Conning, Inc.: investment adviser

As of December 31st, 2025, Conning’s assets under management totaled approximately $107 billion, the majority of which are managed on a discretionary basis. Conning provides investment services for diversified third party clients. Conning’s client base includes various insurance companies and pension plans. Institutional Accounts Conning primarily provides fixed income and equity investment management services to institutional clients. Conning only manages the assets which are the subject of its management agreement and does not consider the client's other assets and other obligations. Conning receives authority to supervise and direct the investment of the assets on a discretionary or non-discretionary basis in accordance with the clients’ written objectives and limitations as outlined in each client’s Investment Management Agreement. Clients could impose restrictions or limitations on investing in specific securities or specific types of securities. Conning’s U.S. High Dividend Equity (“HDE”) and Global High Dividend Equity (“GHDE”) Strategies invest in a portfolio of large cap equities with similar characteristics: strong financial profiles, healthy dividend yields and a history of maintaining or raising the dividend payout. The strategies are designed to participate in the performance of rising equity markets and outperform in down markets, while providing a steady income component to total return in all markets. Conning offers an internally managed U.S. Indexed Equity Strategy which utilizes advanced computer-based portfolio management and trading systems. This passive approach provides broad exposure to the market and a high level of confidence in achieving market performance.

Other Related Investment Management Services Conning utilizes several affiliated registered investment advisers as sub-advisers in relation to investment advice and management with respect to collateralized loan obligations, emerging market debt, real estate related investments and other specialty strategies. Conning acts as an investment manager\sub-advisor for other pooled investment vehicles sponsored by non-affiliated third parties, and which may be exempt from registration under the Investment Company Act of 1940 (the “Private Funds”). Conning is the delegated investment manager of the US IG Credit Article 8 Lux RAIF UCITS fund and US HY Credit Article 6 Lux SICAV UCITS fund (“Funds”), managed by Generali Investments Luxembourg S.A Manco (the “ManCo”), are UCITS Funds regulated under the Luxembourg law. Both the Funds and the ManCo are supervised by the Commission de Surveillance du Secteur Financier (hereinafter the “CSSF”), the Luxembourg competent financial supervisory authority. In 2019, the CSSF assessed Conning Inc’s suitability for the fulfilment of the duties and the appointment as Investment Manager and had no objections to Conning, Inc. being a delegation of the ManCo in the function of investment management. Conning acts as a sub-advisor to Conning Investment Products, Inc. in relation to investment advice and management for its Canadian-domiciled clients. Conning has an agreement with Folio Institutional and FIWA to provide model manager services and receives a negotiated fee for services provided. Investment Solutions Conning will develop customized outcome-oriented investment solutions for insurance companies and pension plans which can assist with increasing the probability of achieving the objectives of plan sponsors with practical market investment solutions. These include on-balance sheet Liability Driven Investing (“LDI”) and ready-to-transfer annuity-like portfolios. These services also include investment advisory, asset allocation, asset liability management and strategic research on a consulting basis. Conning also serves as an investment manager and CTA for a Collective Investment Trust Fund sponsored by the Global Trust Company. Insurance Research Publications Conning publishes research with general themes concerning the insurance industry. Clients occasionally request specific information or research formatted or arranged to suit their needs about industries or issues Conning has researched. To supply that

information, we negotiate a fee with the client to fit the situation in relation to the amount of work required. Risk Solutions Conning's proprietary modeling software products are used in our Asset Management and Investment Solutions businesses and are also available for license to insurers and other financial organizations. At the core is our GEMS® Economic Scenario Generator, which provides real world and risk neutral scenario capabilities, allowing to project realistic future states of global economies and capital markets. These services are offered as stand-alone or included in our full-service product. Conning does not offer manager search or performance evaluation services.

Billing is generally conducted quarterly in arrears with the majority of asset management clients billed using a four period monthly average which adds together assets under management for the month that precedes the current calendar quarter for which the calculation is being made plus assets under management at the end of each month in the current calendar quarter, then dividing the sum by four . Conning does not deduct management fees from client accounts. Management fees are prorated for each capital contribution and withdrawal made during the applicable calendar quarter (with the exception of contributions and withdrawals made in the ordinary course of business, such as fees and expenses). Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee. The fees charged for separately managed accounts are subject to negotiation and are based on the fair market value of the assets depending on the size of the account and strategy selected.

Fixed Income Services and Fees: Annual fees are based on fee schedules the components of which are generally within the range of 10 basis points to 50 basis points for institutional clients. Conning seeks a minimum dollar fee or a minimum mandate size. Specialty Asset Services and Fees: Conning manages portfolios of specialty assets (e.g., HDE, GHDE, Indexed Equity and CLO’s). Annual fee schedules are negotiated on an account-by-account basis, based upon the type and scope of services provided, whether managed actively or passively, and the size of mandate. Fees are billed on a pro-rated basis monthly, quarterly, or semi-annually in arrears. Fee schedules are generally within the range of 10 basis points to 75 basis points annually for institutional clients. Conning typically seeks a minimum dollar fee or a minimum mandate size. Incentive-Based Fees: For certain types of clients and mandates, annual fees are calculated based on the income and capital appreciation of the account. Fees are generally a negotiated combination of fixed and incentive fees and are billed quarterly or semi-annually in arrears. Accounts of this type are accepted only if all conditions of Rule 205-3 of the Investment Advisors Act of 1940 are met. Incentive-based fees are charged to clients as permitted by Rule 205 under the Advisors Act. Private Funds As compensation for its service as the investment manager\sub-advisor of Private Funds, Conning generally receives a management fee. Conning may, but will not always, receive a performance-based fee with respect to a Private Fund. Performance fees generally reflect the capital appreciation of a Private Fund and may include hurdle rates and/or high water marks. The management fees are typically paid quarterly in arrears. Please consult the Private Fund’s Governing Documents for additional information regarding such fees. Investment Solutions Annual fees are based on a tiered fee schedule the components of which are generally within the range of 25 basis points to 50 basis points for separate account clients. The Collective Investment Trust fee schedule varies from 5 basis points to 125 basis points depending on the strategy selected and the size of the mandate. Conning seeks a minimum dollar fee or a minimum mandate size.

Insurance Research Publications Fees Publications are sold individually as well as by annual subscription. Fees are billed prior to fulfillment. All subscriptions can be cancelled by the client upon request. On a rare occasion that a subscription is cancelled, pro-rated refunds are negotiated. Risk Solutions Customized software solutions for insurance companies and pension plans are produced on a contracted basis. Fees for these projects are negotiated on an individual basis and payable either in installments or upon completion of the project.

