Abrdn Inc.: investment adviser

The Advisers may also use the resources of other subsidiaries of Aberdeen Group plc. The Advisers have entered into a Memorandum of Understanding (“MOU”) and have elected to appoint as access persons certain individuals who are employed by affiliated offshore unregistered advisers. These individuals render portfolio management, research and trading services to the Advisers' clients. abrdn Inc. has been registered with the SEC as an investment adviser since 1995 and has offices in: Philadelphia, PA; New York, NY; and Boston, MA. Advisory Services abrdn Inc. provides its clients with discretionary, non-discretionary, and advisory asset management and related services across a broad range of investment strategies and asset classes. Our business is predominantly the active management of financial assets, using first-hand research to make our investment decisions. Managed asset classes include equities, fixed income securities, as well as multimanager research, selection, and portfolio management for hedge funds strategies (“Hedge Funds” or “Alternative Investment Strategies”), real assets, real estate, and infrastructure (“Private Markets Funds”), commodity exchange-traded products (“Commodity ETFs”), and active ETFs (together with Commodity ETFs, “ETFs”). We may also serve as a manager of managers, in which circumstance we hire sub-advisers to provide day-today securities selection. We are responsible for selecting sub-advisers and determining the portion of a fund’s assets to be allocated to each sub-adviser. Additionally, we offer solutions that can blend our abilities across different asset classes to provide tailored investment outcomes to meet specific client needs. See Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) for additional information regarding our advisory services. Our investment expertise is delivered through both segregated and pooled products – allowing us to serve a range of clients from institutions to private investors. We offer investment advisory services with regard to investments in both domestic and global securities to a variety of clients, insurance products, and pooled funds, including investment companies registered under the Investment Company Act of 1940, as amended (“1940 Act”). We provide a variety of asset management capabilities, including: • managing or sub-advising various open-end mutual funds, ETFs, and closed-end investment companies registered under 1940 Act; • offering professional money management services for separately managed accounts, which include providing continuous advice to clients based on individual needs concerning the investment of funds and related activities including, but not limited to trading, and cash management; • providing investment services to international open-end and closed-end funds, collective investment trusts, and various private or institutional mandates sourced globally; • offering investment services to certain limited partnerships and similar private funds; • offering segregated and pooled vehicles focusing on European, or other global property mandates; • offering global and regional fund of funds products (hedge fund, real assets and property); • offering model investment portfolios that can be bought through sponsor firms; and • customizing solutions for clients, including but not limited to those seeking specific exposure or risk/return characteristics within their alternative investment allocations.

abrdn Inc. also creates seed or incubator accounts (“Incubator Accounts”) in order to develop performance track records in new investment strategies or products prior to offering them to outside investors. Tailoring Services to Client Needs We typically manage client accounts on a discretionary basis; however, we will manage client accounts on a non-discretionary or advisory basis subject to client instruction. We make investments for clients in accordance with mutually agreed upon written investment guidelines and provide continuous supervision of client portfolios. Investment services may be tailored for each client’s specific needs and objectives, and clients may impose reasonable restrictions on investing in certain securities or types of securities. We have established procedures and controls to help ensure compliance with each client’s specific investment guidelines and any client-imposed restrictions. Where we are the investment adviser to a pooled investment vehicle, investment objectives, guidelines and any investment restrictions are not typically tailored to the needs of individual investors in those vehicles, but rather are described in the prospectus or other relevant offering document for the vehicle. The advisory or subadvisory fee is subject to negotiation and is fully disclosed to clients. Upon request, clients may also receive investment advice on a more limited basis through advisory or consulting-like services, including advice on isolated areas of concern such as special projects or a specific topic. Clients wishing to engage abrdn Inc. for consulting services will be required to enter into a written agreement and may be subject to certain fees and conditions. We sometimes enter into “side letter” agreements with certain prospective or existing investors (including investors affiliated with abrdn Inc.) granting them, among other things, fee waivers or reductions, future capacity rights in a fund, interests or shares having different voting rights or restrictions, reduced minimum subscription amounts, additional rights to reports and other information and other more favorable terms than the terms that are described in the relevant offering memorandum. The funds that enter into these arrangements have no obligation to offer such differing or additional rights, terms or conditions to all interest holders, and Aberdeen Investments may or may not offer similar differing or additional rights, terms or conditions to other clients in customized discretionary accounts it manages or to advisory and non-discretionary accounts to which it provides investment advice. In rare instances