Silchester International Investors: investment adviser

All of SII Ltd’s employees, including all portfolio managers, research analysts and members of its operations and administration groups, became employees or members of Silchester. Silchester then succeeded to SII Ltd’s SEC registration. In July 2016, SP Ltd contributed its partnership interest in Silchester to Silchester Capital Limited (“SCL”) in exchange for shares in SCL. In April 2019, SCL changed its name to Silchester Continuation Limited. SCL is Silchester’s regulatory capital provider. Silchester is a registered investment advisor in the USA. Silchester is also authorised and regulated by the UK Financial Conduct Authority (the “FCA”) and registered with the Central Bank of Ireland (the “CBI”). This registration is required for Silchester to be appointed as a sub-advisor to Irish funds which are subject to regulation under the rules of the European Union for Undertakings for Collective Investment in Transferable Securities (“UCITS”). Additional registrations may be required from time to time depending on the securities that form part of Silchester’s investment programme. Silchester is a UK limited liability partnership. SCL owns a substantial majority (>75%) of Silchester’s capital. The remaining capital has been contributed by the working members. Under the terms of the limited liability partnership agreement (the “LLP Agreement”), legal members of the partnership may nominate individuals who will form part of Silchester’s Business Supervisory Group. The actual appointment or removal of these individuals is determined by vote. Voting rights are determined by capital ownership. SCL holds a majority of Silchester’s capital and therefore has veto authority over the specific individuals forming part of the Business Supervisory Group. Under the terms of the LLP Agreement, the Chair of the Business Supervisory Group and a majority of the members of the Business Supervisory Group must be legal members or employees of Silchester and/or its wholly owned subsidiary, Silchester International Investors, Inc. (“SII Inc.”). The Business Supervisory Group is entitled to appoint a majority of the members of any underlying business group operated by the firm. SCL is able to appoint one representative to attend and speak at each meeting of the Business Supervisory Group. SCL may also appoint one representative to Silchester’s Investment Supervisory Group and Partnership Promotion / Remuneration Group. The SCL representative may only vote at the Partnership Promotion / Remuneration Group meetings. The SCL representative is prohibited from attending, speaking or voting at any operation group, subgroups, committees, groups or similar that support Silchester’s day to day business and operations (e.g., portfolio implementation, dealing, compliance and operational risk, marketing and client services). Silchester’s income profits are allocated between SCL and the employees and working members of Silchester and SII Inc. Under the terms of the LLP Agreement a majority of income profits must be paid to the employees and working members. The ratio of income profits allocated to each party are subject to various adjustments if a working partner or senior employee retires or adjusts their contribution to the

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business in any material way. This provision allows employees and working members to receive more than 51%, but less than 67%, of Silchester’s income profits. 100% of Silchester’s capital profits accrue to SCL. Description of Advisory Services Silchester provides discretionary investment management services to its Clients. Silchester possesses a wide range of analytical, research, portfolio implementation and administrative skills. Silchester specialises in investing in publicly traded non-U.S. equity securities using a bottom-up intrinsic value based investment approach. Our objective is to maximise the intrinsic value of the portfolio, which we define as the earnings, assets and dividends delivered by our companies and aggregated within the portfolio. This policy is implemented by a strong price discipline – lower multiples of earnings, assets and dividends mean more earnings, assets and dividends at the outset – and by a quality appraisal which seeks to identify companies capable of increasing earnings, assets and dividends by their own efforts. A successful accumulation of intrinsic value can lead to a good investment return. Customisation of Advisory Services and Wrap Fee Programs Silchester does not manage assets on a non-discretionary basis, participate in wrap fee programmes or provide financial planning, quantitative planning or market timing services. Silchester does not customise or modify its investment programme or agree to restrictions on investments in certain securities or types of securities. Unitholders may not impose such restrictions. Assets Under Management As of 31st March 2026, Silchester had approximately US$38.6 billion of discretionary assets under management.

Fees are payable monthly in arrears, although the actual timing of fee payments will depend on the underlying legal domicile of the Fund and the terms of its operating agreements. The Northern Trust Company (“Northern Trust”), the custodian for the Funds, will redeem units of Unitholders to the extent necessary to pay fees to Silchester on a monthly basis.

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Brokerage and Transaction Costs The Funds pay their own direct trading expenses. Direct trading expenses include brokerage commissions related to trade execution, “bid-ask” spreads, mark-ups, clearing fees, exchange fees, registration and transfer fees, regulatory and governmental charges and duties and transactional fees and expenses. The Funds must pay all income, dividend withholding, capital gains and other taxes related to their underlying investments (see Item 12 for more information on Silchester’s brokerage practices). Silchester pays for the costs of third-party research directly out of its own financial resources. Silchester does not pay “soft dollar” commissions and/or receive “soft dollar” benefits from brokers. Substantially all security trades are done at a single global execution only rate of commission. Silchester may occasionally negotiate a further reduction in commission rates and/or periodically “step out” and pay a higher rate if, as an example, it costs a counterparty more to trade a security than the normal global execution only rate of commission or if a higher rate must be paid to participate in a placement or secondary offering of securities. Silchester has negotiated a foreign exchange agreement with Northern Trust. In exchange for Northern Trust developing, maintaining, monitoring and enhancing the foreign exchange algorithm the Funds utilise for trading foreign exchange, operating the foreign exchange panel, providing balance sheet support to foreign exchange trading, bearing the counterparty risks of trading with panel participants and providing TCA reporting, Silchester pays Northern Trust a fee out of its own investment management fees. No mark ups, additional spreads or additional settlement charges are added to foreign exchange transactions executed for the Funds. Expenses Silchester pays all routine legal, audit and accounting fees related to the Funds. Silchester pays the fees payable to the Custodians, Trustees, Fund Administrators, Managers, Managing Members, Auditors, Tax Advisors and other similar service providers of the Funds. Silchester has paid all expenses in connection with the organisation and the formation of the Funds and pays all costs associated with the ongoing issuance of the Units of these Funds. The Funds do not have to raise a minimum amount to defray these expenses. No reimbursement is permitted if the investment management fees do not cover Silchester’s expenses. In addition, the Funds may have to reimburse Silchester or third-party service providers to the Funds for extraordinary legal expenses (i.e., expenses incurred to protect or promote the investment rights or obligations of the Funds). Anti-Dilution Levies on Contributions and Redemptions Unitholders may contribute to, or redeem from, the US Funds on a monthly basis. Typically, Unitholder contributions or redemptions are made directly to or from the Funds in cash. To minimize the impact of trading expenses associated with contributions and redemptions on current Unitholders, an Anti-Dilution Levy may be assessed on the contribution or redemption. Silchester seeks to net or “offset” Unitholder contributions and redemptions to minimize trading activity and the resulting expenses. Primarily, this will occur at the respective Fund level but may also occur between the Funds through a cross trade. Where offsetting is not possible, the immediate cost of buying securities or selling securities to raise cash will be assessed on the Unitholder(s) who initiated the transaction generating the trading costs. Silchester believes this is appropriate and protects the interests of existing Unitholders in the Fund. To calculate this anti-dilution levy (“ADL”), Silchester will compare the actual cost of the trading activity versus the market value of the trading activity at month end. If the additional trading has not adversely impacted the remaining Unitholders an ADL will not be assessed. However, if the remaining Unitholders

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have been adversely impacted (i.e., there has been a cost to the Fund), those transacting Unitholders will be subject to an ADL. The Fund’s Governing Documents permit Silchester to ordinarily assess an ADL of up to 75 basis points (0.75%) on cash contributions and 50 basis points (0.50%) on cash redemptions. Higher levies may be applied in extraordinary circumstances. Silchester may, for particularly significant contributions or redemptions, direct a Unitholder to use a transition account (see Item 7 for more information on transition accounts). In the case of a transition account, trading expenses are accounted for separately per Unitholder. Current and prospective Unitholders should refer to the specific provisions of the Governing Documents for a complete discussion of ADLs, transition accounts and the risks involved. Separate Accounts Clients invested in separate accounts pay their own direct trading expenses. Direct trading expenses include brokerage commissions, bid-ask spreads, mark-ups, clearing fees, exchange fees, stock loan expenses, registration and transfer fees, regulatory and governmental charges and duties, and other fees and expenses. Clients invested in separate accounts must pay all income and other taxes related to their underlying investments. Clients invested in separate accounts may have to reimburse Silchester for legal expenses that Silchester determines are not routine (e.g., extraordinary legal expenses such as those incurred in connection with litigation to protect or promote the investment rights or obligations of the investors invested in separate accounts and legal or accounting expenses in connection with reclaiming foreign withholding taxes) and that are not borne by Silchester. Clients invested in separate accounts pay their own legal, audit and accounting fees and annual audit fees and tax return expenses (if any). Clients invested in separate accounts pay any fees payable to their own Custodians, Trustees, Fund Administrators, Managers, Managing Members, Auditors, Tax Advisors, Independent Third-Parties and other similar service providers. Other Compensation Silchester does not accept additional compensation for the sale of securities or other services from third parties and does not receive compensation for other services besides the investment advisory services it provides. In extremely limited circumstances where pre-approved by the Compliance Group and following a review for any conflicts of interest pursuant to our Code of Ethics, staff are permitted to have outside business interests.

non-U.S. Unitholders as well as certain eligible tax-exempt U.S. Unitholders that qualify as “accredited investors” and “qualified purchasers” as defined under U.S. federal securities laws. An investment in Units of a Fund involves the risk of loss. Silchester, as investment manager, is responsible for reviewing and managing the holdings and for making appropriate recommendations to satisfy each Fund’s investment objective. Further information is available in the Agreement and Declaration of Trust, Private Offering Memorandum and Subscription Agreement of the U.S. Funds, and the Prospectus and Application Form of the Calleva Trust and the Exclusion UCITS (referred to collectively as the “Governing Documents”) respective offering document of each Fund. Silchester has been appointed as investment manager for six Funds. These are:

The Silchester International Investors International Value Equity Trust (the “Business Trust”); The Silchester International Investors International Value Equity Group Trust (the “Group Trust”); The Silchester International Investors International Value Equity Taxable Trust (the “Taxable Trust”); The Silchester International Investors International Value Equity Exclusion Trust (the “Exclusion Trust”); The Calleva Trust – International Equity Fund (the “Calleva Trust”); and, Silchester International Investors (Ireland) Trust – International Equity Exclusion UCITS (the “Exclusion UCITS”).

