Management fee – 0.50% Minimum account size: Typically $100 million

MULTI-ASSET Diversified Growth Management fee – 0.55% on first $200 million, 0.475% on the next $300 million, 0.425% on the next $500 million, 0.40% on the next $500 million, and 0.375% thereafter Minimum account size: $300 million Multi-Asset Retirement Target Return Collective Investment Trust Management Fee – Class 1: 0.36% for early bird with no account minimum, Class 2: 0.45% with no account minimum, Class 3: 0.440% got investors more than $200m

ALTERNATIVES Commodities Total Return Management fee: 0.70% on the first $100 million; 0.60% on the next $100 million; and 0.50% thereafter, plus a relative performance fee of 20% of outperformance over the Bloomberg Commodity TR Index (subject to watermark) Minimum account size: $100 million Commodities Enhanced Beta Management fee: 0.70% on the first $100 million; 0.60% on the next $100 million; and 0.50% thereafter. Minimum account size: $100 million Active Real Return (Inflation Plus) Management fee: 0.70% on the first $100 million; 0.60% on the next $100 million; and 0.50% thereafter. Minimum account size: $100 million Insurance-Linked Securities This strategy is available through pooled investment vehicles. Separate accounts are available with minimum account size of $100 million. Management fees for both depend on strategies and investment volume, Schroders Capital US Labor Aware Infrastructure Fund Management fee – tiered based on total LP commitments (1.25% up to $50 million, 1.15% up to $150 million, and 1.00% thereafter) Performance fee – 15% over 7% hurdle This strategy is available through a pooled investment vehicle Schroders Greencoat US Fund Management fee – 0.95% on the first $50 million, 0.85% on the next $150 million, 0.75% on the next $300 million, and 0.65% thereafter Performance fee – none Minimum investment size - $10 million This strategy is available only through a pooled investment vehicle.

PORTFOLIO SOLUTIONS U.S. Risk-Managed Equities 0.20% on 1st $250mm 0.15% on balance $150,000 per annum minimum fee Fees are assessed on notional exposure rather than the assets under management International Risk-Managed Equities 0.20% on 1st $250mm 0.15% on balance $150,000 per annum minimum fee Fees are assessed on notional exposure rather than the assets under management

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1.

Small Cap, Small/Mid Cap and Mid Cap Strategies

The US Small Cap, Small/Mid Cap and Mid Cap investment strategies use a bottom-up, fundamental and research based approach. Bob Kaynor, the portfolio manager, and a team of analysts work to identify companies that have compelling business models, strong management teams and attractive valuation levels. Research resources include company management, industry competitors, company filings, media and suppliers. Portfolios are diversified by type of company, with approximately 50-70% of the portfolio invested in what the Adviser believes are mispriced growth opportunities, 20-50% in “steady Eddies” (companies with stable and dependable earnings and revenue characteristics), and 0-10% in turnarounds. The strategies are flexible core investment styles; they aim to adapt to changing market dynamics throughout the economic cycle. The portfolios in the Small Cap strategy generally hold 80-120 stocks; the portfolios in the Small/Mid Cap strategy generally hold 80-120 stocks; and the portfolios in the Mid Cap strategy generally hold 60-80 stocks. The Small Cap strategy has as its benchmark The Russell 2000 Index; the Small/Mid Cap strategy has its benchmark the Russell 2500 Index; and the Mid Cap strategy has its benchmark the Russell MidCap Index. The Mid Cap strategy is also offered through model delivery to wrap-fee program sponsors. This version of the strategy differs slightly in that it, among other things, typically holds 50-70 stocks (as compared with 60-80 for a separate account) and excludes certain types of investments (e.g., IPOs, non-US securities, ETFs, futures, etc.). All investments involve risks including the risk of possible loss of principal. The market value of the portfolio may decline as a result of a number of factors, including adverse economic and market conditions, volatile political conditions, prospects of stocks in the portfolio, changing interest rates, and real or perceived adverse competitive industry conditions. Investments in small and medium capitalization companies generally carry a greater risk than is customarily associated with larger capitalization companies, which may include, for example, less public information, more limited financial resources and product lines, greater volatility, higher risk of failure than larger companies, and less liquidity. 2.

