Sompo Asset Management Co., LTD.

Sompo Asset Management Co., Ltd. (“SAM”) was established in February of 1986 as an asset manager with its principal office and place of business in Tokyo, Japan. SAM is a wholly owned subsidiary of SOMPO Holdings, Inc. (“SOMPO”). SOMPO is a publicly traded company listed on the Tokyo Stock Exchange. SAM first registered as a registered investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) in May 2017. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. SAM’s investment philosophy is: •

All securities have an intrinsic value and that the market price tends towards the intrinsic value over time, although interim discrepancies occur;

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Intrinsic value is defined, for us, by asset's future cash flows; and

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Market behavior provides exploitable discrepancies between market price and intrinsic value.

As of March 31, 2026, SAM provides discretionary investment management services to non-U.S. separately managed accounts with approximately $25,391 million in assets under management. In addition, SAM provides model portfolio services to certain Clients (“Investment Model Clients”), who use the investment models provided by SAM as a basis for trades that they may execute in the accounts of their Clients. As of March 31, 2026, SAM provided advice to Investment Model Clients with assets under management in the amount of $33 million. SAM does not have discretionary authority on the Investment Model Clients’ assets. Furthermore, the Investment Model Clients’ assets are not included in the calculation of SAM’s regulatory assets under management because SAM is not responsible for arranging or effecting the purchase or sale of specific securities in those accounts.

For U.S. based Clients, SAM receives a fee based on a percentage of assets under management. SAM does not have a standardized fee schedule. Each fee is agreed upon between the Client and SAM and is documented in each advisory agreement. SAM only charges fees in arrears that are based on a percentage of assets under management. Management fees are generally calculated and paid quarterly in arrears. SAM invoices each Client who pays SAM directly. SAM does not have the authority to debit fees for services provided. Clients are either provided an invoice or calculate their own fee and pay SAM via a wire or check.

The management fee may be waived, reduced or calculated differently with respect to SAM’s affiliates, members or employees or any particular affiliated or unaffiliated Client at SAM’s discretion. Investment Model Clients As noted above, SAM provides investment model portfolio services to Investment Model Clients. SAM amends and updates the model portfolios from time to time and provides updated information to the Client. In such programs, the Investment Model Client typically pays a fee to SAM as compensation for the investment advisory services that it renders to the Client. SAM is not responsible for placing trades for its Investment Model Clients.

Overall Investment Strategy and Methods of Analysis On behalf of our Clients, we primarily focus on Japanese equity and bond related strategies. To achieve the investment goals of a Client, we may engage in investment strategies that include derivatives and foreign-exchange contracts. Since our inception, we have adhered to a disciplined investment process that includes fundamental research, return analysis and portfolio construction. SAM performs detailed, bottom-up analysis and financial modeling on an individual company basis to understand their earnings. SAM seeks to develop proprietary and unique information via its fundamental research. This fundamental analysis may cover (a) annual reports, financial statements, earnings releases, press statements, regulatory filings of companies of interest; (b) communication with and assessment of company management; company visits; (c) industry

research and analysis; (d) competitor, supplier and customer contact and analysis; (e) discussions with sell-side and buy-side analysts; and (f) discussions with industry experts and consultants. Material Risks Investing involves substantial risks, including the risk of total loss of capital, and may not be suitable for all Clients. No guarantee or representation is made that SAM’s investment strategy will be successful. Investment results may vary substantially over time. No assurance can be made that profits will be achieved or that substantial or complete losses will not be incurred. Past results of investments made by the investment professionals of SAM are not necessarily indicative of a Client’s future performance. The following are certain principal risks associated with the investment activities of SAM: Equity Securities – The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short term as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and "growth" stocks can react differently from "value" stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Clients also may be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering or otherwise qualifying restricted securities for public resale. Investments in Corporate Debt and other Fixed Income Securities – These securities may pay fixed, variable or floating rates of interest, and may include zero coupon obligations. Fixed income securities are subject to the risk of the issuer’s inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (i.e., market risk). A major economic recession could disrupt severely the market for such securities and may have an adverse impact on the value of such securities. In addition, any such economic downturn could adversely affect the ability of the issuers of such securities to repay principal and pay interest thereon and increase the incidence of default for such securities. Investments in Preferred Shares – Client’s portfolios may invest in the preferred shares of certain companies. Preferred shares may pay dividends at a specific rate and generally have preference over common stock in the payment of dividends in a liquidation of assets but rank after debt securities. Unlike interest payments on debt securities, dividends on preferred shares are generally payable at the discretion of the board of directors of the issuer. The market prices of preferred shares are subject to changes in interest rates and are more sensitive to changes in the issuer’s creditworthiness than are the prices of debt securities. REIT Securities Risk – A Real Estate Investment Trust (“REIT”) is an entity, typically a trust or corporation that accepts investments from a number of investors, pools the money, and then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income and the

relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. Such investment focus can be beneficial if the properties are successful, but lose significant principal if the properties are not successful. REITs may also employ significant leverage for the purpose of purchasing more investments with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The success of a REIT is highly dependent upon the manager of the REIT. Investments in Restricted Investments – Client portfolios may invest its assets in restricted securities or securities that are subject to certain liquidity restrictions, including, without limitation, lock-up periods. These securities may be subject to legal or contractual restrictions on resale and transfer and, therefore, may be illiquid and subject to wide fluctuations in value. Such securities may be held by Clients until the occurrence of certain events or for an extended period, as determined by SAM’s investment personnel. The resale of restricted and illiquid securities may be difficult to value and oftentimes may have higher brokerage charges. Lack of Diversification – Client’s portfolios generally will not be diversified among a wide range of types of securities or issuers. Further, the Client’s portfolio may not be diversified among a wide range of industry, geographic or sector areas. In fact, Client accounts may be highly concentrated. Further, the portfolio overall may represent only a few investment themes. This concentration of risk may increase the losses suffered by Clients or reduce its ability to hedge its exposure and to dispose of depreciating assets. Accordingly, the investment portfolios of Clients may be subject to concentration risks and more rapid change in value than would be the case if Clients were required to maintain a broader diversification among types of securities, issues, investment themes, industry, geographic or sector areas. Limited diversity could expose Client accounts to losses disproportionate to those incurred by the market in general if the areas in which Client investments are concentrated are disproportionately adversely affected by price movements in those financial instruments or assets. Non-U.S. Investments – Investing in securities of non-U.S. companies, which are generally denominated in non-U.S. currencies, involves certain considerations comprising both risks and opportunities not typically associated with investing in U.S. companies. These considerations include changes in exchange rates and exchange control regulations, political and social instability, expropriation, imposition of non-U.S. taxes, less liquid markets and less available and lower quality information than is generally the case in the United States, higher transaction costs, less government supervision of exchanges, brokers and issuers, greater risks associated with counterparties and settlement, greater difficulty in enforcing contractual obligations, lack of uniform accounting and auditing standards and greater price volatility. Currency Risks – Client investments that are denominated in currencies other than the U.S. dollar are subject to the risk that the value of the particular currency will change in relation to one or more other currencies. As a result, Clients could realize a net loss on an investment, even if there were a gain on the underlying investment before currency losses were taken into account. 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.