The Exclusion Trust and Exclusion UCITS operate on the same basis as Silchester’s other Funds, with one primary exception. As described in the investment guidelines within their Governing Documents, the Exclusion Trust and Exclusion UCITS do not invest in companies involved in the exploration and/or extraction of fossil fuels, utilities that generate more than 25% of their electricity production from oil or coal and/or companies with significant reserves of oil, coal or natural gas which, if extracted and burned, would produce significant levels of carbon dioxide emissions. The Silchester International Investors International Value Equity Alternative Exclusion Trust (the “Alternative Exclusion Trust”) was formed in March 2026 and is expected to being investment activity in or around September 2026. With one primary exception, the Alternative Exclusion Trust will operate on a pari passu basis to Silchester’s other US Funds. As described in the investment guidelines within its Governing Documents, the Alternative Exclusion Trust will not invest in companies whose primary business is the manufacture, sale, licensing or supply of alcoholic products or a company whose primary business is the ownership, operation, support or licensing of gambling facilities, Silchester launched the Silchester (Ireland) Trust – DCF International Value Equity Trust (the “DCF UCITS”) on 15th December 2023. The DCF UCITS has US$0.2bn of total assets as of 31st March 2026. The DCF UCITS is managed by a small team of former Sanderson Asset Management employees who are based in a separate office to Silchester’s own investment team. The DCF UCITS is not currently being actively marketed to external clients. Conditions for Managing Accounts The minimum initial subscription for Units in a U.S. Fund is US$25 million. The minimum additional investment is US$100,000. Silchester may accept or reject, in whole or in part, any investment or impose conditions or restrictions on these investments, such as increasing or decreasing the amount of minimum investment, or requiring a Unitholder to establish a temporary account with the custodian of the Funds and

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to wire funds to that account before an applicable dealing day, subject to any restrictions in the Governing Documents. Subject to the Governing Documents, Unitholders may redeem all or part of their Units in a U.S. Fund on any dealing day by providing Silchester with written notice, confirming the value of the redemption and the name of the account from which the redemption is requested, at least ten (10) business days before the dealing day upon which the redemption is to be effective. Certain documentation must then be returned at least six (6) business days before such dealing day. Subject to the Governing Documents, a redemption must equal or exceed US$1,000,000 and following any such redemption, a Unitholder must maintain Units with a minimum market value of US$10 million. Subject to the Fund’s Governing Documents Silchester may modify these deadlines and minimum amounts in its sole discretion. Unitholders in the Calleva Trust, the Exclusion UCITS and the DCF UCITS, (the “Irish UCITS Funds”), may subscribe for units and/or to redeem on the first calendar day of the month as well as on or immediately after the 15th calendar day of the month. Mid-month redemptions from the Irish UCITS Funds are subject to an additional Anti-Dilution Levy up to 3.00%. Transition Accounts Silchester may direct Unitholders making cash contributions or redemptions to use transition accounts. Transition accounts are temporary custody accounts opened under a Fund’s general legal structure, used to minimize the impact of large subscriptions and withdrawals on Unitholders by requiring the incoming or outgoing Unitholder to bear their own market risk and dealing costs. A withdrawal transition account structure may be used by Silchester to liquidate a security that becomes subject to a legal restriction on ownership or transfer (a “restricted security withdrawal transition account”). Northern Trust, the custodian and fund administrator for the Funds, maintains the accounting books and records and separately values each type of transition account using the same rules and procedures used in valuing the Fund. Silchester retains sole discretion for the management of the transition accounts including cash balances. Prospective investors should refer to the specific provisions of the Fund’s Governing Documents for a complete discussion of transaction accounts and the risks involved. Under UCITS rules, transition accounts cannot normally be used to facilitate contributions or redemptions from the UCITS Funds. Sideletter Agreements Silchester will consider entering into a sideletter agreement only when rules governing the investment by a specific Unitholder (such as state law or the governing documents related to such Unitholder) requires a specific variation, provided that such change is not expected to materially affect the other Unitholders, Silchester or other service providers to the Funds. It is Silchester’s policy not to agree to any sideletter or other similar agreements that grant any Unitholder or group of Unitholders preferential rights regarding the payment or timing of redemptions, indemnification from Silchester, the law governing Silchester’s and each Unitholder’s responsibilities under the Governing Documents, or access to data on a Fund’s holdings or trading activity. Silchester provides a summary of all current sideletter agreements upon the written request of a current or prospective Unitholder. Silchester provides a summary of all current sideletter agreements on an annual basis when it distributes the audited financial statements of each Fund.

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As many companies have multinational operations, Silchester will ordinarily determine a company’s location after considering factors such as (i) its jurisdiction of incorporation, (ii) the location of its head office, (iii) the location of its primary market, (iv) the location of its significant sources of revenues, (v) the location of its income, (vi) the location of its assets, or (vii) its classification as determined by various market indices. Silchester invests primarily in established markets. However, Silchester may invest in emerging market securities and currencies. Silchester generally seeks to invest in a portfolio of equity securities that, in its opinion, possess fundamental value. Silchester believes that securities with low market price to earnings, cash flow, asset value, sales ratios or dividends typically, but not necessarily, possess fundamental investment value. Investments meeting the above criteria are identified by Silchester in part through database screens. Silchester carries out financial analysis on prospective investments and reviews their underlying business strengths and weaknesses, their plans, and their management. Investments that appear attractive according to these criteria generally will constitute a high proportion of each Fund’s investments. When allocating investments among geographic regions and individual countries, the prime determinant for Silchester is the attraction of the individual security investments (a “bottom up” approach). Macroeconomic factors are considered as they affect individual companies. Silchester seeks to retain a reasonable diversification of investments across countries and industries and, will normally incur some exposure to foreign currencies. Silchester may actively manage each Fund’s currency risk through spot and forward currency contracts. In determining its strategy toward currency investment, Silchester considers a country’s real short-term interest rates, the relative purchasing power parity of its currency and its overall financial quality, current account performance, prevailing monetary conditions and any special geopolitical factors. Due to restrictions on direct investments by foreign entities in certain foreign countries, investments in other investment companies may be the most practical or only way each Fund can obtain certain securities. It should be noted, however, that investments in investment companies may (i) involve the payment of premiums above the net asset value of such issuers’ portfolio securities, (ii) be constrained by market availability, and/or (iii) be considered passive foreign investment companies for federal income tax purposes. Silchester does not expect investment companies will comprise a major part of its portfolios. Types of Investments Silchester primarily invests in established security and currency markets. Silchester is permitted to utilise a wide range of equity instruments in attempting to achieve its objective, including common and preferred stocks, special classes of shares available only to foreign persons in markets which restrict the ownership of certain classes of equity, convertible preferred stocks, investment grade instruments and depository receipts. Silchester may invest in physical currencies and spot and forward currency contracts. Subject to investment guidelines, Silchester may invest in (i) non-exchange traded securities including private placements and securities subject to transfer restrictions under Rule 144A or Regulation S of the Securities Act of 1933 or otherwise commit to acquire securities on a forward commitment basis, and (ii)

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unregistered and bearer securities. Silchester does not invest in futures or options on futures. Silchester may, however, invest in, hold, and purchase, or otherwise acquire rights, stock options, stock coupons, warrants, and other similar investments issued, sold, or distributed by a portfolio holding as part of a corporate action or other similar transaction. Silchester may purchase the securities of issuers during an initial public or secondary offering of securities. Companies involved in initial public or secondary offerings of securities typically have short operating and trading histories and generally are less established. The prices of securities issued as part of initial public or secondary offerings traditionally have been volatile. Silchester may have to agree to transferability restrictions to participate in these security offerings. Frequency of Trading Silchester expects the turnover of securities to be in the range of 25-40% per annum depending on market conditions. Information on historic levels of turnover is available from Silchester. Silchester makes investment decisions on when to sell a security solely based on its investment criteria and does not consider tax considerations. Silchester does not engage in “tax loss harvesting”. Strategy Risks: Several material risks are associated with investing in publicly traded equity securities. These include, but are not limited to, the following. Further information on investment risks is disclosed in each Fund’s Governing Documents. All exposures are also subject to each Fund’s investment guidelines.

