New England Asset Management, Inc.: investment adviser

NEAM provides clients with periodic market commentary and investment research pieces at no additional charge. Fixed Income Mandates Most discretionary client portfolios managed by NEAM are investment grade fixed income mandates. These portfolios are actively managed on a separate account basis relative to either a broad market or customized benchmark. Preferred Securities Strategy NEAM’s Preferred Securities strategy seeks to generate attractive levels of after-tax investment income and competitive total returns via investment in preferred stocks and hybrid securities. Structured Products Yield Enhancement Strategy NEAM’s Structured Products Yield Enhancement strategy is a specialized income-driven total return strategy aimed at higher yielding fixed income opportunities within the structured securities sector. Equity Strategies NEAM offers two actively managed equity strategies: Focused Value Equity Management strategy (“FVEM”) applies a value-driven approach that seeks to outperform its benchmarks with less volatility over full market cycles by investing in equity investments primarily among the top 1,500 U.S. capitalized stocks and select international stocks. Dividend Select Equity strategy (“Dividend Select”) seeks to deliver attractive levels of after-tax investment income while positioning portfolios to benefit from dividend growth and price appreciation over the longer term by investing in high-dividend equities from companies with stable earnings profiles. NEAM’s ETF strategies seek to provide generic exposure to specific sectors, markets, and/or geographic regions by utilizing specific ETFs. The selection of specific ETFs is informed by the research carried out by NEAM’s equity group, the investment guidelines set by the client, and discussions with the client. High Yield Strategies Through a sub-advisory arrangement with Polen Capital Credit, LLC (“Polen Credit”), NEAM offers the following strategies: U.S. Opportunistic High Yield; U.S. High Yield; Credit Opportunities; and Bank Loan (see Item 8 for strategy descriptions).

Clients investing in these strategies will receive Polen Credit’s Form ADV Part 2A from NEAM. They should review it for more information about the sub-adviser’s strategies, risks, and potential conflicts of interest. NEAM offers, through a revenue sharing arrangement with Polen Credit, recommendations to participate in the Institutional Class of the Polen Opportunistic High Yield Fund and other Funds offered by Polen Credit (each, a “Fund” and collectively the “Polen Funds”) (see Item 5). As a result of this arrangement, NEAM’s Assets Under Advisement (“AUA”) is $247,018,621 as of December 31, 2025. Private Placement Strategy NEAM’s Private Placement strategy seeks to achieve an incremental spread and yield compared to similarly rated public securities by investing in a diversified portfolio of private placement bonds, which may include 4(a)(2) private placements, credit tenant lease transactions, private assetbacked securities, and private structured finance securities, primarily of investment-grade quality. NEAM shares revenue from the Private Placement Strategy with Nassau Financial group. Investment Accounting and Reporting Services In addition to providing asset management services, NEAM offers investment accounting and reporting services primarily to insurance company advisory and non-advisory clients. This includes assistance in Schedule D data preparation on an annual and quarterly basis. Enterprise Capital Strategy Services NEAM’s Enterprise Capital Strategy services provide a framework and the analytics to support insurance company clients in achieving their capital management financial goals and enterprise risk management objectives. The primary deliverable is an asset allocation analysis customized to the unique needs of insurance companies, called Enterprise Based Asset AllocationTM (EBAATM). Additional information about NEAM’s Enterprise Capital Strategy suite of services is available upon request. Capital and Risk Analytic (CARA®) Platform The CARA® platform is a web-based investment risk management platform that allows clients to monitor and evaluate their investment portfolios daily. Pooled Investment Vehicles/Private Funds NEAM serves as collateral manager for three collateralized debt obligations (which are no longer offering interests to new investors). The interests in these funds are privately placed security offerings that are exempt from registration under the Securities Act of 1933, as amended, and the funds are exempt from registration under the Investment Company Act of 1940, as amended. Tailored Advisory Services NEAM tailors its advisory services to meet the unique needs of its clients. Assets are managed on a separate account basis and investment strategies are developed within guideline constraints unique to each client. Clients may impose restrictions on investing in certain securities or types of securities by specifying in their investment guidelines and/or by notifying NEAM in writing. NEAM’s Assets Under Management (“AUM”) as of 12/31/2025 Discretionary $87,309,518,834 Non-Discretionary $24,408,504,748 Total Assets under Management $111,718,023,582