Conning addresses such conflicts by ensuring that all clients receive fair and equitable transactions by bunching trades when applicable. One way this is monitored is by the performance of a daily trade recap review conducted by the Compliance Department. Our risk management area also performs an independent trade review on a daily basis to identify potential price differences between client transactions. “Side-by-side management” refers to the simultaneous management of multiple types of client accounts and/or investment products. For example, Octagon Credit Investors, LLC., an affiliated registered investment adviser, manages CLO accounts and Private Funds, which may follow similar, complementary or competing investment objectives, policies or strategies. Side-by-side management gives rise to a variety of potential and actual conflicts of interest for Conning and its employees and affiliates, including, as discussed below, the incentive to favor certain accounts with performance-based fees or accounts that generate multiple levels of fees (i.e., when fee earning clients invest in Octagon managed CLOs) or accounts in which Octagon and its related persons have a pecuniary interest. Employees of Octagon and Conning, including persons who serve on Octagon’s investment committee or act as portfolio manager to various clients, may invest in funds, or may take interests in a fund’s general partner and thus participate in the performance fees or “carried interest” paid to the general partner by that fund. Accordingly, Octagon, Conning, and their respective affiliates and personnel, including persons involved in the management of one or more clients, may have differing pecuniary

interests with respect to different clients. These persons may have an incentive to favor those clients in which they have greater pecuniary interests. See Item 10 – Other Financial Industry Activities and Affiliations.

Due to the array of product needs, liability and capital profiles as well as differing company risk preferences, investment strategy customization is also a key component for success in managing insurance assets. Our philosophy focuses on “fundamentals first”; we believe there is no substitute for thorough, proprietary research and analysis. Our focus on fundamentals combines with a strong belief in diversification to provide a stable foundation for all the insurance portfolios we manage. We are risk-aware, accepting risk only when our clients are well compensated. Sector rotation and issue selection drive our investment performance. And while significantly important to success, we believe that effective insurance asset management is more than just outperforming a total return benchmark. Insurance companies have multiple stakeholders, each with potentially different goals. A successful insurance investment strategy needs to achieve multiple goals simultaneously.

Investment Process Conning’s investment process, which is displayed below, leverages our core capabilities in insurance research, strategic asset allocation, and investment management.

Company Overview

Strategic Asset Allocation

Sector Rotation

Issue Selection

Portfolio Construction

These important steps in our investment process are described in detail below: Company Overview The first step in our investment process is to develop a deep understanding of our client’s business and involves our insurance industry research group. Conning is the only insurance asset management firm with its own insurance industry research team. They produce extensive research that includes industry financial forecasts with competitive and market analyses. This team also provides critical input to our asset management team and helps us better understand our client’s opportunities and challenges, and the lines of business in which they compete. Strategic Asset Allocation (SAA) Process The next step in our process, which is displayed below, involves a robust strategic asset allocation analysis that reflects our clients’ specific needs and objectives.

Risk Preference Discussions

Enterprise Financial Modelling

▪ Determine appropriate risk / reward balance

▪ Utilize stochastic optimization process

▪ Establish broad targets and ranges by asset class

▪ Leverage whole company model

▪ Set limits for investment style, sector and issuer exposures ▪ Customize to meet individual needs

▪ Incorporate overall business objectives ▪ Evaluate multiple strategies

Peer Analysis ▪ Focus on industry, peer and competitor metrics ▪ Align strategies with regulator/rating agency perspectives

▪ Identify outliers versus industry norms

Asset Allocation Targets / Custom Benchmarks ▪ Integrate financial modelling, peer analysis, and risk preferences with investment portfolio ▪ Determine neutral position for asset allocation

▪ Create custom benchmark and investment guidelines

▪ Create probability distributions for each strategy

Insurance companies are unique institutions; they have limited capital, operate in a constrained regulatory environment, and face uncertain liabilities of varying terms. Investment strategies for insurance portfolios must reflect these factors. We develop customized investment strategies based on a thorough analysis of each client’s unique issues. Our primary tools are GEMS®, Conning’s award winning proprietary economic scenario generator, and ADVISE®, our proprietary enterprise risk model. These tools are also the basis for our enterprise risk management work. Sector Rotation Conning’s most senior investment leaders meet monthly at a Global Investment Summit to share perspectives and develop a consensus view on the global macroeconomic outlook. This outlook provides a framework that is utilized by our sector teams in the development of our firmwide fixed-income sector strategy. The next step in our process relates to sector allocation strategy. We have dedicated teams consisting of traders and analysts responsible for each sector of the market. These teams meet monthly to develop recommendations to overweight or underweight their respective sectors relative to benchmarks based on a detailed analysis of fundamentals, valuations, technical and quantitative factors. These recommendations are reviewed by our Investment Policy Committee, which consists of several of our senior investment professionals. The recommendations of this Committee regarding specific sectors are implemented by portfolio managers to the extent they are consistent with the specific objectives and risk preferences of their clients.

Global Investment Summit

Global Macro View

Investment Policy Committee (Sector allocation, duration, risk bias)

Sector Allocation Recommendations

Sector Strategy Teams (Corporate, Structured, Municipal)

Sector Strategy Teams (Security selection)

Portfolio Managers

Client Facing

Strategy Implementation

▪ Deep understanding of client’s objectives and constraints

▪ Implementation of IPC / sector strategy team recommendations

▪ Communication on portfolio / market / strategy updates

▪ Customization to meet client objectives

Issuer Selection We have dedicated research analysts and traders in each sector who are responsible for identifying those sub-sectors and issuers that offer the most compelling values on a risk-adjusted basis. These recommendations reflect a careful analysis of qualitative, quantitative and technical factors and an assessment of relative value and are implemented by portfolio managers to the extent they are consistent with portfolio objectives. Portfolio Construction Portfolio managers determine how to incorporate our firm’s views in each client portfolio. In doing so, they consider portfolio’s unique objectives and constraints. The recommendations produced through our firm’s formal investment process provide guidance on where to invest new cash flows and ultimately have a significant influence on individual client strategies. Esoteric ABS Strategy Conning’s investment approach and philosophy focus on the generation of positive riskadjusted returns with an emphasis on capital preservation in consideration of each client’s stated investment guidelines. We focus on “top tier” issuers with a history of strong performance and structures that can withstand considerable volatility in the credit markets. Conning strives to capitalize on market inefficiencies by investing in collateral