Foreign Market Exposure. Silchester can invest in both developed and emerging markets. Portfolios are subject to: (i) currency exchange rate risk; (ii) the possible imposition of withholding, income, capital gains or excise taxes; (iii) the absence of uniform accounting, auditing and financial reporting standards, practices and disclosure requirements and little or potentially biased government supervision and regulation; (iv) financial, economic and political risks, including expropriation, currency exchange control and potential restrictions on foreign investment and repatriation of capital; and (v) global market turmoil. Holders of equity securities are subject to risks, including potential periods of illiquidity, price volatility, the volatility of exchanges due to smaller market capitalisation, evolving clearance and settlement procedures, potential restrictions on foreign investment, security transfer and the repatriation of investment income and capital. Currencies may experience significant declines because of market pressures or government devaluation. Trading may be subject to governmental or significant administrative restrictions or only tradable with certain approved counterparties. Delays may occur in the execution of foreign exchange transactions if, for example, the underlying security transaction is not matched, underlying market or matching procedures are not completed or if settlement has not taken place before relevant cut-off times established by the Custodial Trustee, a sub custodian, counterparty or market participant. This could lead to additional foreign exchange exposure and losses.

Forward Contracts on Foreign Currencies. Forward contracts are not traded on exchanges; rather, a bank or dealer will act as agent or as principal to make or take future delivery of a specified lot of a particular currency. Forward currency transactions may involve less protection against defaults than trading on exchanges and there are generally no limitations on price movements making such transactions subject to the risk of a principal’s failure or inability or refusal to perform with respect to such contracts. The bankruptcy or insolvency of a principal or the failure, inability or refusal of such principal to perform, would likely result in a default, depriving an account of unrealised profits or forcing Silchester to cover commitments for resale at the then market price.

Options. Silchester can invest in options as part of a corporate action or similar transaction. Options can provide a greater potential for profit or loss than an equivalent investment in the underlying asset.

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The value of an option may decline because of a decline in the value of the underlying asset relative to the strike price, the passage of time, changes in the market’s perception as to the future price behavior of the underlying asset, or any combination thereof. In the case of the purchase of an option, the risk of loss of an investor’s entire investment in the option (i.e., the premium paid plus transaction charges) reflects the nature of an option as a wasting asset that may become worthless when the option expires.

Warrants. Silchester can invest in equity warrants as part of a corporate action or similar transaction. Equity warrants are securities that give the holder the right, but not the obligation, to subscribe for newly created equity issues of the issuing company or a related company at a fixed price either on a certain date or during a set period. Changes in the value of a warrant do not necessarily correspond to changes in the value of its underlying security. The price of a warrant may be more volatile than the price of its underlying security, and a warrant may offer greater potential for capital appreciation and capital loss. Warrants do not entitle a holder to dividends or voting rights with respect to the underlying security and do not represent any rights in the assets of the issuing company. A warrant ceases to have value if it is not exercised prior to its expiration date. These factors can make warrants more speculative than other types of investments.

Convertible Securities. Silchester can invest in convertible preferred stock, which may be converted at either a stated price or at a stated rate into underlying shares of common stock. Because of this feature, convertible securities enable an investor to benefit from increases in the market price of the underlying common stock. Convertible securities may provide yields higher than the underlying equity securities, but generally offer yields lower than non-convertible securities of similar quality. The value of convertible securities fluctuates in relation to changes in interest rates like bonds, and, in addition, fluctuates in relation to the underlying common stock.

Price Fluctuations. Prices of equity securities and other instruments are highly volatile and may respond to several factors that affect markets, particular companies or other issuers. For example, prices are affected by a wide variety of complex and difficult-to-predict factors, including, but not limited to, supply of money, inflation, weather and climatic conditions, changing supply and demand relationships, governmental activities and regulations, political and economic events and prevailing psychological characteristics of the marketplace. These same factors also can affect the securities markets adversely. Prices of equity securities also may be affected by individual company earnings, product developments and other factors.

Position Limits. Market regulatory authorities may establish limits as to the maximum number of shares that Silchester and its various associated entities may hold or control in particular securities of a company without requiring the investment adviser to make an offer to purchase all the outstanding shares of the company or obtaining a regulatory waiver to hold a larger position. All accounts controlled by Silchester and its associated entities may be combined for these purposes. It is possible that trading decisions taken by Silchester and its associated entities may have to be modified such that a further position in a company is not acquired or that positions held would have to be liquidated to avoid exceeding such limits or that such limits may be exceeded. This may influence overall returns.

Illiquidity. Silchester can purchase investment instruments that later become illiquid or otherwise restricted. Silchester might only be able to liquidate these positions at disadvantageous prices. For example, substantial redemptions could require Silchester to liquidate positions more rapidly than otherwise desired in order to obtain the cash necessary to fund the redemptions. Illiquidity in certain markets could make it difficult for Silchester to liquidate positions on favorable terms, resulting in losses or a decrease in a Fund’s net asset value. Although many securities that Silchester may acquire may be traded on public exchanges, each exchange typically has the right to suspend or limit trading in

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the securities which it lists. Such a suspension could render it difficult or impossible to liquidate any or all of its positions and would expose it to losses. This may lock in adverse price movements for several days or more which may cause immediate and substantial losses.

Transactions on Non-U.S. Exchanges. Silchester engages in trading on markets outside the United States. Transactions on non-U.S. exchanges are not regulated by U.S. governmental agencies. Some non-U.S. exchanges may be “principal markets” in which responsibility for performance is only that of the principal with whom a trader has entered into a transaction and not of an exchange or clearing corporation. In some cases, a broker with whom Silchester enters into a transaction may in effect take the opposite side of Silchester’s trades. Because some non-U.S. exchanges lack a clearinghouse system, market disruptions may be more likely to occur and, in extreme circumstances such as the failure of a broker or other counterparty, the settlement of security trades may be delayed or cancelled. To minimise the risk of broker or counterparty default and subsequent loss, Silchester will ordinarily arrange for security purchases and sales to be settled on a “delivery versus payment” basis.

Cash Balances. When eligible, U.S. Dollar cash balances are typically invested in the Government Select Portfolio, a money market fund sponsored by Northern Trust. Silchester may direct Northern Trust to hold U.S. Dollar cash balances in other money market funds, deposit accounts or other vehicles in its sole discretion. The Government Select Portfolio primarily invests in securities issued by the U.S. Government, government agencies and government sponsored enterprises. Clients could incur losses if the net asset value of the Government Select Portfolio was to fall below US$1.00 or if redemptions from the Government Select Portfolio or such other money market funds, deposit accounts or other vehicles were restricted by the Custodial Trustee. Non-U.S. Dollar cash balances are held in deposit accounts established by Northern Trust with various financial institutions. These deposit accounts are subject to counterparty and credit risk.

Credit Risk. Clients are subject to the risk that the brokers and counterparties with which, and the exchanges on which, Silchester executes transactions or carries positions may default. The default by an exchange, clearing house or counterparty with or through which Silchester trades could result in material losses. Certain markets require all securities to be held in a central securities depository and, in certain cases, the depository may be owned by a foreign government or government body and not be supported by a national network of well capitalized financial institutions. The default of such government or depository, or the failure of a depository to maintain suitable and sufficient procedures to mitigate against theft or loss, could result in material losses.

Investment Approach. There is no guarantee that Silchester’s investment approach or trading strategies will succeed or be profitable. All investments risk the loss of capital. There can be no assurance that the specific trading strategies utilized by Silchester will produce profitable results. Because the value of a Unitholder’s investment will fluctuate, there is the risk that a Unitholder will lose money. Unitholders should carefully review the risks of investing and be prepared to bear those risks, including the possible loss of the principal amount invested.

Depository Receipts. Silchester may invest in Depository Receipts. Depository Receipts generally evidence an ownership interest in a corresponding foreign security on deposit with a financial institution. Transactions in Depository Receipts rarely settle in the same currency in which the underlying securities are denominated or traded. Generally, American depositary receipts (“ADRs”), in registered form, are designed for the U.S. securities markets and European depositary receipts (“EDRs”), in bearer form, are designed for European securities markets. Global depositary receipts (“GDRs”) may be traded in any public or private securities markets and may represent securities held by institutions located anywhere in the world. Non-Voting Depository Receipts (“NVDRs”) are

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depositary receipts issued by the Thai NVDR Company Limited, a subsidiary wholly owned by The Stock Exchange of Thailand (“SET”). The main purpose of such receipts is not only to stimulate trading activities in the Thai stock market, but also to help eliminate foreign investment barriers, such as certain foreign investment limits. NVDR holders will normally receive all financial benefits, i.e. dividends, right issues or warrants, as if they had invested directly in a company’s ordinary shares. However, unlike ordinary shareholders, NVDR holders cannot be involved in company decision-making. Silchester may invest in Depository Receipts through “sponsored” or “unsponsored” facilities. A sponsored facility is established jointly by the issuer of the underlying security and a depository, whereas a depository may establish an unsponsored facility without participation by the issuer of the deposited security. Holders of unsponsored Depository Receipts generally bear all the costs of such facilities and the depository of an unsponsored facility frequently is under no obligation to distribute shareholder communications received from the issuer of the deposited security or to pass through voting rights to the holders of such receipts regarding the deposited securities. In addition, local practices (such as a requirement to be physically present to vote, a need for foreign language translation of voting materials or complex share registration procedures) may make exercising voting rights more difficult for holders of Depository Receipts.