Counterparty Risk – Counterparty risk arises from each party with whom our Clients contract for the purpose of making derivative investments off-exchange, over any foreign exchange or in over-the-counter transactions (the “Counterparty”). In the event of the Counterparty’s default or bankruptcy, our Clients will typically only rank as unsecured creditors and risk the loss of all or a portion of the amounts they are contractually entitled to receive. Lack of Liquidity – Client assets may, at any given time, include securities and other financial instruments or obligations which are thinly-traded or for which no market exists and/or which are restricted as to their transferability under applicable securities laws. Dispositions of investments may be subject to contractual or other limitations on transfer or other restrictions that would interfere with subsequent sales of such investments or adversely affect the terms that could be obtained upon any disposition thereof. The sale of any such investments may be possible only at substantial discounts and it may be difficult to accurately value any such investments. Leverage – Subject to applicable regulations, Clients may leverage their capital if it is believed that the use of leverage may enable the achievement of a higher rate of return. Accordingly, Clients may pledge their securities to borrow additional funds for investment purposes. The amount of borrowings which Clients may have outstanding at any time may be substantial in relation to their capital. Performance will likely be more volatile with the use of leverage. Importance of Key Employees of SAM – The authority to make decisions and to exercise business discretion on behalf of Clients is delegated to SAM. The success of Clients is expected to depend on the expertise of certain of SAM key employees. Therefore, the death incapacity or withdrawal of such employees could materially affect Clients. Accuracy of Public Information – SAM selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to SAM by the issuers or through sources other than the issuers. SAM evaluates all such information and data and ordinarily seeks independent corroboration when SAM considers it appropriate and when it is reasonably available. SAM is not in a position to confirm the completeness, genuineness or accuracy of all such information and data, and in some cases, complete and accurate information is not available. Risk Management Failures – Although SAM attempts to identify, monitor and manage significant risks, these efforts do not take all risks into account and there can be no assurance that these efforts will be effective. Moreover, many risk management techniques, including those employed by SAM, are based on historical market behavior, but future market behavior may be entirely different and, accordingly, the risk management techniques employed on behalf of Clients may be incomplete or altogether ineffective. Similarly, SAM may be ineffective in implementing or applying risk management techniques. Any inadequacy or failure in risk management efforts could result in material losses to Clients. Environmental, Social, and Governance Investing Risk – The use of ESG factors could result in selling or avoiding investments that subsequently perform well or purchasing investments that subsequently underperform. As a result, accounts that take ESG factors into account could underperform similar accounts that do not take into account ESG factors.

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SAM provides investment advisory services, on a discretionary basis, primarily to institutional Clients, which include, but are not limited to, pension funds, financial institutions, multi-manager funds, family offices, high net worth individuals, and private banks. SAM also provides investment advisory services to institutional Clients through the provision of model portfolios as described above in Item 5. SAM negotiates each Client relationship. Normally, SAM’s minimum for entering into a Client advisory account is $50 million dollars.

SAM does not charge any performance fees to U.S. Clients. Some investment advisers experience conflicts of interest in connection with the side-by-side management of accounts with different fee structures. However, these conflicts of interest are not applicable to us.

As noted above in Item 4, SAM is owned 100% by SOMPO which is a publicly traded company listed on the Tokyo Stock Exchange. SOMPO also wholly owns Sompo Japan Insurance Inc., Sompo Risk Management Inc., and Sompo Japan DC Securities Inc.

Personal Trading Code of Ethics SAM has adopted a code of ethics (“Code”) pursuant to Rule 204A-1 under the Advisers Act. The Code describes the high standards of business conducts and fiduciary duty that SAM and its employees owe to SAM’s Clients. The Code is intended to detect and prevent conflicts of interest and activities prohibited by US federal securities laws in connection with personal trading and other regulatory matters. Accordingly, SAM employees must avoid activities, interests and relationships that run contrary to the best interest of Clients. SAM endeavors to maintain current and accurate records of all personal securities accounts of SAM employees covered by these policies and procedures and the Code (note that not all SAM employees are required to be so covered) in an effort to monitor all such activity. Generally, employees may not purchase or sell securities that are also recommended to Clients. SAM’s US’s Code is available for review and will be provided to Clients, upon request. Recommending, Buying, or Selling Securities in which we or a Related Person Have a Material Financial Interest; Conflicts of Interests Conflicts of interest may occur when SAM, its affiliates, or its employees, invest and or trade in the same securities at or about the same time, or have a material financial interest in the same investments that we recommend to Clients. For example, our employees may own securities in their personal accounts that we also have recommended to or are owned by our Clients. Our Code and the policies and procedures set forth therein have been designed to limit these conflicts of interest. Personal Trading Employees must obtain written pre-clearance for certain personal securities transactions, including IPOs and private placements, before completing the transactions. SAM may deny any proposed

transaction, particularly if the transaction poses a conflict of interest. Employees are also required to provide quarterly reports regarding transactions and holdings in “Reportable Securities” as defined in the Advisers Act. Employees must disclose all personal trading accounts initially upon commencement of employment and annually thereafter.