and issuers with strong historical performance not fully appreciated by most investors and by seeking relative value opportunities created by market volatility and supply/demand factors. Conning strives to find Esoteric ABS sectors that are attractive versus competing sectors like corporates, plain vanilla ABS, agency mortgages, etc. Our portfolio construction aims to produce a high level of income, achieve portfolio diversification, pass Conning's rigorous stress testing and emphasizes sectors where we expect robust investor demand and spread tightening. A typical portfolio will have no leverage, no HY, and a limit of 20% BBB exposure. This portfolio will have a duration target of less than 5yrs and an average rating of A-. When constructing a portfolio for an Esoteric mandate Conning aims to understand each client’s rating, yield and duration requirements. EQUITY: U.S. High Dividend Equity \ Global High Dividend Equity Strategies The objective of Conning’s HDE strategy is to enhance the amount of income generated from a client’s equity allocation, while simultaneously lowering the volatility of equity returns versus broad market indices. The investment strategy is focused on the financial metrics of each specific company. Conning uses a balance-sheet and cash flow approach to issuer selection. Through a series of quantitative screens and a qualitative review process, we seek to identify companies with strong financial profiles, a history of generating free cash flow from operations, a healthy dividend yield, and a pattern of maintaining or increasing the dividend payout over time. Companies that do not pass the screening and review process are not included in the final portfolio. Companies selected for inclusion in the portfolio are equally weighted. The portfolio construction process is repeated quarterly, and in connection with this, the portfolio is also rebalanced quarterly. Conning believes the discipline of a consistent, repeatable process that minimizes “stock picking” within the portfolio construction process is a major driver of the success of the HDE strategy. The HDE strategy does not focus on sector allocations as a primary component of the investment process. Consequently, the portfolio can have significant variance in terms of sector weights versus its benchmark. Portfolio construction in Conning’s HDE strategy is based upon a disciplined three-step process designed to filter the universe of potential investment candidates and identify a set of companies with similar financial characteristics and dividend histories.

First Step – Quantitative Screening Conning screens the companies in the S&P 500 Index using six distinct metrics designed to identify companies that currently pay an attractive dividend, have a history of maintaining or increasing their dividend, have a strong financial profile, and have a history of generating free cash flow from operating activities. ◆

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Dividend yield: minimum dividend yield >= the average yield of the S&P 500 Index for “A” or higher rated companies, or >= the average S&P 500 yield +40 bps for “BBB” rated companies. Unrated companies can be held if they offer a dividend yield >= the average S&P 500 yield +100 bps. Dividend history: minimum four years of stable or increasing regular dividend payments. Credit ratings: must have investment grade credit ratings from Conning and all major nationally recognized statistical rating organizations (NRSROs). Market capitalization: minimum $15 billion ($20 billion for unrated companies to enter the portfolio) at the time of purchase, $13.5 billion to remain in the portfolio. Leverage: maximum 0.35x gross debt to equity market capitalization, or minimum 3x gross debt to earnings before interest, taxes, depreciation and amortization (EBITDA). Financial companies as defined by GICS classification have an alternative leverage calculation of maximum 0.25x gross debt to capital (gross debt + equity – accumulated other comprehensive income (AOCI)). Free cash flow from operations: must be positive in at least three of the past five fiscal years, and is calculated after capital expenditures and dividends.

All six metrics are of equal importance, and companies must pass all of them to move to the next step of the portfolio construction process. Second Step – Qualitative Review Conning’s investment research team performs a full fundamental review of the remaining names, eliminating companies with inappropriate characteristics such as business or event risk, or companies our analyst believes may not be able to maintain their dividends. Third Step – Security Selection Companies reaching the third step are reviewed by the HDE strategy management team comprising six co-managers. Companies are compared based on dividend yield

and earnings growth momentum, business trends and earnings surprise history among other factors. Roughly 10% are eliminated from consideration for the final portfolio. The remaining companies are equally weighted in the final portfolio. The portfolio is actively monitored by the investment research team and the screening process is repeated quarterly. Companies no longer passing our process are sold; new companies that do pass our screens are added. The portfolio is then rebalanced to equal weighting for all names. The HDE team may sell a position intra-quarter if our analyst believes there has been a meaningful deterioration in a company’s financial profile or in its capacity to continue making dividend payments. If a sale occurs, a name previously eliminated in the comparative review will be substituted into the portfolio or the proceeds will be invested in all the remaining names in the portfolio. INVESTMENT SOLUTIONS: Liability Driven Investing We develop and manage assets relative to benchmarks that are customized to reflect each pension plan. These include customized credit benchmarks to reflect the term structure and credit spread exposure of the plan’s liabilities (accounting, funding or annuity-like). Investment Process: Conning’s LDI solution approach includes: Long duration credit strategies, including corporate and government; ❖ Custom liability-driven benchmark strategies; ❖ Completion management strategies - that include customized credit completion portfolios in addition to Treasury and interest rate derivative and futures instruments; ❖ Development of liability driven strategies within the de-risking glidepath framework that clients are developing or have already established. ❖

Risk Management 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 assure a 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. Credit Risk: The risk that the issuer of a security will fail to pay interest 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. Debt securities rated below investment-grade are especially susceptible to this risk. Sector Risk: The value of securities focused in a particular industry or market sector will be highly sensitive to financial, economic, political and other developments affecting that industry or market sector, and conditions that negatively impact that industry or market sector will have a greater impact as compared to an account that does not have its holdings similarly concentrated. Interest Rate Risk: The value of fixed income securities usually rise and fall in response to changes in interest rates. Declining interest rates generally increase the value of existing instruments, and rising interest rates generally decrease the value of existing instruments. Changes in value usually will not affect the amount of interest income, but will affect the value of shares. Interest rate risk is generally greater for investments with longer maturities. Certain fixed income securities pay interest at variable or floating rates. Variable rate securities reset at specified intervals, while floating rate securities reset whenever there is a change in a specified index rate. The market prices of these securities could fluctuate significantly when interest rates change. Structured Risk: These types of securities share many of the same risks. The impairment of the value of collateral or other assets underlying a mortgage-backed or asset-backed security, such as that resulting from non-payment of loans, results in a reduction in the value of such security and losses. Early payoffs in the loans underlying such securities result in receiving less income than originally anticipated. Securities with longer maturities tend to fluctuate in value more widely in response to changes in interest rates than shorter-term securities. Market and Economic Risk: Investment value may decline due to changes in general economic and market conditions. A security’s value held in an account may change in response to developments affecting entire economies, markets or industries, including changes in interest rates, political and legal developments, and general market volatility.