International and Global Small Cap

The International and Global Small Companies strategy has a core investment style with a growth bias. It is managed by a team led by Luke Biermann and Alex Deane (SIMNA Ltd) for International Small Cap and Luke Biermann and Bob Kaynor (SIMNA Inc.) for Global Small Cap. The investment strategy uses a bottom-up, fundamental, research-based approach. The portfolio managers and analysts seek to identify those companies that have compelling business models, strong management teams, attractive valuation levels and favorable long-term growth prospects. The team invests in undervalued stocks where it identifies catalysts for appreciation. In normal market conditions, the portfolio of approximately 125-175 stocks (approximately 200-250 for Global Small Cap) is diversified by region, country and type of company. It contains companies that typically exhibit solid return and growth characteristics, stronger than average balance sheets and cash flow attributes, and valuations broadly similar

to or below those of the universe. The focus is on companies’ long-term growth prospects with an investment horizon of approximately three years. The team seeks to manage risk at the security and country level. The portfolio managers pick stocks within a regional framework. The team reviews an entire portfolio, monitors the overall sector positioning and attempts to ensure that the balance of risks and return is within expectations. The team also determines how to distribute the portfolio among regions, placing emphasis on regions with the most attractive prospects for smaller companies. All investments, domestic and foreign, involve risks including the risk of possible loss of principal. The market value of the portfolio may decline as a result of a number of factors, including adverse economic and market conditions, volatile political conditions, prospects of stocks in the portfolio, changing interest rates, and real or perceived adverse competitive industry conditions. Investing overseas involves special risks including among others, enhanced risks related to political or economic instability, foreign currency (such as exchange, valuation, and fluctuation) risk, market entry or exit restrictions, illiquidity and taxation. Emerging markets pose greater risks than investments in developed markets. Investments in small capitalization companies generally carry greater risk than is customarily associated with larger capitalization companies, which may include, for example, less public information, more limited financial resources and product lines, greater volatility, higher risk of failure than larger companies, and less liquidity. 3.

Global and International Equities

The Global and International Equity strategies offers a high conviction, fundamental research-driven approach, aimed at delivering strong outperformance over the longer term within the context of a risk management framework. The portfolio management team at SIMNA Ltd works to identify those companies which will deliver positive earnings surprise (we term this ‘positive growth gap’). The strategies focus on selecting the best investment ideas that are identified by a team of global sector specialists who leverage the work of Schroders large network of locally based equity analysts. All investments, domestic and foreign, involve risks including the risk of possible loss of principal. The market value of the portfolio may decline as a result of a number of factors, including adverse economic and market conditions, prospects of stocks in the portfolio, changing interest rates, and real or perceived adverse competitive industry conditions. Investing overseas involves special risks including among others, risks related to political or economic instability, foreign currency (such as exchange, valuation, and fluctuation) risk, market entry or exit restrictions, illiquidity and taxation. Emerging markets pose greater risks than investments in developed markets. Products with high turnover may experience higher transaction costs. 4.

Emerging Markets Equity and Frontier Markets Equity

The Emerging Market Equity strategy, which is managed by SIMNA Ltd, provides diversified exposure to a range of developing countries around the world. Developing economies are generally growing at a faster rate than developed economies, which leads to the opportunity for premium returns but potentially with higher risk attached. Ideas may be generated from many sources including our ongoing program of company engagement, analysts’ core coverage requirement, macroeconomic assessments, and our experienced investment professionals. In addition, we employ a system of quantitative style screens to flag potential new investment ideas. The investable universe is primarily defined by the MSCI Emerging Markets Index, which covers 24 countries and approximately 1200 stocks (index data as at 31st December 2025). The Frontier Markets Equity strategy provides diversified exposure to a range of frontier market countries around the world. Frontier markets are at an even earlier stage of development than the emerging markets and offer some of the fastest rates of economic growth in the world. This leads to the opportunity for premium returns, although there can be potentially higher risk

attached. The primary investable universe is defined by the MSCI Frontiers Index which covers 28 countries and approximately 80 stocks, although the investment team will also invest in the wider frontier markets universe (index data as at 31st December 2021). Key characteristics of both strategies are summarized below:

50% of alpha generation is targeted from country allocation and 50% from stock decisions

Country decisions are guided by a proprietary quantitative country model together with judgment overlay

Fundamental in-house research with integrated ESG analysis, carried out by a large team of analysts drives stock

Risk management is applied in a proactive and disciplined fashion and includes tracking error targets and stop-loss

selection reviews

Team based approach organized around a matrix structure All investments, domestic and foreign, involve risks including the risk of possible loss of principal. The market value of the portfolio may decline as a result of a number of factors, including adverse economic and market conditions, prospects of stocks in the portfolio, changing interest rates, and real or perceived adverse competitive industry conditions. Investing overseas involves special risks including among others, risks related to political or economic instability, foreign currency (such as exchange, valuation, and fluctuation) risk, market entry or exit restrictions, illiquidity and taxation. Emerging markets pose greater risks than investments in developed markets. These risks include political and economic risks, civil conflicts and war, greater volatility, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, expropriation and nationalization risks, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in emerging markets. These countries may have relatively unstable governments and less-established market economies than developed countries. Emerging markets may face greater social, economic, regulatory and political uncertainties. These risks make investments in emerging market more volatile and less liquid than in more developed countries.