High Yield (sub-advised) Private Placements

Dividend Select ETF Focused Value Equity Management (FVEM) U.S. Opportunistic High Yield U.S. High Yield Credit Opportunities Bank Loan Private Placements

First $250 million Over $250 million Greater than $0

Greater than $0

Greater than $0

Basis Points 35 bps 30 bps 25 bps 20 bps 50 bps Up to 20 bps 50 bps 50 bps 43 bps 95 bps 50 bps Up to 30 bps1

Enterprise Capital Strategy Services Enterprise Capital Strategy services for managed assets are generally included in the overall asset management fee. Any additional fees for Enterprise Capital Strategy services are determined based on the level of complexity and scope of the assignment. Capital and Risk Analytics (CARA®) Platform Fees are inclusive of access to the CARA® platform for managed assets. Any additional fees are subject to negotiation and are fully agreed to in writing for client’s unmanaged assets on the CARA ® platform. The amount of the fee depends on the size of the portfolio, the nature of the unmanaged assets, the frequency of data being loaded into the CARA® platform, and if NEAM provides investment accounting services on the unmanaged assets. Investment Accounting Services The standard fee is 1 basis point on the market value of assets managed by NEAM and accounted for, and 2 basis points on assets that are unmanaged but accounted for, and is, on occasion, included in the overall asset management fee. The investment accounting services can also be subject to a minimum annual fee which varies, based on the agreed upon fee schedule. Depending on data quality and the date that investment accounting services begin, a one-time flat fee for conversion of the investment data into NEAM’s accounting system may be charged. Additional Fee Considerations

NEAM pays a portion of the advisory fee to a third-party. This arrangement is specified in Item 14 of this Brochure.

NEAM’s fees are billed to clients one month in arrears of quarter end unless other billing cycle terms are agreed to in writing with the client. NEAM sends quarterly invoices directly to clients for payment of fees, based on the market value of the assets as of the close of business on the last day of each month, unless other valuation terms are agreed to in writing with the client. Accounts initiated or terminated during a calendar quarter are charged a prorated fee. Upon termination of the IMA, since fees are billed in arrears, clients will not receive a refund of advisory fees and any earned, unpaid fees will be due and payable. If the IMA is terminated prior to month end, the fees for the final partial month are prorated and calculated based on the prior month end valuation. In addition to NEAM’s fees described above, clients will incur other costs and expenses related to the investment of their accounts, including transaction charges, service provider fees, and fees and expenses related to underlying fund investments, among others. Transaction Charges Clients will pay brokerage commissions for equity transactions. For fixed-income transactions, there are no additional costs. See Item 12 for a further description of the brokerage practices, including brokerage and other transactions costs. Service Provider Expenses Clients will pay the fees charged by the service providers to their accounts, including the fees charged by the custodian, administrator, and any other service providers to their accounts. Underlying Fund Expenses If a client’s account is invested in a pooled investment vehicle (e.g., a mutual fund or ETF), a client is subject to conditions or restrictions regarding the purchase or holding of fund shares, including minimum purchase requirements and fees for redemption of shares within a specified period. Clients should carefully review the fund’s prospectus for details pertaining to fees and expenses. The management fees and other expenses associated with mutual funds and ETFs are exclusive of and in addition to NEAM’s fee. NEAM does not receive any portion of such fees except for the Polen Funds. Revenue Sharing Arrangement with Polen Credit NEAM receives compensation from Polen Credit through a revenue sharing arrangement when clients elect, on NEAM’s recommendation, to invest in the Polen Funds. The fee is paid from Polen Credit’s own profits or retained earnings and not directly from the assets of the Polen Funds. The fee is calculated based on an annualized revenue sharing fee that varies based on the net asset value (“NAV”) of each Fund and NEAM client assets represented in that Fund. This payment continues for the duration of the relationship between NEAM and the client to the extent they are a shareholder in a Fund. These payments create a conflict of interest as NEAM has a financial incentive to recommend the Polen Funds over another investment that does not pay NEAM with revenue sharing. NEAM seeks to mitigate this conflict by disclosing it in this Brochure and providing additional written disclosures when recommending the Polen Funds.