Foreign Investing Risk: Investing 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 non-U.S. securities are more volatile than those of U.S. securities. The values of non-U.S. securities are subject to economic and political developments in countries and regions, or where the securities are traded. Values could also be affected by restrictions on receiving the investment proceeds from a non-U.S. country. Emerging Market Risk: The risks of foreign investments are generally greater in countries whose markets are still developing than they are in more developed markets. Emerging market countries typically have economic and political systems that are less fully developed, and can be expected to be less stable than those of more developed countries. Investments in emerging markets are considered speculative. Liquidity Risk: Due to a lack of demand in the marketplace or other factors, an account may not be able to sell some or all of the investments promptly, or may only be able to sell investments at less than desired prices. Certain debt securities are substantially less liquid than many 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. Risks Affecting Specific Issuers: The value of an equity security or debt obligation may decline in response to developments affecting the specific issuer of the security or obligation, even if the overall industry or economy is unaffected. These developments may comprise a variety of factors, including but not limited to management issues or other corporate disruption, political factors adversely affecting governmental issuers, a decline in revenues or profitability, an increase in costs, or an adverse effect on the issuer’s competitive position. Risks Associated with Financial Derivative Instruments: Financial derivative instruments involve risks different from, and in certain cases greater than, the risks presented by more traditional investments. Depending on the particular client mandate, we enter transactions in over-the-counter (OTC) markets that expose a client account to the credit of its counterparties and their ability to satisfy the terms of such contracts. Where a particular client account employs derivative contracts, such account will be exposed to the risk that the counterparty may default on its obligations to perform under the relevant contract. In the event of a bankruptcy or insolvency of a counterparty, the client account could experience delays in liquidating the position and may incur significant losses. There is also a possibility that ongoing derivative transactions will be terminated unexpectedly as a result of events outside of our or our client’s control, for instance, bankruptcy, supervening illegality or a change in the tax or accounting laws relative to those transactions at the time the agreement was originated. In accordance

with standard industry practice and where agreed with the applicable counterparty, an account may net exposures on a counterparty by counterparty basis. Furthermore, risks associated with counterparties may be further complicated by recently enacted U.S. and non-U.S. financial reform legislation which includes provisions for new clearing, execution, margin and reporting requirements for derivatives transactions and new restrictions on the types of derivatives transactions that can be entered into by certain financial companies. The U.S. government has adopted mandatory minimum margin requirements for bilateral derivatives. Similar requirements are expected to be adopted by the European Union. Such requirements could increase the amount of margin required to be provided by a client in connection with its derivatives transactions and, therefore, make derivatives transactions more expensive. The ultimate impact of these regulatory changes remains unclear. Also, the new legislation may limit the flexibility of a client to protect its interests in the event of an insolvency of a derivatives counterparty because of powers granted to clearinghouses and to the Federal Deposit Insurance Corporation to limit or delay close-out of derivatives positions of insolvent clearing members or financial companies and to transfer such positions to other entities. Since many financial derivative instruments have a leverage component, adverse changes in the value or level of the underlying asset, rate or index can result in a loss substantially greater than the amount invested in the derivative itself. Certain financial derivative instruments have the potential for unlimited loss regardless of the size of the initial investment. If there is a default by the other party to any such transaction, there will be contractual remedies; however, exercising such contractual rights could involve delays or costs which could result in the value of the total assets of the related portfolio being less than if the transaction had not been effected. The swap market has grown substantially in recent years with a large number of banks and investment banking firms acting both as principals and as agents utilizing standardized swap documentation. There can be no assurance, however, that a liquid market will exist at any specified time for any particular swap. Derivatives do not always perfectly or even highly correlate or track the value of the securities, rates or indices they are designed to track. Consequently, our use of derivative techniques for a particular client account may not always be an effective means of, and sometimes could be counter-productive to, the client’s investment objective. An adverse price movement in a derivative position could require cash payments of variation margin by the particular client account that might in turn require, if there is insufficient cash available in the portfolio, the sale of the client account’s investments under disadvantageous conditions. Also, there are legal risks involved in using financial derivative instruments which could result in loss due to the unexpected application of a law or regulation or because contracts are not legally enforceable or documented correctly. Other risks in using derivatives include the risk of mispricing or improper valuation of derivatives. Many derivatives, in particular OTC derivatives, are complex and often valued subjectively. Improper valuations can result in increased cash payment requirements to counterparties or a loss of value to a portfolio. Risks Associated with Futures, Forwards and Options: Depending on the particular client mandate, we may from time to time utilize both exchange-traded and over-the-

counter futures, forwards and options as part of our investment policy. These instruments are highly volatile, involve certain special risks and expose investors to a high risk of loss. The low initial margin deposits normally required to establish a futures position permit a high degree of leverage. As a result, a relatively small movement in the price of a futures contract could result in a profit or a loss which is high in proportion to the amount of funds actually placed as initial margin and may result in unquantifiable further losses exceeding any margin deposited. Further, when used for hedging purposes there may be an imperfect correlation between these instruments and the investments or market sectors being hedged. Transactions in over-the counter derivatives involve additional risk as there is no exchange or market on which to close out an open position. It may be impossible to liquidate an existing position, to assess or value a position or to assess the exposure to risk. Private Placement Risk: Client portfolios that include private placements, such as company equity or debt, funds, joint ventures, and other non-liquid assets, are generally subject to restrictions on transferability, and can carry several general risks. These include, but are not limited to, risks from lack of liquidity, regulatory constraints on restricted securities, and assumptions-based approach pricing methodology. Private placement issuers differ from public companies in that they are not held to as rigorous a level of reporting and disclosure obligations. This lack of detailed information, coupled with the absence of a readily available market, amplifies the risks associated with valuing such investments. Leverage Risk: For some programs where Octagon acts as sub-advisor to Conning, losses incurred on leveraged investments will increase in direct proportion to the degree of leverage employed. The accounts will also incur interest expense on the borrowings used to leverage its positions. The use of leverage also may result in the forced liquidation of positions (which may otherwise have been profitable) as a result of margin or collateral calls, depending on an account’s structure. To the extent the assets have been leveraged through the borrowing of money, the purchase of investments on margin or otherwise, the interest expense and other costs and premiums incurred in relation thereto may not be recovered. If gains earned by the portfolio fail to cover such costs, the leveraged instrument may decrease faster than if there had been no borrowings. Moreover, to the extent Octagon can adjust leverage levels, Octagon could increase (or decrease) leverage at times when it is not advantageous to do so and, as a result, the value of your investment can decrease. (refer to Octagon’s Form ADV Part 2A for more detail). Business Continuity/Operational and Cyber Security Risks: Conning 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 our control. While we 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 our ability to do business and service our clients, harm our reputation, result in a violation of applicable privacy and other laws, require additional compliance costs, subject us 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. We will seek to notify affected clients of any known cybersecurity incidents posing a risk of harm to clients as required by law or regulation. Conning 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 our ability to continue active management of our clients’ portfolios and to provide for services contracted for by our clients. Our policy is to consider the events that it might reasonably face given its business and location and to have procedures in place to allow us to resume providing service to our clients as soon as possible. Our Investment Technology Group is responsible for the recovery effort and various departments participate in both the updating and testing of the plans. Environmental, Social, Corporate Governance Considerations – Conning is a signatory to the United Nations Principles for Responsible Investing (“UN PRI”),and seeks to align its investment activities with the tenets of the UN PRI. However, Conning does not automatically negatively screen investments based on ESG, unless specified by client guidelines and does not represent that services are “ESG Compliant“ or similar. Clients can continue to hold securities or industries that pose ESG risks. Implementation of AML/CFT Compliance Program Under FinCEN’s Final Rule (January 2028). Effective August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a final rule requiring certain investment advisers to establish and implement anti-money laundering and countering the financing of terrorism (AML/CFT) programs. As a result, Conning adopted compliance policies to align with these new regulatory requirements, with implementation required by January 1, 2028. While our AML/CFT framework is already largely in alignment with the new requirements, we’ve enhanced our program to incorporate independent testing, as now mandated under the rule. This addition strengthens our compliance oversight but does not introduce material changes to our day-to-day investment strategies or client interactions. As a best practice, Conning’s AML/CFT program already substantially comports with the new regulatory requirements that includes establishing and maintaining an anti-money laundering program and/or procedures in accordance with all applicable laws, rules and

