SUN LIFE CAPITAL MANAGEMENT (U.S.) LLC

Our Firm Adviser registered with the SEC in 1991 and operates using the trade name “SLC Management”, the brand name for the global institutional asset management business of Sun Life Financial Inc. (“Sun Life Financial”). Adviser is an indirect wholly owned subsidiary of Sun Life Financial, a publicly traded holding company for a diversified financial services organization. SLC Management provides diversified solutions to meet clients’ evolving needs. SLC Management’s clients include pension plans, insurance companies and other institutional investors such as endowments, foundations, and family offices. Certain of these clients are affiliates of SLC Management. Adviser leverages the research, portfolio management, trading and related functions of its global affiliates and in certain cases, Adviser’s services are delegated to, or provided in connection with, one or more of its affiliates as described in Item 10. In some cases, Adviser retains affiliated third-party managers or subadvisers to provide portfolio management services under Adviser’s oversight. Advisory Services Adviser provides asset and risk management services to institutional investors, some of whom are affiliated with Sun Life Financial. Adviser also provides recommendations, investment advice and analysis regarding investment strategies and potential investments to affiliated and unaffiliated entities. The nature of investment advice and analysis provided can include portfolio holdings and/or weightings, analysis and evaluation of potential investments and other related information regarding the construction and maintenance of portfolios. Adviser customizes clients' portfolios to meet their objectives. Clients invested in certain products can request investment restrictions, including on certain of securities (e.g., credit quality, type) and on responsible investment or environmental, social, and governance (“ESG”) restrictions. Adviser has capabilities in developing multi-asset class solutions, liability driven investing strategies and alternative investments to help institutional investors match assets and liabilities as a part of a total return portfolio. Adviser’s strategies are managed through a disciplined investment process which follows one or more of these disciplines:

Focus on Fundamentals Disciplined Risk Management Extensive Credit Research Team Approach to Portfolio Management

However, as discussed below, not all strategies follow the same investment process.

Insurance Asset Management (“IAM”): Adviser provides clients with decades of insurance expertise through a global insurance asset management platform that seeks to deliver performance through traditional and alternative asset classes. IAM provides asset and risk management services to institutional investors, with a particular focus on customizing portfolios for insurance companies. This is achieved through proprietary financial modeling and analysis that considers each client’s unique business environment, financial position, and regulatory context. The integrated team designs comprehensive investment policies, develops or refines investment guidelines, and creates optimal mixes of taxable and tax-advantaged investments tailored to each client’s objectives and risk tolerances. These same techniques are also applied to non-insurance entities and high net worth family offices. In addition to discretionary and nondiscretionary investment advisory services, Adviser’s trade desk and personnel may effect transactions for affiliates that are not advisory clients, strictly on a “cost recovery” basis. These accommodation trades are not considered part of the Adviser’s core advisory business, but support the broader investment infrastructure. Total Return Fixed Income (or “TRFI” ): Adviser seeks to provide returns consistent with the risk profile of the client’s mandate. From short and intermediate duration to core fixed income and long credit, Adviser offers total return fixed income strategies managed against the traditional fixed income benchmarks across the duration spectrum. TRFI’s philosophy seeks to add value through issue selection and sector rotation, minimizing interest rate risk by adhering to a duration neutral posture, and working towards reducing downside risk. TRFI seeks relative value at the issue level by examining historical relationships with comparative bonds and sub-sectors in order to identify possible mean reversion trades in both structured and corporate credit. TRFI also looks for upgrade candidates, especially in securitized bonds, and mispriced securities across the curve. Liability Driven Investment (“LDI”): Adviser works with plan sponsors at all stages of de-risking, from early-stage clients taking their first steps to reduce funded status volatility, to late-stage clients looking to fine tune their liability- hedging programs. Derivative Overlay: Adviser designs, models and manages customized overlay solutions that can shape a client’s portfolio risk profile and improve the risk/return profile of their investments. Adviser can help clients optimize portfolio beta and reduce uncompensated or unwanted risk across a broad range of risk types – from currency, to credit, to interest rates, to equity. Private Fixed Income: Advisory provides advisory services within primarily investment grade private fixed income markets, including sourcing investments in project, corporate and midmarket finance, private real estate finance, and private securitization finance. Adviser also provides investment management services related to commercial mortgage and commercial real estate investment management, mortgage origination agreements, loan servicing agreements, and mortgage administrative agreements. Adviser manages assets on a discretionary and a non-discretionary basis. As of December 31, 2025, Adviser’s total regulatory assets under management (“RAUM”) was

$76,410,239,323 including $66,429,406,539 in discretionary and $9,980,832,784 in nondiscretionary accounts.

Fees Generally, clients are charged an asset-based fee for Adviser’s investment advisory services. Fees may be negotiable depending on the service being provided and are generally billed directly to the client in arrears. For some of its advisory clients, Adviser bills on assets inclusive of accrued interest, while other clients are billed on assets exclusive of accrued interest, which is often dependent upon whether the client intends to reinvest or sweep out interest generated within the account. In addition, clients will incur other types of fees and expenses related to their accounts, each as described below. Insurance Asset Management (“IAM”) IAM negotiates fees with clients based on the scope and complexity of services provided. The fees are generally calculated as a percentage of assets under management and are payable monthly or quarterly in arrears, prorated for partial periods or may charge based on a tiered fee schedule, typically 0.25% for the first $50 million, 0.20% for the next $200 million, 0.13% for the next $250 million, and negotiable rates for assets exceeding $500 million—with fees billed quarterly in advance based on prior quarter-end valuations. High net worth clients typically pay fees of between 15 and 25 basis points per year with annual minimum fees of $12,500 per year. Accounts initiated or terminated during a calendar quarter are charged a pro-rated fee. IAM may also negotiate fixed fees or alternative arrangements, particularly for clients with multiple accounts. In both cases, fees are exclusive of brokerage commissions, transaction fees, custodial fees, and other related costs incurred by clients. These typically include charges from custodians, brokers, and third parties such as deferred sales charges, transfer taxes, wire transfer fees, and fund-level expenses disclosed in prospectuses. Private placements may incur Securities Valuation Office filing and maintenance fees, as well as restructuring or workout-related costs. For more information on brokerage services and fees, please see Item 12 – Brokerage Practices below. IAM may impose additional fees for customized reporting. IAM does not charge management fees on client assets invested in affiliated private funds, instead invoicing investors directly, with all associated costs detailed in the respective offering documents. IAM does not deduct fees from client assets unless explicitly approved by the client, and in the event of termination, IAM will prorate fees through the end of the notice period, as outlined in each client’s investment management agreement. For clients who are billed in advance, if the account is terminated prior to the end of a billing period fees will be refunded to the client on a pro-rata basis based on the account’s termination date. Total Return Fixed Income (“TRFI”) For discretionary asset management, TRFI utilizes a standard asset-based fee schedule for the products shown in this section. However, fees are negotiable at Adviser’s sole discretion.