where Aberdeen Investments is provided with enhanced portfolio disclosure from other managers (including potentially material non-public information concerning the portfolio holdings of an underlying fund pursuant to a confidentiality agreement with the underlying fund or its manager), Aberdeen Investments will not be able to share information concerning such holdings or information or the fact of the existence of such a confidentiality agreement with advisory clients unless specifically authorized to do so by the underlying fund or its manager. The relevant disclosures regarding markets, risks, strategy, benchmarks, fees, expenses and other investment details will be detailed in the offering memorandum of the vehicle. Model Delivery/SMA abrdn Inc. participates as an investment manager in Separately Managed Account programs (“SMAs”) sponsored by third-party firms (the “Sponsor”) or turnkey asset management programs (“TAMP”), including single and dual contract SMAs. The investor contracts with the Sponsor or Registered Investment Adviser (“RIA”) in a single contract SMA. In dual contract SMAs, the investor contracts with the Sponsor or RIA and abrdn Inc. as investment manager. SMAs are offered by non-affiliated Sponsor or TAMP entities and may involve strategies of other outside managers in addition to our own. In these arrangements, abrdn Inc. provides investment management services on an advisory or discretionary basis to that client in accordance with one or more model strategies selected by the client. The Sponsor would typically perform the trades for Sponsor clients in SMAs that invest in equity strategies, but the investment manager may do so based on investment strategy or in order to seek best execution, which may result in additional fees to clients. In fixed income strategies, abrdn Inc. performs the trading. The Sponsor or RIA typically has primary responsibility for client communications and service, but we are available to the client for consultation. Additionally, abrdn Inc. provides advisory investment advice whereby abrdn Inc. provides investment recommendations in the form of a model portfolio to a Sponsor or overlay manager which then utilizes all or part of the model in managing its clients’ accounts. Model delivery programs are often referred to as Unified

Managed Accounts (“UMAs”). In these arrangements, abrdn Inc. does not place trades or exercise trading discretion for the client accounts. In such programs, the Sponsor typically charges the client a comprehensive fee, inclusive of the advisory fee charged by abrdn Inc. together with the fee for all other services being provided by the Sponsor. The Sponsor generally executes client portfolio transactions on behalf of abrdn Inc. and provides custodial services for the client’s assets. Except for execution charges for certain transactions executed away from the Sponsor, clients pay a single, all-inclusive (“wrap” or “Wrap Program”) fee charged by the Sponsor based on the value of the client’s account assets for asset management, trade execution, custody, performance monitoring and reporting through the Sponsor. The wrap fee often, but not always, includes the advisory fees charged by abrdn Inc. and other participating managers through the program. The Sponsor typically assists the client in defining the client’s investment objectives based on information provided by the client, aids in the selection of one or more investment managers to manage the client’s account, and periodically contacts the client to ascertain whether there have been any changes in the client’s financial circumstances or objectives that warrant a change in the management of the client’s assets. In certain Wrap Programs, the Sponsor contracts with other investment advisers to perform these services. In a Wrap Program, the Sponsor pays the investment advisers, such as abrdn Inc., a fee based on the assets of clients invested in the applicable strategy in the Wrap Program. In certain cases, abrdn Inc. may instead be paid fees based on the size of the total Wrap Program assets under management. abrdn Inc. may retain a portion of the Wrap Program fee when it participates as manager in Wrap Program arrangements. Wrap fee accounts and other client accounts following a strategy with the same name managed by the same portfolio management team may be managed differently. For example, the Sponsor or client may impose investment restrictions or administrative requirements upon us in managing accounts that could cause those accounts to be managed differently from other client accounts in the same strategy managed by the same portfolio management team that were not subject to those restrictions or requirements. For example, if a Wrap Program sponsor or client imposes investment restrictions on an account which prohibits investment in a security that is held in the selected strategy, the security may not be replaced with a directly comparable security and the client’s account may be overweight other positions or hold a larger cash position than other clients in that strategy. Not all strategies managed by abrdn Inc. are available in such programs. A portfolio constructed for a model delivery or SMA account may differ from how the same strategy is constructed for our other accounts. For example, we may use an affiliated registered investment company to purchase locally traded securities, where ADRs are not available (known as a “Completion Fund”). ADRs are generally used in model delivery/SMA programs as local lines of a security generally cannot be traded in those programs. Please also see the “Fees and Compensation” and “Brokerage Practices” items of this Brochure for more information on differences between wrap program arrangements and other types of client accounts. Assets under Management As of December 31, 2025, abrdn Inc. had approximately $41,473,439,300 in assets under management (“AUM”) on a discretionary basis, and approximately $3,615,300 in assets under management on a nondiscretionary basis, and total assets under management of approximately $41,477,054,600.

