Veritas Asset Management LLP

Veritas Asset Management LLP (the “Firm” or “Veritas”) was organised as a limited liability partnership in the United Kingdom in 2014 but, taking into account its predecessor entities, the Firm has been in business since 1993. The Firm’s principal office is at One Smart’s Place, High Holborn, London, WC2B 5LW, United Kingdom. The Firm serves as an investment manager, investment adviser or sub-adviser to various clients, including, but not limited to pension plans, foundations, investment vehicles, U.S. mutual funds and governmental entities. (Please see Item 7 of this Brochure for more information with respect to the Firm’s clients.) The Firm provides such investment management services on a discretionary basis.

Principal ownership of the Firm The Firm’s principal owner is Affiliated Managers Group, Inc. (“AMG”). AMG holds a minimum of 65% interest in Veritas indirectly through three wholly owned subsidiaries. AMG is a publicly listed asset management company (NYSE: AMG) with equity investments in boutique investment management firms. In addition to its equity interest in the Firm, AMG also holds equity interests in other investment management firms (collectively the “AMG Affiliates”). Each of the AMG Affiliates, including Veritas, operates autonomously and independently, except as described in this Brochure. The remaining interest in the Firm is owned by the individual partners in the Firm. The Firm has one Corporate Partner and four Managing Partners. AMG owns a minimum of 65% depending on the appointment of new operating partners and retirement of existing operating partners.

Governance of the Firm The Firm is organised in the United Kingdom as a limited liability partnership, and is managed by the firm’s Managing Partners comprising two Portfolio Managers, the Chief Operating Officer and the Head of Clients and Investment Specialists. The Managing Partners Board, which is comprised of the Managing Partners and a non-Executive Chairperson, have overall responsibility for managing the Firm. The day-to-day business is overseen by the Management Committee and several subcommittees which include the Operating Committee and Investment Risk Committee. Such committees meet regularly and are comprised of Managing Partners and senior members of staff. The Firm undertakes discretionary management of mandates which are offered to clients by way of separate accounts Advisory services provided to separate account clients For separate account clients, the Firm offers asset management services that consist of continuous and ongoing supervision over specified account(s). Each client enters into a written investment management agreement to appoint the Firm as the investment adviser with respect to an account. Each account consists only of assets held by a qualified custodian under the client’s name. As set forth in each investment management agreement, each account shall be managed inline withone of the Firm’s investment strategies. A description of each strategy and certain risk factors is set forth in Item 8 below. The investment recommendations and any decisions of the Firm with respect to each strategy and account are subject to various market, currency, economic, political and business risks, and will not necessarily be profitable. The Firm cannot guarantee the future performance of any strategy or account, promise any specific level of performance, or promise that the Firm’s investment decisions or overall management of any strategy or account will be successful. Any asset withdrawals or any client investment restrictions may impair achievement of investment objectives. The Firm may manage investments for a

number of clients and may give advice or take actions for some clients that is different than the advice provided or actions taken for others.. Neither the Firm nor its partners or employees make any representations or warranties, express or implied, that any level of performance or investment results will be achieved by any strategy or account, or that any strategy or account will perform comparably with any standard or index, including any other strategies or clients of the Firm, and including clients whose accounts may be invested in the same strategy as other clients. The Firm is generally not expected to consider and diversify a client’s account based on any other assets the client might hold, and the Firm’s only responsibility with respect to diversification is to invest the assets held in the account in accordance with the investment strategy set forth in the investment management agreement. Each investment management agreement will also identify any investment restrictions that the client may impose with respect to the account. The Firm will not enter into any investment management agreement if a prospective client seeks to impose unduly restrictive investment restrictions.

Advisory services provided to U.S. registered investment companies The Firm serves as portfolio manager and sub-advisor to U.S. open-end investment companies (“Mutual Funds”) registered under the Investment Company Act of 1940 (“Company Act”). The Firm has entered into sub-advisory agreements with the investment advisers to the Mutual Funds to manage all or allocated portions of the assets of each Mutual Fund. Under the subadvisory agreements, the Firm is responsible for the day-to-day portfolio management of all or a distinct allocated portion of each Mutual Fund’s portfolio, subject to oversight by each Mutual Fund’s adviser. The Firm is responsible for managing all or the allocated portion of each Mutual Fund in accordance with the Mutual Fund’s registration statement as filed with the SEC, the Firm’s investment strategy selected by the Mutual Fund’s adviser, and applicable portfolio management and trading restrictions or limitations under the Company Act. Certain Mutual Funds are advised and distributed by affiliates of Veritas as discussed in Item 10.

Assets under management As of the 31st December 2025, Veritas managed approximately USD 19,132,764,879 client assets on a discretionary basis. Veritas does not manage any assets on a non-discretionary basis.

Fees paid to the Firm for investment advisory services are generally dependent on the nature of the services being provided. In addition to management fees, which cover only the Firm’s advisory services, clients bear other costs that are necessary or incidental to the advisory service. The particular incidental expenses may vary from client to client, although all clients will be subject to certain types of incidental expenses, including costs associated with buying, selling, or holding investments, such as custody fees and charges, and expenses associated with transactions such as taxes, duties and commissions, commission equivalents and other brokerage expenses. The Firm’s fees and any incidental expenses will reduce the assets held in, and the returns in client accounts and incidental expenses associated with accounts managed by the Firm are described below.