3) Execution – Research Analysts and Traders aggregate the high level directives provided by the Portfolio Management function and match those directives with individual securities. This is done by applying our relative value and credit processes on an individual security basis, selecting securities and conducting trade execution in the marketplace. 4) Controls – The overall investment process is managed through trading, compliance, and risk workflows and controls. Other Investment Strategies Preferred Securities Strategy NEAM’s Preferred Securities strategy seeks to generate attractive levels of after-tax investment income and competitive total returns via investment in preferred stocks and hybrid securities. Structured Products Yield Enhancement Strategy NEAM’s Structured Products Yield Enhancement strategy is a specialized income-driven total return strategy aimed at higher yielding fixed income opportunities within the structured securities sector. The Structured Products Yield Enhancement strategy seeks to capture the premium associated with non-benchmark ABS asset types and subordinate tranches in relation to their relative value and market yield attractiveness. The Structured Products Yield Enhancement strategy is intended for Qualified Institutional Buyer (“QIB”) investors with a tolerance for potential volatility and/or limited liquidity. Private Placements Strategy NEAM’s Private Placements strategy aims to earn an incremental spread and yield to comparably rated public securities by investing in a diversified portfolio of private placement bonds, which may

include 4(a)(2) private placements, credit tenant lease transactions, private asset backed securities and private structured finance securities of primarily investment grade quality. Equity Mandates NEAM’s Focused Value Equity Management strategy (“FVEM”) and Dividend Select Equity strategy (“Dividend Select”) combine quantitative analysis and qualitative judgments within a controlled risk framework. NEAM’s ETF strategies provide exposure to specific sectors, markets and/or geographic regions. Focused Value Equity Management Strategy NEAM’s FVEM strategy applies a value-driven approach that seeks to outperform its benchmarks with less volatility over full market cycles by investing in equity investments primarily among the top 1,500 U.S. capitalized stocks and select international stocks. Dividend Select Equity Strategy NEAM’s Dividend Select Equity strategy seeks to deliver attractive levels of after-tax investment income while positioning portfolios to benefit from dividend growth and price appreciation over the longer term by investing in high-dividend equities from companies with stable earnings profiles. ETF Strategies NEAM’s ETF strategies seek to provide generic exposure to specific sectors, markets, and/or geographic regions by utilizing specific ETFs. The selection of specific ETFs is informed by the research carried out by NEAM’s equity group, the investment guidelines set by the client, and discussions with the client. Sub-Advisory Arrangement – NEAM has entered into a sub-advisory arrangement to delegate portfolio management and day-to-day investment management services for the following high yield strategies: U.S. Opportunistic High Yield Strategy The sub-adviser seeks to outperform the broader high yield market by employing a bottomup, fundamentally-oriented investment process that primarily targets middle market opportunities in the lower tier (i.e., rated single B and below) of the non-investment grade credit markets. U.S. High Yield Strategy The sub-adviser seeks to outperform the broader U.S. high yield market by employing a bottom-up, fundamentally-oriented investment process that focuses heavily on downside protection. Portfolios pursuing this strategy have limited exposure to CCC-rated debt issues, seek to avoid defaulted securities, and may or may not have exposure to syndicated loans depending on specific client guidelines. Credit Opportunities Strategy The sub-advisor seeks to produce a high level of total return by primarily targeting investments in fixed income securities across the capital structure of an issuer (and, in particular, leveraged middle market companies). To achieve this objective, Polen Credit employs a deep value approach and retains a high degree of flexibility to make tactical allocations to the most compelling opportunities in the market, including all types of investments targeted by the U.S. Opportunistic High Yield strategy with a greater emphasis on second lien loans and direct lending opportunities. In addition, depending on specific client guidelines as well as market conditions, Polen Credit may make limited allocations