Foreign Ownership Restriction Risk. Certain governments impose restrictions on foreign investment in companies incorporated in their jurisdiction to address concerns such as those relating to loss of national sovereignty. If Silchester purchases securities which later become subject to foreign ownership restrictions, there may be a delay in Silchester learning of such restriction. This may cause the compulsory sale or other disposition of the securities.

Sanctions Risk – Investment in Hong Kong and Chinese Companies. The U.S. Government has established a variety of sanctions regimes targeting Hong Kong and Chinese companies that the U.S. Government believes are assisting the Chinese military, involved with human rights abuses and/or involved with the repression of individual freedoms in Hong Kong. A list of companies deemed to be Communist Chinese Military Companies (“CCMCs”) is maintained by the U.S. Treasury and OFAC. These sanctions and the threat of additional sanctions on an expanded list of companies could have adverse consequences for the Chinese and Hong Kong economies. They may also trigger a significant decline in the value and liquidity of securities issued by the designated CCMCs and other companies affiliated with the Chinese government or the Chinese Communist Party. The sanctions could prohibit Silchester from initiating an investment in or maintaining investments in certain listed companies.

Investment in Initial Public Offerings, Secondary Offerings and New Issues. Silchester may purchase the securities of issuers during an initial public or secondary offering of securities and new issues. Companies involved in initial public or secondary offerings of securities typically have short operating and trading histories and generally are less established. The prices of securities issued as part of initial public or secondary offerings traditionally have been volatile. Silchester also may have to agree to certain transferability restrictions as a precondition for participating in these security offerings. Financial Industry Regulatory Authority (“FINRA”) rules generally prohibit securities firms from selling “new issues” (i.e., initial public offerings of equity securities) to investment funds if restricted persons hold beneficial interests in the investment fund over ten percent (10%) in the aggregate or if covered persons hold beneficial interests in the investment fund over twenty-five percent (25%) in the aggregate. Due to these FINRA rules, if the 10% and/or 25% thresholds are exceeded, an account cannot invest in new issues. Silchester may invest in securities of foreign issuers which are offered and sold in the U.S. as part of a new issue. The offering of securities that have a pre-existing market outside of the U.S. are excluded from the definition of a “new issue”. In addition, offerings made under Regulation S that are not concurrently registered for sale in the U.S. are excluded, as are rights offerings,

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exchange offers, or offerings made pursuant to a merger or acquisition. Unitholders in the Funds should notify Silchester in writing if they are a restricted or covered person under FINRA rules.

Transition Accounts. The securities, cash and other assets of a subscription or withdrawal transition account are maintained in a separate custody account with separate accounting records. While a subscription or withdrawal transition account is operating, the investor’s profits or losses shall be calculated based solely upon the investment experience of the subscription or withdrawal transition account and not the respective Fund as a whole. Depending on prevailing market conditions, using a subscription or withdrawal transition account may cause (i) the aggregate value of Units issued to the investor being greater or less than the purchase amount deposited by the investor into a subscription transition account; and/or (ii) the proceeds of the securities, cash and other assets liquidated in a withdrawal transition account being greater or less than the aggregate value of the Units withdrawn on the date of transfer to the withdrawal transition account.

Such disclosures may be triggered at widely disparate levels, take different formats, are calculated based on varying voting entitlements or aggregation requirements and have different filing deadlines. Many disclosures must be made in languages other than English. Many regulatory bodies impose minimum fines for late filings, or for immaterial/non-substantive errors relating to such filings, regardless of intent. Silchester will, occasionally, make an error when calculating whether a disclosure is required or fail to submit a disclosure on a timely basis. This may trigger fines or penalties which Silchester pays directly from its own financial resources.

SP Ltd is owned and controlled by current Silchester employees, members and their related parties and former SP Ltd employees and their related parties. In addition to its indirect interest in Silchester, SP Ltd has a substantial minority equity interest in eight investment management firms - Colchester Global Investors Limited (“Colchester”), Heronbridge Investment Management LLP (“Heronbridge”) through a participation in Heronbridge Limited, Highclere International Investors LLP (“Highclere”) through a participation in Highclere Investment Management Limited, Nippon Value Investors KK (“NVI”), Edgbaston Investment Partners LLP (“Edgbaston”) through a participation in Edgbaston Partners Limited, Kiltearn Partners LLP (“Kiltearn”) through a participation in Kiltearn Limited and Cape Ann Asset Management Limited (“Cape Ann”). Colchester,

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Sanderson, Highclere, Heronbridge, NVI, Edgbaston, Kiltearn and Cape Ann are collectively called the “Associates” in this ADV. Heronbridge, Highclere, Edgbaston, Kiltearn, and Cape Ann are registered with the SEC and the United Kingdom Financial Conduct Authority (“FCA”) as investment advisers that principally manage non-U.S. equities, UK equities, smaller capitalisation non-U.S. equities (sub US$10 billion), Asian equities ex-Japan, global equities, developing market equities and global equities respectively. Amongst other regulators, Colchester is registered with the SEC, the CFTC and the FCA as an investment adviser and principally manages global fixed income accounts. NVI is registered with the SEC and Japanese FSA as an investment adviser and principally manages Japanese equities. Silchester, SCL and SP Ltd do not control the business operations of the Associates or their investment strategies. SP Ltd helped capitalise each firm and assisted in setting up their initial operations. SP Ltd does not hold a controlling interest in the Associates. SP Ltd holds less than 50% of the shares in issue of the Associates. Associates generally have two classes of shares with different rights. SP Ltd is required to provide consent when material business decisions are made, such as the sale of business, liquidation of the business, significant expenditure or amendments to the Articles of Association. SP Ltd cannot control the day-to-day business or investment activity operations of any Associate firm. Further information is set out below and may be found in the ADV2 filings of the individual Associate firms. Silchester’s Organisation Chart

Colchester Global Investors Limited: In October 1999, SP Ltd acquired Class A Shares issued by Colchester, a United Kingdom based investment manager regulated by the FCA (FCA Firm Registered Number 191005), registered with the SEC (SEC File Number 801-57116). SP Ltd is a minority owner of Colchester and may receive dividends on a periodic basis from Colchester under Colchester’s articles. Colchester, with its wholly owned subsidiaries, acts as the investment manager and operations manager for several privately offered commodity pools. Lucy Crawford, a member of Silchester’s Marketing and Client Services Group, sits on Colchester’s Board of

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Directors in the capacity of Non-Executive Director, with limited influence on the day to day management of Colchester’s operations and business. Silchester and its related parties may invest assets in Colchester’s commingled funds and/or privately offered commodity pools. Heronbridge Investment Management: In November 2005, SP Ltd acquired Class A Shares issued by Heronbridge Limited, a United Kingdom limited company that holds a significant membership interest in Heronbridge. Heronbridge is a United Kingdom based investment manager regulated by the FCA (FCA Firm Registered Number 437507) and with the SEC (SEC File Number 123-45678). SP Ltd is a minority owner of Heronbridge Limited, and may receive dividends on a periodic basis from Heronbridge Limited under Heronbridge Limited’s articles. Lucy Crawford, a member of Silchester’s Marketing and Client Services Group, sits on Heronbridge Limited’s Board of Directors and is a member of Heronbridge’s Supervisory Group in the capacity of NonExecutive Member and Non-Executive Director, with limited influence in the day to day management of Heronbridge’s operations and business. Silchester and its related parties may invest assets in Heronbridge’s commingled funds. Nippon Value Investors KK: In February 2006, SP Ltd acquired Class A Shares issued by NVI, a Japanese kabushiki kaisha (limited company). NVI is an investment manager registered with the SEC (SEC File Number 801- 66876). NVI also holds a license to act as a discretionary investment manager from the Japanese Financial Services Agency (the “Japanese FSA”). SP Ltd is a minority owner of NVI and may receive dividends from NVI under NVI’s articles. Lucy Crawford, a member of Silchester’s Marketing and Client Services Group, sits on NVI’s Board of Directors in the capacity of Non-Executive Director, with limited influence in the day to day management of NVI’s operations and business. Silchester and its related parties may invest assets in NVI’s commingled funds. Highclere International Investors: In May 2006, SP Ltd acquired Class A Shares issued by Highclere Investment Management Limited (“HIM Ltd”), a United Kingdom limited company that holds a significant membership interest in Highclere. Highclere is a United Kingdom based investment manager regulated by the FCA (FCA Registered Number 533554) and registered with the SEC (SEC File Number 801-66718). SP Ltd is a minority owner of HIM Ltd and may receive dividends on a periodic basis from HIM Ltd under HIM Ltd’s articles. Tim Linehan, Silchester’s Chief Compliance Officer, sits on HIM Ltd’s Board of Directors and is a member of Highclere’s Executive Group in the capacity of Non-Executive Member and Non-Executive Director, with limited influence in the day to day management of Highclere’s operations and business. Silchester and its related parties may invest assets in Highclere’s commingled funds. Edgbaston Investment Partners: In April 2008, SP Ltd acquired Class A shares issued by Edgbaston Partners Limited (“EIP Ltd”), a United Kingdom limited company that holds a significant membership interest in Edgbaston. Edgbaston is a United Kingdom based Asian (ex-Japan) equity investment manager regulated by the FCA (FCA Registered Number 720002) and registered with the SEC (SEC File Number 801-71392). SP Ltd is a minority owner of EIP Ltd and may receive dividends on a periodic basis from EIP Ltd under EIP Ltd’s articles and memorandum of association. Ray Cheung, Silchester’s Head of Investment Administration Group, sits on the Board of EIP Ltd in the capacity of Non-Executive Director and is a member of Edgbaston’s Supervisory Group in the capacity of Non-Executive Member, with limited influence in the day to day management of Edgbaston’s operations and business. Silchester and its related parties may invest assets in Edgbaston’s commingled funds.