5.

Emerging Market Equity Alpha

The Emerging Market Equity Alpha strategy, which is managed by SIMNA Ltd, provides exposure to the team’s top graded stocks from developing countries around the world. Developing economies are generally growing at a faster rate than developed economies, which leads to the opportunity for premium returns but potentially with higher risk attached. Idea generation is driven by various sources including our ongoing program of company engagement, analysts’ core coverage requirement, macroeconomic assessments, and our experienced investment professionals. In addition, we employ a system of quantitative style screens to flag potential new investment ideas. The investable universe is primarily defined by the MSCI Emerging Markets Index, which covers 24 countries and approximately 1200 stocks (index data as at 31st December 2025), plus selected companies from the wider emerging and frontier markets universe. Key characteristics of the strategy are summarized below:

Alpha generation is targeted through bottom-up fundamental stock selection, driven by in-house research with integrated ESG analysis, carried out by a large team of analysts

Proactive and disciplined risk management including tracking error targets and stop-loss reviews is applied to produce a concentrated, high conviction portfolio of 30-50 stocks with no systematic style bias

Team based approach organized around a matrix structure All investments, domestic and foreign, involve risks including the risk of possible loss of principal. The market value of the portfolio may decline as a result of a number of factors, including adverse economic and market conditions, prospects of stocks in the portfolio, changing interest rates, and real or perceived adverse competitive industry conditions. Investing overseas involves special risks including among others, risks related to political or economic instability, foreign currency (such as exchange, valuation, and fluctuation) risk, market entry or exit restrictions, illiquidity and taxation. Emerging markets pose greater risks than investments in developed markets. These risks include political and economic risks, civil conflicts and war, greater volatility, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, expropriation and nationalization risks, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in emerging markets. These countries may have relatively unstable governments and less-established market economies than developed countries. Emerging markets may face greater social, economic, regulatory and political uncertainties. These risks make investments in emerging market more volatile and less liquid than in more developed countries.

6.

Global Emerging Markets Small Cap

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The Adviser provides investment management services predominantly to institutions, endowments, foundations, pension funds, government retirement plans, and insurance companies and, as sub-adviser, to registered investment companies sponsored by other advisers. These clients and prospects are usually sophisticated investors. The Adviser does offer municipal bond strategies through separate accounts and markets to high net worth clients in addition to institutions. The high net worth clientele generally consists of individuals, trusts, family offices, endowments, pension funds and private investment funds. The Adviser also sub-advises mutual funds open to retail investors but the Adviser almost exclusively markets to institutional clients and fund of funds products, who may have direct investments in the funds. As noted, the Adviser provides model portfolios to wrap-fee program sponsors, whose clients typically are in the high net worth category.

The Adviser manages private institutional vehicles including trusts and partnerships and offers those only on a private placement basis. In order to invest in private vehicles, prospective clients generally must be “qualified purchasers” as defined under Section 2(a) (51) of the Investment Company Act of 1940. The Adviser reserves the right not to enter into an advisory agreement with any person or institution for any legally acceptable reason.