TRFI’s fees exclude any brokerage commissions, transaction fees, custodial fees and other related costs and expenses that are incurred by clients in connection with TRFI’s advisory services. In certain circumstances, clients will incur charges imposed by custodians, brokers, and/or other third parties, including fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Prospective clients should be aware that in addition to TRFI’s advisory fees for separate account management, exchange-traded funds (ETFs) or mutual funds in which a client's account is invested also charge advisory fees and clients invested in those funds will bear each such fund’s advisory fees and other fund expenses. Fee schedules and information about fund expenses for ETFs and mutual funds can be found in the relevant prospectus. In addition, clients participating in TRFI derivatives strategies will pay execution commissions, clearing fees, and exchange fees for commodity interests purchased and sold for their accounts. For more information on brokerage services and fees, please see Item 12 – Brokerage Practices below. Collective Investment Trust (“CIT”) Management Fees In return for managing CIT assets, TRFI receives investment advisory fees, which the CIT Trustee accrues daily, charges the CIT investors quarterly in arrears, and remits such earned advisory fees to TRFI on a quarterly basis. A separate fee class is available only for investment by plans with direct relationships with TRFI for management fees. Private Fund Management Fees TRFI does not charge a fee on client assets invested in the private funds to which Adviser or an affiliate act as manager because it receives a management fee directly from each fund as described and disclosed, alongside all other costs and expenses, in the funds’ respective offering documents. Additional costs and expenses borne by investors are detailed in the fund offering documents. Separately Managed Account Fees Fee schedules for separately managed accounts are listed in the tables below. Fees are payable quarterly in arrears unless otherwise agreed in the investment management contract. Accounts initiated or terminated during a calendar quarter are charged a pro-rated fee. TRFI billing is done in two ways depending on the type of account: 1) Direct billing for discretionary asset management quarterly in arrears; 2) Billing for accounts participating in certain consulting platforms quarterly via the custodian and can include the direct debiting of fees as further described in Item 15 - Custody.

Additional Compensation and Conflicts of Interest Sale of Affiliated Funds to Clients Certain supervised persons of Adviser are also registered representatives of Sun Life Institutional Distributors (U.S.) LLC (“SLID”), Adviser’s affiliate broker-dealer, in order to sell interests in securities offered by Adviser or its affiliates, as detailed in Item 10. Such supervised persons receive compensation in connection with the sale of such securities and have a financial incentive to recommend such securities to clients based on the compensation received, rather than on a client’s needs. SLID registered persons only offer affiliated funds to clients. Adviser will disclose to a client its involvement, or that of a related person, as principal, investment adviser, or investor in any affiliated pooled vehicle which it is recommending to that client. Adviser does not exercise its discretionary authority over client accounts to invest those accounts in any affiliated pooled vehicle in which Adviser or a related person is involved as a principal, investment adviser, or investor, unless the client has specifically authorized Adviser to do so in its contract with the client. Structuring or Commitment Fees Generally, the private fixed income transactions that Adviser recommends and/or invests in for its clients do not generate structuring or commitment fees. However, to the extent any such fees are received, Adviser credits such fees to the client account. Compensation of Adviser and Adviser’s Investment Professionals Compensation of Adviser’s investment professionals includes a combination of base salary, a performance-based annual cash incentive bonus, and a long-term incentive (“LTI”) grant (for more senior roles). The base salary component depends on market data relative to similar positions within the industry as well as the past performance, experience, and responsibility of the individual. Investment professionals’ annual cash incentive bonus and long-term incentive grant is paid from an annual incentive pool. The incentive pool is determined annually based on a combination of individual compensation targets and competitive market pay levels formulated in consultation with external compensation experts. This target pool is increased or decreased annually by a multiplier based on Adviser’s performance. The multiplier is agreed annually between Adviser and Sun Life Financial and it reflects both investment performance and business performance. Each investment professional's incentive compensation, including both the annual cash incentive bonus and the long-term incentive grant, is primarily determined by client investment performance and client satisfaction, business performance and individual performance against

established personal goals. All are important factors in determining the size of the annual bonus awarded to each individual. The LTI is delivered through SLC Management’s Phantom Share Unit Plan (SLC Shares), designed to align compensation to long-term SLC Management value creation. LTI awards for eligible participants are determined on an annual basis according to the deferral rates. For awards that exceed the deferral threshold, a portion of the award is deferred and awarded in Adviser’s long-term incentive compensation, with the remainder paid in cash. Total compensation is designed to be competitive with the market, but an individual’s actual compensation will vary. Investment professionals are all covered by the same general compensation structure. With respect to certain investment advisory services provided to affiliated companies, Adviser’s compensation can be limited to either reimbursement from the affiliate for the expenses Adviser incurs in providing these services, or reimbursement of such expenses plus a percentage of cost. Conflicts Related to Valuation and Fees Adviser could value identical assets differently in different client accounts across the business units due to, among other things, different valuation guidelines applicable to such client accounts or different third-party pricing vendors. The discrete lines of business within the Adviser typically will be guided by specific policies and requirements with respect to valuation of client holdings, which can include valuations that are provided by third parties, when appropriate, as well as comprehensive internal valuation methodologies. When client accounts hold illiquid or difficult to value investments, Adviser uses a third-party valuation firm with relevant expertise when feasible and agreed to by the client. In situations where this is not practical, Adviser faces a conflict of interest when making recommendations regarding the value of such investments since Adviser’s fees are generally based on the value of assets under management.

Adviser provides investment strategies for institutional clients, many of whom are affiliated, including insurance companies. Adviser’s primary securities investment strategies involve investments in both publicly traded and privately offered fixed income securities. Adviser also provides a range of investment strategies involving ETFs, derivatives, and equity securities. Adviser also provides risk management and hedging strategies, which involve the use of various types of derivative instruments. Adviser relies on sector specialists to assess credit and relative value across and within sectors and make recommendations to the Investment team. The portfolio management team utilizes a team of credit research analysts and structured credit and mortgage research analysts to formulate opinions based on fundamental research. The credit research team focuses on company fundamentals such as revenue and earnings growth, ability to generate cash flow and debt repayment. Members of the credit research team are assigned to specific industry sectors, and each focuses on the fundamentals of their assigned sectors and the economic drivers that could impact the credit direction of their sectors. The structured credit research and mortgage team focuses on value and quality of collateral, structure and subordination of the collateral pool and economic trends that could affect the performance of the security or sector. Adviser utilizes the research and services of affiliates in formulating advice delivered to clients:

Sun Life Capital Management (Canada) Inc. research staff provide general research services to Adviser pursuant to an Administrative Services Agreement. Adviser also relies on Sun Life Capital Management (Canada) Inc. to source and underwrite certain types of transactions in private fixed income investments for portfolios of its clients, subject to the oversight and approval of Adviser.

Adviser has outsourced some of its investment research functions to a Sun Life Financial service center in India for public fixed income and mortgage reviews.