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Kiltearn Partners: In October 2011, SP Ltd acquired Class A shares issued by Kiltearn Limited (“KP Ltd”), a United Kingdom limited company that holds a significant membership interest in Kiltearn. Kiltearn is a United Kingdom based global investment manager regulated by the FCA (FCA Registered Number 540470) and registered with the SEC (SEC File Number 801-72673). SP Ltd is a minority owner of KP Ltd and may receive dividends on a periodic basis from KP Ltd under KP Ltd’s articles and memorandum of association. Ray Cheung, Silchester’s Head of Investment Administration Group, sits on the Board of KP Ltd in the capacity of Non-Executive Director and on the Supervisory Group of Kiltearn in the capacity of Non-Executive Member, with limited influence in the day to day management of Kiltearn’s operations and business. Silchester and its related parties may invest assets in Kiltearn’s commingled funds. Cape Ann Asset Management Limited: In February 2016, SP Ltd acquired Class A shares in Cape Ann Asset Management Limited (“Cape Ann”), a United Kingdom based global developing markets equity investment manager regulated by the FCA (FCA Firm Registered Number 735908) and registered with the SEC (SEC File Number 801-107996). SP Ltd is a minority owner of Cape Ann and may receive dividends on a periodic basis from Cape Ann under Cape Ann’s articles and memorandum of association. Tim Linehan, Silchester’s Chief Compliance Officer, sits on the Board of Cape Ann in the capacity of Non-Executive Director, having done so since inception with limited influence in the day to day management of Cape Ann’s operations and business. Silchester and its related parties may invest assets in Cape Ann’s commingled funds. Partnership Representative Silchester acts as the “partnership representative” for the Funds that are taxed as partnerships for U.S. income tax purposes. Privacy Considerations The following represents the Privacy Policy for the Funds. This Privacy Policy applies to both current and former Unitholders of the Funds. Silchester is committed to maintaining the confidentiality, integrity and security of personal information provided by Unitholders. Personal information includes, amongst other things, individual names, personal contact details, addresses, details of tax residency and tax identification numbers, bank account details, date of birth, identification details (e.g. passport number) and financial information such as income and assets. Personal information may be obtained in several ways, such as during the application process for Units or ongoing communications between Silchester and Unitholders. All information obtained about Unitholders is treated as confidential unless the Unitholder has otherwise made the information public, such as its relationship with Silchester or investment in a Fund. Silchester has controls in place to physically and electronically safeguard such personal information and to dispose of or delete such data, when required. Select physical, administrative and technical safeguards have been established to guard Unitholder information as documented in Silchester’s Information Security Policy. Silchester uses data obtained from Unitholders for the purpose of communicating information about its investment products. Silchester also provides information about Unitholders to firms that assist Silchester in servicing a Fund and its Unitholders, including the Northern Trust, SII Inc., the Fund’s auditors and Silchester’s tax advisors, legal firms and technology providers. This helps to ensure that all Unitholders are given an appropriate level of service. Silchester is required to establish, maintain and enforce policies

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and procedures reasonably designed to oversee and monitor service provider relationships, particularly those with access to personal information. Information about Unitholders may also be passed to regulatory authorities or law enforcement officials with jurisdiction over Silchester, or Northern Trust, as part of Silchester’s withholding and capital gains tax efforts or if reasonably required to prevent fraud and unauthorised transactions or as otherwise required by law or regulation. Silchester does not “sell” Unitholder personal information. On at least an annual basis, Silchester provides copies of its privacy policy to Unitholders. Unitholders may request a copy at any time by contacting Silchester’s Client Services representatives. Silchester’s Data Protection Policy which describes its approach to data protection more fully, including the rights of individuals under European and/or UK law regarding their personal data, is available on Silchester’s website (www.silchester.com).

To obtain a copy of Silchester’s Code of Ethics, please contact Silchester’s Chief Compliance Officer or Compliance Officer (see Item 1 for contact details). Participation or Interest in Client and Fund Transactions Silchester established each of its Funds and pays for the ongoing costs of operating these Funds, including custody, fund administration, legal, tax accounting, annual audit and reporting fees. Silchester derives fees from each Unitholder based upon the market value of each Unitholder’s Units in the Funds. Silchester believes that asset managers should maintain high levels of co-investment alongside clients. These investments provide significant stability to the firm and long-term alignment with our clients. Silchester, SCL, SP Ltd, SII, Inc., their employees, working members and directors, and their related parties, as well as their shareholders and related parties, are invested in the Funds. These parties currently control 25% of the units issued by The Calleva Trust – International Equity Portfolio (the “Calleva Trust”). As such, the Calleva Trust is considered a ‘principal’ account under Section 206(3) of the Investment Advisers Act of 1940. It is possible that other commingled funds or accounts for which Silchester is appointed as investment manager could be deemed ‘principal’ accounts from time to time. Silchester must provide Unitholders with certain disclosures and obtain certain approvals from independent third parties before the Silchester engages in any transactions involving ‘principal’ accounts, including cross transactions. Silchester has appointed Newport Trust Company, LLC (“Newport Trust Company”) to review, and approve, any cross transactions involving a ‘principal’ account(s). Silchester will pay Newport Trust Company’s fees and charges. A member of the Silchester’s Compliance Group will review and sign off on all cross-transactions that are deemed to be ‘principal’ account trading activity. Silchester

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will provide Unitholders with details of the Fund’s cross-trade activities that have been executed with a ‘principal’ account on a quarterly basis. Silchester, SCL, SP Ltd, SII, Inc., their employees, working members and directors, and their related parties, as well as their shareholders and related parties, are invested in the privately offered commingled funds established by the Associates. Employees and shareholders of the Associates may, in certain circumstances, also invest in the Silchester Funds. Personal Account Trading Policies Silchester’s Code of Ethics does not allow staff to purchase any publicly traded equity securities for their own accounts. Subject to certain exemptions, Silchester staff may invest in shares issued by private companies, open-ended collective investment schemes such as U.S. mutual funds or index tracking ETFs, Silchester’s Funds and those of its associated firms. Certain allowances are made for restricted shares and/or options received from prior employers or shares received through an inheritance or gift. Silchester’s procedures prohibit Silchester from favouring accounts in which it, its associated entities, or its/their employees, members, principals, or directors have a direct or indirect financial interest over the accounts of Silchester’s Funds. Certain agents and other independent contractors (including individuals that provide research to Silchester) are subject to differing restricted trading procedures. Outside Business Interests Policies Employees and members may not have any external employment and are generally prohibited from holding any external directorships, sitting on credit committees or participating in joint ventures. This includes both public and private companies. All staff must confirm that they have no external employments or material external activities at least annually. Material Non-Public Information Silchester employees and members are prohibited from using or disclosing material, non-public information for their personal benefit or to benefit third parties, including clients. If an employee or member believes that they have received inside information, they must notify Silchester’s Chief Compliance Officer immediately. If the Chief Compliance Officer determines that Silchester is in possession of material non‐ public information, all trading in the given name is immediately suspended. If Silchester has inadvertently been provided with the market sensitive information (say as part of a meeting with company management) as opposed to engaging in a voluntary “wall crossing”, the Chief Compliance Officer will work with the company involved, external legal counsel and, if necessary, market regulators to normalise the situation so trading activity can continue. If the Chief Compliance Officer is not available, the relevant regulatory and compliance issues will be dealt with by another member of the Compliance Group. Determination of Type, Number and Timing of Transactions Other than as specified by a Fund’s investment guidelines or under a separate account investment management agreement, Silchester has sole authority to determine, without obtaining specific consent, the amount and specific securities to be bought and sold for each account.

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In selecting brokers, Silchester seeks the best combination of price and quality of execution services, after considering factors that may affect the transaction. Commission cost factors include the particular expertise of the broker regarding the size or type of transaction, the commission rates charged, the nature and character of the markets on which the transactions will be executed and the broker’s execution experience, integrity, creditworthiness, financial responsibility and operational efficiency. Silchester may determine to pay broker commissions or mark-ups over that which another broker might have charged for effecting the same transaction in recognition of the execution services provided by the broker. Commission rates generally are subject to periodic reappraisal. To facilitate subscriptions and redemptions and to minimise liquidity risks, Silchester may utilise program or block trades. Program and block trades involve directing a broker to trade a large number of securities at a specific point in the day (for example, at market open or close) or over the course of part or all of the trading day. The broker may also be asked to guarantee that a specific price can be obtained for the security purchases or sales (for example, the volume weighted average price of each security during the trading day, the opening price or the closing price). Additional charges or increased spreads may be payable to facilitate these program or block trades. Cross Trading Subject to the Employee Retirement Income Security Act (“ERISA”) or other applicable laws, Silchester may cause the Funds to enter cross-transactions with another commingled fund or separate account for which the Silchester also acts as a discretionary investment manager. Executing cross-transactions allows the Silchester to, amongst other things, reduce transaction costs, offset contributions and redemptions across its investment programme, reduce the quantum of anti-dilution levies, and minimize stock and cash level dispersion. Silchester complies with the ERISA Statutory Cross Trading Exemption when crosstransactions are executed with a plan asset vehicle, including the Silchester International Investors International Value Equity Group Trust. Similar procedures are followed when cross-transactions are executed exclusively between commingled funds and/or separate accounts that are not considered plan asset vehicles. Silchester will provide Unitholders with a copy of its cross-trading policies and procedures on request. Cross-transactions are normally executed where inflows into one commingled fund or account coincide with outflows from another commingled fund or account for which Silchester also acts as a discretionary investment manager. In the event that the Silchester causes the Fund to purchase securities from or sell securities to such other commingled fund or separate account, Silchester will use its best efforts to mitigate potential conflicts of interest by causing such transactions to ordinarily occur at the then prevailing market price of the applicable security and by considering the interests of both the Fund and such other commingled funds and separate accounts. A member of Silchester’s Compliance Group will review and sign off on all