Selection of Brokers and Dealers For accounts managed on a discretionary basis, SAM has complete discretion in deciding which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. In selecting brokers to effect portfolio transactions for Clients, SAM considers such factors as the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; the financial strength, integrity and stability of the broker; the firm’s risk in positioning a block of securities; the quality, comprehensiveness and frequency of related services considered to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying SAM’s selection criteria. Accordingly, if SAM determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and products or services provided by such broker, Clients may pay commissions to such broker in an amount greater than the amount another broker might charge for effecting the same transaction. Soft Dollar Arrangements SAM does not have any formal arrangements in place to use Client commission dollars, known as “soft dollars”, to pay for any products or services. However, from time to time and consistent with applicable law and regulatory guidance, SAM will select brokers that provide it and its Clients or their affiliates or personnel, directly or through third-party or correspondent relationships, with research or brokerage services that provide, in SAM’s view, lawful and appropriate assistance in the investment decision-making or trade execution processes (including such processes with respect to futures, fixed-price offerings, and over-the counter transactions). SAM might endeavor, subject to the duty to seek best execution, to execute trades with such brokers in order to obtain research or brokerage services or in order to help ensure the continued receipt of such research or brokerage services. Research or brokerage services that can be acquired by SAM with its trade commission include, without limitation and to the extent permitted by applicable law: (i) research reports on companies, industries and securities; (ii) economic, market and financial data; (iii) quantitative analytical software and algorithms; (iv) electronic trading and algorithmic facilities; and (v) market data related software and services. SAM could pay, or be deemed to have paid, commission rates higher than it could have otherwise paid in order to obtain such research or brokerage services. With respect to its U.S. Clients, such higher commissions would be paid in accordance with Section 28(e) of the Securities Exchange Act of 1934 as interpreted by the SEC and its staff, which requires SAM to determine in good faith

that the trade commissions paid, are reasonable in relation to the value of the research or brokerage services received. SAM believes that using commission payments to obtain the type of research or brokerage services mentioned above enhances its investment research and trading processes. To the extent that SAM uses Client commission payments to obtain research or brokerage services, it will not have to pay for those products and services itself. Trade Errors SAM has established trade processes and procedures designed to reduce the likelihood of trade errors and, in its sole discretion, will determine what constitutes a trade error. SAM’s general policy is to seek to identify and correct any trade errors promptly and in a way that mitigates any losses. In an event that a trade error occurs, SAM will ensure that a Client account is “made whole.” Thus, trades are adjusted as needed in order to put the Client in such a position as if the error had never occurred and at no cost to the Client. Gains associated with any trade error shall be retained by the Client. SAM will use reasonable methods to calculate the reimbursement due to the Client, if any. SAM’s process to correct trade errors may involve procedures required by applicable law, which may be complex and require coordination with multiple parties, and therefore SAM’s ability to correct trade errors promptly will be based on the specific circumstances of the error. Brokerage for Client Referrals In selecting or recommending broker-dealers, we do not consider whether we, or any of our affiliates, receive Client referrals from a broker-dealer or other third party. Directed Brokerage SAM does not engage in any directed brokerage at this time. Aggregating Orders for Various Client Accounts SAM has adopted Trade Aggregation Procedures to ensure that its Clients are afforded fair and equitable treatment when aggregating and allocating Client trade orders. For a more detailed discussion of the allocation portions of our Trade Aggregation Procedures, please see Item 6, “Performance-Based Fees and Side-by-Side Management.” As a general principle, we will only aggregate transactions when we believe that such an aggregation is lawful and consistent with our duty to seek best execution for our Clients and is consistent with the pertinent Clients’ advisory agreement or any other obligation we may have undertaken with respect to each Client for which trades are being aggregated. In such cases, individual investment advice and treatment will be accorded to each Client, and we will not receive any additional compensation or remuneration of any kind as a result of the proposed aggregation. Foreign Currency Transactions