to distressed debt as well as to reorganized and leveraged equities. The strategy may target liquid and illiquid investment opportunities. Bank Loan Strategy The sub-advisor seeks to provide high current income primarily by investing in floating rate debt instruments with an emphasis on principal protection. This strategy targets predominantly syndicated, first lien secured term loans that are senior in the capital structure of middle market, non-investment grade issuers. Clients pursuing this strategy may also permit allocations to second lien secured term loans as well as fixed rate high yield bonds. Description of Risks Investing in securities involves risk of loss that clients should be prepared to bear. No investment process is free of risk; no strategy or risk management technique can guarantee returns or eliminate risk in any given market environment. There is no guarantee that our investment strategies will be profitable. Past performance is not indicative of future performance. The value of investments, as well as any investment income, is not guaranteed and will fluctuate based on market conditions. Diversification does not ensure profit or protect against risk of loss. Our discretionary investment management strategies are subject to some or all of the risks described below. General Securities Risks Securities Investment Risk: All securities investments involve the risk of loss of capital. Market Risk: Securities are subject to an increase or decrease in value as a function of interest rates, credit spreads or other economic factors. Prices may fluctuate widely over short or extended periods in response to company, market, or economic news. Markets also tend to move in cycles, with periods of rising and falling prices. If there is a general decline in the securities, bond and other markets, an account may lose value, regardless of the individual results of the securities and other instruments in which an account invests. Sector Risk: The value of securities focused in a specific sector or sectors can be adversely impacted by developments specific to that sector compared to accounts that do not have concentrated holdings. Examples of developments that might cause adverse outcomes on a sector’s valuations include legislative actions, regulatory changes, tax or accounting changes, and technical conditions specific to that market segment. Currency /Country Risk: Investments in securities of non-U.S. companies involves special risks and considerations not typically associated with investing in U.S. companies, and the values of nonU.S. securities may be more volatile than those of U.S. securities. Investments in foreign currencydenominated securities are subject to the risk that those currencies will decline in value relative to the U.S. dollar. Currency rates in foreign countries may fluctuate significantly over short periods of time for several reasons. This includes changes in interest rates, intervention (or the failure to intervene) by U.S. or foreign governments, central banks or supranational entities such as the International Monetary Fund, or by the imposition of currency controls or other political developments in the United States or abroad. Additionally, investments in non-U.S. markets in general may carry a high degree of risk, particularly those in “emerging” markets that may not have the depth and liquidity of markets in the U.S. or Western Europe. The value of securities of nonU.S. companies are subject to economic and political developments in countries and regions, particularly where the securities are traded. Government/Geopolitical Risks: The value of securities may be influenced by various uncertainties, including international and domestic political developments, changes in government policies,

taxation/tariffs, restrictions on foreign investment and currency repatriation, currency fluctuations, and other legal and regulatory changes in the countries where the issuers or securities are exposed. Private Placement Risk: Client portfolios that include private placements, such as private placement bonds, which may include 4(a)(2) private placements, credit tenant lease transactions, private asset backed securities, private structured finance and other non-liquid assets, are generally subject to several risks. These include, but are not limited to, litigation risk, risks from lack of liquidity and pricing of less liquid securities. Private placement issuers differ from public companies in that they are not held to comprehensive reporting and disclosure obligations. This lack of detailed information, coupled with the absence of a liquid and transparent market, amplifies the legal complexity and risks associated with valuing such investments. Private placement transactions may be subject to legal or contractual restrictions on resale in accordance with applicable securities laws. The sale of private placement securities involves a price discovery process that is longer than publicly traded securities. Valuation Risk: Certain client portfolios may hold securities or other assets that are illiquid, thinly traded, or otherwise difficult to value. In valuing such assets, NEAM may rely on third‑party sources, including pricing services, indicative quotes, models, or other relevant information. In some instances, valuations will be based on assumptions, estimates, or methodologies rather than on observable market transactions. These valuations are inherently subject to judgment and may be revised if additional information becomes available. Any such adjustments can result in a corresponding change to the value of a client’s portfolio. There can be no assurance that illiquid or thinly traded assets can be sold or otherwise liquidated at the values assigned by NEAM. Fixed Income Risks Investment in fixed income securities is integral to NEAM’s investment strategies. NEAM focuses on credit risk, interest rate risk, pre-payment risk, liquidity risk, reinvestment risk, and structural risk when analyzing fixed income securities. Credit Risk: The risk that an issuer of a security will fail to pay interest and or principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of the security to decline. Fixed income securities rated below investment grade are especially susceptible to credit risk. Interest Rate Risk: The value of fixed income securities is related directly to the level of interest rates. Consequently, fluctuations in rates will cause market prices to fluctuate. Declining interest rates generally increase the value of fixed income securities, and rising interest rates generally decrease the value of fixed income securities. Securities with the longest maturities (and/or “durations”) will exhibit the most price volatility. Changes in value usually will not affect the amount of interest income but will affect the value of the fixed income securities. Floating rate or variable rate instruments are less susceptible to price volatility versus fixed rate securities since their coupon (cash flows) will adjust up or down periodically based on the general level of rates. Pre-Payment Risk: This is the risk that a security's cash flows deviate from those originally anticipated due to a change in interest rates or due to structural characteristics (optionality) of the security. Liquidity Risk: In some circumstances, the markets for fixed income securities can become “illiquid.” In other words, the spread between the “bid” (level where a market participant would buy) and the “ask” (level at which one would sell) becomes very wide. In these instances, it may become difficult or even impossible to transact in the affected securities. Certain fixed income securities may be substantially less liquid compared to other securities.