Generally, fees are paid monthly or quarterly in arrears based on account balances at the close of each month, quarter, or the average of the month-ends within a quarter, or in advance based on assets outstanding at the end of prior month or quarter, pursuant to the prospectus, investment management agreement, or other relevant offering document for the vehicle. We will either invoice clients for these fees, or in certain situations deduct these fees from the client’s custody account. In some instances, fee schedules are negotiable and can vary depending on a variety of factors such as the client, size of the account, and the investment strategy selected. abrdn Inc. may also charge fees for certain services at a fixed or hourly rate. These fees are negotiable and depend upon the needs of the client, complexity of the situation, and experience of the personnel providing services under these arrangements. Some clients may from time to time seek to negotiate most favored nation (“MFN”) clauses in their investment management agreements with Aberdeen Investments. These clauses may require us to notify the MFN client if we subsequently enter into an investment management agreement with another client that offers more favorable pricing or other contractual terms than those currently offered to the MFN client. The applicability of an MFN clause will depend on the degree of similarity between clients, including the type of client, the scope of investment discretion, reporting and other servicing requirements, the amount of assets under management, the fee structure and the particular investment strategy (and therefore the relevant investment adviser) selected by each client. We have sole discretion over whether or not to grant any MFN clause in all circumstances. All advisory arrangements may be terminated by either party upon prior written notice, according to the termination provisions outlined in the investment management agreement. If a contract is terminated, all advisory fees are subject to a pro-rata adjustment based upon the date of termination. Upon termination of the agreement, any prepaid, unearned fee will be promptly refunded, and any earned, unpaid fees will be due and payable. For our standard segregated and/or commingled account fee schedules for U.S. clients and investors, please refer to Appendix A of this brochure. Registered Fund Fees With respect to U.S. SEC registered open-end and closed-end funds advised or sub-advised by abrdn Inc., each fund’s prospectus sets forth the applicable fees and expenses. For the Commodity ETFs, abrdn Inc. appointed an external manager that serves as the sub-adviser and is responsible for the day-to-day investment management, including the day-to-day trading, rebalancing and cash management on behalf of each Commodity ETF. In this instance, abrdn Inc.’s advisory role is to oversee the external manager and the management of the portfolios they manage. abrdn Inc. pays the sub-adviser fee from its advisory fee in accordance with the investment sub-advisory agreement between abrdn Inc. and the external manager. Each fund’s prospectus sets forth the applicable fees and expenses. On an annual basis, the Board of Directors/Trustees (the “Board”) of each registered investment company registered under the 1940 Act (“Registered Fund”), including the independent Board members, considers renewal of the Registered Fund’s investment management services agreement, including the advisory or subadvisory fee paid by the Registered Fund to the Registered Fund’s adviser or sub-adviser. These fees are typically higher than the representative fee schedules shown in Appendix A.

Sub-advised Mutual Funds and Other Pooled Vehicle Fees We serve in a sub-advisory capacity for U.S. and offshore investment companies, both registered and unregistered, that are managed by third parties. Fees for such services are negotiated with the manager and may be set forth in the fund’s registration statement or other similar offering document. Aberdeen Investments may have the opportunity to participate in co-investments alongside a manager that we have invested with through one of our portfolios. This occurs mostly via Aberdeen Investments’s investment in private markets. The manager may choose to waive the management fee for the co-investment if Aberdeen Investments is invested in the manager’s main fund. In these instances, some portfolios may benefit by receiving a fee waiver on the co-investment because another Aberdeen Investments portfolio is invested within the main fund. This could lead to a perceived conflict of interest where one portfolio makes an investment to benefit others. This potential conflict is mitigated by the investment due diligence and approval process. Collective Investment Trust Fees We serve as investment adviser to Collective Investment Trusts (“CITs”) and receive a management fee from the trustee for such services. The trustee fee rates paid by investors in these CITs may be equal to, exceed, or be lower than fees for other similarly managed products. Additionally, the trustee may separately negotiate “side letters” with certain investors without applying terms negotiated with such investors, including terms relating to fees, to all investors in the CIT in accordance with applicable law. Model Delivery and Wrap Programs abrdn Inc. may participate in arrangements where it provides a model portfolio to clients of Sponsors or RIAs but does not exercise investment discretion or trade in the client’s account, including, but not limited to, UMAs. abrdn Inc.’s actual fees, minimum fees, and minimum account sizes may be negotiable, and in arrangements where it provides a model portfolio, may be lower than those for providing investment advisory services where it has full discretion, depending on the circumstances. Payment of a bundled asset-based wrap fee may or may not produce accounting, bookkeeping, or income tax results better than those resulting from the separate payment of securities commissions and other execution costs on a trade-by-trade basis and advisory fees. With respect to SMA programs for which abrdn Inc. is not the Sponsor, the client pays an asset-based fee to the Sponsor Firm or RIA, and the Sponsor firm or RIA is responsible for paying the investment advisory fee to abrdn Inc. abrdn Inc.’s fees from the Sponsor firm are negotiable and differ from program to program. Program fees paid by clients cover trading charges only when transactions are executed through the Sponsor or its