Such research personnel are covered under Adviser’s Code of Ethics. Some business units within Adviser conduct their own research for their portfolio management activities that is not broadly shared. Adviser does not automatically screen investment opportunities based on ESG considerations. Adviser integrates ESG factors and other non-financial risks into its research and investment processes to ensure that material ESG information is effectively incorporated into investment decisions as necessary. Adviser does not represent that any Client is or will be “ESG Compliant” or, unless provided to the contrary in the relevant governing documents, assign any particular ESG scoring or factor(s) that would operate as a restriction on the client’s ability to make or retain an

investment. The ESG integration approach for each investment team varies given the objectives of the underlying mandate, asset type(s), availability of information, as well as the relative importance of other financial factors used in assessing an investment opportunity. Adviser can obtain ESG-related research (including analyses of particular companies or industries), scoring and other data from third parties and rely on such information when weighing ESG considerations for a particular investment. If data is of lower quality, or if the research, scoring or data contains errors, Adviser’s decision making could be adversely impacted. Adviser believes that investing with a rigorous analysis of both financial and ESG factors can generate attractive risk-adjusted returns over time. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. Clients should understand that they could lose some or all of their investment and should be prepared to bear the risk of such potential losses. Client mandates may be limited to certain types of securities (e.g., fixed income) or to the Adviser’s recommendations and may not be diversified. The advisory services are generally not intended to provide a complete investment program and Adviser expects that the assets it manages do not represent all of the client’s or investor’s assets. Clients and investors are responsible for appropriately diversifying their assets to guard against the risk of loss. TRFI The following factors guide the formulation of Adviser’s TRFI investment philosophy:

Adviser employs bottom-up security selection using a repeatable process that creates value. Adviser seeks “upgrade” candidates and mispriced securities (particularly in securitized credit) and looks for relative value at the issue level by examining historical relationships with comparative bonds and sub-sectors to isolate mean reversion trades in both structured and corporate credit. Adviser takes a neutral stance on interest rates.

Adviser is opportunistic and believes in actively managing portfolios to seek relative value. Adviser looks for risk that is fundamentally or technically priced in order to find investment opportunities. Avoiding the downside is critical to outperformance, and Adviser is willing to underweight any sector.

TRFI’s investment management strategies are usually developed with active involvement of the client and their consultants and can utilize customized asset- liability benchmarks as an investment management technique. Clients routinely impose restrictions, including responsible investment or ESG restrictions, on investing in certain types of securities (e.g., credit quality, type). The imposition of restrictions can act to prevent TRFI from fully implementing a desired investment strategy for a client, which could adversely impact performance when compared with accounts of the same strategy that are not restricted. TRFI uses various methods of analysis in managing its client assets: Qualitative 1. Fundamental: Bottom-up/top-down credit research analysis of bond issuers

2. Relative: Research and screens on the relative value of a position compared with other fixed income sectors and sub-sectors, as well as spread valuation compared with the Treasury or swap curve. 3. Technical: Supply and demand of products across the market 4. Yield curve: Various positions perform differently based on both the shape of the curve and macroeconomic forces/trends Quantitative 1. SMART: Daily index replication, risk-reward calculations of the Index 2. DAILY: Risk management of the portfolio versus the Index on a daily basis; documentation of risk/reward issues Investment Strategies 1. Interest rate neutral versus an index 2. Value added through issue selection and sector rotation Risk of Loss Analysis 1. Breakeven analysis over a 3, 6, and 12-month horizon 2. Probability of default analysis 3. Portfolio diversification TRFI also manages an overlay completion strategy, which seeks to modify duration synthetically via the use of commodity interests to augment asset-liability management strategies. This can be achieved in a variety of ways, including strategic and tactical objectives. A strategic objective can be achieved through positions that enhance duration and key rate matching against an index. A tactical objective can be achieved through positions that offset anticipated interest rate movements (e.g., using interest rate swaps or swaptions). IAM Fixed Income Strategies IAM seeks to manage the liabilities of clients through the selection of securities that match the duration and expected cash flows of each client’s insurance products. Public Fixed Income IAM’s relative value strategy seeks performance through security and sector selection and weighting based on fundamental research, and rotation within and across sectors based on relative value opportunities and economic outlook to achieve attractive risk adjusted returns. IAM seeks to manage portfolio risk by active diversification across securities and sectors. Where pertinent, IAM seeks to actively manage interest rate risk by looking to maintain

portfolio duration within ranges agreed to by the client. The outlook for rates evolves from IAM’s view on the economy and economic policy over time. Private Fixed Income Adviser’s relative value strategy in the private fixed income markets is to seek yield above public bonds of comparable credit quality from transactions that require industry sector expertise, as well as expertise in evaluating complex transactional structures. Examples of such investments include long term debt financing; senior secured and unsecured loans to high credit quality large corporate borrowers; structured finance, including financing of clean energy, infrastructure and transportation assets, and financing secured by pools of financial assets originated and managed by third parties which may include loans, leases, or other types of financial obligations. Credit research focuses on company fundamentals such as revenue and earnings growth, ability to generate cash flow and debt repayment, and economic drivers that could impact the credit of the borrower. In structured transactions, the analyst focuses on value and quality of collateral, structure and subordination of the collateral pool and economic trends that could affect the performance of the security or sector. Fixed Income Investment Strategy Risks Applicable to TRFI and IAM There is no assurance that the objective of any fixed income investment strategy can be achieved. The principal risks associated with Adviser’s fixed income strategies are interest rate risk, credit risk, liquidity risk, prepayment risk, extension risk, market risk, and rating agencies risk. To the extent a fixed income strategy employs investments in mortgage-backed or asset-backed securities, high yield securities, private fixed income or foreign fixed income securities, it can also experience risks associated with these investments. These risks are described below. In addition, Adviser’s judgments about the relative value of securities selected for the portfolio can prove to be wrong.

Interest Rate Risk. Interest rate risk involves the risk that interest rates will go up, causing the value of the portfolio’s fixed income securities to go down, and the risk that interest rates will go down, potentially causing a negative impact on reinvestment returns. Various factors can affect market interest rates including, inflation; slow or stagnant economic growth or recession; unemployment; money supply, Central bank monetary policies and other monetary system participants; actions of other market participants; international disorders; and instability in domestic and foreign financial markets. This risk can be greater for securities with longer maturities. Risks associated with changing interest rates can have unpredictable effects on the markets and client accounts.

Credit Risk. Credit risk is the risk that the issuer of fixed income securities owned by the portfolio will default on its payment obligations, become insolvent, or have its credit rating downgraded by a rating agency and thereby causing the market value of the securities to decrease.

Liquidity Risk. Liquidity risk is the risk that Adviser will be unable to sell a given security at an advantageous time or price or to purchase the desired level of exposure for the portfolio. This is especially relevant for private fixed income investing.

Prepayment Risk or “Call” Risk. Prepayment risk or “call” risk is the risk that the issuer of a callable security will exercise its right, when interest rates are falling, to prepay principal earlier than scheduled, forcing the portfolio to reinvest in lower yielding securities.

Extension Risk. Extension risk is the risk that the issuer of a security will exercise its right, when interest rates are rising, to extend the time for paying principal, which will lock in a below-market interest rate, increase the security’s duration and reduce the value of the security.

Market Risk. Market risk is the risk that prices of securities in the portfolio will fall as a result of general market movements, adverse market reactions to recent events or trends, including unfavorable company news.

Rating Agencies Risk. Rating agencies risk is the risk that rating agencies, on which the Adviser can rely in part when selecting securities for the portfolio, are incorrect in their evaluation of an issuer’s financial condition or fail to make timely changes in credit ratings upon a change in such issuer’s condition.

Risks Related to Investing in Mortgage-Backed or Asset-Backed Securities. For investments in mortgage-backed or asset-backed securities, the portfolio’s investments in these types of securities are affected by the characteristics of the underlying assets, which can increase their levels of interest rate risk, extension risk and prepayment risk.

Risks Related to Investing in High Yield Securities. For high yield securities, there is also the risk that an economic downturn or period of rising interest rates will adversely affect the market for high yield securities and reduce the portfolio’s ability to sell its high yield securities. High yield securities can be subject to greater levels of interest rate risk, credit risk, and liquidity risk than other fixed income securities. High yield securities are considered primarily speculative with respect to the issuer’s continuing ability to make principal and interest payments.