The Adviser sometimes enters into agreements for performance-based fee with qualified clients. Some private funds also have fees calculated in part or in whole on performance. There are instances in which a portfolio manager is managing accounts in the same strategy that have differences in the fee paid by different accounts. This would include the management “side-by-side” of accounts with performance based and nonperformance based fee, including where the Adviser has made an investment in certain funds that also include a performance fee. Managers have a potential conflict of interest arising from the fee difference among accounts, including the possible incentive to favor accounts for which the Adviser receives performance based fees. Performance based fee arrangements may provide more of an incentive than asset based only fee arrangement for portfolio managers to make investments that may present a greater potential return but also present a greater risk of loss. Side-by-side management of accounts with different fee structures may also create an incentive for portfolio managers to allocate scarce investment opportunities to accounts that pay higher fees and those that pay performance based fees. To address these types of conflicts, the Adviser has adopted policies and procedures pursuant to which allocation decisions may not be influenced by fee arrangements, and investment opportunities are allocated in a manner that the Adviser believes is consistent with its fiduciary obligations to each client. Accounts in the same strategy are included in a single composite for the purposes of performance presentations for that strategy. Trades for accounts in the same strategy are generally carried out as aggregated trades. In such trades, each account gets an average price and shares pro rata in the transaction cost. Where trades are done in the aggregate, a portfolio manager cannot favor one account over the other. In addition, a performance committee consisting of investment and compliance staff oversees these composites including a review of any account that is an “outlier.” An outlier would be any account that deviated significantly from the performance of the composite as a whole. Portfolio managers are required to explain whenever account performance is significantly different than composite results. The Adviser believes that the outlier review would identify accounts that needed further analysis if a manager unduly favored one account in the same strategy.

The Adviser is registered with the National Futures Association as a Commodity Trading Advisor and Commodity Pool Operator. The Adviser is also registered as a Portfolio Manager with the Canadian Securities Commissions in Alberta, British Columbia, Manitoba, Nova Scotia, Ontario, Quebec and Saskatchewan. The Adviser maintains significant relationships relating to its advisory business with affiliated companies.

Schroder Investment Management North America Limited ("SIMNA Ltd”) provides sub-advisory services on fund and separate account mandates for strategies as described in Item 4. SIMNA Ltd is regulated by the Financial Conduct Authority in the United Kingdom and registered with the SEC. SIMNA Ltd is also registered in Canada as a Portfolio Manager with the Securities Commissions in Alberta, British Columbia, Manitoba, Nova Scotia, Ontario, Quebec and Saskatchewan. The Adviser oversees the management by SIMNA Ltd, but the overseas investment teams carry out day to day management of delegated accounts. SIMNA Ltd receives a portion of the advisory fees that the Adviser receives as compensation. Schroder Investment Management (Japan) Limited provides sub-advisory services on fund and separate account mandates for strategies as described in Item 4. SIM Japan is regulated by the Financial Services Agency in Japan and is registered with the SEC. The Adviser oversees the management by SIM Japan, but the Tokyo-based investment teams carry out day to day management of delegated accounts. SIM Japan receives a portion of the advisory fees that the Adviser receives as compensation. Schroder Fund Advisors LLC (“SFA”) is a wholly owned subsidiary registered as a broker dealer with FINRA and an exempt market dealer in Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland, Nova Scotia, Ontario, Quebec and Saskatchewan. SFA distributes equity interests of certain pooled investment vehicles that the Adviser and its affiliates advise. SFA may solicit existing qualified clients to invest into those vehicles. Schroders Capital Management US Inc. (“Schroders Capital Private Equity“) is an affiliate of the Adviser. Schroders Capital Private Equity is an asset manager investing in private equity globally and offers specialized investment solutions which allow the firm’s clients to access select private market segments through primary, secondary and direct/co-investments. There is a combined sales effort to market and sell Schroders Capital Private Equity’s products; however, Schroders Capital Private Equity’s investment management team operates independently of the Adviser’s investment teams. In addition, Schroders Capital Private Equity serves as the investment sub-sub-adviser to the Hartford Schroders Private Opportunities Fund, a fund for which the Adviser is the investment sub-adviser. Schroders Capital Private Equity investment professionals serve as the day-to-day portfolio managers for this Fund. The Adviser has delegated some back office functions to Schroder Investment Management Limited. (“SIM”). SIM is a Londonbased investment manager regulated by the Financial Conduct Authority and not registered with the SEC. It provides finance, clearance and settlement and IT system support for the Adviser.