affiliates. To the extent that trades are “stepped-out” to broker-dealers other than the Sponsor (or executed away from the Sponsor), additional fees may be incurred by the client (e.g., commissions on transactions executed by a broker-dealer other than the Sponsor or program’s designated broker-dealer(s), dealer mark-ups, mark-downs and expenses with respect to investments in pooled vehicles). The Sponsor’s Program Brochure generally contains information on minimum account sizes and fees payable to the Sponsor and participating investment managers. abrdn Inc.’s fees for managing SMA program accounts may be lower than those for providing investment advisory services outside the SMA program. Clients should contact their program Sponsor or RIA for more information on the fees payable to abrdn Inc. in connection with such program. Alternative Investment Strategies (Hedge Funds) Investors and prospective investors should review the confidential private placement memorandum, limited partnership agreement and other governing documents (collectively, the “Governing Documents”) of each Hedge Fund in conjunction with this brochure for complete information on the fees and compensation payable with respect to that particular Hedge Fund. Different Hedge Funds and advisory accounts may be subject to different management fees and performance-based compensation arrangements. In certain circumstances, the advisory fees payable to abrdn Inc. by individual investors are negotiable and are waived for certain investors. abrdn Inc. is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Hedge Funds. Payments of advisory fees are made in accordance with the terms set forth in the

Governing Documents. Please refer to the Governing Documents of each of the Hedge Funds for complete information on the timing of advisory fee payments. Management fees are generally paid quarterly in arrears, are tiered in some cases based upon the net assets under management for the Hedge Fund or account, are subject to breakpoint discounts in some cases based upon capital under management by abrdn Inc., and are generally up to 2.00% annually, as described in the relevant Governing Documents. The formulas for calculation of performance-based compensation arrangements vary by Hedge Fund but are generally up to 20% of investment performance, subject to a hurdle rate and/or loss carry forward in some cases, as described in the relevant Governing Documents. Unless otherwise noted in the Governing Document, performance-based compensation is generally assessed and payable at the end of each calendar quarter. Such management and performance-based compensation is calculated after application of underlying manager fees and expenses. As described below, abrdn Inc. provides services to Hedge Funds that invest in other investment vehicles (“underlying funds”) whose managers (“underlying managers”) typically charge: (i) an asset-based fee (that generally is in the range of 1% to 2% annually) and (ii) a profits-based fee (that generally is approximately 20%), and in some cases higher rates, and which fee rates vary for each such underlying fund. Additionally, the fees of abrdn Inc. do not include the expenses of any service providers hired by the Hedge Funds and/or any operating and overhead expense reimbursements paid to abrdn Inc. and do not include expenses indirectly borne through investments in underlying funds or customized portfolios (e.g., redemption fees may be charged by certain hedge funds). Each Hedge Fund sets forth any such additional operational expenses in the relevant Governing Documents. abrdn Inc. may negotiate fee rebates with the underlying funds in which it invests through its fund of funds products. These fee rebates will be disclosed in the relevant fund documents. Once these fee rebates are received by abrdn Inc. up to the defined amount, the rebate will then be shared with the abrdn Inc. fund once the specified threshold has been met. Factors abrdn Inc. may consider in negotiating fees or other terms to which any investor may be subject may include, without limitation, the nature of the services required, the extent of reporting or other administrative services required, the type of assets invested, the amount of assets invested, abrdn Inc.’s prior relationship with the applicable investor or its affiliates, other investments with abrdn Inc. by the applicable investor or its affiliates, the other terms to which the investor’s investment with abrdn Inc. would be subject and the impact such special terms might have on other investors. Private Markets Funds Investors and prospective investors should review the Governing Documents of each Private Markets Fund in conjunction with this brochure for complete information on the fees and compensation payable with respect to that particular Private Markets Fund. Different Private Markets Funds may be subject to different management fees and performance-based compensation arrangements. In certain circumstances, the advisory fees payable to abrdn Inc. by individual investors are negotiable and waived for certain investors. Investors and prospective investors in each Private Markets Fund should note that similar advisory services may (or may not) be available from other investment advisers for similar or lower fees. Fees charged by abrdn Inc. vary from client to client depending on the type, size, and complexity of the client account. In general, such fees may include a management fee (which is generally calculated as a percentage of the notional value of the separate account portfolio or client commitment) and/or a performance-based compensation arrangement. abrdn Inc. is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Private Markets Funds. Payments of advisory fees are generally made quarterly in advance and in accordance with the terms set forth in the Governing Documents. Please refer to the Governing Documents of each of the Private Markets Funds for complete information on the timing of advisory fee payments. abrdn Inc. will typically charge and deduct advisory fees directly from its separate account or investment advisory clients pursuant to the contracts entered into with such clients. Payments of advisory fees will generally be made quarterly in advance and in accordance with the terms of such contracts. Upon termination of any client advisory relationship with abrdn Inc. any prepaid, unearned advisory fees will be promptly refunded to the client, and any earned, unpaid fees will be due and payable.