regulations of its own jurisdiction including, where applicable, the Bank Secrecy Act (as amended by the USA PATRIOT Act of 2001 (the “Act”), the requirements of the Office of Foreign Assets Control (“OFAC”), and filing and reporting requirements with the Director of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). Ongoing AML/CFT continuing education/training is required for all employees. Conning represents that after appropriate due diligence, it believes that the sources of its clients’ funds are legitimate. Furthermore, it is Conning’s policy that it does not maintain or transact business for or with personal or commercial accounts held in the names(s) of individuals or organizations that the U.S. Treasury Department’s OFAC has listed as “Specially Designated Nationals and Blocked Persons” nor with any account in an embargoed country as determined by OFAC. We also will promptly provide our books and records of Conning to the United States Securities and Exchange Commission (the "Commission") or to authorized law enforcement agencies, either directly or indirectly through the Conning, at the request of the Commission, or an authorized law enforcement agency. Artificial Intelligence (“AI”) Use Risk. Conning utilizes certain artificial intelligence (“AI”) tools to support internal operational efficiencies. While these tools enhance productivity, AI technologies are rapidly evolving and may introduce unique risks, including algorithmic inaccuracies, data‑privacy or cybersecurity vulnerabilities, and potential legal or reputational impacts. Conning has implemented AI governance, oversight, and risk‑management frameworks designed to enable the responsible use of AI. These frameworks aim to ensure that Conning can capture the benefits of AI while safeguarding the interests of clients, employees, and other stakeholders and appropriately managing associated risks.

Conning Holdings Limited subsidiaries also include Goodwin Capital Advisers, Inc., Conning Investment Products, Inc., Octagon Credit Investors, L.L.C., Conning Asset Management Limited, Conning Asia Pacific Limited, Global Evolution Holding ApS Pearlmark Real Estate, L.L.C., MGG Investment Group, LP and its subsidiaries. Conning Investment Products, Inc., Goodwin Capital Advisors, Inc., Octagon Credit Investors, L.L.C., Global Evolution USA, LLC, MGG Investment Group, LP and PREP Investment Advisers, L.L.C. are registered with the SEC under the Investment Advisers Act of 1940, as amended. Conning has investment centers in Asia, Europe, and North America. Additional information regarding Conning’s affiliated entities is disclosed on Schedule D of Form ADV, Part 1 at Item 7.A. (Part 1 of our Form ADV can be accessed by following the directions provided on the cover page of this Brochure.) Certain individuals will assume dual responsibilities within Conning and its affiliates in relation to Portfolio Management, Trading, IT, Compliance, Legal, Board Member’s and other services. All individuals must adhere to our Code of Ethics, which is outlined in Item 11. Conning provides investment accounting and reporting services to both investment advisory and non-advisory clients and has a separate department of employees that dedicate 100% of their time to this function. Conning also licenses proprietary software to clients in connection with its investment advisory services. Finally, Conning offers general business advice that does not fall within the definition of investment advice to some clients. Conflicts of Interest Associated with Affiliated Advisers and Other Business Activities Conning & Company owns a majority interest in Octagon. Octagon’s investments generally consist of different investment asset classes from those that Conning generally invests in on behalf of their clients. Currently investment opportunities are generally not expected to overlap between Octagon and Conning clients. Octagon and Conning maintain separate investment committees which are responsible for making the investment decisions on behalf of each adviser’s clients, in accordance with their investment strategies. Conning’s Chair of the Board is appointed as an observer with respect to Octagon’s Investment Committee. As an observer, the Chair of the Board will have access to material nonpublic information (“MNPI”) with respect to all issuers discussed and will be subject to strict firm policies and procedures regarding access to MNPI. This individual is not involved in the investment decision making process or portfolio management for Conning or any other affiliate. Material Nonpublic Information Discussions and interactions between Octagon and Conning personnel are subject to the compliance policies and procedures that have been implemented within and between their respective businesses, including the establishment of information barriers

in order to mitigate the potential for any conflict of interest involving material nonpublic information concerning an issuer of securities or a borrower of bank loans. Also, certain Conning professionals may perform services for both Conning and Octagon, which involve access or the ability to access Octagon confidential information and MNPI, including for example, certain information technology employees with access to Octagon’s network or data files. Such employees will be subject to Octagon’s Code of Ethics and policies and procedures regarding MNPI. Though unlikely, a breach or failure of information barriers between the firms could occur, which could result in clients of Conning being unable to engage in certain transactions they would otherwise find attractive or being able to engage in such transactions only during limited periods of time. This could result in a client of Conning not being able to acquire or sell an investment that it otherwise might have acquired or sold. In an effort to manage possible risks from the inadvertent sharing of such information, both Octagon and Conning maintain a Code of Ethics program and provide training to supervised persons with respect to the receipt and handling of material nonpublic information. In addition, each advisor maintains a separate Compliance Department which maintains a restricted securities list which the firm may have access to material nonpublic information and which clients and\or employees are not permitted to trade. Nevertheless, notwithstanding the maintenance of restricted lists and other internal controls, it is possible that the internal controls relating to the management of material nonpublic information could fail and result in Conning or one of its investment professionals, buying and selling a security while, at least constructively, in possession of material nonpublic information. Inadvertent trading on material nonpublic information could have adverse effects on Conning’s reputation, result in the imposition of regulatory or financial sanctions, or Conning could be required to refrain from taking an investment action. Each of these could negatively impact Conning’s ability to perform their investment management services on behalf of their clients. Conning may decline to receive certain information available to loan market participants, which may include material non-public information about a loan issuer, in order to avoid trading restrictions with regard to securities of that issuer, even though access to such information may have been advantageous to a client investing in loans. Clients and investors may be adversely affected by such restrictions. Affiliated Referral & Sub-Advisory Relationships Conning has entered into referral and sub-advisory arrangements with Octagon and other affiliated entities, whereby fees are exchanged in connection with referrals of clients’ and\or prospects, in relation to investment advice, and with respect to the subadvisory of collateralized loan obligations (“CLO”s). This practice creates a conflict of interest, in that Conning could have an incentive to refer prospective clients to an affiliate based on the compensation received, rather than based on that client’s needs.