The Adviser sometimes purchases for certain accounts shares of funds for which the Adviser serves as the investment manager. The Adviser will not assess its advisory fee on the portion of an account that is invested in such funds. Private investment funds organized by the Adviser invest in the same securities as those invested in behalf of other clients, including registered investment companies. The private investment funds’ trading methodologies are generally different than that of other accounts and may include short selling and the aggressive use of leverage. At times, the private investment funds may be selling short securities held long in other portfolios. The Adviser is aware of potential conflicts of interest created in part by the compensation structure of the funds. It has instituted procedures to assure that transactions effected on behalf of the private funds do not adversely impact other clients. The Adviser is the investment manager for the Schroder Capital Management Collective Trust. The Trust consists of commingled funds available to ERISA/Public Sector pension plans. Where the Adviser has discretion over allocation of pension assets, it may invest the pension’s funds in the Trust. In such instances, the Adviser will generally not assess an advisory fee at the trust level. The fees are generally negotiated at the time the agreement is executed when investments in the Trust are contemplated. The day to day management of the Trust has been delegated to SIMNA Ltd. The Adviser also is the investment adviser for certain collective investment trusts (“CITs”) for which SEI Trust Company, which is unaffiliated with the Adviser, serves as trustee. These CITs are commingled funds available to certain types of employee benefit plans. Where the Adviser has discretion over allocation of pension assets, it may invest the pension’s funds in one or more CITs. In such instances, the Adviser will generally not assess an advisory fee at the CIT level. The fees are generally negotiated at the time the agreement is executed when investments in one or more CITs are contemplated. The day to day management of some of the CITs has been delegated to SIMNA Ltd.

Transactions and Personal Trading The Adviser has adopted a Code of Ethics that sets forth the standards of business conduct that it requires of all its supervised persons. The Code of Ethics addresses the Adviser’s and its access persons’ fiduciary obligations to its clients. The Code also addresses confidentiality of client information and includes the Adviser’s Insider Trading Policy and its Policy on Personal Securities Transactions, discussed in further detail below. The Code of Ethics also requires all supervised persons to comply with the federal securities laws and to inform the Chief Compliance Officer of suspected violations of the Code. Clients or prospective clients who wish to request a copy of the Code of Ethics may do so by contacting the Chief Compliance Officer at Schroder Investment Management North America Inc., 7 Bryant Park, New York, NY 10018-3706. The Adviser’s officers, directors and employees may, from time to time, buy or sell for themselves securities issued by issuers whose securities the Adviser also buys or sells on behalf of clients. The Adviser imposes restrictions Thon such transactions in accordance with applicable law and regulations. All directors, officers, employees and supervised persons of the Adviser are subject to the provisions of a Code of Ethics regarding personal securities transactions and an Insider Trading Policy. These policies are designed to prevent conflicts of interest and violations of law by persons subject to the Code. In particular, all directors, officers and employees are required to pre-clear their personal transactions through a rules-based automated personal trade dealing system. In this way, all personal securities transactions can be monitored or, if necessary, prohibited or delayed so as not to conflict with a client transaction. The Adviser has also imposed upon employees a mandatory 60 day holding period on transactions in covered securities, including registered investment companies it advises or sub advises. From time to time and in accordance with the terms of the Adviser’s Code of Ethics, there are instances when the Adviser is precluded from trading in certain securities for its advisory clients’ accounts. These instances may arise if the Adviser receives material non-public information (“Inside Information”) from an issuer or otherwise. The Adviser's parent maintains a stop list, which consists of securities for which one or more persons at the Adviser or its affiliates may hold Inside Information. Employees

of the Adviser are not permitted to trade in those securities in their personal accounts. It is a violation of United States federal law and a serious breach of the Adviser’s policies for any employee to trade in, or recommend trading in, the securities of a issuer, for his/her personal gain or on behalf of the firm or its clients, while in possession inside information which may come into his/her possession either in the course of performing his/her duties, or through a breach of any duty of trust and confidence. Further, it is a violation of anti-fraud provisions of the Advisers Act for employees who are or become aware of transactions being considered for clients or are aware of the portfolio holdings in the reportable funds to which the Adviser (or an affiliate) acts an adviser to disclose such information to a party who has “no need to know” or to trade on such information for personal gain by, among other things, front-running or market timing.