In addition to the advisory fees and performance-based compensation payable to abrdn Inc., each client invested in certain Private Markets Funds will generally incur certain charges imposed by abrdn Inc. and/or third parties, including (but not limited to): legal, auditing, consulting, financing, accounting (including, without limitation, accounting software), independent appraisal, valuation, administration and custodian fees and expenses; expenses associated with preparing, printing and distributing communications and reports to investors and monitoring Private Markets Funds’ portfolio activity, including the Private Markets Funds’ financial statements, tax returns and K-1s (including, third party expenses in connection with tax preparation, financial statements and other accounting or similar administrative functions); costs of developing, licensing, implementing, maintaining or upgrading any web portal, extranet tools, computer software or other administrative or reporting tools (including subscription-based services) for the benefit of the Private Markets Fund or investors; out-of-pocket expenses incurred in connection with transactions not consummated (including costs and expenses that might have been borne by a co-investment vehicle or other co-investors had the transaction been consummated, but which instead are allocated to the funds for which the investment was identified and not co-investors, even if co-investors were being sought or in some cases had agreed to participate had the transaction been consummated. Underlying managers incur these and/or other expenses in addition to their previously described management and performance fees); expenses of the Private Markets Fund’s advisory board (including, without limitation, its independent legal counsel and/or other consultants as permitted pursuant to the relevant Private Markets Fund’s Governing Documents) and annual or special meetings of the Private Markets Funds’ and/or their limited partners (including, without limitation, travel related expenses, setup, room and board, dining and entertainment and other related expenses in connection with attendance with the foregoing); premiums for insurance (including director and officer liability) obtained by a Private Markets Fund to protect such Private Markets Fund, its general partner, and/or any of their affiliates, directors, officers, employees or agents in connection with the activities of the Private Markets Fund; fees, costs and expenses incurred in connection with the Private Markets Funds’ legal and regulatory compliance with U.S. federal, state, local, non-U.S. or other law or regulation; compliance with Foreign Account Reporting Regimes, or in connection with complying with provisions of the Private Markets Funds’ Governing Documents or any side letter or similar agreements; interest on, and fees and expenses arising out of, all borrowings made by the Private Markets Funds and entities formed to facilitate investments, including, but not limited to, the costs and expenses incurred in arranging, negotiating, structuring, entering into and amending any credit facility with any lenders, investment banks and other financing sources; other expenses associated with the investigation, evaluation, acquisition, holding or disposition of investments, including extraordinary expenses (such as litigation or threatened litigation involving the client or the general partner of a Private Markets Fund and its affiliates or investigations undertaken by governmental entities, if any), costs of attending meetings of investors and/or with representatives thereof and travel-related expenses in connection with the foregoing; any other extraordinary expense of the Private Markets Funds, including fees and expenses associated with any pending or threatened litigation, audit, investigation, administrative or other proceedings, settlement or review of the business or activities of the Private Markets Funds and certain indemnification expenses or liabilities relating to the Private Markets Funds’ affairs; any taxes, tax fines incurred for late state filings resulting from failure to receive underlying tax forms, fees or other governmental charges levied against the client or the separate account vehicle; certain organizational expenses (as described below); bank service fees, investment banking fees, registration fees and expenses, title fees, commissions or brokerage fees, financing fees, finders’ fees or similar charges incurred in connection with the purchase and sale of securities; expenses incurred in connection with the managed distribution of marketable securities; public notice or communication costs; fees, expenses or costs for activities with respect to protecting the confidential or nonpublic nature of any information or data; costs incurred in connection with the default by an investor in the payment of any capital contributions; unreimbursed costs and expenses incurred in connection with any transfer or proposed transfer of interests in a Private Markets Fund; fees attributable to ancillary, operational, strategic or financial support provided to any actual or prospective portfolio investment of a Private Markets Fund; private placement or finders’ fees paid to placement agents, finder or other third-parties; taxes assessed against the client or the general partner of a Private Markets Fund in respect of advisory fees (e.g., any sales or value added tax on services, should such a tax become applicable); and costs of dissolving and liquidating a Private Markets Fund (or a separate account vehicle). The Private Markets Funds have engaged a third-party administrator. Administration costs will be borne by certain funds, separate accounts and SPVs as permitted in the Governing Documents.