In accordance with Clients’ investment guidelines, SAM engages in foreign currency transactions (FX), including forward currency contracts when seeking to manage exposure to or profit from changes in interest or exchange rates, and protect the value of portfolio securities. It is the policy of SAM to seek out and trade with those broker-dealers that it believes will provide best execution on behalf of all of its Clients. In limited instances, SAM may establish standing instructions with the custodian selected by the Client for the auto-repatriation of income and certain corporate action fees and expenses. Investment Model Clients If a Client has retained SAM to provide investment models, there is the potential for the Investment Model Client to be disadvantaged. Generally (but not always), SAM will execute orders for its discretionary accounts prior to sending recommendations to its Investment Model Clients. Because SAM will not be involved in the execution of trades on behalf of Investment Model Clients, such Clients will not always benefit from SAM’s aggregated orders or there may be delays in execution of their orders, and as a result Investment Model Client accounts may receive a price that potentially is less favorable than that obtained for SAM’s discretionary accounts. In addition, when SAM provides model portfolios to Investment Model Clients such model portfolios generally are not expected to reflect or take into account any portfolio re-balancing which SAM conducts as part of its process for discretionary Client accounts; such active rebalancing takes into account SAM’s executions and/or settlements and such other factors it deems relevant. SAM’s model portfolios for Investment Model Clients typically are constructed using recent market closing prices. SAM takes reasonable steps to attempt to minimize the market impact of the recommendations provided to Investment Model Clients on accounts for which SAM exercises full investment discretion, including when it is implementing its active portfolio rebalancing processes. However, because SAM does not control Investment Model Client execution of transactions, SAM cannot affect the market impact of such transactions to the same extent that it is able to for its discretionary Client accounts. As a result of these and other factors, the performance of SAM’s Investment Model Client accounts can differ from (and be better or worse than) the performance of SAM’s discretionary accounts following the same or similar investment strategy, and the trades and executions by Investment Model Clients may differ from those SAM effects or achieves using its model portfolios and active re-balancing processes for its discretionary Clients.

SAM does not receive any economic benefits from non-Clients in connection with the provision of investment advice to any of its U.S. based Clients, nor does SAM compensate any person for making referrals for Clients based in the U.S.

SAM and its employees are not aware of any legal or disciplinary events that are material to a Client's or prospective Client's evaluation of SAM’s advisory business or the integrity of SAM’s management.

Client accounts are reviewed on a continuous basis. SAM’s investment personnel hold investment meetings to discuss investment ideas, investment strategies, economic developments, current events, and other issues related to current portfolio holdings and potential investment opportunities. SAM’s Portfolio construction meeting reviews the portfolios it manages on a regular basis. Written monthly or quarterly reports reflecting portfolio transactions and holdings are made accessible to Clients from the custodian(s). SAM makes other written reporting available to Clients

upon request. SAM will provide each Client with reports in accordance with the terms of the applicable Client agreement.

SAM does not hold Client assets and all Client assets are held in custody by unaffiliated broker/dealers or banks or other qualified custodians appointed by Clients. SAM does not play a role in fee billing or otherwise have access to Client accounts other than in limited circumstances where it has authority to make investment decisions and submit trades for execution as subinvestment manager. Further, SAM conducts all business operations such that it will not physically hold any funds or securities belonging to Clients. Finally, SAM sends account statements to Clients after SAM reconciles the data received from the independent custodian.

For accounts that SAM has investment discretion, SAM has the authority to determine the securities to be bought and sold without obtaining Client consent to specific transactions subject to any reasonable restrictions placed by the Client. Clients grant SAM trading discretion through the execution of a limited power of attorney included in SAM’s advisory contract. As noted in Item 5, SAM provides investment advisory services to Clients, which include the provision of the Model Portfolio. SAM will not have any trading discretion for these Investment Model Clients.

As a matter of policy, we disclaim any responsibility for voting securities on behalf of U.S. Clients. U.S. Clients may contact us for advice or information about a particular proxy vote but we do not exercise proxy voting authority over U.S. Client securities and should not be designated by custodians as the party to receive information on voting U.S. Client proxies. The obligation to vote Client proxies rests with the U.S. Client. With regard to all matters for which shareholder action is required or solicited with respect to securities beneficially held by a U.S. Client’s account, such as (i) all matters relating to class actions, including without limitation, matters relating to opting in or opting out of a class and approval of class settlements; and (ii) bankruptcies or reorganizations, SAM affirmatively

disclaims responsibility for voting (by proxies or otherwise) on such matters and will not take any action with regard to such matters.

SAM has never filed for bankruptcy and is not aware of any financial condition that would affect its ability to manage Client accounts.