The Adviser selects brokers or execution forums to try to obtain the overall best execution for its clients. The Adviser does not execute trades for clients through affiliated broker-dealers. Its traders route orders where they expect to obtain the most favorable overall price and efficient execution. Traders do not operate under constraints concerning their choice of brokers other than on the basis of their creditworthiness or client restrictions. The Adviser uses a number of brokerage firms. Some are full service firms that may execute on the Adviser’s behalf and others are electronic crossing networks, automated trading firms or execution-only firms. The Adviser deals with brokerage firms that it deems capable of providing best price and execution and is financially stable. All brokers are approved by a Credit Committee operated globally for the firm. The Committee reviews the brokerage firm when trading begins and at least once a year. Where appropriate the Adviser establishes credit limits for the counterparties. 1. Research Commissions The Adviser places trades for equity securities with broker-dealers that provide research. The Adviser may pay higher total commissions on equity trades when executing trades that include a provision for research. The Adviser’s Brokerage Committee proposes, reviews, and approves total commissions and the split of the commissions between the portion that compensates the broker-dealer for execution or research. US law permits the use of commissions to pay for research, and the Adviser programs are in compliance with the applicable regulatory requirements. Fixed income trades do not include a provision for research. Schroder entities that are subject to MiFID II such as SIMNA Ltd, have committed to pay the full cost of research for clients of those entities. Therefore, client accounts that have day to day management delegated by the Adviser to SIMNA Ltd will not have any of their commissions used to pay for research. Similarly, client accounts delegated to the Adviser by an affiliate subject to MiFID II will also not have their commissions used to pay for research. Client accounts that contract with the Adviser and whose day to day management is performed by the Adviser will continue to participate in the soft dollar programs described herein. The allocation of research costs paid by the Adviser and its affiliates on behalf clients subject to MiFID and those paid through the soft dollar program are reviewed at least annually. Accounts managed by SIM Japan do not utilize Research Commissions as Japanese law does not permit the use of commissions to pay for research. The Adviser may have an incentive to choose a broker-dealer based on receiving research or brokerage services. However, the trading desk trades where it believes it will obtain best execution and the receipt of research does not

factor in the traders’ decision. The Adviser tries to establish programs at the broker-dealers where its traders execute orders. The Adviser periodically reviews where the trading desk is trading and establishes or changes programs at its top broker-dealers. The Adviser considers best price and efficient execution as the paramount considerations in choosing where to trade for clients. The Adviser establishes maximum commission rates for equity trading by type of security and reviews those rates periodically based on industry standards. The Adviser reviews both commission rates and overall commissions to monitor whether trades are being executed within guidelines. For trades placed through some electronic crossing networks and automated trading systems, the commission rates may include total commissions that are above the minimum rate that broker-dealer provides for execution–only. Additional commissions may be paid in light of research services provided, typically provision of third party research and services from other broker-dealers or service providers. Research may constitute a larger portion of the total commission paid to electronic crossing networks or automated trading systems than a similar commission paid to a full service broker-dealer that charges higher execution rates as a result of committing its own capital or providing other execution services. The research products and services provided by broker-dealers through soft dollar arrangements benefit the Adviser and may benefit other clients of the Adviser. The Adviser may use the products and services in formulating investment advice for any and all advisory clients, including clients other than those that paid commissions to the broker-dealers on a particular transaction. As such, research generated by a particular client’s trade may not benefit that particular client’s account. The Adviser’s research programs make research payments under the safe harbor in Section 28(e) of the Exchange Act. The Adviser may obtain research through a variety of media including through verbal security analysis and opinion in these programs. The services the Adviser receives in its programs may include third party reports or services, seminars, computer software and certain related hardware for arranging and processing research data, portfolio evaluation services and brokerage services. Analysis of economic, political and market factors is also provided. The Adviser seeks research services that complement or expand on its internal research. When the Adviser delegates day to day management for a client account to SIMNA Ltd, trades for that account will ordinarily be placed by SIMNA Ltd.’s trading desk and no research commissions will be generated. The Adviser makes a good faith determination regarding the allocation of research costs borne by the Adviser and its affiliates and the costs borne by the clients participating in the soft dollar programs. This allocation is generally done on the basis of assets under management in a particular strategy that are subject to MiFID II relative to the assets under management in that strategy are not subject to MiFID II. Periodic reviews of the cost allocation are made by the Adviser. Portfolio managers periodically evaluate the value of the research products and services provided by brokerage firms. Broker-dealers providing general research services are ranked as to their usefulness. The Adviser may also request a broker-dealer to provide a specific research product or service which may be proprietary to the broker-dealer or produced by a third party. The Adviser does not agree with any broker-dealer to direct a specific or minimum amount of commissions. It makes no commitment to compensate the broker-dealer if commissions fall short of covering the target level of commission for the specific research service. Although not obligated to do so, the Adviser may, at its discretion, voluntarily pay the balance due in cash from its own resources. The Adviser may subscribe to investment research services that have a “mixed use”, i.e., a part of the service is used in the investment decision making process and a part is used for non-research purposes. The Adviser’s Brokerage Committee oversees its commission practices. The Committee includes representatives of the equity investment teams, trading, operations and compliance. The Committee reviews issues including: which broker-dealers the trading desk uses, soft dollar and other research programs, commission rates, the eligibility of services received and changes in research programs. Because of the nature of the markets, most bond transactions