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We provide investment advisory services to a variety of affiliated and unaffiliated institutional clients. Our clients include pension and profit-sharing plans, public employee retirement systems, credit institutions, corporations, publicly offered investment funds and their investment managers, insurance companies, commingled trust funds, Taft-Hartley plans, charitable institutions, foundations, endowments, municipalities, family offices, high net worth individuals, holding companies, and private investment funds and their investment managers. Minimum account sizes vary by investment strategy. In certain circumstances, Adviser exercises its discretion to waive these requirements. To help fight the funding of terrorism and money laundering activities, U.S. federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account on behalf of an investor. This means that Adviser will request from the client or its beneficial owners its name, address, government identification number and other information that allows Adviser to identify the client. If the client refuses to provide the information requested, Adviser will not be able to manage assets for the client.

Adviser’s general fee schedules for separate account and private fund clients do not include a performance component.

As an indirect wholly-owned subsidiary of Sun Life Financial, Adviser is a part of a diversified, global financial services organization. Adviser is affiliated with many types of U.S. and nonU.S. financial service providers, including insurance companies, broker- dealers, commodity trading advisers, commodity pool operators and other investment advisers. Some of Adviser employees are officers of and/or provide services to some of these affiliates. Adviser Personnel that are Registered Representatives of a Broker-Dealer Certain supervised persons of Adviser are registered representatives of SLID, an affiliated SEC-registered broker-dealer, to sell interests in securities offered by Adviser or its affiliates. Conflicts related to certain management persons and other employees that are registered representatives of SLID are discussed below under “Advisers Relationships with Affiliates – Adviser’s Relationships with Affiliated Broker-Dealers” and in Item 5 above. Adviser’s CFTC Registration/NFA Membership Adviser is registered as a Commodity Trading Advisor with the CFTC under the CEA and a Member of the NFA, and certain of Adviser’s management persons and other employees are associated persons when Adviser acts in such capacities. Adviser’s Relationships with Affiliates Affiliated Broker-Dealers Sun Life Financial indirectly owns 100% of SLID, a SEC-registered broker-dealer and member of the Financial Industry Regulatory Authority (FINRA). SLID markets private funds and limited partnerships managed by Adviser and its affiliates. Certain supervised persons of SLID are associated persons of Adviser or its affiliates. SLID and Adviser are under common control. On a non-discretionary basis, Adviser can recommend that a client invest in a private fund advised by Adviser and distributed by SLID. BGO US Real Estate LP is the sole member of BentallGreenOak Real Estate US LLC, which is registered with the SEC as a broker-dealer and a member of FINRA. BentallGreenOak Real Estate US LLC acts as placement agent for certain of the funds advised by BGO US Real Estate LP and BentallGreenOak (U.S.) LP. BentallGreenOak Real Estate US LLC, BGO US Real Estate LP, and Adviser are under the common control of Sun Life Financial. Advisors Asset Management, Inc. (“AAM”) is registered with the SEC as an investment adviser and a broker-dealer and a member of FINRA. AAM is an independent U.S. retail distribution firm, providing a range of solutions and products to financial advisors at wirehouses, registered investment advisers, and independent broker-dealers. AAM and Adviser are under the common control of Sun Life Financial. To facilitate the sale of private placement securities offered by Adviser or its affiliates, certain supervised persons of Adviser are registered representatives of SLID. SLID registered

representatives only offer affiliated funds to clients. Those supervised persons receive compensation in connection with the sale of such securities and have a financial incentive to recommend such securities to clients. Additional details regarding individuals registered with SLID can be found in the Form ADV Part 2B Brochure Supplements. Adviser will disclose to its clients its involvement as principal, investment adviser, or investor, or that of a related person, in any affiliated pooled vehicle which it is recommending to such clients. Adviser does not exercise its discretionary authority over client accounts to invest those accounts in any affiliated pooled vehicle in which Adviser or a related person is involved as a principal, investment adviser, or investor, unless the client has specifically authorized Adviser to do so in the Investment Management Agreement. Adviser does not use affiliated broker-dealers to execute portfolio transactions for its clients; however, when advising clients to invest in private funds advised by Adviser or its affiliates, and the client chooses to so invest, the placement of interests in the fund will be through an affiliate. Affiliated Investment Advisers Adviser is affiliated with, and has material relationships with, the following investment advisers: Massachusetts Financial Services Company Sun Life Financial owns indirectly approximately 95.1% of the outstanding securities of Massachusetts Financial Services Company, d/b/a MFS Investment Management (“MFS”). MFS is an SEC-registered investment adviser and sponsor of various investment companies. MFS Institutional Advisors, Inc. (“MFSI”) is a SEC-registered investment adviser that is a wholly owned subsidiary of MFS. MFSI is a subadviser to Adviser. MFS and Adviser are under common control of Sun Life Financial. SLGI Asset Management Inc. Sun Life Financial indirectly owns 100% of SLGI Asset Management Inc. (“SLGI”), a fund manager that designs and manages both in-house and sub-advised investment solutions for retail and institutional investors. SLGI is registered with the securities commissions and regulatory authorities in all provinces in Canada. Adviser is a subadviser to SLGI. SLGI and Adviser are under common control of Sun Life Financial. Sun Life Capital Management (Canada) Inc. Sun Life Financial indirectly owns 100% of Sun Life Capital Management (Canada) Inc. (“SLCC”), a Toronto-based asset management company specialized in liability driven investing to defined benefit pension plans and other institutional investors in Canada. SLCC is registered with the securities commissions and regulatory authorities in all provinces in Canada. SLCC is a member of the SLC Management group of companies. SLCC and Adviser are under common control of Sun Life Financial.

Adviser shares certain personnel with, or relies on the resources of, SLCC, as a “Participating Affiliate” of the Adviser, in providing advice to clients, including SLCC’s trading desk. Adviser and SLCC have entered into a Memorandum of Understanding pursuant to which SLCC agreed, among other things, that all of its personnel who are involved in the provision of investment advice to Adviser’s clients (each, an “Affiliate Associated Person”), are subject to the relevant provisions of Adviser’s compliance program and Code of Ethics and required to maintain relevant records with regard to such activities. SLCC has also agreed to submit to the jurisdiction of U.S. courts for actions arising under the U.S. securities laws in connection with these investment advisory activities. BentallGreenOak Sun Life Financial indirectly owns a majority of BentallGreenOak (BGO). BGO is a member of the SLC Management group of companies. Both BGO and Adviser provide advisory services to Sun Life Financial affiliates concerning mortgages and real estate. BGO’s affiliated investment advisers, each of which is under common control with the Adviser, include: (a) BentallGreenOak (U.S.) Limited Partnership, a Seattle-based SEC-registered investment adviser that counsels clients on their direct investments in office, industrial, retail, multi-family residential and hospitality real estate throughout the United States. (b) BGO Capital (Canada) Inc. (“BGOCC”), a Canadian dealer, adviser and investment fund manager. BGOCC and BentallGreenOak are under common control. BGOCC markets funds managed by BentallGreenOak. (c) BGO US Real Estate LP is a SEC-registered investment adviser. It is an investment advisory services firm specializing in investment management for private funds focused on investment in real estate and real estate related assets. The firm is indirectly majority-owned by Sun Life Financial. (d) BentallGreenOak Strategic Capital Partners, LLC is SEC-registered investment adviser. It is an investment advisory services firm specializing in investment management for private funds and separately managed accounts focused on investment in real estate and real estate related assets. The firm is indirectly majority-owned by Sun Life Financial. Crescent Capital Group LP Sun Life Financial indirectly owns 51% of Crescent Capital Group LP (“Crescent”). Crescent is a SEC-registered investment adviser. Crescent is a member of the SLC Management group of companies. Crescent offers investment advisory services primarily to institutional investors and invests in closed-end and open-end limited partnerships, collateralized loan obligations, collateralized debt obligations, and other investment vehicles on behalf of its clients. InfraRed Capital Partners