Separate account clients The following represents the Firm’s current standard fee arrangements for separate account clients:

First £25 million 0.75% (75 basis points) per annum

Next £50 million 0.60% (60 basis points) per annum

Next £50 million 0.50% (50 basis points) per annum

Thereafter 0.45% (45 basis points) per annum

Separate account fees have evolved over time and may be changed from time to time at the Firm’s discretion in discussion with clients. Set up and operating costs for a separate account would relate to the specific Custodian and Trustee appointed by the Client. Aside from the Annual Management Charge (“AMC”), VAT may be applicable, subject to status. In addition, each client is responsible for custody/administration fees, brokerage outside of the Firm’s charges. The specific manner in which fees are charged is established in a client’s written agreement with the Firm. Veritas will generally bill its fees on a monthly or quarterly basis in arrears. Management fees will be prorated for each contribution and withdrawal made during the applicable calendar quarter. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. The Firm’s management fees only cover advisory services from Veritas. Separate accounts are responsible for certain additional fees, expenses and costs (in addition to the management fee) which are incidental or related to the maintenance of an account for the buying, selling and holding of investments, including but not limited to brokerage commissions and related costs and expenses, transaction fees, custodial fees, governmental charges, deferred sales charges, odd-lot differentials, taxes and duties, wire transfer and electronic fund fees, transfer fees, registration fees, withholding taxes payable and required to be withheld on by issuers or agents, fees associated with cash sweep or cash management vehicles (including unaffiliated money market funds) and other fees and taxes on brokerage accounts and securities transactions. Collective investment schemes and exchange traded funds also charge internal management fees, which are disclosed in a Fund’s offering memorandum. Such charges, fees and commissions are exclusive of and in addition to the Firm’s fee, and the Firm shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that the Firm considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g. commissions).

U.S. registered investment companies The Firm furnishes investment advice as sub-adviser, trade execution, and certain administrative, and compliance services to the Mutual Funds. Each Mutual Fund’s primary investment adviser compensates the Firm for services provided pursuant to the sub-advisory agreements. Detailed information on the services and fees can be found in each Mutual Fund’s prospectus and statement of additional information.

Item 8 describes the general investment strategies employed by the Firm in managing separate accounts, client portfolios and the Veritas Funds, as well as the primary risks associated with these investment strategies, although it is not always possible to identify all the risks associated with investing. Particular risks applicable to a client portfolio will depend on the nature of the account, its investment strategy or strategies and the types of securities held. The Firm is an investment management firm whose key investment objective is to deliver long-term real returns for its clients. In general, the Firm may invest client assets in the following securities and instruments: equity securities, listed and unlisted securities, securities traded over the counter, non-U.S. securities, warrants, private placements, rights offerings, open-end funds, convertible bonds and preferred stock. The Firm may also invest in depositary receipts, synthetics or participation notes if direct local holdings in a market are not permitted or less advantageous. The Firm primarily utilises its own independent research and analysis and uses a bottom-up investment approach to create a diversified portfolio of equities. The Firm does not construct portfolios with reference to an index. The Firm has a long-term investment horizon. With respect to the management of Veritas Funds and the Mutual Funds, the investment objectives and restrictions are set forth in the relevant offering document. In respect of the separate accounts, certain clients do not permit investment in the securities of companies which operate in certain countries or which, for example, manufacture tobacco or are involved in the gambling industry. Such restrictions are set out in the investment management agreements. Any investment includes the risk of loss and there is 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 portfolios generally invest in equity securities, each in accordance with general investment strategies described below, subject to portfolio-specific investment objectives, guidelines and restrictions. Strategies will be taking liquidity, servicing and resources into consideration. Whilst the investment objective is specific to each strategy, there is commonality between them all with respect to the investment process, ideas generation, research, portfolio construction and risk management.

Global Equity Investment Strategy The aim of investment at VAM LLP is to generate total real returns whilst seeking to minimise risk of permanent capital loss. As a result, capital preservation and growth are considered paramount in the investment process and consequently the Investment Team mindset is focused on real returns. STEP ONE: Identify good quality companies to add to the Universe List 1. Idea Generation The Veritas Global Focus Strategy invests in 25 to 40 companies that are over $5 billion in market capitalisation. The investable universe consists of 4,000 of publicly listed companies of this size in which the Global Investment Team (the Investment Team) could theoretically invest. The Strategy aims to only invest in what is defined as good quality companies. The Investment Team defines quality as companies that generate high returns on capital, and significant free cash flow, have distinct structural drivers to ensure that cash generation is sustainable, offer barriers that prevent competitors competing away returns/cash, and management that deploys the cash in a predictable manner. The first step in the investment process is therefore to narrow down the thousands of publicly listed companies to a “long list” of companies suitable for further research. The Investment Team does not attempt to analyse all stocks in the index but use three broad idea generation methods to produce the long list. These are themes, proprietary insights and quantitative screening.