are executed “over-the-counter” on a net basis. Therefore, execution ability dominates the decision for the selection of broker-dealers on bond transactions. With respect to fixed income transactions, the Adviser does not have any soft dollar arrangements with brokerdealers and does not direct client trades to particular broker-dealers in exchange for research or other soft dollar benefits. However, the Adviser may receive or have access to research generally made available by a broker-dealer to its clients. 2. Trade Aggregation and Allocation When the Adviser buys or sells securities for multiple clients, it ordinarily aggregates all client transactions to obtain more favorable prices, and efficient execution. Clients participating in an aggregated order will receive an average price and a pro-rata share of the transaction costs. There may be variable costs relating to aggregate trades imposed directly by the broker-dealer or custodian for an account that are not shared with other clients. Some clients may not be able to participate in because of regulatory or client-imposed restrictions. In those instances, trades are placed in a manner calculated to achieve the best overall execution for all clients. When the Adviser does not aggregate client orders traders may not be able to negotiate a single price for each client order and the prices may be less favorable than those achieved through aggregation. Commissions and transaction costs likely will not be uniform for all accounts. The Adviser may not aggregate orders for all clients for reasons including the following:

A client may direct that the Adviser use a specific type of broker such as the use of minority-owned broker dealers);

A client may prohibit the use of one or more broker-dealers, sometimes for regulatory reasons;

A client may require that the Adviser use a particular brokerage firm for some or all trades; or

Some offshore markets may prohibit trade aggregation.

The Adviser also maintains procedures for allocating initial public offerings (“IPOs”) for its accounts. Accounts that are similarly managed will generally aggregate their expressions of interest orders. Allocations of the shares in the IPO are made in a fair and equitable manner. The Adviser sometimes excludes accounts from participating based on a client restriction, such as broker restrictions. The Adviser allocates among eligible accounts on a pro-rata basis unless allocating a pro-rata would cause the participating account to receive only a de minimis amount such as a small odd lot. If an account could only receive a de minimis allocation, the Adviser will eliminate that account from the trade. If more than one portfolio manager indicates interest in an IPO, the allocation is first made to each portfolio manager based on the indications of interest and then allocated pro rata to each portfolio manager’s accounts. If the Adviser receives an allocation in an IPO too small to meaningfully aggregate, it will allocate to managers on an alternating basis. The Adviser then allocates to accounts for each manager in accordance with the policy set forth above. The Chief Compliance Officer must approve any allocation made other than on a pro-rata basis. The Adviser may manage accounts that have significant investment by affiliates of the Adviser, as seed capital or as capital investments. In circumstances where the interest in an account on behalf of an affiliate of the Adviser exceeds 25%, the Adviser places restrictions on the trading of those accounts. Such accounts may be included in aggregated trades but only when its participation has been determined prior to the order, and the account may receive no more than a pro-rata allocation of securities. Trades in municipal bonds often are for small lots that cannot be allocated across all accounts. The Adviser generally allocates among client accounts based on one or more of the following criteria:

Client guidelines, including state specific needs;

Cash availability;

Duration needs;

Sector needs, and

Client restrictions, including issuer limitations, ratings, etc.

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The Adviser compensates affiliated persons for client solicitations and does occasionally enter into solicitation agreements with unaffiliated third parties. For affiliated persons, compensation is done on a discretionary basis. Assets raised are taken into account in determining discretionary bonuses. For unaffiliated persons, the Adviser will pay a portion of its advisory fee to the third party for introducing or servicing accounts. All such arrangements must comply with SEC Rule 206(4)-3. Among other requirements, the Adviser must ensure that the third party provides a written disclosure statement that sets forth the terms of the arrangement. The costs of any such referral fees would be paid entirely by the Adviser and therefore would not result in any additional charges to the client. SIMNA has entered into a solicitation agreement with Hartford Funds Management Company (“HFMC”) pursuant to which HFMC will refer, offer and provide marketing support services with respect to certain strategies that the Adviser offers through separately-managed account or unified managed account platforms. SIMNA pays HFMC a fee based on the Adviser’s assets under management in each of the sponsor programs in which it participates. At this time, this is the only solicitation arrangement that the Adviser has with unaffiliated third parties.

There have been no disciplinary actions against the Adviser, its officers or directors.