Sun Life Financial indirectly owns 100% of InfraRed Capital Partners Limited and InfraRed Capital Partners (US) LLC, both investment advisers registered with the SEC (collectively “InfraRed”). InfraRed is a member of the SLC Management group of companies. Headquartered in London, U.K., InfraRed is a global infrastructure manager. Advisors Asset Management, Inc. Sun Life Financial indirectly owns 51% of Advisors Asset Management, Inc. (“AAM”). AAM is a SEC-registered investment adviser and broker-dealer and a member of FINRA. AAM is an independent U.S. retail distribution firm, providing a range of solutions and products to financial advisors at wirehouses, registered investment advisers, and independent broker- dealers. AAM and Adviser are under the common control of Sun Life Financial. Adviser regularly exchanges investment research and economic analysis with investment personnel employed by Sun Life Financial affiliates, excluding MFS where Sun Life Financial has established an Ethical Wall Operating Guideline. In addition to the advisers described above, other affiliated investment advisers include Sun Life Financial ’s Philippines and Hong Kong businesses. Adviser provides advisory or subadvisory services with respect to certain accounts managed by these affiliates. Adviser also has service agreements with some of these affiliates under which Adviser can perform services for them, or they can perform services for Adviser. Adviser can use this research and analysis in its investment decision making on behalf of its clients. To mitigate potential and actual conflicts of interest in personal securities trading of the individuals who participate in these exchanges, such participants are subject to the Adviser’s Code of Ethics, which is described in Item 11 below. Subadvisers are typically compensated out of Adviser’s management fees. Adviser periodically reviews each subadviser to identify any potential and actual conflicts of interest. One such conflict is Adviser’s incentive to select an affiliate of Adviser as a subadviser so that the benefits of the subadviser fees stay within Sun Life Financial’s corporate family. Affiliated Insurance Companies Sun Life Financial is an indirect owner of Adviser. Sun Life Financial is the 100% owner of Sun Life Assurance Company of Canada (“Sun Life of Canada”), a Canadian life insurance company, to whom Adviser provides investment advisory services for a portion of the general accounts and certain separate accounts. Sun Life Financial was also the 100% owner, indirectly, of the following insurance companies and dental plans to which Adviser provides investment advisory services as of December 31, 2025:

Independence Life and Annuity Company (“Independence Life”); Professional Insurance Company (“PIC”);

Sun Life and Health Insurance Company (U.S.) (“SLHICUS”); Sun Life Financial (U.S.) Reinsurance Company; Sun Life Financial (U.S.) Reinsurance Company II; Sun Life Hong Kong Limited (“Sun Life (H.K.)”); Sun Life Financial (Bermuda) Reinsurance Ltd.; Denticare of Alabama, Inc.; UDC Dental California, Inc.; UDC Ohio, Inc.; Union Security DentalCare of Georgia, Inc.; Union Security DentalCare of New Jersey, Inc.; United Dental Care of Arizona, Inc.; United Dental Care of Colorado, Inc.; United Dental Care of Missouri, Inc.; United Dental Care of New Mexico, Inc.; United Dental Care of Texas, Inc.

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Pursuant to SEC rule 204A-1, Adviser has adopted and maintains a Code of Ethics to which Adviser and each of its employees must adhere. Adviser’s Code of Ethics describes the high standard of business conduct expected of its personnel, and the fiduciary duties owed to its clients. The Code of Ethics includes provisions relating to the confidentiality of client portfolio information, a prohibition on insider trading, a prohibition on rumor mongering, restrictions on the acceptance of significant gifts and the reporting and/or preclearance of certain gifts and business entertainment items, and personal securities trading procedures. Certain of these provisions are described further below. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the employees of Adviser will not interfere with making decisions in the best interest of Adviser’s clients and implementing such decisions. Employee trading is monitored under the Code of Ethics to prevent conflicts of interest between Adviser and its clients via a software system. All supervised persons at Adviser must acknowledge to the terms of the Code of Ethics annually, and as amended. Adviser will provide a copy of the Code of Ethics to any client or any prospective client upon request. Personal Securities Trading Standards Adviser maintains personal securities trading standards that govern the trading activities of its employees as well as their household members and dependents. Subject to certain limited exceptions, employees are required to:

report personal securities transactions on a quarterly basis; pre-clear relevant personal securities transactions (for persons considered to be “access persons” under SEC rules); and report personal securities holdings annually. Additionally, under the Code: access persons are generally prohibited from purchasing securities in initial public offerings; access persons cannot knowingly trade any reportable security on the same day that Adviser trades such security (or an equivalent security) for client accounts (other than in client accounts that replicate a broad-based index); access persons are prohibited from knowingly trading any security subject to pre-clearance requirements within seven days before or after Adviser trades such security (or an equivalent security) for client accounts (other than in client accounts that replicate a broadbased index).

Adviser compares personal trading activity versus firm trading activity and its restricted list, and any matches are investigated by Adviser’s Ethics Office compliance unit. An ethics committee is notified regularly of any potential violations and where appropriate disciplinary action is taken after approval from the committee. All employees receive routine training regarding Adviser’s personal securities trading and information barrier standards. In addition, employees must annually confirm that they have read and understand the Code of Ethics, including the personal securities trading and information barrier standards. Gift and Entertainment Adviser’s employees occasionally give or receive gifts, meals, or entertainment, subject to compliance with applicable laws and regulations and rules of self- regulatory organizations. Adviser has adopted a policy to address the conflicts of interest related to gifts and entertainment, such as the appearance of having given or received something of value that influenced Adviser’s business decisions or the business decisions of clients. The policy requires the reporting and/or preclearance of gifts, meals and entertainment given or received which exceed certain thresholds. In addition, Adviser employees are prohibited from soliciting the receipt of gifts, meals, or entertainment. The Ethics Office periodically reviews summaries of gifts and entertainment activity to detect trends of abuse, conflicts of interest, or possible violations of the policy. This data is presented to the Ethics Committee, and appropriate actions are taken as advised by the committee. Political Contributions Due to the potential for conflicts of interest, Adviser has established policies and procedures relating to political contributions that are designed to comply with applicable federal, state, and local law. Under Adviser’s political contributions policy, all covered employees must obtain preapproval before making any political contribution. This policy also prohibits covered employees from making any political contributions with the intent of influencing a public official regarding the award of a contract to Adviser or its affiliates. Outside Business Activities From time to time, certain Adviser employees or officers engage in outside business activities, including outside directorships. Certain outside business activities are subject to preclearance and reporting pursuant to the Code of Ethics. Actual and potential conflicts of interest are analyzed during the approval process for any outside activity. Adviser could be restricted in trading the securities of certain issuers in client portfolios in the event that an employee or officer, as a result of outside business activity, obtains material, nonpublic information regarding an issuer. Adviser’s Recommendations or Allocations of Client Assets Adviser will disclose to its clients its involvement as principal, investment adviser, or investor, or that of a related person, in any affiliated pooled investment vehicle which it is recommending to such clients. Adviser does not exercise its discretionary authority over client accounts to