Themes: at any one-time certain industries will be facing economic or structural headwinds/tailwinds. These forces may be temporary or permanent in nature and their impact can be material. Within healthcare, for example, lifestyle diseases are growing as populations lead more sedentary lifestyles and spend more time using computers or smart devices. Myopia, or short-sightedness is becoming an epidemic problem, with up to 80% of schoolchildren in China suffering from the condition. Myopia is exacerbated by the increased time spent using computers or smart devices. This provides an enduring trend for companies that offer solutions. By analysing and understanding such themes, the Investment Team can identify lists of industries and companies for further analysis. Proprietary Insights: The Investment Team at VAM LLP has developed a wide and diverse proprietary network of contacts that includes company management, industry practitioners and consultants, political advisors, country specialists, economic and strategic consultants. The Investment Team utilises its years of experience and broad network, both as a source of ideas and as a method to validate existing ideas. Idea generation can come in many ways from this group. For example, an idea may be generated by attending a trade conference on obesity and the under diagnosed condition of sleep apnea. Similarly, with focus on decarbonisation, there are experts in the field of hydrogen, which discussions with could elucidate potential solutions. These ideas can lead to a short list of potential beneficiaries which move into the next phase of the research process. Quantitative Screening: The Investment Team also uses proprietary screening to identify potential candidates for further analysis. This in-house model has been developed specifically to look for quality companies that appear to be mispriced. The model consists of several quality metrics and overlays these with valuation metrics. The screen is run monthly and tends to be more useful at times of stressed/falling markets. In sharply falling markets for example, investors tend to panic and sell high quality liquid companies first which can create an opportunity for the long-term investor. 2. Research Having identified companies for further analysis, the idea moves into the next phase of the process: stock-specific research with ESG considerations fully embedded into the Investment Team’s assessment of quality. The Investment Team is arranged into Investment Analysts specialising in specific industries and roving Investment Analysts. The Investment Analysts specialising in specific industries cover Healthcare, Technology, and Financials, whilst the roving Investment Analysts will look at companies across more than one sector with a primary responsibility. For example, Owen Thomas analyses Consumer companies but will also look at Industrials. All Analysts perform in-depth fundamental analysis on investment candidates with the aim of assessing the quality characteristics. The key element is understanding what competitive advantages a company possesses and how enduring those advantages are likely to be. The Investment Team may utilise industry consultants to ensure it has a broad perspective on both the industry and company concerned. Given the importance of governance of a business, management will be independently rated by each of the Investment Team members. This will occur after a meeting with management. If over time, the rating drops, the thesis will be reassessed. At any stage during the research into a company, which can take many weeks, it may be discarded from the process. This is typically because during the research process, the analyst becomes concerned that the company does not have the durable competitive advantages it appeared to have or, its accounting metrics are not considered to be strong enough to meet the Investment Team criteria or, ESG considerations do not meet its assessment of quality. As a result, only around one in four of all ideas generated pass their criteria and are then eligible to join the Universe List of c.250 companies worldwide. The analysts must assess a company as being within the top third of companies in the world by quality. 3. Valuation Valuation is a critical element of the investment process. The Investment Team focusses on absolute valuations, not relative, and looks for a 15% p.a. internal rate of return (“IRR”) over a 5-year period. The analysts capitalise the cash they believe the company can generate in year 5 to place a value on the business. This valuation is then compared with today’s value. Given the analysts are valuing a company’s ability to generate cash, which is not an exact science, it is important to be conservative in their assumptions to offer a margin of safety.

STEP TWO: Portfolio construction The strategy is constructed from a bottom-up perspective without any reference to the benchmark. It is fairly concentrated with 25 to 40 holdings. Position sizing is determined by the rating of the company on the Universe List and strength of conviction in the stock. The Investment Team assigns a ranking of 1, 2 or 3 to each company on the Universe List with 1 being the highest quality, i.e., the very best business models in the world, 2 very high-quality companies and 3 is a high-quality company but within a more challenging industry or geography. For companies ranked ‘1’ the Investment Team are prepared to accept a lower margin of safety to reflect their highest quality and therefore lower internal rate of return (IRR) to enter the equity of that business, typically 12% p.a., for ‘2’ they would seek a higher margin of safety/higher IRR of 15% p.a. and ‘3’ an even bigger margin of safety/higher IRR of 20% p.a.. The rating is related to an overall assessment of quality including the predictability of cash flows, barriers to entry, competitive advantages, quality of management, strength of corporate governance and overall ESG assessment. The Investment Team will always construct the strategy with the lowest risk profile available, meaning that where the option arises to own either a company it ranks as ‘1’ i.e., the best quality company with an anticipated 12% p.a. IRR (or a company ranked as say ‘3’ i.e., lower quality but offering an anticipated 20% p.a. IRR it will always opt for the lower risk. A typical entry position is 1-3% and will buy up to a maximum of 6% Emerging market stocks or those rating 3 are unlikely to individually represent more than 3% of the portfolio. Consequently, cash is not a strategic allocation but an outcome of the valuation discipline and patience. Cash is usually held in the base currency of the Fund unless the fund managers have a strong medium-term view that another currency offers substantial appreciation potential in which case, a proportion of the cash will be invested in that currency. The Global Team operates mandates as follows:

Global Focus: The strategy is designed for long-term investors who wish to build capital over a number of years through investment in a focused portfolio of global companies in equities and equity derivatives consisting of 25 – 40 stocks.

Global Equity Income: The strategy, consisting of 25 – 40 stocks, is designed to provide a high and growing level of income and thereafter to preserve capital in real terms over the long term in equities which display an acceptable dividend profile.

Global Real Return: The strategy is designed to deliver real returns over the medium and longer term. More specifically, the target is to achieve a return on a compound annualised basis exceeding the OECD G7 CPI plus 4 % per annum in predominantly equities but can invest in CFDs.

Izoard: The strategy is designed for long-term investors who wish to build capital over a minimum five-year rolling period through investment in a concentrated portfolio of global companies of between 8 – 25 stocks, predominantly in equities.

Asia Equity Investment Strategy The investment strategy is long-only equity which uses six long-term structural growth themes as a filter from which to start in depth analysis of companies that benefit from these structural tailwinds to see if they have the necessary characteristics. The six investment themes within the Asian strategy are, Green Asia, Healthy Asia, Efficient Asia, Self-Reliant Asia, Aspirational Asia and Connected Asia, some of which are focused on a clear environmental and social impact that has been recognised by the management teams of the companies in which we are invested.

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Veritas provides portfolio management services to institutional clients primarily including: corporate pension schemes, local authorities, charitable institutions, foundations, government entities, and non-U.S. domiciled funds such as UCITS. The Firm also acts as a sub-advisor to Mutual Funds. The Firm does not generally set account minimums for separately contractually managed arrangements; however an amount of $20 million is deemed appropriate to ensure ongoing viability. However this minimum may be waived by the Management Board at its sole discretion. In addition, the Mutual Funds, and other pooled investment vehicle products, this Brochure is qualified in its entirety by the respective product’s offering memorandum, operating agreement, prospectus, statement of additional information, or similar disclosure and governing documents.