Organizational expenses for which a Private Markets Fund may be responsible include any fees, costs, or expenses incurred by the Private Markets Fund’s general partner, Service Provider, or affiliate thereof, the Private Markets Fund and any parallel fund, or entity related to the Private Markets Fund or parallel fund, but only to the extent that such items are attributable to the organization of such Private Markets Fund, parallel fund, or any entity related to such Private Markets Fund or any parallel fund (including but not limited to the Private Markets Fund’s general partner), or the offer of and sale of interests in such Private Markets Fund or any parallel fund to the investors or prospective investors of such funds, including, without limitation, costs, or expense relating to reasonable travel, legal fees and expenses relating to organizational and Governing Documents, prospectuses, diligence responses, disclosure documents, legal opinions, side letters and similar agreements, consulting or other advice needed as a result of making funds available to investors outside of the United States, accounting fees and expenses, printing fees and expenses, and filing fees. In addition, each private investment fund in which a Private Markets Fund acquires an interest will generally pay advisory fees, performance-based compensation and/or other fees and expenses to an investment adviser and/or general partner that are not affiliated with abrdn Inc. Compensation and expenses paid to abrdn Inc., as the case may be, for investment advisory services are separate and distinct from the advisory fees, performance‐based compensation and expenses charged by the independent investment advisers or general partners of the private investment funds in which Private Markets Funds, separate account clients or investment advisory clients invest. Certain Private Markets Funds may offer to provide investors with liquidity at the tail-end of a Fund’s life by offering investors the opportunity to sell their interests to prospective secondary private market investors (“Prospective Buyers”). This process is referred to as a “tail-end sale”. The offer comes after abrdn Inc.’s consultation with the Fund’s advisory board and a bidding process for Prospective Buyers by abrdn Inc. Any sales price is expected to be at a discount to NAV of the Fund but will depend on a number of factors, including market demand. In general, as a condition to participating in a tail-end sale, abrdn Inc. and each Prospective Buyer agrees that, pursuant to terms that may amend or modify the Fund’s Governing Documents, Aberdeen Investments may charge and allocate, solely to the Prospective Buyers, a per annum management fee based on the fair market value of the Prospective Buyer’s acquired interests (the “Secondary Buyer Fee”). Any Secondary Buyer Fee will be borne solely by the Prospective Buyer and will not be borne by any investor choosing not to sell its interest. Proportionate expenses incurred by the Private Markets Fund and the general partner in the transaction may be borne by the selling investor. Investors are not required to sell their interests and may elect to continue to hold their interest in the Private Markets Fund without material change to their rights under the Governing Documents. The specific terms and conditions of any prospective tail-end sale will be disclosed in advance to all investors. This arrangement may create an incentive for abrdn Inc. to promote a tail-end sale to Prospective Buyers. However, abrdn Inc. makes no recommendations to clients on whether or not to participate in the tail-end sale. For investors seeking liquidity, we believe a tail-end sale is a useful mechanism by which such investor may receive liquidity in a timely and cost-efficient manner without the need to seek offers on the secondary market. For investors seeking to retain their economic exposure to the Private Markets Fund, the tail-end sale is optional, allowing them to decline to participate or to continue to potentially benefit from realizations of the underlying portfolio funds. Neither abrdn Inc. nor any of its affiliates receive any compensation as broker or agent for the sale of securities or other investment products to any Private Markets Fund. Customized Solutions Clients participating in solutions mandates may be recommended Aberdeen Investments-managed products and/or other advisory services. As a shareholder of an Aberdeen Investments product or client of Aberdeen Investments advisory services, a client may be subject to advisory fees (and other expenses) at the product level or for other Aberdeen Investments advisory services in addition to fees charged to the advised account. Advisory fees will be negotiated in good faith between the parties when client AUM is invested in Aberdeen Investments-managed products. This may include a waiver of the underlying fee, or a reduction thereto based on associated charges not related to investment management or a reduction of the advisory fee attributable to those assets invested in Aberdeen-managed products.