Prospective clients are under no obligation to engage with or purchase investment products or services from a Conning affiliate. Any compensation received from an affiliate will be paid by that affiliate from fees collected from the client and will not be imposed on the client in addition to established fees in connection with management of an account or product. Conflict of interest within these interrelationships could also include using the same vendor for different services. Broker-Dealers Conning has a direct affiliated broker-dealer, Conning Investment Products, Inc. (“CIP”). Conning does not use this entity for client security transactions; however, CIP does offer affiliated and/or non-affiliated private funds to current Conning clients, if suitable. CIP has entered into placement agreements with Octagon, Pearlmark, MGG and Global Evolution through which interests of proprietary Private Funds will be offered going forward. Placement fees will be paid out of existing management and incentive fees, and additional fees will not be imposed on the client or investor. To the extent permitted by a Private Fund’s Governing Documents, expenses in connection with offering Private Fund interests, including those incurred by CIP, may be borne by the Private Funds. Certain Conning, Octagon. Pearlmark, MGG and Global Evolution personnel are registered as representatives or principals of CIP, for the purpose of offering Private Funds.

The Code of Ethics prohibits employees from buying or selling a security (with certain exemptions) held in their personal account within three business days after a client account trades the same security. In addition, employees are required to hold a security for no less than 30 days after purchase.

Conning’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting the Chief Compliance Officer.

Conning also considers the availability of the broker to stand ready to execute possibly difficult transactions in the future, and the financial strength and stability of the broker. Conning currently does not participate in soft dollar arrangements. Conning does not receive client referrals from any broker. Conning aggregates orders, when possible, in accordance with client guidelines, for the purchase or sale of the same security for all participating accounts. When an order is filled in its entirety, each participating account receives their full allocation at the agreed upon trade execution price. When an order is partially filled, each participating account receives a pro rata allocation, at the agreed upon trade execution price, subject to certain exceptions including de minimis orders. Transaction costs are shared on a prorata basis for all participating accounts. SEC Rule 206(3)-2 of the Investment Advisers Act of 1940 allows an investment adviser, under certain circumstances, to engage in inter-account transactions. If one client of an investment adviser is looking to sell a security in its portfolio and another client of the same investment adviser is looking to purchase that security, this rule permits the investment adviser to do a cross trade between the two accounts. The buy/sale must be at fair market value and with no commissions. Conning will only engage in these cross trades when advantageous to both clients and with prior approval from the Chief Compliance Officer. Cross transactions will not be conducted through an affiliated broker-dealer.

Conning does accept direction from clients regarding which brokers to use. Currently, all client-directed brokerages are subject to most favorable execution and best execution. Conning’s Best Execution Committee consists of members from Investment Management, Trading, Operations and Compliance. The Committee meets quarterly to set, guide and review brokerage allocation and practices. New brokers are reviewed and approved by the Chief Risk Officer and the Compliance Department. Conning does direct the purchase of securities on behalf of clients, in secondary market transactions, in public offerings directly from an underwriter or in privately negotiated transactions with an issuer. Securities purchased in public offerings could be resold shortly after acquisition in the immediate aftermarket to take advantage of price appreciation from the public offering price or for other reasons. Short-term trading of securities acquired in public offerings, or otherwise, result in higher portfolio turnover. If consistent with a client’s investment objectives, investment restrictions, and risk tolerance, Conning purchases securities sold in underwritten new issues, (“deal securities”) for client accounts. Deal securities are allocated among participating accounts in a fair and equitable manner so as not to unfairly discriminate in favor of certain clients or types of accounts. When a portfolio manager receives a reduced allocation of deal securities, the portfolio manager will allocate the reduced allocation among accounts in accordance with the allocation percentages set forth in the initial allocation instructions for the deal securities, except where this would result in de minimis allocation to any client account. For some programs where Octagon acts as sub-advisor to Conning, certain clients may not be able to participate in investment opportunities absent participation by other clients or may be prevented from participating where it would not be possible to allocate opportunities fairly or equitably among clients. Equity and fixed income securities are priced on a daily basis when available from Conning’s pricing vendor (Refinitiv/Markit). For month end portfolio pricing, Conning manually prices any security that is not priced by a vendor, using a pre-determined source hierarchy. When Refinitiv is unable to provide a price, Conning will look to Markit, Intercontinental Exchange (ICE), Pricing Direct, Bloomberg BVAL, then the Street (i.e., brokers buying/trading/selling) to provide pricing. For Bank Loans, CMO’s and CLOs, Markit is the primary price source, and Refinitiv is used as a secondary price source. Conning’s Credit and Trading Groups may research securities, particularly distressed securities, and if documented and justified for using a particular price level/method, that price will be used. Where pricing is not available from any 3rd party sources and sufficient information is available (via Bloomberg or other documentation) to model the security on Yieldbook, an accredited pricing model, it is modeled using the best available indicative information. Conning will then use the Corporate Spread Matrix to provide a spread and apply to Yieldbook. Also, depending

on the availability and timeliness of supporting documentation, the purchase price is used if/when it has been purchased within the month as this price represents an actual transaction price. Where the purchase was made closer to the beginning of the month there is greater emphasis on identifying a source from the hierarchy. Where supporting documentation is not available the purchase price is used. Conning could give advice, or take action, with respect to any one client account which differs from the advice given, or action taken, with respect to another client account. However, Conning, to the extent practical and over a period of time, allocates investment opportunities to each account on a fair and equitable basis relative to other similarly situated client accounts based on client guidelines and cash availability. As in any business, mistakes do happen despite the good intentions of employees and the controls in place. Conning will correct trading errors in a timely and appropriate manner.

case basis, after Conning ascertains that the referring party is not a person disqualified under Rule 206-1(b)(3). Solicitor compensation greater than $1,000, cash or non-cash is paid pursuant to a written agreement. As a matter of firm practice, the advisory fees paid to us by clients referred by solicitors are not increased as a result of any referral. It is Conning’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients.

A situation where Conning’s interest would be directly in conflict with that of a client when voting proxies is when the issuer of the security is an insurance company that is either a client or potential client of Conning. In that interest, it is conceivable that Conning could be tempted to vote a proxy in line with management’s interest rather than shareholders’ interest, to obtain favorable treatment from company decision makers who have the ability to hire or retain Conning as an investment adviser. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. To direct us to vote a proxy in a particular manner, clients should contact their portfolio manager. Under no circumstances will Conning act on behalf of its clients in legal proceedings, including class actions or bankruptcies involving securities purchased or held in the client account, other than with respect to bankruptcies involving private placement securities where such services have been retained by a client. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner.