Performance based fees and conflicts of interest Certain separate accounts managed by the Firm operate performance-based fees. In each instance, the fee applies once the performance exceeds a pre-defined level referred to as a high-water mark. The Firm could be considered to have an incentive to favour performance fee accounts over other accounts and to also have an incentive to make relatively more risky investments in performance fee accounts but this potential conflict is managed as set out below. Because the performance fees received by the Firm may be subject to a benchmark or hurdle rate, the Firm may have the potential incentive to favour accounts that are generally above their respective benchmarks or hurdle rates (and therefore required to pay performance fees) over those accounts that are generally below their respective benchmark or hurdle rate (and therefore are not required to pay performance fees until such accounts return to their applicable high water marks) or accounts that are not subject to performance fees. This conflict is most apparent where two accounts follow the same, or a similar, investment strategy. Accordingly, the Firm and its personnel may have differing compensatory interests with respect to different clients. However, the Firm’s fiduciary obligations to act in the best interest of its clients mitigate potential conflicts of interest that may exist with respect to Veritas’ allocation of time, resources and investments among the clients based on differing compensatory interests. In addition, Veritas has a strict Code of Ethics and a Conflicts of Interest Policy in place, which applies to all employees and partners. Compliance with such policies is monitored by the Compliance team and management information is also provided to the Management Committee for review on a quarterly basis. In some strategies both an account that charges a performance fee and one which only charges an annual management fee may be managed by the same Portfolio Manager. In cases such as these, there may be the potential for conflicts of interest to arise, including the incentive to preference accounts for which performance fees are payable. However, in these circumstances, the investment process should largely be the same and the risk controls and trade allocation process is documented and reviewed by the Compliance team. Further, electronic monitoring via the Firm’s order management system ensures both accounts are treated equally.

Side by side management Side-by-side management of different accounts may raise potential conflicts of interests. Where the actions taken on behalf of one account may affect other similar or different accounts (e.g. because such accounts have the same or similar investment styles or have potentially conflicting investments or investment styles) and Veritas and its personnel have different interests in such accounts, Veritas may have an incentive to favour certain accounts over others that may be less lucrative, or to favour accounts in which it or its affiliates have a significant proprietary interest. Similarly, when Veritas receives performance-based fees or allocations, or Veritas personnel have a financial incentive to achieve gains in excess of the disincentive to suffer losses, Veritas and or such personnel may have an incentive to choose investments that are riskier or more speculative than might otherwise have been chosen. Such conflicts may present particular concern when, for example, Veritas places, or allocates the results of securities transactions that Veritas believes could more likely result in favorable performance, engages in cross trades or executes potentially conflicting or competing investments. To mitigate these potential conflicts, Veritas’ policies and procedures seek to provide that investment decisions are made based on the best interests of the accounts and without consideration of Veritas’ (or such personnel’s) pecuniary, investment or other financial interests. In addition, Veritas has a duty to treat all accounts fairly and equitably over time. Although the Firm has a duty to treat all portfolios within an investment strategy fairly and equitably over time, such portfolios will not necessarily be managed the same at all times. Specifically, there is no requirement that the Firm use the same investment practices consistently across all portfolios. In general, investment decisions for each client account may be made independently from those of other client accounts, and will be made with specific reference to the individual objectives of each client account. Furthermore, different client guidelines and/or restrictions, operational issues such as custody facilities and availability of cash, may lead to the use of different investment practices for portfolios within a similar investment strategy. As a result, although the Firm manages numerous portfolios with similar or identical investment objectives, or may manage accounts with different objectives that trade in the same securities, the portfolio decisions relating to the accounts, and the performance resulting from such decisions, may differ from portfolio to portfolio.

The Firm’s portfolio and dealing procedures are designed to ensure that all eligible portfolios (separate accounts and Veritas Funds) have an equal opportunity to participate in any investment opportunity at the same time. This applies to IPOs and limited offerings. Trades are allocated on a pro-rata basis across eligible client accounts unless there are specific business reasons to allocate otherwise. Partial fills are allocated pro-rata unless they are so small that this is uneconomic. Holdings of client portfolios are reviewed on a regular basis by the relevant members of the investment team. See Item 13. Allocations are reviewed internally as part of the compliance monitoring programme. Relevant controls are externally reviewed as part of the AAF 01/06 Type 2 report (which is an Internal Controls report, conducted by external auditors on an annual basis). A written Conflicts of Interest policy is maintained and reviewed at least annually. See Item 11. Along with the Firm’s Personal Account Dealing, Gifts and Hospitality, Order Execution and Order Allocations policies, these provide a framework for promoting the fair treatment of all accounts managed by the Firm.