All fees paid to Aberdeen Investments for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A client may be able to invest in these products directly, without the services of Aberdeen Investments, but would not receive the services provided by Aberdeen Investments which are designed, among other things, to assist the client in determining which products or services are most appropriate for each client’s financial situation and objectives. Additionally, Aberdeen Investments may recommend utilizing one or more unaffiliated investment managers. Aberdeen Investments’ fees do not include the fees of independent managers who are selected to manage a portion of the securities, cash and/or other investments held from time to time in a client's account. In the event that an account is invested in one or more such pooled vehicles, the aggregate fees payable to Aberdeen Investments by a client will not exceed the advisory fee set forth in the client’s written investment advisory agreement. In addition, certain costs or charges associated with certain securities transactions, including custody, dealer mark-up or mark-downs and normal broker commissions are separately charged to the account. Other Fees and Expenses abrdn Inc. may have different fee schedules for products and services offered in other jurisdictions outside of the U.S. We examine fee ranges and average fees using comparative universes. Terms are negotiated on a case-by-case basis. In addition to the advisory fees discussed above, clients may incur additional fees related to the services we provide. Clients may incur the fees and expenses charged by the custodian of client assets managed by us, as well as brokerage and other transaction costs associated with securities trades that we order on behalf of the assets in a client account. In addition to expenses otherwise disclosed in fund offering documents, Hedge Funds and other private funds managed by Aberdeen Investments and underlying managers also incur additional expenses that include, and/or may in the future include, expenses in connection with the organization of the funds; legal; accounting; auditing and other professional expenses; administrator fees and expenses; director fees and expenses; news, quotation and computer equipment expenses; investor reporting expenses; technical and telecommunications equipment expenses and services; investment expenses such as brokerage commissions, clearing and settlement charges, custodial fees, bank service fees and interest expenses; research expenses; third party consultant fees and expenses; expenses related to regulatory compliance or filings related to the funds or their assets; interest on borrowings, direct fees and expenses, such as legal fees and due diligence expenses, related to analysis, purchase or sale of investments whether or not the investment is consummated. Additionally, costs and expenses that might have been borne by a co-investment vehicle or other co-investors had the transaction been consummated are generally allocated to the funds for which the investment was identified and not co-investors, even if co-investors were being sought or in some cases had agreed to participate had the transaction been consummated. Underlying managers incur these and/or other expenses in addition to their previously described management and performance fees. Aberdeen Investments occasionally invests client assets in other products that abrdn Inc. or an affiliate may also advise. As a result, abrdn Inc. and its affiliates may retain more fees than if abrdn Inc. had invested in unaffiliated funds or products. In some instances, management fees for the underlying affiliated fund will be waived in order to avoid conflicts of interest and to comply with applicable regulatory requirements. For an additional discussion of brokerage and other transaction costs, please refer to Item 12 - Brokerage Practices of this Brochure.

Furthermore, we may seed investment vehicles and make coinvestments along with clients invested in Private Markets Fund investments. The potential management of different types of accounts and accounts with different fee arrangements for the same strategy may give rise to potential conflicts of interest. Registered funds, for example, generally pay management fees based on a fixed percentage of assets under management, while separate accounts and private funds potentially may have more varied fee structures, including performance-based incentives. Where performance is good, performance-based fee clients may be charged fees higher than the industry standard. We may have a material incentive to favor certain, more lucrative accounts over those that may be less lucrative. Additionally, we may have a material incentive to favor accounts in which we, or our affiliates, have significant proprietary interest. For example, we have an incentive to allocate better-performing securities to those accounts subject to performance fees rather than to those which are not. These performance fees may also incentivize the portfolio manager to take riskier positions than would have otherwise been initiated. Additionally, the calculation of performance fees is based upon a number of factors both within and out of our control. To mitigate these conflicts, we have adopted policies and procedures to ensure that investment decisions are made in the best interests of our clients and without consideration of our financial interests. abrdn Inc. may provide concurrent advisory services to client accounts that are not charged a performancebased fee or allocation by abrdn Inc.’s related persons and client accounts that are charged a performancebased fee or allocation by a related person of abrdn Inc. abrdn Inc. or one of its affiliates may also provide concurrent advisory services to private funds, Hedge Funds, and/or separate account or investment advisory clients that are charged different performance-based fees or allocations and, in certain cases, abrdn Inc. may only be permitted to take a performance-based fee or allocation from a private fund, Hedge Fund, or separate account client or investment advisory client after the applicable investors or client received a preferred return on their committed or contributed capital. Aberdeen Investments’s policies generally prohibit portfolio managers from trading in conflict with themselves – specifically, across same strategy accounts that they manage. Generally, portfolio managers are prohibited from taking an “inconsistent position”, or from holding the same security long in some accounts and short in others, unless they are materially underweight in a long only account that must hold that security at some level for benchmark tracking purposes (as this would not appear to represent a conflict of interest). Portfolio managers may however make different investment decisions for the same security for different strategies they manage, as appropriate. In the event that a potential conflict of interest regarding portfolio managers’ trading is identified, the Department Head and the Risk & Compliance Department will discuss the conflict and take appropriate corrective action. Risk & Compliance will also review the procedures in such instances to ensure that they are appropriately crafted to identify similar future conflicts of interest. From time to time, Aberdeen Investments, its directors, officers, employees or affiliates (“affiliated persons”) may, directly or indirectly, have interests in securities owned by or recommended to our clients. In addition, abrdn Inc. manages a number of accounts which serve as seed accounts for potential investment strategies (“Incubator Accounts”). In certain circumstances, Incubator Accounts invest in the same securities as other client accounts which may create an incentive for us to put our interests ahead of clients. As these situations may represent a potential conflict of interest, we maintain trade allocation and account valuation policies and procedures designed to address such conflicts of interest. We have adopted a Code of Conduct in compliance with the requirements of Rule 17j-1 adopted under the 1940 Act and Sections 204A and 206 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), to govern personal transactions by directors, officers,