Portfolio managers review all transactions in client accounts on a daily basis. The Adviser also assigns product managers to each team. The product manager reviews the portfolio characteristics and act as the liaison with clients. Portfolio managers or product managers approve client reports before the Adviser sends them to clients. Additional reviews take place when necessary. The events that might trigger additional reviews can include changes in client objectives; unusual investment environments; or a change in investment strategy. The Adviser uses an automated system that allows its compliance function to review trades daily to confirm that the trades meet regulatory requirements and client guidelines.

The Adviser does not take or retain custody of client funds or securities. Clients retain their own custodians and the Adviser does not make custodial recommendations. However, the Adviser and certain affiliates do act as general partner to some private institutional partnerships and therefore is deemed to have custody under Rule 206(4)-2 under the Advisers Act. The partnerships are audited and the audit reports delivered to investors in the partnerships in compliance with Rule 206(4)-2. The Adviser has authority to deduct fees for some clients.

The Adviser generally manages investments on a discretionary basis. Under a discretionary arrangement, portfolio managers have the authority to determine which securities to buy and sell on the client’s behalf and at the client’s risk, consistent with the client’s investment guidelines. In some instances, however, there are restrictions imposed by clients on investments in specific industries or companies. The Adviser provides model portfolios to sponsors of third party wrap programs. In those instances, the Adviser only has discretion over the model. The sponsoring firm raises all orders for the underlying accounts after determining how to implement the model for its individual clients. The Adviser does not include the assets in model portfolio programs as part of its assets under management as set forth in Item 4 above. The Adviser has entered into trade delegation agreements under which (i) orders from offshore affiliates route orders in US securities to the Adviser’s trading desk for execution and (ii) orders it raises for client accounts in foreign securities are routed to the trading desk of affiliated advisers for execution. In such instances, those orders typically are aggregated with orders for the Adviser’s clients or executed sequentially subject to a written order priority procedure.

The Adviser treats the voting of proxies as an important part of its management of client assets. It votes proxies in a manner that it deems most likely to protect and enhance the longer term value of the security as an asset to the account. The Adviser has a Proxy Committee consisting of investment professionals and other officers which is responsible for ensuring compliance with its proxy voting policy. That committee includes input from all offices including affiliated advisers. The actual voting of proxies is carried out by Schroder Investment Management Ltd., the UK affiliate of the Adviser. When voting proxies, the Adviser and its affiliates follow Schroders’ Voting Guidelines (the “Guidelines”). The Guidelines sets forth positions on recurring issues and criteria for addressing non-recurring issues. The Proxy Committee exercises oversight to assure that proxies are voted in accordance with the Guidelines and that any votes inconsistent with the Policy are documented. The Adviser uses proxy research from third party service providers. It considers their recommendations for voting on particular proxy proposals. The Adviser bears ultimate responsibility for proxy voting decisions. Occasionally, proxy voting proposals will raise conflicts between the Adviser’s interests and those of its clients. Those conflicts are managed in accordance with the procedures set out in the Guidelines and our Proxy Voting Policy. If the Adviser receives a proxy relating to an issuer that raises a material conflict of interest, the proxy is voted after review by the Global Head of Equities. The proxy will be voted as follows:

If a proposal or aspect of the meeting business is specifically addressed by the Guidelines, the Adviser will vote or act in accordance with the Guidelines unless the Adviser considers it is in the best interests of clients to depart from the Guidelines. In that case or if the proposal or meeting business is not specifically covered by the Guidelines, the Adviser may vote or act as it determines to be in the best interest of clients, provided that such vote or action would be against the Adviser’s own interest in the matter.

If the Adviser believes it should vote in a way that may also benefit, or be perceived to benefit, its own interest, then the Adviser will either (a) vote in accordance with the recommendations of a third party (which will be the supplier of our proxy voting processing and research service); or (b) obtain approval of the decision from the Adviser’s Head of

Equities: the rationale of such vote will be recorded in writing; or (c) in exceptional cases, inform the client(s) of the conflict of interest and obtain consent to vote as recommended by the Adviser. If the third-party recommendation is unavailable, we will not vote. A copy of the Guidelines and information as to specific votes are available to clients upon request. Requests should be made to your Client Service Representative.

The Adviser is a subsidiary of a public company in the UK, Schroders plc. Schroders plc. is listed on the London Stock Exchange. The shareholder reports for Schroders plc. are available on the internet at http://ir.schroders.com/. Clients or prospective clients may also obtain copies of Schroders plc. reports by contacting their Client Service Representative.