Affiliations The Firm’s principal owner is Affiliated Managers Group, Inc. (“AMG”). AMG holds a minimum of 65% interest in Veritas, indirectly through three wholly owned subsidiaries, depending on the appointment of new operating partners and the retirement of existing operating partners. AMG, a publicly listed asset management company (NYSE:AMG) with equity investments in boutique investment management firms, holds a majority equity interest in Veritas. AMG also holds equity interests in certain other investment advisers (“AMG Affiliates”). Each of the AMG Affiliates, including Veritas, is operated autonomously and independently, and except as described in this Brochure, the Firm does not have any business dealings with these AMG Affiliates and does not conduct any joint operations with them. The AMG Affiliates do not knowingly provide advice for the Firm’s clients. One Mutual Fund client is a multi-manager product for which the Firm is a subadvisor amongst one or more other managers to the Mutual Fund client. The Mutual Fund client’s sponsor has other related fund products for which the Firm does not provide management services. It is possible that certain AMG Affiliates are hired by the client’s sponsor to manage the Mutual Fund or any of its products without the affirmative knowledge of the Firm as the selection of managers does not involve the Firm. As such, AMG’s ownership interest in the Firm does not, in the Firm’s view, present any potential conflict of interest for the Firm in respect of clients. As of April 2021, Veritas sub-advises four Mutual Funds sponsored and advised by its affiliate AMG Funds LLC and distributed by its affiliate AMG Distributors, Inc. Pursuant to a sub-advisory agreement with AMG Funds LLC, Veritas will be compensated by AMG Funds LLC for its sub-advisory work for the four funds. Veritas will receive no other compensation from the funds, or either affiliated entity. Given its limited broker-dealer status, Veritas will not place any securities transactions through AMG Distributors, Inc. The Firm is based in the United Kingdom and regulated by the UK Financial Conduct Authority. Veritas also provides services to institutional clients in a number of other countries including Australia via a class order exemption, and is licensed as a Financial Services Provider by the Financial Sector Conduct Authority in South Africa. Veritas is also authorized by the Central Bank of Ireland to provide investment management services to regulated funds in Dublin, Ireland. In addition, Veritas is not registered or regulated in Canada but does rely on a number of exemptions from registration as an exempt international dealer and as an exempt international advisor in Ontario, Canada. The Firm’s subsidiary, Veritas Asset Management (Asia) Limited (“Veritas Asia”) is a Hong Kong Limited Company and holds a financial services license from the Securities and Futures Commission (SFC) in Hong Kong. The Firm has entered into a service agreement with its affiliate Veritas Asia, pursuant to which Veritas Asia acts as a “participating affiliate” of the Firm and certain employees of Veritas Asia are treated as “associated persons” of the Firm. These associated persons provide investment research and Portfolio Management services to the Firm both in relation to US and non US clients as a Participating Affiliate. Veritas Asia itself is otherwise engaged in business exclusively outside of the United States.

Other financial activities Neither the Firm nor any of its management persons are registered, or have an application pending to register, as a broker/dealer, futures commission trader, commodity pool operator, commodity trading advisor, or an associated person of one of the foregoing types of entities.

The Firm has established a variety of restrictions, procedures and disclosures designed to address conflicts of interest arising between and among client accounts as well as between client accounts and the Firm and its personnel. All the Firm’s partners and personnel must act in accordance with the fiduciary standard. In addition to the provisions of the Code of Ethics which are described in greater detail below, the Firm maintains a written Conflict of Interest policy which identifies conflicts and potential conflicts of interest faced by the Firm and the relevant controls in place to address such conflicts. A current copy of the Code of Ethics can be obtained by contacting: compliance@vamllp.com

Code of ethics The Firm has a fiduciary duty to its clients, and accordingly has adopted a Code of Ethics (the “Code”) that applies to all partners and employees. The Code describes the standard of conduct the Firm requires of its partners and employees including personal trading in accounts owned, managed or beneficially owned by the individual. The Code’s provisions also include requirements relating to areas such as gifts and business entertainment, confidentiality of information, the provision and solicitation of political and charitable contributions and outside appointments. The Code of Ethics is reviewed at least annually and approved by the Compliance Officer.

Personal trading All partners and employees must provide the Firm with a listing of their securities holdings, as well as copies of trade confirmations and details of their brokerage accounts. These requirements of the Code apply to all accounts over which employees have investment discretion, or in which they have a direct or indirect beneficial ownership interest.

Participation or interest in client transactions Employees and partners of the Firm may invest in funds and other securities managed by the Firm. Personal investments may vary from product to product and investment personnel may choose not to invest in all products they manage. These investments may create a potential conflict of interest as investment personnel may have an incentive to favour the products in which they have a personal interest. The Firm requires that any such personal transactions must be approved by the Compliance Officer and/or Chief Operating Officer. The Firm does not buy or sell for the Firm’s own account as principal and only acts on behalf of its clients Veritas maintains policies and procedures, including the Code and policies and procedures regarding batch transactions (described in Item 12), reasonably designed to assure that Veritas and its personnel service all client accounts in a manner consistent with the duties an adviser owes to its clients and applicable law and without considering such persons’ ownership, compensatory or other pecuniary or financial interests.

Insider trading/material non-public information In addition, the Firm’s Code of Ethics also includes policies and procedures prohibiting the use of material non-public information that are designed to prevent insider trading by any partner or employee of the Firm. In accordance with these policies, any matter which may involve inside information is required to be brought to the attention of the Compliance Officer or the Chief Operating Officer prior to any trading activity. In addition, to prevent trading of public securities based on material, non-public information, the Firm maintains a “restricted list” that identifies any securities that cannot be purchased for personal or client accounts because material, non-public information may have been received by a partner or employee of the Firm. Provided such issuers are set up in the Firm’s systems, such issuers named on this restricted list are coded as “prohibited”

in the Firm's trading and portfolio compliance system, thus blocking the Firm from trading in these securities without the consent of the Firm’s Compliance Officer.

Gifts and business entertainment The Firm’s Code of Ethics includes policies and procedures regarding giving or receiving gifts and business entertainment between the Firm’s partners, employees and certain third parties (e.g. vendors, broker/dealers, consultants, etc.) to help mitigate the potential for conflicts of interest surrounding these practices. The Firm specifically monitors any potential conflicts of interest with respect to individual instances of gifts or entertainment, as well as patterns of the same over time, to prevent the interests of the Firm and its partners and employees from being placed ahead of the interests of clients.

Charitable contributions From time to time, the Firm may donate to charitable causes. In general, those donations are made in response to requests from the Firm’s partners or employees. The Managing Partners approve all charitable contributions to be made by the Firm. Political contributions The Firm prohibits its partners and employees from making political contributions on behalf of the Firm or to be reimbursed for personal political contributions, or from making political contributions for the purpose of securing or retaining business. All requests for political or campaign contributions from clients or potential clients are required to be declined and are strictly forbidden.