1967) obtained his Master of Business Administration as a Baker Scholar from Harvard Business School in 1993 and his Bachelor of Science Degree in Chemistry from Worcester Polytechnic Institute in 1989 where he graduated with high distinction. Mr. Bradford was recently named CEO and GM of Generali Investment Holding S.p.A. (Conning’s ultimate parent). He has been with Conning since February 2010 and remains the Chair of the Board. Previously, Mr. Bradford was an Operating Partner for Advent International from January 2009 to February 2010; and a Managing Director for Putnam Investments where he worked from July 1996 to July 2008. Mr. Bradford earned his Chartered Financial Analyst (CFA) designation in 2011. The CFA charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute – the largest global association of investment

professionals. There are currently more than 90,000 CFA charterholders working in 135 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: ❖ Place their clients’ interests ahead of their own ❖ Maintain independence and objectivity ❖ Act with integrity ❖ Maintain and improve their professional competence ❖ Disclose conflicts of interest and legal matters Passing the three CFA exams is a difficult feat that requires extensive study. Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global financial industry. As a result, employers and clients are increasingly seeking CFA charterholders - often making the charter a prerequisite for employment. Additionally, regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own finance course. The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the dynamic and complex nature of the profession. To learn more about the CFA charter, visit www.cfainstitute.org. Item 3- Disciplinary Information Mr. Bradford does not have any disciplinary information to report.

Item 4- Other Business Activities Mr. Bradford is the Chair of the Board of Goodwin Capital Advisers, Inc. and Conning Investment Products, Inc. (“CIP”). He is also the Chair of the Board for Octagon Credit Investors, LLC. and other affiliated SEC registered investment advisers. Mr. Bradford serves as the Chief Executive Officer and GM for Generali Investments Holding S.p.A. (IT) and Chair of the Board at Generali Asset Management SGR S.p.A. (IT). Mr. Bradford also serves and Chair of the Board and a member of the Board of Directors of several domestic and foreign domiciled Conning affiliates. Mr. Bradford serves as a member of the Board of Trustees of Worcester Polytechnic Institute and as the Chair of the Investment Committee and a member of a number of other Committees and Task Forces as requested and appropriate. He is also a registered representative of CIP which is utilized as a placement agent for alternative investments offered to affiliated and non-affiliated clients which a commission is paid to CIP for services rendered. Item 5- Additional Compensation Compensation paid includes commission or bonuses based on placement fees earned. While Mr. Bradford endeavors at all times to put the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest, and could affect the judgment of this individual when making recommendations. All placement fees are disclosed to the client prior to investing. Item 6 - Supervision Conning has a continuing responsibility to adhere to the Advisers Act, including the supervision of, and the responsibility for, portfolio managers and anyone acting on behalf of Conning to read, understand and attest to comply with the policies and procedures located within Conning’s Compliance Policies and Procedures Manual. Mr. Bradford reports directly to the Group CEO of Assicurazioni Generali S.p.A.

CONNING, INC. Form ADV Part 2B Brochure Supplement One Financial Plaza Hartford, CT 06103 860-299-2184 www.conning.com

Matthew Daly, CFA Chief Executive Officer This Brochure Supplement provides information about Matthew Daly that supplements the Conning’s Brochure. You should have received a copy of that Brochure. Please contact us at us at 860-299-2151 or at robert.pearce@conning.com if you did not receive Conning’s Brochure or if you have any questions about the contents of this supplement. Item 2- Educational Background and Business Experience Matthew Daly, CFA, is the Chief Executive Officer of Conning, Inc. and Head of Conning North America. He is a member of Conning’s Investment Policy Committee and Conning’s Sustainability Leadership Group. Before assuming his current role, Mr. Daly was the Head of Corporate and Municipal Teams. Prior to joining Conning in 2003, he held a variety of roles with Webster Bank, Brown Brothers Harriman & Co., and FleetBoston. Mr. Daly earned a degree in economics and business administration from Gordon College and holds FINRA Series 7, Series 63, and Series 24 Registrations. Mr. Daly earned his Chartered Financial Analyst (CFA) designation in 2001. The CFA charter is a globally respected, graduate-level investment credential established in 1962

and awarded by CFA Institute – the largest global association of investment professionals. There are currently more than 90,000 CFA charterholders working in 135 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: ❖ Place their clients’ interests ahead of their own ❖ Maintain independence and objectivity ❖ Act with integrity ❖ Maintain and improve their professional competence ❖ Disclose conflicts of interest and legal matters Passing the three CFA exams is a difficult feat that requires extensive study. Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global financial industry. As a result, employers and clients are increasingly seeking CFA charterholders - often making the charter a prerequisite for employment. Additionally, regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own finance course. The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the dynamic and complex nature of the profession. To learn more about the CFA charter, visit www.cfainstitute.org. Item 3- Disciplinary Information Mr. Daly does not have any disciplinary information to report.

Item 4- Other Business Activities Mr. Daly is also the Chief Executive Officer of CIP and Goodwin Capital Advisers, Inc., both affiliated SEC registered investment adviser. Item 5- Additional Compensation Mr. Daly does not have any additional compensation. Item 6 - Supervision Conning has a continuing responsibility to adhere to the Advisers Act, including the supervision of, and the responsibility for, portfolio managers and anyone acting on behalf of Conning to read, understand and attest to comply with the policies and procedures located within Conning’s Compliance Policies and Procedures Manual. Mr. Daly is supervised by Woody Bradford, Chair of the Board. Mr. Bradford may be reached at 860-299-2076.

CONNING, INC. Form ADV Part 2B Brochure Supplement One Financial Plaza Hartford, CT 06103 860-299-2184 www.conning.com

Cynthia A. Beaulieu Managing Director This Brochure Supplement provides information about Cynthia A. Beaulieu that supplements the Conning, Inc. Brochure. You should have received a copy of that Brochure. Please contact us at us at 860-299-2151 or at robert.pearce@conning.com if you did not receive Conning’s Brochure or if you have any questions about the contents of this supplement. Item 2- Educational Background and Business Experience Cynthia A. Beaulieu (b. 1970) obtained her Bachelor of Science degree from LaSalle University in 1992. Ms. Beaulieu is a Managing Director of Conning, Inc. since 2011 and a Managing Director of Goodwin Capital Advisers, Inc. (previously known as Phoenix Investment Counsel) since 1994. Ms. Beaulieu held various jobs of increasing responsibility while at Phoenix. Previously, Ms. Beaulieu was a corporate trust analyst at Shawmut Bank. Item 3- Disciplinary Information Ms. Beaulieu does not have any disciplinary information to report.