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cross-transactions. Silchester will provide Unitholders with details of the Fund’s cross-trade activities on a quarterly basis. No Commission Recapture or Directed Brokerage Arrangements Silchester does not participate in commission recapture or directed brokerage arrangements and Unitholders may not direct Silchester to use or allocate commissions from any broker. Silchester does not share, directly or indirectly, in the revenues generated by brokerage transactions. Foreign Exchange Trading Silchester has executed an agreement with Northern Trust whereby spot foreign exchange transactions are normally executed (i) for certain highly liquid non-restricted currencies using a foreign exchange trading algorithm developed by Northern Trust against a trading panel consisting of some of the largest foreign exchange dealers, exchanges and liquidity providers in the world and will execute, subject to depth of liquidity, validity of quotes and anti-gaming constraints, foreign exchange trades on a “best bid, best offer” basis; (ii) for other non-restricted currencies for which the foreign exchange trading algorithm is not available through direct negotiations between Silchester and Northern Trust’s foreign exchange desk at market prevailing rates; and (iii) for restricted currencies, by Northern Trust or a sub custodian under standing instructions. Northern Trust, or sometimes a sub custodian, receives an agreed upon spread from the Fund in exchange for facilitating these transactions. Northern Trust is not included in the panel of foreign exchange counterparties and is not an eligible foreign exchange counterparty for the trades (except for certain residual order balances and di minimus transactions). Silchester pays Northern Trust a fee out of its own financial resources in exchange for Northern Trust developing, maintaining, monitoring and enhancing the foreign exchange algorithm, operating the foreign exchange panel, providing balance sheet support, bearing the counterparty risks of trading with panel participants and providing TCA reporting. No other spread, mark up, or additional charges are added to foreign exchange transactions. Soft Dollar Considerations Silchester does not pay “soft dollar” commissions and/or receive “soft-dollar” benefits or “inducements” from brokers. Goods or services that, if received without payment could be deemed “soft dollar” benefits or “inducements” (such as broker research and transaction cost analysis of executed trades) are paid for in full by Silchester out of its own financial resources. Allocation of Investment Opportunities Silchester endeavours to act in a manner it considers fair, reasonable and equitable in allocating investment opportunities. Other than as set forth in the Governing Documents, separate account investment management agreements and its Code of Ethics, Silchester is under no specific obligations or requirements about the allocation of time, effort or investment opportunities or any restrictions on the nature or timing of investments. Subject to ERISA and other applicable laws, to reduce transaction costs, rebalance portfolio(s) or for other reasons, Silchester may cause an account to enter cross transactions with other accounts, including principal accounts, for which Silchester also acts as a discretionary investment manager. This normally occurs where inflows into one account coincide with outflows from other accounts. If Silchester causes an account to purchase securities from or sell securities to other accounts, Silchester will use its best efforts to mitigate potential conflicts of interest by causing such transaction to ordinarily occur at the then prevailing market price of the security and by considering the interests of all accounts. In the specific case of the Group Trust, additional requirements apply.

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When Silchester determines that it would be appropriate for more than one account, including principal accounts, to participate in an investment opportunity, Silchester seeks to execute orders equitably. If Silchester has determined to invest simultaneously for more than one account, Silchester may place combined orders for all such accounts simultaneously and, if any order is not filled at the same price, Silchester will average the prices paid. If an order is to take place on behalf of more than one account and the order cannot be executed under prevailing market conditions, Silchester will allocate the trade on a pro rata basis subject to market minimum trading sizes and other regulatory restrictions.

Frequency of Regular Reports to Clients Unitholders receive a monthly valuation report showing selected information about their investments in a Fund, temporary holding account or transition account, directly from Northern Trust. Unitholders also receive audited financial statements for the respective Fund on an annual basis. On a monthly basis, Silchester provides a written review of the investment programme, together with certain analytical information including a description of portfolio holdings.

Unlike most privately offered collective investment funds which generally are organised as limited partnerships or limited liability companies, the US Funds (except for the Group Trust) generally are organised as Delaware Statutory Trusts. These funds call for a specific custodial trustee and Delaware

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trustee to be appointed. Northern Trust has been appointed as custodial trustee and an indirect wholly owned subsidiary of Northern Trust has been appointed as Delaware trustee. The Group Trust is an Illinois Group Trust established for investment by qualified state, governmental and corporate pension plans. The UCITS Funds are legally structured as Irish trusts . This type of vehicle to requires a specific custodial trustee. Northern Trust’s Irish subsidiary has been appointed custodial trustee and depository of the UCITS Funds pursuant to each fund’s Trust Deed. Northern Trust is solely responsible for the custody and safekeeping of each Fund’s assets, performs certain administrative functions for each Fund at the direction of Silchester under each Fund’s Governing Documents and provides certain recordkeeping and accounting services to the Funds, including the calculation of the net asset value of the Funds and its units on a monthly (or more frequent) basis and distributing valuation statements directly to the Unitholders. Silchester pays Northern Trust’s fees related to the services Northern Trust performs on behalf of the Funds and the Unitholders. Northern Trust acts as the principal counterparty to each Fund’s spot and forward currency contracts and provides certain foreign exchange trade services under various agreements with Silchester. Valuation of the Funds Northern Trust acts as the custodian and fund administrator for the Funds. As fund administrator, Northern Trust is responsible for independently valuing each Fund’s assets in accordance with US Generally Accepted Accounting Principles (“US GAAP”). Equity securities are valued using the closing price reported by their primary stock exchange and translated into USD using exchange rates provided by WM/Reuters. These are the same prices and exchange rates used by major market indices such as MSCI for valuing (among others) the MSCI EAFE Index and the MSCI EAFE ex Fossil Fuels Index. Forward currency contracts are valued using WM/Reuters exchange rates and adjusted to reflect the settlement period for the forward currency contract. Dividend and withholding tax accruals are valued at fair market value. The Net Asset Value of the Funds and the calculation of the Net Asset Value of each Unit of the Funds are determined in U.S. dollars by Northern Trust as of the end of each month (the Irish UCITS Funds are also valued at a mid-month point in accordance with UCITS rules) and on such other dates as Silchester determines necessary (each a “Valuation Date”). The net asset value of a Fund equals the aggregate value of the assets of the Fund, less its accrued liabilities (irrespective of whether such liabilities may in fact ever be paid) determined by Northern Trust in good faith in its sole discretion in accordance with each Fund’s valuation rules and such other procedures as Northern Trust may establish from time to time with Silchester’s consent. The Net Asset Value of a Fund is determined under the accrual method of accounting in accordance with U.S. GAAP. The net asset value of any Units held by a Unitholder as of a valuation date are equal to the Net Asset Value of the Fund as of a given date multiplied by the number of Units held by such Unitholder, divided by the total number of Units outstanding as of the Valuation Date. Securities listed or traded on any generally recognised securities exchange are valued at their closing price as is customarily ascertained by the respective primary exchange on which such security is traded and disseminated by quotation services such as WM/Reuters or Bloomberg or published in recognised newspapers such as The Wall Street Journal and the Financial Times. If no sale has been reported for that day or if the exchange or market herein designated for the valuation of any given asset was not open on that day, the last published sale price or the last recorded bid price, whichever is more recent, shall be used, unless in the opinion of Northern Trust the value thus obtained does not fairly indicate the actual market value, in which case Northern Trust may rely on the value obtained from a reputable broker, or investment banker as of the valuation date. Other valuation methods may also be used as provided under each Fund’s Governing Documents. Securities traded only in the over-the-counter market are valued at the mid-point between the closing representative bid and asked prices therefore as reported by such securities’ reporting