The Firm owes each of its clients a duty of care and loyalty and is required to execute securities transactions for its clients in a manner such that the net proceeds to the client are the most favourable under the circumstances. It is the Firm’s policy to select brokers or counterparties to execute client transactions in a manner that is consistent with the best interests of its clients and to employ a trading process that attempts to maximize the value of a client’s portfolio within the client’s stated investment objectives and constraints. In addition to the in-house execution trading desk, the Firm have appointed Northern Trust Securities LLP (‘Northern Trust’), an outsourced trade execution provider. The Order Execution Policy of Northern Trust operates in conjunction with the Firm’s Order Execution Policy. The Firm will continue to retain an in-house execution trading desk who will incorporate Northern Trust into their processes. In selecting a broker, the Firm may consider various relevant factors, although no one factor is determinative in the Firm’s decision-making process. These factors include one or more of, but are not limited to, best price, current market conditions, time constraints, liquidity, volatility in the markets, volatility in the particular type of security or asset, size and type of transaction, the nature and character of the market for the security or asset in the transaction, confidentiality, execution efficiency, settlement capabilities, financial soundness and credit worthiness of the Broker, full range and quality of the broker’s services, the responsiveness, reputation, reliability and experience of the broker, the reasonableness of any commissions or spreads, difficulty of execution, ability and willingness to commit capital to the transaction, past effectiveness in executing illiquid or difficult types of securities or assets or difficult types of orders. Best execution means that the net proceeds to a client are the most favourable under the circumstances. Best execution does not mean that the client must obtain the lowest possible commission cost. It is the Firm’s policy to establish the methods to be followed to ensure that it is seeking to achieve best execution of its clients' portfolio transactions while complying with all applicable regulatory standards and the investment guidelines of its clients. The relative importance of the execution factors is judged on an order-by-order basis in line with the Firm’s industry experience and the prevailing market conditions at the time. As the arrangement with Northern Trust is complementary to the in-house dealing desk, the decision whether to transmit the order to Northern Trust or be executed internally (once pre-trade compliance has been completed) lies with the in-house execution trading desk. Once Northern Trust receive the order, they are contractually obligated to provide the Firm with ‘best execution’. The Firm will not direct the broker where to direct the trades. The Firm has an obligation to monitor the effectiveness of its order execution arrangements in accordance with the Order Execution Policy. The best execution performance of Northern Trust will be monitored by Compliance on an ongoing basis and on a monthly basis, utilising Transaction Cost Analysis reports produced by an independent third party. All Firm brokers are subject to initial vetting and thereafter regular performance review by the Operating Committee, which comprises the Chief Operating Officer, Execution Trader, Compliance Officer, General Counsel, Investment Operations Manager and Head of Technology. The Firm will always seek brokers that provide an efficient service at a commission rate that is competitive and in line with market norms or better. The rate negotiated is reviewed on a regular basis by the Operating Committee. The Firm uses a retrospective analysis of services provided to identify brokers who have consistently and substantively added value to the investment process. With respect to execution factors, the trading desk conducts a quarterly review and input may be sought from the Investment Operations team. This review of execution factors is also reported to the Management Committee. Trade aggregation and allocation When the same investment decision is made for more than one client on the same day, the Firm may place orders to buy or sell the same security for a number of clients. Whenever possible, orders to purchase or sell the same security for multiple accounts are aggregated. The Firm will not aggregate investment transactions for accounts unless the transaction is consistent with the Firm’s duties to its clients, the terms of the applicable investment advisory agreement and each account’s investment objectives, restrictions and policies. The Firm’s general policy is to aggregate orders for one or more clients in the same security if the investment decisions for such clients are made contemporaneously or, before an order for one client has been executed, a decision to purchase or sell the same security is made on behalf of another client. The orders for two or more clients should be aggregated only if the Firm determines that:

Aggregation is consistent with the Firm’s duty to obtain best execution;

Aggregation is consistent with the terms of the investment advisory contract of each participating client; and

No advisory client will be favoured over any other client.

The Firm’s policy is to allocate investment opportunities among various clients (including the sequence of placing orders) in a manner believed by the Firm to be fair and equitable to each client over time. The allocation of investment opportunities will never favour any client account over the detriment of another client. In addition, the allocation of investment opportunities will not favour the Firm. The key elements of the procedures for implementing this policy are summarised below: The Firm’s trading procedures incorporate a systematic allocation model which requires Fund Managers to identify on the dealing sheet, the basis of allocation for each trade undertaken. The Firm may manage multiple accounts with similar investment objectives and strategies or may manage accounts with different objectives or strategies that may trade in the same securities. Despite these similarities, the Firm’s portfolio decisions about each client’s investments and the performance resulting from these decisions may differ from those of other clients. The Firm will not necessarily purchase or sell the same securities for client accounts at the same time or in the same proportionate amounts for all eligible clients. It is expected, however, that client accounts with similar investment objectives may trade many of the same securities at the same time. When the Firm purchases thinly traded securities or oversubscribed public offerings, it may not be feasible to allocate a transaction pro rata to all eligible clients. Therefore, not all clients will necessarily participate in the same investment opportunities or participate on the same basis. The Firm shall allocate investment opportunities among its clients (including the sequence of placing orders) in a manner believed by the Firm to be fair and equitable to each client over time. In making these allocations, the Firm should take into account the following factors:

The client’s investment objectives and strategies.

The composition, size and characteristics of the account.

The client’s country weightings.

The cash flows and amount of investment funds available to each client.

The amount already committed by each client to a specific investment.

Each client’s risk tolerance and the relative risk of the investment.

The marketability of the security being considered.