Reinvestment Risk: This is the risk that future cash flows from existing investments may have to be reinvested at lower rates of return than the rates originally achieved. This risk is amplified in the case of securities which have embedded optionality which may cause prepayments to accelerate as rates decline. Structured Securities Risk: For structured securities, this is the risk that adverse developments in the collateral pool supporting the structured transaction jeopardize payment of interest and principal for one or more classes of the structured transaction. This may result in a loss due to a reduction in the value of the structured security. Early payoffs in the loans underlying structured securities may result in receiving less income than originally anticipated. Non-Investment Grade Securities (“High-Yield”) Risk: Strategies investing in high-yield fixed income securities where instruments are below investment grade credit quality (below BBB-) or unrated and in certain cases in default are considered speculative and may involve greater risk than that of securities of investment-grade credit quality (BBB- and higher). The lower rating of securities in the high yield sector reflect a greater risk of absorbing adverse changes in the financial condition of a position and/or general economic conditions which could negatively impact the payment of principal and interest. The prices of high-yield securities are sensitive to changes of an issuer’s credit worthiness. Issuers of lower-rated debt securities may have increased difficulty making their payment obligations and in securing additional financing. Senior Secured Loan Risk: Strategies investing in bank debt are subject to certain risks in addition to those present in high yield bond portfolios. Clients are bound by contractual obligations established under bank debt loan documentation and the transfer agreements executed when purchasing and selling bank debt. Bank debt investments are often subject to certain resale restrictions. Purchases and sales of bank debt can involve extended and delayed settlement times, which can result in increased counterparty and liquidity risk. Bank debt is not registered or regulated under federal securities laws. Equity Securities Risks Market Risk: Equity securities include common stocks, preferred stocks, convertible securities, and mutual funds that invest in these securities. Equity markets can be volatile. Stock prices rise and fall based on changes in an individual company’s financial condition and overall market conditions. Stock prices can decline significantly in response to adverse market conditions, company-specific events, and other domestic and international political and economic developments. Exchange Traded Fund (“ETF”) Risk: ETFs are pooled investment vehicles that hold portfolios of securities, commodities and/or currencies that commonly are designed, before expenses, to closely track the price and yield performance of (i) a specific index, (ii) a basket of securities, commodities, or currencies, or (iii) a particular commodity or currency. ETF shares are traded on exchanges and are traded and priced throughout the trading day. Because ETFs trade on an exchange, they may not trade at NAV. Sometimes, the prices of ETFs may vary significantly from the NAVs of the ETFs’ underlying securities. Additionally, if redeeming ETF shares rather than selling them on a secondary market, the investor may receive the underlying securities which must be sold to obtain cash. Polen Credit Opportunities Fund (“Closed-end / Interval Fund”) Risk: This closed-end fund is nondiversified, which means that a large portion of the fund’s assets may be invested in one or few companies or sectors. The fund could fluctuate in value more than a diversified fund. The fund is designed for long-term investors and not as a trading vehicle. An investment in the fund, unlike an investment in a traditional listed closed-end fund, should be considered illiquid. The fund is appropriate only for investors who are seeking an investment in less liquid portfolio investments within an illiquid fund. An investor should be aware that this isn’t an exhaustive list of all associated