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system and for other over-the-counter securities at the mid-point between the last current bid and asked prices therefore determined in accordance with quotations obtained from a reputable broker or investment banker as of the valuation date. Notwithstanding the foregoing, Northern Trust may use any other method of valuation which is or which becomes generally accepted practice for valuation of assets of group trusts or similar collective investment vehicles or which is or becomes permitted by the Codification of Financial Reporting Policies promulgated by the SEC. To determine the value of a Fund’s securities, Northern Trust may rely upon reports printed in any newspaper of general circulation or in any other newspaper Northern Trust deems appropriate, or in any financial periodical or industry-recognised quotation service, or in the records of any securities exchange, as sufficient evidence of sale, bid and asked prices, and over-the-counter quotations. Other securities or assets which cannot be valued under the preceding provisions are valued based on data obtained from the best available sources, including employees of Northern Trust, brokers or dealers who deal in or are familiar with the type of investment involved or other qualified appraisers including Silchester, or by reference to the market value of similar investments for which a market value is readily ascertainable. Notwithstanding the foregoing, if the securities to be valued constitute a block that, in the judgment of Silchester, could not be liquidated in a reasonable time without depressing or inflating the market, or restrictions upon marketability exist with respect to such securities, Silchester may direct Northern Trust to assign securities a different value than that calculated above; provided that such block shall not be valued at a unit value above the quoted market price of such securities. The foregoing valuations also may be modified by Silchester, if and to the extent, Silchester determines that modifications are advisable to reflect other factors affecting the value of assets. Silchester has established an internal Pricing & Valuation Group to provide oversight of pricing and asset valuation for each Fund in order to ensure that the resulting valuations are fair and consistent (within agreed tolerances) with those of the independent valuations prepared by Northern Trust. The group consists of one member of the Compliance Group, one member of Investment Administration and one member of the Investment Group. The group’s remit is to: (i) review pricing sources ahead of each month end and document considerations taken into account with a particular focus on securities whose trading has been suspended other than as a result of a routine market holiday, where restrictions have been imposed on trading a particular currency (e.g., Malaysia in 1998) or where it is determined that a premium or discount should be applied to reflect certain market specific factors (e.g., certain Indian equities). The group will be alerted by the Dealing Group of any trading suspensions; (ii) determine if a pricing challenge is required once Northern Trust has provided its proposed valuations for review. If a pricing challenge is required, the group will prepare the pricing challenge document for review and signature by one of Silchester’s authorised signatories; and, (iii) sign off on the pricing process supporting each month end valuation. The sign off is included with each Fund’s month end valuation pack. Before permitting Silchester to modify a valuation, Northern Trust requires Silchester to follow an established pricing “challenge procedure”. Under this challenge procedure, Silchester must provide evidence in writing of the discrepancy and support for its market price and/or exchange rate. Northern Trust will consider the challenge over the next twenty-four hour period and compare the proposed price and/or exchange rate to other independent pricing sources and its own internal valuations. If Northern Trust determines that the proposed price and/or exchange rate is more appropriate than the original price or exchange rate, Northern Trust will change the market price/exchange rate used in the valuation of the Client’s net asset value. If the proposed price and/or exchange rate are not determined to be more appropriate than the original price or exchange rate and Silchester does not direct Northern Trust with respect to a given valuation, the original market price and/or exchange rate used in the valuation will stand unless Silchester formally directs Northern Trust to use a different price or exchange rate. Silchester will notify Unitholders in writing within ten (10) business days of any such overrides or directions. Here the

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term “in writing” shall include, but not be limited to, notifications via email and notices included in Silchester’s periodic newsletters. Net asset value determinations reflect the deduction of all accrued debts and liabilities of a Fund, as the case may be, including any contingencies for which reserves are determined to be required by Silchester, in its sole discretion. Unitholders should be aware that situations involving uncertainties as to the valuation of portfolio positions could have an adverse effect on the Fund’s net asset value if Northern Trust’s or Silchester’s judgements regarding valuations should prove incorrect. Northern Trust may request that Silchester certifies the value of any securities or other property held in a Fund. Any such certification shall be regarded as a direction with regard to such valuation and shall be conclusive with respect to the valuation of the assets involved. Northern Trust prepares Unitholder statements. As with Fund valuations, Silchester reviews the reports before their transmittal to Unitholders. Once approved, the reports are sent directly by Northern Trust to the Unitholder. Silchester does not have any opportunity to ‘alter’ or ‘adjust’ Unitholder valuations. Occasionally, Silchester receives notice of class actions from Northern Trust. Where Silchester believes that it is cost effective, Silchester will work with Northern Trust to pursue the claim. Silchester does not actively participate in class actions and would not normally expect to engage counsel to pursue class action claims.

When it bears legal responsibility for correcting the error, Silchester generally seeks to place an account in a substantially similar position as it would have been in had the error not occurred. In certain circumstances, Silchester may have to obtain the consent of its Clients, insurers, regulators (which may include, but are not limited to the FCA, the SEC, the Central Bank of Ireland and the U.S. Department of Labour) and/or independent fiduciaries acting on behalf of one or more Clients before resolving an error. Obtaining these consents or correcting the error may cause, among other items, delays in placing an account in a substantially similar position as it would have been in had the error not occurred, the payment of compensatory amounts (these payments may be paid over a period of years if Silchester has insufficient funds available for reimbursement) and/or the suspension of the calculation of a Fund’s net asset value.

underlying portfolio company to cope with competitive commercial pressures. It is Silchester’s policy, subject to the considerations described below, to use its best efforts to vote proxies arising on all shares. Standard issues typically arise at Annual General Meetings (“AGMs”) or Ordinary General Meetings (“OGMs”). Standard issues may include items of a routine nature such as the presentation of financial statements to shareholders, approval of routine executive compensation or incentive plans, approval of financial statements by shareholders, election of directors and approval of director’s fees, election of auditors and approval of audit fees and declaration of dividends. Material issues may arise at Extraordinary General Meetings (“EGMs”), Special General Meetings (“SGMs”), OGMs or AGMs. Material issues may include items that relate to corporate governance matters; changes in a company’s country of incorporation; mergers and other corporate restructurings; anti-takeover provisions such as staggered boards, poison pills, or supermajority provisions; changes to capital structures including increases and decreases of capital and preferred stock issuance; material stock option, management compensation, or incentive plan issues; and social and corporate responsibility considerations. Silchester also considers standard issues to be material issues when it knows there is a potential conflict of interest with management is present. These situations can arise where a portfolio company’s U.S. retirement plan assets are managed by Silchester, or when a portfolio company or one of its affiliated entities is also a brokerage or counterparty to Silchester’s security or foreign currency transactions, or where the person responsible for overseeing investments of a client is also a director or officer of a portfolio company that would materially benefit from any executive compensation or incentive scheme subject to shareholder vote. Silchester may not be aware of the roles performed for current and/or potential portfolio companies by Unitholders. Silchester asks to be notified in writing of any known affiliations with publicly traded companies that could fall within Silchester’s investment universe as part of the subscription process for its Funds. As part of this, Silchester asks to be notified in writing of any active involvement in the financial services industry or affiliated or employed by an investment bank, broker, custodian or asset management firm. Silchester subscribes to proxy voting research from Glass, Lewis & Co (“Glass Lewis”) and Institutional Shareholder Services (“ISS”), to assist in the assessment of resolutions and the identification of contentious issues. Although Silchester receives proxy voting information from both Glass Lewis and ISS, Silchester has no default position for voting and does not default to either counterparty’s proxy voting recommendations. Each issue being voted on is assessed individually. Northern Trust acts as custodian for the Funds, holding all Client securities, cash and other assets for the benefit of the Unitholders. Northern Trust has outsourced certain of its proxy processing responsibilities to Broadridge Financial Solutions (“Broadridge”), a leading provider of proxy voting services. Broadridge provides Silchester with meeting notification and ballot delivery services, agenda summaries, detailed agenda content including original source documents, translation services, power of attorney maintenance, recordkeeping and custom reports, and vote instruction processing services. Meeting notifications are provided according to an established service level agreement in place between Northern Trust and Broadridge and one in place between Northern Trust and Silchester. Silchester does not outsource any part of its proxy voting decision making process to Broadridge or Northern Trust. Following receipt of proxy voting materials from Broadridge, Silchester’s Investment Administration Group prepares a “Proxy Voting Summary Ballot” (the “Ballot”). The Ballot includes the meeting agenda, details of the number of shares held by each Client, the previous year’s votes (if applicable) and a deadline for the response. The Ballot will also include the Glass Lewis and ISS reports for additional information. Each Ballot must be approved by two authorised signatories, primarily members of the

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Stewardship Group, or other members of the Portfolio Implementation Group, who assess the potential impact the votes may have on the portfolio company and decide on how to vote the proxy in question. In certain circumstances, Silchester may be unable to vote a specific proxy including (but not limited to) when Northern Trust or Broadridge does not provide a voting service in a given market, because Northern Trust or Broadridge, in error, does not process a proxy or provide sufficient notice of a vote, or because an error is committed by any party involved in the proxy voting or registration process. Silchester may also refrain from voting if, for example, it is considering liquidating a position (as shares may be blocked when proxies are submitted), or when Silchester has sold out of the company prior to the vote deadline, or where the costs of voting a specific proxy outweigh the economic benefit that Silchester believes would be derived, or where a specific class of shares or equity instrument does not carry voting rights with respect to a given issue subject to shareholder vote, or where re-registration of the shares into a Fund’s (rather than Northern Trust’s nominee) name may (or may reasonably be expected to) violate local privacy laws or adversely affect the Fund’s economic interests. When voting proxies in certain markets, Silchester may be constrained by certain country or portfolio company specific issues. For example, some companies in the portfolio impose voting caps on the maximum number of proxy votes that any single outside shareholder may control. Others require all board issues to be resolved by a show of hands, rather than a poll. As all shares may be held by one nominee, these restrictions have the effect of substantially limiting the impact of any proxies cast. Some companies in the portfolio may restrict Silchester from voting proxies where disclosures of holdings or securities under Silchester’s control have not been made on a timely basis or in a format required under their articles of incorporation. Additional information on Silchester’s proxy voting and corporate governance policies can be found in the Stewardship Code Statement on Silchester’s website (www.silchester.com/press.html). Silchester will provide a quarterly summary of proxies voted, or not voted, and issues raised at meetings held by portfolio companies as required by the terms of its separate account investment management agreements and the Fund Governing Documents.