invest those accounts in any affiliated pooled investment vehicle in which Adviser or a related person is involved as a principal, investment adviser, or investor, unless the client has specifically authorized Adviser to do so in the Investment Management Agreement. Sub Advisory Relationships Adviser engages affiliated and/or unaffiliated subadvisers for certain investment services. Adviser typically compensates subadvisers out of the advisory fees it receives, which creates an incentive for Adviser to select affiliated subadvisers or subadvisers with lower fee rates. In addition, the subadvisers have interests and relationships that create actual or potential conflicts of interest, which are described in the subadviser’s brochure. Adviser periodically reviews each subadviser to identify and address any potential conflicts of interest. Adviser must adhere to its fiduciary duty owed to its clients in selecting subadvisers. Adviser has established policies and procedures to manage these conflicts. Investment in Securities which Adviser or a Related Person Has a Material Financial Interest Adviser and its related persons recommend or invest in securities on behalf of its clients that Adviser and its related persons also purchase or sell. As a result, positions taken by Adviser and its related persons can be the same as or different from, or made contemporaneously or at different times than, positions taken for clients of Adviser. As these situations involve actual or potential conflicts of interest, Adviser has adopted policies and procedures relating to personal securities transactions, insider trading and other ethical considerations. These policies and procedures are intended to identify and mitigate actual and perceived conflicts of interest with clients and to resolve such conflicts appropriately if they do occur. The policies and procedures contain provisions regarding pre-clearance of employee trading, reporting requirements and supervisory procedures that are designed to address potential conflicts of interest with respect to the activities and relationships of related persons that might interfere or appear to interfere with making decisions in the best interest of clients, including the prevention of front- running. In addition, Adviser has implemented monitoring systems designed to monitor compliance with these policies and procedures. Adviser and its directors, partners, officers, agents, and employees also buy, sell, or trade securities for their own accounts or the proprietary accounts of Adviser. Adviser has discretion to make investment decisions and take other actions (including the timing or nature of such investment decisions or actions) with respect to its proprietary accounts where such decisions and actions are different from those made for client accounts. The proprietary activities, investments, or portfolio strategies of Adviser, give rise to a conflict of interest with the transactions and strategies employed by Adviser on behalf of its clients and affect the prices and availability of the investment opportunities in which Adviser invests on behalf of its clients. For example, in certain circumstances, Adviser can buy or sell securities for its proprietary account where Adviser can recommend the same securities to clients. Further, Adviser is not required to purchase or sell for any client account securities that it or any of its employees, principals, partners, directors, officers or agents purchase or sell for their own accounts or the proprietary accounts of Adviser. Adviser, and its partners, principals, directors, officers, employees, and agents face a conflict of interest as they will have income or other incentives to favor their own accounts or the proprietary accounts of Adviser.

Adviser and its related persons can also have interests in affiliated pooled investment vehicles. Adviser will disclose to a client its involvement, or that of a related person, as principal, investment adviser, or investor in any affiliated pooled vehicle which it is recommending to that client. As these situations can involve conflicts of interest, as described in more detail in Item 10, above, Adviser does not exercise its discretionary authority over client accounts to invest those accounts in any affiliated pooled vehicle in which Adviser or a related person is involved as a principal, investment adviser, or investor, unless the client has specifically authorized Adviser to do so in the Investment Management Agreement. Additionally, as also described in more detail in Item 10, above, Adviser generally will not invest third party client accounts in any debt or equity interest in a Sun Life Financial Affiliate. This can result in clients being unable to participate in an investment opportunity that might otherwise be suitable and beneficial. From time to time, Adviser or an affiliate could sell an asset to, or buy an asset from, a client. These "principal transactions" create a conflict of interest because each party has an interest in obtaining the most favorable economic terms. Where required by the Advisers Act, other applicable law, or the terms of an agreement with the client, Adviser will provide prior written disclosure of the material terms and conflicts associated with the particular transaction and obtain consent prior to completing the transaction. Advising of Multiple Accounts Certain portfolio managers of Adviser manage multiple client accounts or investment vehicles. These portfolio managers are not required to devote all or any specific portion of their working time to the affairs of any specific client. Conflicts of interest do arise in allocating management time, services, or functions among such clients, including clients that have the same or similar types of investment strategies. Adviser addresses these conflicts by disclosing them to clients and through its supervision of portfolio managers and their teams. Responsibility for managing Adviser’s client portfolios is organized according to investment strategies within asset classes. Generally, client portfolios with similar strategies are managed by portfolio managers in the same portfolio management group using the same or similar objectives, approach and philosophy. Therefore, portfolio holdings, relative position sizes, industry and sector exposures generally tend to be similar across client portfolios with similar strategies. However, Adviser faces conflicts of interest when Adviser’s portfolio managers manage accounts with similar investment objectives and strategies. For example, investment opportunities that are potentially appropriate for certain clients can also be appropriate for other groups of clients, and as a result not all client accounts for which the investment opportunity is appropriate may be able to participate, subject to Adviser’s allocation policy requiring fair and equitable treatment of client accounts over time. There is no specific limit on the number of accounts which can be managed by Adviser or its related persons. Once held by a client, certain investments compete with other investments held by other clients of Adviser. See “Contemporaneous Trading” below for further details on this subject.

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Adviser’s two investment groups (i.e., IAM, and TRFI) are largely independent of each other with regard to brokerage practices. This is due to differing system requirements, geographic locations, and related time differences, all of which have a material impact on managing client assets. Research is generally shared by the three business units. Transactions executed in the secondary market are processed at the business unit level without seeking prior input from the other business units. In certain circumstances this can lead to inadvertent crossing of client orders (a client of one business unit sells to a client of another business unit on a nonprearranged basis). Adviser monitors for such inadvertent cross trades. If an ERISA account is involved, Adviser will take all necessary actions to address related obligations. Adviser is generally retained on a discretionary basis and is authorized to determine which securities to buy or sell (including the amount thereof) within the client’s specified investment objective, and to select broker-dealers to execute portfolio transactions, without consultation with the client on a transaction-by-transaction basis. Each business unit makes its own determination as to what broker it uses for a particular transaction without consideration of the brokers used by other business units. Some clients limit Adviser’s discretionary authority in terms of the type or amount of securities to be bought or sold, the maximum concentration in any one company or industry, the minimum credit quality or maximum maturities for fixed income securities, the broker-dealer to be used, and/or the commission rates to be paid. Adviser can, but need not, select broker-dealers for accounts that are non-discretionary in nature. Adviser does not direct client brokerage to SLID, its affiliated broker-dealer. Except where a client limits Adviser’s discretion to select broker-dealers to execute trades, including through a directed brokerage arrangement (as described below), Adviser’s primary objective in the selection of broker-dealers is to seek to obtain the best combination of price and execution under the particular circumstances. Best price, giving effect to brokerage commissions, if any, and other transaction costs, is normally an important factor in this decision, but the selection also takes into account the quality of brokerage services, including such factors as execution capability, willingness to commit capital, financial stability, and clearance and settlement capability. In addition, as discussed further below, the provision of research and related services can also be considered. While Adviser does not maintain formal soft dollar arrangements, we do receive unsolicited or “street” research from broker-dealers from time to time. Where Adviser believes that more than one broker-dealer is capable of providing the best combination of price and execution with respect to a particular portfolio transaction, Adviser can select a broker-dealer that furnishes useful research services. Such research can include (i) advice as to the value of securities, the advisability of investing in, purchasing or selling securities, and the availability of securities or purchasers or sellers of securities (ii) information, analyses and reports concerning issuers, industries, securities, trading markets and methods, economic factors and trends, portfolio strategy (iii) access to research analysts, industry experts and economists, (iv) comparative performance evaluation and technical measurement services and quotation services, (v) products and other services, such as third party reports and analysis, software that processes