risks within the Interval Fund and should refer to the prospectus and other fund documents for more information. Business Continuity/Operational and Cyber Security Risks: NEAM depends on telecommunication, information technology, and other operational systems, whether its own or those of others (e.g., custodians, financial intermediaries, and others that we or our service providers use). These systems may fail to operate properly or become disabled because of events wholly or partly beyond NEAM's control. While NEAM uses risk management and information security measures, its information technology, and other systems, and those of others, could be subject to physical or electronic break-ins, unauthorized tampering or other security breaches, resulting in a failure to maintain the security, availability, integrity, and confidentiality of data assets. Technology failures or cyber security breaches, whether deliberate or unintentional, including those arising from use of third-party service providers or client usage of systems to access accounts, could delay or disrupt NEAM's ability to do business and service its clients, harm its reputation, result in a violation of applicable privacy and other laws, require additional compliance costs, subject NEAM to regulatory inquiries or proceedings and other claims, lead to a loss of clients and revenues or financial loss to its clients or otherwise adversely affect its business. NEAM will seek to notify affected clients of any known cybersecurity incidents posing a risk of harm to clients as required by law or regulation. NEAM has developed a business continuity plan that provides for the availability of critical personnel and systems in the event of a business interruption, including preparations in the event of another pandemic-type outbreak. The plan is designed to address specific types of events that could impact NEAM’s ability to continue active management of their clients’ portfolios and to provide for services contracted for by their clients. NEAM’s policy is to consider the events that it might reasonably face given its business and location and to have procedures in place to allow NEAM to resume providing service to its clients as soon as possible. NEAM’s Investment Technology Group is responsible for the recovery effort and various departments participate in both the updating and testing of the plans. Generative Artificial Intelligence (“AI”) Risks: NEAM currently employs limited usage of AI applications to assist with investment research, portfolio analysis, and operational activities. While these tools are designed to assist, enhance efficiency and provide analytical capabilities they do not replace professional judgment, and can introduce operational, model, cybersecurity, privacy, and regulatory risks. NEAM mitigates AI‑related risks through established policies and procedures, human oversight, data validation, and cybersecurity controls. NEAM uses approved AI applications, specifically Microsoft Copilot on approved devices, as part of efforts to support operational efficiency while adhering to data privacy and information security standards. NEAM prohibits the input of sensitive, personally identifiable, confidential, or proprietary information into unapproved external AI tools as part of its efforts to safeguard this information. AI tools, including those provided by third parties, may experience operational, cybersecurity, or business‑continuity vulnerabilities that could result in service disruptions, data breaches, financial loss, or reputational harm. AI‑generated outputs are dependent on the quality, accuracy, and objectivity of the underlying data and models; as a result, outputs may appear reliable but may be incomplete, inaccurate, or biased. Environmental, Social, Corporate Governance Considerations: We have adopted an integrated approach whereby ESG considerations are used where deemed appropriate to complement traditional quantitative and qualitative research.

NEAM has entered into several services agreements with NEAM Limited. In addition, there is a sub-advisory agreement in place to permit NEAM Limited to act as a sub-adviser to NEAM for certain non-US dollar mandates on behalf of NEAM's clients. An agreement also exists to permit NEAM to serve as a sub-adviser to NEAM Limited for certain US dollar mandates on behalf of NEAM Limited clients. If NEAM recommends or selects NEAM Limited to manage assets for NEAM clients on a subadvisory or non-sub-advisory basis, both NEAM and NEAM Limited will receive advisory fees. Due to the additional economic benefit to NEAM from recommending or selecting NEAM Limited, a conflict exists between the interests of our clients and the interests of NEAM. NEAM addresses this conflict through disclosure to clients. Other Investment Advisers Polen Credit is a wholly-owned subsidiary of Polen Capital Management LLC and is an investment adviser registered with the SEC. This registration does not imply a certain level of skill or training. NEAM has entered into a sub-advisory arrangement with Polen Credit for certain High Yield strategies (See Item 4) on behalf of NEAM’s clients. Due to the additional economic benefit to NEAM from recommending or selecting Polen Credit, a conflict of interest exists between the interests of our clients and the interests of NEAM. NEAM addresses this conflict through disclosure to clients. NEAM has also entered in a revenue sharing arrangement with Polen Credit when clients elect, on NEAM’s recommendation, to invest in the Polen Funds (See Item 5). These payments create a conflict of interest because NEAM has a financial incentive to recommend the Polen Funds over another investment that does not participate in revenue sharing. NEAM addresses this conflict through disclosure in this Brochure and by providing NEAM clients with additional written disclosures when recommending the Polen Funds. If you have any questions or require more information regarding the revenue-sharing arrangement, please contact us at 860409-6006.