Allocation is imposed through the automated order management system. All allocation objectives and implementation procedures are designed to ensure that all clients receive equitable treatment, ensuring as far as possible that all portfolios with the same mandate look alike. Partial fills are allocated pro rata, to the value of orders placed unless resultant allocation is so small to make settlement uneconomic. Separate and pooled accounts are treated alike under this allocation process. Allocations across portfolios are reviewed as part of the compliance monitoring programme.

Initial Public Offerings (“IPOs”) An initial public offering is a company’s first offer of stock for sale to the public. Depending on the interest in this initial offering, the Firm’s access to these newly offered shares may be limited in amount at the time of the initial offering. In the event that the Firm participates in any initial public offerings and other securities with limited availability (collectively, “IPOs”), the Firm allocates IPOs among accounts as it would for any other security that is, on a pro rata basis and taking into consideration factors such as client eligibility, client account objectives and preference, investment restrictions, account sizes, cash availability, and current specific needs. Allocation of IPOs and other limited offerings across client accounts is monitored periodically as part of the internal monitoring process to ensure that all accounts are treated fairly and equitably over time.

Trade errors and trade error accounts The Firm has a Breaches and Errors Escalation Policy which is adhered to in the event that such an incident occurs. If a trade error were to occur, it is the Firm’s policy to make the client account whole. Also, if a client account were to benefit from a trade error, any profits would remain with the account (unless the client instructed otherwise). Any material breach of an investment restriction would be disclosed to the Client.

Internal cross trades In certain circumstances, the Firm may deem it advisable and appropriate to sell securities held in one client account managed by the Firm to another client account managed by the Firm, an internal cross trade. The Firm may engage in internal cross trades where prudent, in compliance with SEC and Department of Labor rules, and where permitted by client contracts and the Firm’s policies and procedures. In the ordinary course of its business, the Firm primarily executes cross trades between client accounts that have particular liquidity mandates. The Firm does not engage in agency cross transactions (i.e., transactions in which the Firm earns a fee other than its advisory fee). Cross trades are rare but where they are permitted, take place, other than in exceptional circumstances, via executing brokers at market prices, generally executed at mid-point of the bid-ask price at the time the last order is placed. Where an internal cross trade involves a Mutual Fund client on either end of the transaction, the cross trade will be subject to Rule 17a-7 under the Company Act which may differ in how the price is determined than from the Firm’s policy. The Firm does not permit internal cross trades involving one or more retirement accounts (e.g., subject to ERISA). In other cases, the Firm will ensure that any internal cross transactions are in the best interests of and appropriate for both clients, the transactions are consistent with the Firm’s obligations to seek best execution, and an independent or objective pricing mechanism is used. To the extent a broker is intentionally utilized to facilitate a cross trade with or without compensation, the Firm will honor the same process and requirements. Cross trades present an inherent conflict of interest because the Firm acts on behalf of both the selling account and the buying account in the same transaction. As a result, the use of cross trades could result in more favorable treatment of one client over the other. Additionally, there is a risk that the price at which a cross trade is executed may not be as favorable as the price available in the open market selling account and the buying account in the same transaction. As a result, the use of cross trades could result in more favorable treatment of one client over the other. The Compliance Officer/Chief Operating Officer must approve any internal cross trade. In considering such requests, the regulatory requirements, client guideline restrictions and fairness of the trade to both parties are assessed and the transactions are done for the sole benefit of all participating clients. The Compliance team maintains a register and it is reviewed and monitored on a weekly basis. Notwithstanding the above, the Firm has prohibited cross trades for all Registered Investment Company clients.

Foreign exchange (“FX”) transactions For the majority of separate account clients, the Firm instructs FX transactions through an FX trading platform (“Info FX”) operated by a third-party provider, Brown Brothers Harriman. In addition, the firm appointed Northern Trust for third party trade execution services who also execute trade related FXs for securities transactions they execute and settle. For clients that have not elected to use the Info FX platform, there are standing instructions in place of the Custodian to execute any trade related FXs. This is done either through standing instructions communicated to the custodian when the account is established or at the time settlement instructions are sent to the custodian for a particular transaction. The custodian is responsible for executing FX transactions, including the timing and applicable rate, of such execution pursuant to its own internal processes. Where a client has arrangements in place with their custodian regarding the execution of FX transactions, such arrangements may impact the fees and expenses charged to the client by the custodian. Therefore, all such FX transactions are effected with the client's custodian, and the Firm does not seek to obtain different FX rates from other sources.

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The Firm has dealings with investment consultants, both in the consultants’ role as adviser for their clients and through independent business relationships. Specifically, consultants are provided with information on portfolios managed for the Veritas Funds, and separate accounts at their request. The Firm also provides information on the various investment styles to consultants, who use that information in connection with searches they conduct for their clients. The Firm may also respond to “Requests for Proposals” (“RFPs”) from prospective clients in connection with those searches.

Neither the Firm or its management persons have been subject to legal or disciplinary events that are material to its advisory business or that would be material to its existing or prospective clients’ evaluation of its advisory business or the integrity of its management.

Client accounts are monitored regularly based on each client's investment objective and investment guidelines, the Firm's investment policies, and compliance with statutory and regulatory requirements by the Investment Team and Compliance. Client accounts are monitored on a pre- and post-trade basis through the Firm’s order management system. The system has programmed rules and restrictions that are monitored through daily exception reports. The Investment Teams also meets formally on a weekly basis to review portfolio weights, country allocation, as well as the performance of each strategy for the prior week, month-to-date, quarter-to-date and year-to-date. Clients will receive regular reporting which will include monthly and quarterly fact sheets as well as Fund Manager commentary. The fact sheets include information on account performance and allocations.