or otherwise utilizes information, including the research described above, that assist Adviser in carrying out its responsibilities to clients. Research services furnished by broker-dealers can be used in servicing any or all of Adviser’s clients and can be used in connection with accounts other than those that pay commissions to, or effect portfolio transactions with or through, the broker-dealer providing the research. Investment advisory fees will not be reduced as a result of Adviser’s receipt of research services. Adviser’s view is that the broker should receive a commission that will assure its best effort, compensate it for any research or related services provided, and at the same time result in a favorable rate for the client. Thus, transactions will not always be executed at the lowest available commission, but Adviser seeks to assure that commissions remain within a generally competitive range of what is available from full- service brokers. Transactions in fixed income securities are generally effected on a net basis with no brokerage commission paid by the client; rather the client bears a spread between the price a brokerdealer is willing to pay to purchase a security and the price the broker- dealer is willing to accept to sell a security. Subject to Adviser’s primary objective of seeking to obtain best price and execution under the particular circumstances, Adviser can place fixed income securities transactions with broker- dealers that provide Adviser with proprietary research or related services. Adviser does not make any commitments to allocate transactions among broker- dealers on a prescribed basis or to place a specified volume of transactions with any particular brokerdealer. Adviser periodically determines which brokerage research services, if any, are deemed useful in Adviser’s investment advisory activities. The receipt of research services from broker-dealers raises conflicts of interest for Adviser. The availability of research services provides an incentive for Adviser to place trades with brokers-dealers who provide such services. Adviser also has an incentive to recommend broker-dealers based on the Adviser’s interest in receiving the research or other products or services, rather than on Adviser’s clients’ interest in receiving most favorable execution. As noted above, Adviser’s primary objective in the selection of broker-dealers is to seek to obtain the best combination of price and execution under the particular circumstances. Adviser has a Trading Practices Committee that reviews Adviser’s trading activity quarterly, including brokerage placement to assess whether Adviser’s trading is consistent with this primary objective. In addition, Adviser conducts a review of brokerage policies and practices at least annually. Adviser can, but is not required in each instance to, aggregate or “bunch” orders for accounts for which it has investment discretion in circumstances in which Adviser believes that bunching will result in a more favorable overall execution. Where appropriate, Adviser will allocate such bunched orders at the average price of the aggregated order. Adviser generally does not aggregate orders where aggregation is not appropriate or practicable from Adviser’s

operational or other perspectives or if doing so would not be appropriate in light of applicable regulatory considerations. For example, time zone differences, trading instructions, cash flows, separate trading desks or portfolio management processes, among other factors, necessitate or result in separate, non-aggregated trades in the same security being placed contemporaneously for different clients. Clients can instruct Adviser to use one or more broker-dealers in managing their accounts. Clients who direct Adviser to use a particular broker-dealer should understand that, in so doing, they waive Adviser’s duty to seek best execution and forego the possibility that Adviser could (absent the direction) be able to obtain a more favorable net price and execution from another broker-dealer in particular transactions. Clients who direct the use of a particular broker-dealer for transactions should further understand that such direction can prevent Adviser from effectively negotiating brokerage commissions on their behalf and from aggregating orders with other clients. Thus, those clients that direct brokerage business could lose possible advantages that would potentially be available to clients who do not direct brokerage, such as volume discounts. Further, in instances in which Adviser is bunching a trade for clients who do not direct brokerage, Adviser will normally complete such non-directed discretionary transactions before effecting transactions for the directed brokerage clients. Thus, those clients who direct brokerage do not always obtain prices for their transactions as favorable as those obtained for other clients. Those clients that direct brokerage business should also consider whether the commission expenses, execution, clearance, and settlement capabilities of the brokers to which their brokerage business is directed are comparable to those that Adviser could otherwise attain for them. Similarly, these clients can also receive less favorable execution when they direct the use of broker-dealers that are not participating or eligible to participate in a portion of a "new issue" or other opportunity that is allocated to Adviser. Adviser manages foreign currency (FX) transactions through our approved counterparties or our clients' custodians. Adviser will execute FX transactions through a client’s custodian when directed by a client or when local market rules or settlement practices indicate this to be a more efficient method for settling our trade orders. Adviser will seek to aggregate FX transactions when doing so would be in the clients’ best interests and where permitted by applicable regulation. When Adviser executes through custodians at the direction of its clients, Adviser’s execution is generally subject to the limitations and considerations described above. Master Trading Agreements for Derivatives Certain investment strategies that Adviser manages utilize derivatives, such as swaps, futures, forwards and other forward settling transactions. These types of transactions typically require the negotiation of an agreement with one or more counterparties (for example, ISDAs, customer agreements with futures commission merchants, clearing agreements and master securities forward transaction agreements) (collectively, “Master Agreements”). Certain nonderivative securities, such as to-be-announced transactions, including adjustable-rate mortgage transactions and transactions in collateralized mortgage obligations, also use Master Agreements. These agreements can be executed by clients or, with client authorization, by Adviser on a client’s behalf.

When a client authorizes Adviser to execute Master Agreements on its behalf, Adviser is acting solely as agent on behalf of the client. This means that the client is the named party to the agreement and a party to the underlying transactions. Accordingly, such clients are responsible for any obligations incurred under the agreements. Adviser also can adhere to ISDA protocols on behalf of such clients, which effectively amend ISDAs that are already in place. Master Agreements require each party to make certain representations and warranties. Adviser does not have the information necessary to confirm the accuracy of many of these representations and warranties on behalf of our clients, and therefore it is important for clients to review these agreements and other materials that we provide in order to understand the applicable terms and to confirm the accuracy of any representations and warranties. Inaccurate or incomplete information in a Master Agreement can result in an event of default and allow the counterparty to terminate the agreement and take other adverse actions. Clients should also note that Master Agreements often contain indemnification provisions and, for sovereign or government clients, require the waiver of sovereign immunity. Cross Trades In some instances, a security to be sold by one client account may be considered appropriate for purchase by another client account. For example, a security sold to meet a redemption request may be an attractive investment opportunity for an account with excess cash, particularly securities which trade irregularly. For this reason, Adviser may effect cross-trades whereby one advisory client buys securities or other investments from or sells securities or other investments to another advisory client. Cross trades present conflicts of interest, such as the potential to favor one client over another. Adviser has implemented procedures to establish and evidence that when it crosses securities between clients: 1) the cross trade is in the best of interest of both clients; 2) the cross trade is commission free; 3) Adviser earns no fees on the trade; and 4) the sale and purchase are executed at an independently determined market price. Adviser also engages electronic platforms to sell securities and, when in the client’s best interest, it seeks to repurchase the same securities for the benefit of other clients (the repurchasers). Such repurchases are exposed to other bidders on the electronic platform and consequently do not constitute cross trades. Adviser takes steps to determine the high bid before selling and repurchasing a security. Adviser may not be able to repurchase attractive securities sold for selling accounts (such securities being sold for account specific reasons, e.g., to meet a redemption request) because a third party may outbid Adviser on the electronic platform. This may result in lost investment opportunities for repurchasing accounts.