NEAM’s Supervised Persons are required to follow NEAM’s Code and certify that they read, understand and will comply with the terms of the Code on an annual basis, or sooner if the Code is amended. Participation or Interest in Client Transactions and Personal Trading: The Code incorporates general principles, such as placing the interest of clients first and conducting personal securities transactions to avoid conflicts of interest, which all Supervised Persons are expected to uphold and apply to all their conduct. NEAM’s Code is designed to prevent personal securities transactions, activities and interests of NEAM’s Supervised Persons from interfering with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions, while at the same time, allowing employees to invest for their own accounts. NEAM’s procedures allow Supervised Persons to buy or sell the same security in their personal accounts that NEAM buys or sells in their client accounts. Due to the potential conflict of interest, NEAM Supervised Persons cannot buy or sell securities for their own personal account until after transactions of securities in clients’ accounts are completed. This is controlled by requiring preclearance for personal trades and disallowing pre-clearance approval if the security is on the restricted list. NEAM’s ultimate parent company, Berkshire Hathaway Inc (“BRK”), is a publicly traded company. To manage the conflict of interest that arises, NEAM refrains from investing client assets in BRK unless directed to do so by a client. The Compliance Department monitors reported personal securities trading activities. This includes a quarterly review of the reported trading activities of all Supervised Persons compared to the preapproval records. NEAM’s Research Analysts and Traders are primarily responsible for the transactions of securities in client accounts and their actions are subject to NEAM’s policies and practices including gifts and entertainment activities which are subject to review and approval by NEAM’s senior management. If while providing its services, NEAM and its Supervised Persons come into possession of material, non-public information (“MNPI”), NEAM and its Supervised Persons are prohibited from improperly disclosing or using such information for their personal benefit, for the benefit of immediate family members, or any other person, including NEAM's clients. Principal Transactions and Cross Trades: It is NEAM’s policy that NEAM will not effect any principal or agency cross securities transactions for client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of

an affiliated broker-dealer, buys from or sells any security to any advisory client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as adviser to one side of the transaction and broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer; NEAM has no such affiliations. NEAM does not engage in cross transactions, where NEAM causes one client to buy a security from another client.

In selecting a broker-dealer for client transactions, the Trader considers not only the available spreads, prices and commission rates, but also other factors it deems relevant, such as NEAM's knowledge of the nature of the security or instrument being traded; cost (by comparing the yield or price of bonds of comparable quality, coupon, maturity and type quoted by various broker, dealers or banks); the size and type of the transaction; the desired timing of the transaction; the activity existing and expected in the market for the particular security or instrument; and the execution, clearance, and settlement capabilities of the broker, dealer or bank. NEAM utilizes a third-party vendor to provide quarterly execution comparisons of NEAM trades versus benchmarks and/or comparable securities. Execution prices of each transaction are reviewed relative to broadly available transaction price data. Transactions with execution prices that deviate the furthest from the vendor’s derived or observed valuation levels based on dollar amount and market impact are identified. Members of the investment group provide rationale for these trades along with any available back-up documentation. The CIO reviews the explanations, documents approval, and the Policy Committee prepares a Corporate Resolution evidencing review and approval. NEAM does not participate in soft dollar arrangements. If NEAM agrees, a client may instruct NEAM to direct brokerage for a client's account to a particular broker, dealer or bank. When a client directs NEAM to use a particular broker, dealer or bank, NEAM generally cannot freely negotiate commission rates or spreads, or select brokers, dealers or banks on the basis of best price and execution. In addition, transactions for a client that directs brokerage would not be aggregated for execution with transactions in the same securities for other clients. As a result, directed brokerage transactions could result in higher commissions, greater spreads or less favorable net prices than would result if NEAM were authorized to choose the brokers, dealers and banks through which to execute transactions from the client's account. As a general matter, NEAM’s Traders strive to aggregate individual account orders into larger orders to improve speed and efficiency of execution. When aggregating orders, each client participating in the aggregated order receives the same execution price. NEAM will allocate bonds purchased among eligible clients (which, at times, could

include clients affiliated with NEAM) on a basis which NEAM believes to be fair and equitable. In instances where the orders are partially filled, NEAM uses a random allocation process to allocate bonds across participating accounts. In the case of equity transactions, orders are allocated on a pro rata basis, using each account’s order size relative to that of the total order. In the case of private placement transactions, orders are allocated on a pro-rata basis, subject to the minimum allocation level established for the client's private placement portfolio mandate. Any excess or shortage amounts from the calculation are allocated in order of proximity to the pro-rata allocation.