The Firm does not act as custodian for any assets in the accounts managed on behalf of clients. Clients must make their own arrangements for custody of securities in their account(s). Such custodians may be broker/dealers, banks, trust companies, or other qualified institutions. Qualified custodians will typically provide clients with account statements no less frequently than quarterly relating to the assets held within the account managed by the Firm. The Firm urges clients to carefully review the qualified custodian’s statement upon receipt to determine that it completely and accurately states all holdings in their account and all account activity over the relevant period. If a client has any questions, concerns, or notes any discrepancies between the qualified custodian’s report and any reports provided by the Firm, they are encouraged to contact both the Firm and qualified custodian immediately. The information contained in the statements provided by the Firm and the statements from qualified custodians may differ slightly for reasons including but not limited to the use of different pricing sources, pending trades, the use of trade-date data versus settlement-date data, corporate actions, payment of dividends, and tax reclaims. Any questions in this regard can be addressed to the Firm by emailing the following: Email: complianceteam@vamllp.com

The Firm does not have actual physical custody of any client assets or securities held in the funds managed by the Firm. Rather, portfolio assets are held by an independent qualified custodian. The Veritas Funds are audited annually and investors receive annual financial statements by the funds’ independent public accounting firm.

For separate account clients, each client delegates investment management discretion to the Firm pursuant to its investment management agreement. In exercising its judgment in managing client accounts, the Firm takes into account the individual objectives, restrictions and guidelines of each client, as communicated by the client, and other factors deemed relevant by the client and disclosed to the Firm. Generally, to the extent that a client wishes to impose limitations on the management of its account, the Firm will review any such limitations or guidelines provided by a client prior to the inception of the account. To the extent that any such guidelines or limitations are not acceptable, Veritas will work with the client to make appropriate revisions to such documentation in a manner that is mutually acceptable to both parties. With respect to the Veritas Funds, the Firm is appointed as the investment manager on a discretionary basis based on the investment objectives and restrictions as set forth in each Veritas Fund's offering memorandum. Client portfolios with similar investment objectives within the same investment strategy are generally managed similarly with a goal that each such client account would have the same percentage of the portfolio invested in the same securities (subject to differences arising from a variety of factors, including, but not limited to, client restrictions and liquidity of underlying securities, when the portfolio was opened and cash flows into and out of the portfolio). Investment opportunities are generally allocated to those accounts, which the Firm determines, in its sole discretion, to have an investment mandate and profile consistent with the type of security and which the Firm determines, in its sole discretion, should be included in the portfolio. All such allocation decisions are subject to client guidelines and restrictions. Other factors considered by the Firm include but are not limited to, the availability of alternative investments, the extent to which the allocation would represent a meaningful position for the account, the liquidity of the security and the availability of cash to settle the transaction. Client requests for particular securities may also be considered.

The Firm has adopted a Global Voting Policy (“Voting Policy”), as required by Rule 206(4)-6 (the “Proxy Voting Rule”), governing conflict of interest resolution, disclosure, reporting and recordkeeping relating to voting proxies. The Voting Policy is intended to facilitate compliance with the Proxy Voting Rule and other applicable fiduciary obligations under rules and regulations of the SEC and interpretations of its staff. The Global Voting Policy is disclosed to all clients. The Firm considers proxy voting an important responsibility on behalf of those clients it has discretionary voting authority for and seeks to vote proxies of securities held in such clients’ accounts for which it has such authority in the best economic interest of that client. To the extent that the Firm receives such proxies, it is guided by general fiduciary principles. The Firm need not vote all proxies held by clients. From time to time, the Firm may abstain from voting on behalf of a client. However, if the Firm does vote, it shall cast ballots in a manner it believes to be consistent with the interests of clients and shall not subordinate client interests to its own.

Voting agent The Firm has contracted with Institutional Shareholder Services (ISS), an independent third-party provider of proxy voting and corporate governance services. The proxy agent has been retained to provide vote recommendations, research and vote execution services as instructed by the Firm. In addition, they assist with maintaining the necessary records for tracking proxy voting materials and proxy voting actions. The Firm uses ISS to execute voting on behalf of clients and have also mandated ISS to construct a customized screen for various ESG issues which incorporates the AMNT Red Lines, on a best endeavors basis. The Red Line Voting Policy contains guidelines covering topics associated with ESG. Should any of the red lines be breached, the instruction is to either vote against management or explain why not. Given this AMNT Red Line Voting Policy was developed principally for pooled fund investors (who have been unable to direct votes) and for UK stocks only, ISS have been instructed to apply the custom policy globally where applicable and apply the policy across all clients.

Conflicts of interest The Firm votes proxies in the manner that it believes is consistent with efforts to achieve a client’s stated objectives, including maximizing the value of the client’s portfolio. The Firm follows procedures that are designed to identify conflicts or potential conflicts that could arise between its own interests and those of clients. Examples of potential conflicts within proxy voting include, but not limited to an investee company, whose pension scheme may be one of the Firm’s clients, or where the clients are shareholders in two companies involved in both sides of a deal or dispute. The Firm’s Environmental Social and Governance team provides ongoing monitoring to ensure that the conflicts of interest register is kept up to date, with the deletion or addition of any conflicts as necessary, and the relevant teams will be notified of any changes to ensure that voting is carried out in accordance with this policy. The Firm’s Management Committee oversees this process and are informed of any amendments to the conflicts of interest register. A copy of the Firm’s Voting Policy and details on how the Firm voted on a particular security in respect of your account, please contact: Email: complianceteam@vamllp.com

The Firm does not have any financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and it has not been the subject of bankruptcy proceedings.

Veritas Asset Management LLP 1 Smart’s Place, London WC2B 5LW T +44 (0)20 3758 9900 F +44 (0)20 3070 0990 investorservices@vamllp.com vamllp.com Authorised and regulated by the Financial Conduct Authority. Registered office: 1 Smart’s Place, London WC2B 5LW Registered in England & Wales. Registered Number: 0C392918. VAT Registration Number: 231 6200 58