A summary of the education and the last ten years of the business background of various Silchester Members and other members of senior management are set out below. Additional information is available from Silchester’s Chief Compliance Officer, Compliance Officer and/or Silchester’s client services representatives, details of which are shown elsewhere in this Form ADV Part 2. Additional information is available on the SEC’s website at www.adviserinfo@sec.gov Business Supervisory Group Raymond K.Y. Cheung Hugh McCaffrey

Timothy J. Linehan Farias Parakh

International Value Equity Programme Jeffrey J. Arnold Jennifer L. Bourque John S. Burke Stephen C. Butt Raymond K.Y. Cheung Darrel C. Cotton Lucy A. Crawford Simon Fidler Jun Man Fong Akiko Kikuchi Bertrand Le Pan de Ligny

Timothy J. Linehan Alexander S. Markillie Amber E. Maxmin Hugh McCaffrey Delia Muresan Susan J. Page Farias Parakh Katharine R. Sage Daniel Slotte Hannah Sprigings

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International Value Equity Programme:

Jeffrey J. Arnold 1986

Education and degree:

University of Cape Town Accounting and Finance (Hons)

Silchester International Investors LLP; 2017 to present Member of Investment Administration Group Member of Silchester International Investors LLP Sygnia Asset Management; 2015 to 2016 Quant Analyst

Supervised by Silchester’s Business Supervisory Group. _____________________________________________________________________________________

Jennifer L. Bourque 1971

Education and degree:

(1) New York University Master of Business Administration (2) Carnegie Mellon University Bachelor of Arts

Silchester International Investors Inc.; 2007 to present U.S. Client Service Manager Member of Marketing and Client Services Group

Supervised by Silchester’s Business Supervisory Group.

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John S. Burke 1979

Education and degree:

St Anne’s, Oxford University BA (Oxon) Economics & Management

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 2009 to 2010 Investment Manager Head of Research Group Member of Silchester International Investors LLP

Supervised by Silchester’s Business Supervisory Group. _____________________________________________________________________________________

Stephen C. Butt 1951

Education and Degree:

Magdalen College, Oxford University Honors Degree in Philosophy, Politics, and Economics

Silchester International Investors LLP; 2010 to present Investment Manager Chair of Investment Supervisory Group Member of Silchester International Investors LLP Silchester Continuation Limited; 2016 to present Director, Chair Silchester Partners Limited; 1994 to present Director, Chair

Supervised by Silchester’s Business Supervisory Group. __________________________________________________________________________________

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Raymond K.Y. Cheung 1971

Education and Degree:

(1) Hull University Accountancy (2) Humberside University Business

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 1995 to 2010 Head of Investment Administration Group Member of Business Supervisory Group Member of Silchester International Investors LLP Edgbaston Investment Partners LLP; 2018 to present Non-Executive Member of Supervisory Group Edgbaston Partners Limited; 2018 to present Non-Executive Director Kiltearn Partners LLP; 2018 to present Non-Executive Member of Supervisory Group Kiltearn Limited; 2018 to present Non-Executive Director

Supervised by Silchester’s Business Supervisory Group. _____________________________________________________________________________________

Darrel C. Cotton 1972

Education and degree:

Massey University Bachelor of Business Studies (Accountancy)

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 2005 to 2010 Head of Finance, Tax and Audit Group Member of Silchester International Investors LLP Silchester International Investors, Inc.; 2017 to present Director

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Supervised by Silchester’s Business Supervisory Group.

Lucy A. Crawford 1971

Education and degree:

Humberside University BA (Hons) Business Studies

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 2001 to 2010 Investment Liaison Member of Marketing and Client Services Group Member of Silchester International Investors LLP Nippon Value Investors KK; 2018 to present Director Heronbridge Investment Management LLP; 2018 to present Non-Executive Member of Supervisory Group Heronbridge Limited; 2018 to present Non-Executive Director Colchester Global Investors Limited; 2020 to present Director

Supervised by Silchester’s Business Supervisory Group.

Simon M. Fidler 1986

Education and degree:

Loughborough University BA (Hons) Politics, International Relations and Economics

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Silchester International Investors LLP; 2011 to present Head of Dealing Group, Primary Equity Dealer Member of Silchester International Investors LLP

Supervised by Silchester’s Business Supervisory Group.

Jun Man Fong 1992

Education and degree:

University of Birmingham Chemical Engineering MEng

Silchester International Investors LLP; 2020 to present Member of Investment Administration Group Member of Silchester International Investors LLP FactSet Research Systems Inc.; 2016 to 2020 Analytics Specialist

Supervised by Silchester’s Business Supervisory Group.

Akiko Kikuchi 1968

Education and Degree:

(1) Anna Maria College Honors BBA in Finance (2) London Business School Master of Business Administration

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 1997 to 2010 Investment Manager

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Member of Investment Supervisory Group Member of Silchester International Investors LLP

Supervised by Silchester’s Business Supervisory Group.

Bertrand Le Pan de Ligny 1966

Education and Degree:

(1) Ecole Centrale Master of Business Administration (2) University of Paris, II Assas DESCS in Corporate Finance

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 1995 to 2010 Investment Manager Member of Investment Supervisory Group Member of Silchester International Investors LLP Silchester Partners Limited; October 2023 to present Director Silchester Continuation Limited; October 2023 to present Director

Supervised by Silchester’s Business Supervisory Group.

Timothy J. Linehan 1970

Education and Degree:

University of Notre Dame BA in Accounting

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Silchester International Investors LLP; 2010 to present Chair of Business Supervisory Group Chief Compliance Officer and Head of Operations Silchester Continuation Limited; 2016 to present Director Silchester Partners Limited; 2003 to present Chief Compliance Officer and Head of Operations; 2003 to 2010 Director; 2011 to present Silchester International Investors, Inc. Client Services Manager / Legal and Compliance; 1997 to 2003 Highclere International Investors LLP; 2011 to present Non-Executive Member of Supervisory Group Highclere Investment Management Limited; 2006 to present Non-Executive Director Cape Ann Asset Management Limited; 2015 to present Non-Executive Director

Supervised by Silchester’s Business Supervisory Group.

Alexander S. Markillie 1984

Education and degree:

Warwick University Mechanical Engineering

Silchester International Investors LLP; 2019 to present Investment Manager Member of Silchester International Investors LLP Universities Superannuation Scheme; 2008 to 2019 Portfolio Manager

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Supervised by Silchester’s Business Supervisory Group.

Amber E. Maxmin 1978

Education and degree:

Keble College, Oxford University MA (Oxon) in Philosophy, Politics & Economics

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 2008 to 2010 Investment Manager Member of Silchester International Investors LLP

Supervised by Silchester’s Business Supervisory Group.

Hugh I. McCaffrey 1981

Education and Degree:

Bath University Masters in Mechanical and Manufacturing Engineering

Silchester International Investors LLP; 2013 to present Member of the Business Supervisory Group Investment Manager Head of Stewardship Group Member of Silchester International Investors LLP

Supervised by Silchester’s Business Supervisory Group.

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Delia Muresan 1986

Education and Degree:

(1)

Babes‐Bolyai University of Cluj‐Napoca Bachelors Degree in Finance and Computer Science

(2)

Cass Business School, City University, London MSc in Finance & Investment

Silchester International Investors LLP; 2019 to present Investment Manager Member of Silchester International Investors LLP Seven Pillars Capital Management LLP; 2013 to 2019 Equity Analyst

Supervised by Silchester’s Business Supervisory Group.

Susan J. Page 1967

Education and Degree:

(1)

University of North London, Master of Business Administration

(2)

University of Manchester BSc (Hons) in Geography

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 2000 to 2010 Member of Investment Administration Group Member of Silchester International Investors LLP

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Supervised by Silchester’s Business Supervisory Group.

Farias Parakh 1974

Education and degree:

(1) Tulane University, New Orleans BA in Political Science (2) Columbia University, Business School MBA in Finance

Silchester International Investors Inc.; 1997 to present Director, Silchester International Investors, Inc. Head of Marketing and Client Services Group Silchester International Investors LLP; 2022 to present Member of Business Supervisory Group

Supervised by Silchester’s Business Supervisory Group

Katharine R. Sage 1977

Education and Degree:

University of Exeter BA (Hons) in Geography

Silchester International Investors LLP; 2010 to present Silchester Partners Limited; 2003 to 2010 Investment Manager Member of Investment Supervisory Group Member of Silchester International Investors LLP

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Supervised by Silchester’s Business Supervisory Group. _____________________________________________________________________________________

Daniel J. Slotte 1981

Education and Degree:

University of Glasgow BSC (Hons) Computing Science

Silchester International Investors LLP; 2023 to present Head of Technology & Data Manager Member of Silchester International Investors LLP Lanware Ltd; 2012 to 2023 Account Director

Supervised by Silchester’s Business Supervisory Group. _____________________________________________________________________________________

Hannah L. Sprigings 1986

Education and Degree:

King’s College London LLB (Hons) in Law

Silchester International Investors LLP; 2019 to present Compliance Officer Cover Equity Dealer Firm Secretary Member of Silchester International Investors LLP William Blair Investment Management; 2015 to 2019 Compliance Officer

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Supervised by Silchester’s Business Supervisory Group. _____________________________________________________________________________________

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