A suite of reports is available that combines the investment accounting book values and book yields with market valuations and market analytics. For asset management clients, NEAM produces monthly appraisal and transaction reports. Client account performance reports are provided monthly, quarterly or annually upon client request. Each client is assigned a specific NEAM investment accountant responsible for reporting. For investment accounting clients, NEAM utilizes a core set of reports. NEAM can also supplement the core package with additional reports that are designed to meet clients’ investment accounting and reporting needs. NEAM provides additional reports to its clients, as mutually agreed upon, to meet specific needs or to show in more detail investment performance or current investment status. NEAM provides clients with online access to investment accounting reports including appraisal reports via the web at ww1.neamgroup.com, on a password-protected basis. NEAM provides hard copies or sends via email if requested by the client. Client Investment Committee Reports/Board Reports In addition to our normal cycle of frequent communication, monthly reports and periodic client meetings, client team members are available for client portfolio reviews and to discuss client needs and objectives, market outlook, investment strategy and portfolio activity or other issues. If requested by a client, Investment Committee/Client Board presentations are prepared by the Portfolio Managers and generally include a capital market overview, summary of portfolio activity, review of transactions, presentation of performance and other issues of interest. Capital and Risk Analytics (CARA®) Platform In addition to the client reporting package, NEAM clients have online access to their portfolio information via the Capital and Risk Analytics (CARA ®) platform and client dashboard. Within the CARA® platform, clients can monitor various portfolio investment metrics including duration, convexity, credit quality, book and market yields.

This authority also includes the execution of all documentation related to the purchase or sale, assignments, transfers and ownership of any securities, and documentation relating to restructuring, reorganization, or other action of or relating to the issuer.

NEAM reviews and approves for implementation the Proxy Voting Guidelines developed by the third-party vendor and evaluates the performance of the vendor on a periodic basis. This evaluation includes an assessment of the vendor's business operational changes, SOC Audit Reports (when available), reporting of conflicts of interest, voting capacity, competency of personnel, adherence to NEAM's policies and adequacy of its proxy voting process, including recordkeeping and other relevant policies. It is our policy to monitor that proxy voting decisions for our clients are not influenced by any material conflict between our interests and client interests. We monitor that proxies are voted in accordance with the independent vendor's recommendations. The third-party vendor will also disclose conflicts relating to its ownership and maintains that it follows management procedures to mitigate all such events. In instances where NEAM deems that it is in the best interest of its clients

to vote against the third-party vendor’s guidelines, NEAM will document the reason and direct the third-party vendor to vote in accordance with the decision. If for any reason the vendor does not provide a voting recommendation on a particular matter, or in the event that the vendor's interests conflict with those of a client, we request client direction on how to vote or take other appropriate action to resolve the conflict as provided in the Proxy Policies. The proxy voting process is administered by our Compliance Department, under the oversight of the Proxy Committee. NEAM maintains the stance that it is important for companies to effectively oversee and manage material environmental, social, and governance issues and that oversight and reporting encourage director accountability. Generally, NEAM’s third-party vendor supports shareholder resolutions that seek to enhance companies’ governance structures, as it believes that, in most cases, this enhancement benefits shareholders. With respect to shareholder resolutions related to environmental and social issues, the vendor evaluates each on a case-by-case basis. To direct us to vote a proxy in a particular manner, clients should contact their Portfolio Manager and/or the Compliance Department. If you would like a copy of the Proxy Policies, including Proxy Voting Guidelines, or if you are a client and would like information on how proxies were voted on your behalf, please contact us by calling 860-409-6006 or via email at bill.wilcox@neamgroup.com. NEAM will not provide legal advice or act for its clients in any legal proceedings involving companies whose securities are held in the client's account(s). This includes the filing of bankruptcy documentation or "Proof of Claims" in class action suits. Certain clients direct us to forward class action notices to them if received by NEAM. In such situations, NEAM will forward documentation to its clients in a timely manner on a best-efforts basis.