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Adviser does not have any client referral arrangements in place at this time. However, from time to time Adviser could enter into solicitation agreements with certain of our affiliated investment advisers to refer clients to each other in which case Adviser would expect to pay or receive compensation in compliance with related SEC requirements.

Adviser has no disciplinary information to report.

Periodic Review of Client Accounts Adviser monitors accounts daily. Adviser’s investment professionals, within their respective business units, work in teams, each of which is dedicated to a specific asset class such as derivatives or public bonds. Adviser’s portfolio managers are responsible for making day-today management decisions for their accounts in accordance with applicable investment objectives and guidelines, and for ongoing evaluation of their accounts against those parameters. The portfolio managers routinely discuss market developments, investment ideas and strategy with other investment professionals of Adviser who have appropriate knowledge of the accounts and their investment strategies. Adviser’s investment teams review account performance and strategy more formally, generally on a monthly or quarterly basis, with the content of the reviews depending on the nature of the account and any needs that have been specified by the client. Additional Ongoing Reviews of Client Accounts Adviser’s Compliance Department, working with the investment staff, monitors client accounts in several different ways. The Compliance team uses automated testing, manual reviews, attestations, and forensic testing. Adviser uses electronic trade order management systems, including automated compliance modules, to monitor compliance with portfolio guidelines on both pre- and post-trade bases. Adviser’s oversight program for subadvised portfolios includes compliance reports, compliance certifications, and periodic due diligence visits to the subadvisers. Reports to Clients Clients generally receive at least quarterly written portfolio reports. The portfolio reports include account summaries and other pertinent information related to the account.

In certain instances, Adviser is deemed to have custody of client assets pursuant to Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). This can include, but is not limited to, instances in which: Adviser or an affiliate is acting as the administrative or servicing agent to a loan; Adviser or an affiliate instructs the qualified custodian and performs callbacks on behalf of clients for loan fundings; Adviser or an affiliate is acting as the general partner, managing partner or other similar role for a pooled vehicle; or where Adviser deducts management fees directly from a client account. Where Adviser is deemed to have custody of client assets, and except as permitted by the Advisers Act, such cash and securities are maintained in accounts established with qualified custodians, as defined in the Custody Rule (each, a “Qualified Custodian”) and the account’s Qualified Custodians will send quarterly or more frequent account statements directly to Adviser’s clients indicating the amount of funds and each security in their account at the end of the relevant period as well as any transactions in the account during that period. Clients should carefully review such statements and compare them to any account statements they receive from Adviser. If any discrepancies are found, clients should contact Adviser and their Qualified Custodian as soon as possible. Adviser’s statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. There are instances where Adviser or an affiliate serves as the administrative or servicing agent (in such role, the “Agent”) for one or more loans in which a client invests. Funds related to such loans and attributable to such clients (“Client Funds” related to “Client Loans”) are held in accounts established by the Agent for that purpose (the “Agent Accounts”). Each Agent Account is held with a Qualified Custodian in the name of the Agent for the benefit of the lender (the client). The Agent Account holds only cash and not loans. In its role as administrative agent, the Agent performs a variety of traditional services pursuant to credit agreements in accordance with negotiated guidelines regarding the movement of cash into and out of the Agent Accounts for such purposes as collecting and distributing loan proceeds or payments. As administrative agent, the Agent must apply the terms of the credit agreement in dealing with funds in the Agent Accounts and has no discretion to determine how such funds should be used, allocated or disbursed; however, other than the terms of the credit agreements, nothing prevents an Agent from withdrawing cash from the Agent Accounts for unrelated purposes. Therefore, Adviser considers itself to have custody over the Client Funds in the Agent Accounts for purposes of the Custody Rule. Adviser is deemed to have custody of the assets of certain funds by virtue of its role as general partner or Manager of the fund. Adviser provides investors in these funds with audited financial statements within 120 days from the end of each fiscal year (within 90 days from the end of each fiscal year for funds that are commodity pools). Investors should carefully review those statements. Additionally, Adviser is required to engage an independent public accounting firm to conduct an annual surprise verification of those client accounts over which Adviser is deemed to have

custody (other than those of the private funds for which audited financial statements are provided to investors), including the Agent Accounts.

For certain clients, we have investment discretion to manage securities on behalf of client accounts. Clients may impose restrictions on this discretion by, among other things, prohibiting the purchase of specific securities, or prohibiting the purchase of securities within a specific industry. Clients can restrict the use of certain broker- dealers to execute trades or restrict the amount of securities that can be bought or sold within the account. Client-imposed restrictions as well as discretionary authority are detailed in the client’s investment advisory agreement. Prior to on-boarding a new client account, Adviser obtains information, including any relevant restrictions needed to the account on our trading and accounting systems.

While Adviser generally does not have proxies to vote as an investment manager of primarily debt securities, in accordance with Rule 206(4)-6 under the Advisers Act, Adviser has adopted Proxy Voting Policies and Procedures (the “Proxy Voting Policies”) that are reasonably designed to ensure that proxies are voted in the best interests of its clients. In voting proxies on behalf of clients, Adviser will cast votes consistent with its fiduciary duty. The Proxy Voting Policies are designed to identify actual or potential conflicts of interest that exist or could arise between Adviser and its clients. If a conflict of interest or potential conflict of interest is determined to be material, one or more methods can be used to resolve the conflict, as specified in the Proxy Voting Policies. If it is determined that an actual or potential conflict is not material, Adviser can vote notwithstanding the conflict. Adviser takes responsibility for voting proxies for each client that has provided Adviser with express written authorization to do so, or where such express authority is provided by the advisory agreement. Where the advisory agreement is silent and where the client has not provided Adviser with express proxy voting authority, Adviser does not accept responsibility for voting proxies. A client that has authorized Adviser to vote proxies can also direct Adviser to vote in a manner different from the Guidelines (defined below) from time to time. All proxies received by Adviser will be voted based upon Adviser’s instructions and/or Proxy Voting Policies. As a general matter, Adviser will vote in accordance with the Proxy Voting Guidelines (the “Guidelines”) incorporated into the Proxy Voting Policies. Adviser is not obligated to follow the Guidelines in every case, however, and a proxy proposal receives further review, including a review for potential conflicts of interest, in circumstances where: a) the Guidelines call for caseby-case analysis; b) the Guidelines do not address the specific type of proxy proposal; or c) Adviser’s investment personnel wish to vote differently than the relevant Guidelines. Adviser takes responsibility for identifying material proxy-related conflicts between the interests of Adviser and its clients, and for resolving such conflicts in the best interests of the client. Adviser might be unable to vote or determine not to vote a proxy in certain situations, such as if, in Adviser’s good faith determination, the costs involved in voting the proxy outweigh the benefits to the client of voting. Upon request, Adviser will provide each client with a copy of the Proxy Voting Policies or with information about how Adviser voted proxies for securities held in the client’s account. Please direct requests to Adviser using the contact information that appears on the cover page of this Brochure. Proxies for subadvised portfolios with affiliated advisers will be voted by the subadviser in accordance with its policies and procedures.

Adviser is not aware of any financial condition that is reasonably likely to impair its ability to meet any contractual commitments to clients.