Item 4- Other Business Activities Ms. Beaulieu is the Chief Investment Officer, Conning North America and Managing Director and Senior Portfolio Manager of CIP and Goodwin Capital Advisers, Inc., both affiliated SEC registered investment advisers. Item 5- Additional Compensation Ms. Beaulieu does not have any additional compensation. Item 6 - Supervision Conning has a continuing responsibility to adhere to the Advisers Act, including the supervision of, and the responsibility for, portfolio managers and anyone acting on behalf of Conning to read, understand and attest to comply with the policies and procedures located within Conning’s Compliance Policies and Procedures Manual. Ms. Beaulieu is supervised by Matt Daly, CEO and Head of Conning North America. Mr. Daly may be reached at 860-299-2231.

CONNING, INC. Form ADV Part 2B Brochure Supplement One Financial Plaza Hartford, CT 06103 860-299-2210 www.conning.com

Daniel Mainolfi, CFA Managing Director This Brochure Supplement provides information about Daniel Mainolfi that supplements the Conning, Inc. Brochure. You should have received a copy of that Brochure. Please contact us at us at 860-299-2151 or at robert.pearce@conning.com if you did not receive Conning’s Brochure or if you have any questions about the contents of this supplement. Item 2- Educational Background and Business Experience Daniel Mainolfi (b. 1963) obtained his Bachelor of Science Degree in Finance & Investments from Babson College in 1985. Mr. Mainolfi has been with Conning since 1992 and is a Managing Director. Mr. Mainolfi earned his Chartered Financial Analyst (CFA) designation in 1990. The CFA charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute – the largest global association of investment professionals. There are currently more than 90,000 CFA charterholders working in 135 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six hour examinations; 2) have at least four years of qualified professional investment

experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: ❖ Place their clients’ interests ahead of their own ❖ Maintain independence and objectivity ❖ Act with integrity ❖ Maintain and improve their professional competence ❖ Disclose conflicts of interest and legal matters Passing the three CFA exams is a difficult feat that requires extensive study. Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global financial industry. As a result, employers and clients are increasingly seeking CFA charterholders - often making the charter a prerequisite for employment. Additionally, regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own finance course. The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the dynamic and complex nature of the profession. To learn more about the CFA charter, visit www.cfainstitute.org. Item 3- Disciplinary Information Mr. Mainolfi does not have any disciplinary information to report.

Item 4- Other Business Activities Mr. Mainolfi does not have any other business activities. Item 5- Additional Compensation Mr. Mainolfi does not have any additional compensation. Item 6 - Supervision Conning has a continuing responsibility to adhere to the Advisers Act, including the supervision of, and the responsibility for, portfolio managers and anyone acting on behalf of Conning to read, understand and attest to comply with the policies and procedures located within Conning’s Compliance Policies and Procedures Manual. Mr. Mainolfi is supervised by Matt Daly, CEO and Head of Conning North America. Mr. Daly may be reached at 860-299-2231.

CONNING, INC. Form ADV Part 2B Brochure Supplement One Financial Plaza Hartford, CT 06103 860-299-2203 www.conning.com

Andrew Pace Managing Director This Brochure Supplement provides information about Andrew Pace that supplements the Conning, Inc. Brochure. You should have received a copy of that Brochure. Please contact us at us at 860-299-2151 or at robert.pearce@conning.com if you did not receive Conning’s Brochure or if you have any questions about the contents of this supplement. Item 2- Educational Background and Business Experience Andrew Pace (b. 1966) obtained his Master of Business Administration Degree in Finance from RPI in 1997 and a Bachelor of Arts Degree in Economics from The University of Connecticut in 1988. Mr. Pace has been with Conning since 1995 and is a Managing Director. Item 3- Disciplinary Information Mr. Pace does not have any disciplinary information to report.

Item 4- Other Business Activities Mr. Pace is a Managing Director and Portfolio Manager of Conning Investment Products, Inc., an affiliated SEC registered investment adviser. Item 5- Additional Compensation Mr. Pace does not have any additional compensation. Item 6 - Supervision Conning has a continuing responsibility to adhere to the Advisers Act, including the supervision of, and the responsibility for, portfolio managers and anyone acting on behalf of Conning to read, understand and attest to comply with the policies and procedures located within Conning’s Compliance Policies and Procedures Manual. Mr. Pace is supervised by Matt Daly, CEO and Head of Conning North America. Mr. Daly may be reached at 860-299-2231.

CONNING, INC. Form ADV Part 2B Brochure Supplement One Financial Plaza Hartford, CT 06103 860-299-2350 www.conning.com

Lynn M. Ryan, CFA Managing Director This Brochure Supplement provides information about Lynn M. Ryan that supplements the Conning, Inc. Brochure. You should have received a copy of that Brochure. Please contact us at us at 860-299-2151 or at robert.pearce@conning.com if you did not receive Conning’s Brochure or if you have any questions about the contents of this supplement. Item 2- Educational Background and Business Experience Lynn M. Ryan (b. 1969) obtained her Bachelor of Arts degree from Dartmouth College in 1992. Ms. Ryan is a Managing Director of Conning, Inc. since 2011 and a Managing Director of Goodwin Capital Advisers, Inc. (previously known as Phoenix Investment Counsel) since 2004. Previously, Ms. Ryan was Senior Vice President for Phoenix National Trust Co. Ms. Ryan held various positions within The Phoenix Companies since 1997. Prior to that, Ms. Ryan held the position as corporate lender for BankBoston. Ms. Ryan has earned her Chartered Financial Analyst (CFA) designation. The CFA charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute – the largest global association of investment professionals. There are currently more than 90,000 CFA charterholders working in 135 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six hour examinations; 2) have at least four years of qualified professional investment

experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: ❖ Place their clients’ interests ahead of their own ❖ Maintain independence and objectivity ❖ Act with integrity ❖ Maintain and improve their professional competence ❖ Disclose conflicts of interest and legal matters Passing the three CFA exams is a difficult feat that requires extensive study. Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global financial industry. As a result, employers and clients are increasingly seeking CFA charterholders - often making the charter a prerequisite for employment. Additionally, regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own finance course. The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the dynamic and complex nature of the profession. To learn more about the CFA charter, visit www.cfainstitute.org. Item 3- Disciplinary Information Ms. Ryan does not have any disciplinary information to report.

Item 4- Other Business Activities Ms. Ryan is a Managing Director and Senior Portfolio Manager of Goodwin Capital Advisers, Inc., an affiliated SEC registered investment adviser. Item 5- Additional Compensation Ms. Ryan does not have any additional compensation. Item 6 - Supervision Conning has a continuing responsibility to adhere to the Advisers Act, including the supervision of, and the responsibility for, portfolio managers and anyone acting on behalf of Conning to read, understand and attest to comply with the policies and procedures located within Conning’s Compliance Policies and Procedures Manual. Ms. Ryan is supervised by Daniel Mainolfi, Managing Director. Mr. Mainolfi may be reached at 860-299-2210.