and advisory personnel of Aberdeen Investments (“Access Persons”). For further detail on Aberdeen Investments’s Code of Conduct, please refer to Item 11 of this Brochure. We also monitor for conflicts by implementing “best execution” trading procedures and reviewing account allocation and performance. abrdn Inc. or a related entity of abrdn Inc., as general partner of certain pooled investment vehicles or adviser to a separate account or investment advisory client, will typically receive certain allocations or fees calculated and charged based on a share of capital gains on or capital appreciation of the assets of the pooled investment vehicles, separate account client or investment advisory client. These performance-based allocation arrangements comply with regulatory requirements. Any share of profits paid to abrdn Inc., one of its affiliates, or the general partners of the pooled investment vehicles, is separate and distinct from the advisory fees charged by abrdn Inc. for advisory services. In addition to performance-based fees paid to the Adviser, the funds may cover operating and organizational expenses of the Adviser, as detailed in Item 5 above. Please refer to the Governing Documents of the applicable pooled investment vehicles (or the investment advisory agreement of the applicable separate account client) for complete information on the performance-based compensation arrangements entered into with respect to such client. To mitigate this potential conflict of interest, investment decisions are made by abrdn Inc. or an affiliate for pooled investment vehicles, separate accounts and investment advisory clients in accordance with investment allocation policies. With respect to investment opportunities that are appropriate for more than one client including a fund and/or a separate account or investment advisory client, Aberdeen Investments’s investment allocation policies takes into account multiple criteria, including but not limited to the investment objectives and strategies of each applicable client, differences with respect to the available capital, size, and remaining life of the applicable clients, differences in risk profile at the time the opportunity becomes available, potential conflicts of interest, the nature of the security or the transaction, and current and anticipated market conditions. In the event the investment opportunity is suitable for more than one client, abrdn Inc. will derive an allocation that, over a period of time, is fair and equitable to each applicable client relative to other clients, taking into account all relevant facts and circumstances.

We utilize a bottom-up, fundamental stock-picking approach, where sector, regional and country allocations are a residual of our bottom-up stock selection decisions, constrained by appropriate risk controls. Our scale affords coverage of a wide and dynamic universe with in-depth, locally sourced insights. We have experienced equity professionals across the world engaged in fundamental stock research and insight generation. Broad research coverage is organized on a sector basis. We also have fund managers that undertake specialized fund-specific research. We may also use quantitative screening tools and risk tools to help us identify interesting stock opportunities and the most appropriate coverage universe. Aberdeen Investments evaluates companies against quality criteria and builds conviction using a team-based approach and peer review process. The quality assessment covers five key factors: 1) the durability of the business model, 2) the attractiveness of the industry, 3) the strength of financials, 4) the capability of management, and 5) the most material environmental, social and governance (“ESG”) factors impacting a company. As ESG information is just one investment consideration, ESG considerations generally are not solely determinative in any investment decision made by the Adviser. Aberdeen Investments seeks to understand what is changing in companies, industries and markets but is not being priced into the market or is being mispriced. Through fundamental research, supported by a global research presence and proprietary tools, Aberdeen Investments seeks to identify companies whose quality is not yet fully recognized by the market. To leverage the benefits of our research resources, our equity teams use a common investment language and research framework that structures how we express our thinking on companies. Our investment ideas are subject to peer review, both at regular meetings and on an ad hoc basis. This facilitates the effective articulation of research insights. The generation of research insights combined with rigorous peer review allows our fund managers to effectively assess the investment potential of companies for any of our distinct client outcomes. Portfolios are built from the bottom up, prioritizing high conviction stock ideas in a risk aware framework. Portfolio risk budgets are derived from our clients’ investment objectives and required outcomes. As active equity investors we express our research views through a principled portfolio construction process which actively takes appropriate and intentional risk to drive return. We expect that the largest component of our active risk will be stock-specific along with appropriate levels of diversification. We use a variety of both proprietary and external quantitative tools to support this decision making. Our risk systems monitor and analyze risk exposures across multiple perspectives. We are able to break down the risk within the portfolio by industry and country factors, by currency and macro factors, and by other fundamental factors (quality, momentum, etc.). We can thus highlight the stocks with the highest marginal contribution to risk and the largest diversification benefit which can be usefully combined with our view of the return we expect from each stock. We also have pre-trade functionality which can simulate changes to our current portfolio and assess how any changes would impact the overall risk profile of the fund. We can then manage that risk with the objective of maximizing risk-adjusted returns and ensuring appropriate diversification. Continuous coverage and monitoring of both the company fundamentals and price action allow us to review any stock’s position in the portfolio.

abrdn Inc. also manages four healthcare-focused registered investment companies that adhere to different research methodology from Aberdeen Investments’ other equity strategies. The portfolio management team applies both bottom-up and top-down strategies in its investment process. A bottom-up strategy is taken on the company level where individual opportunities are evaluated in three fundamental bases as appropriate: the scientific basis, the market basis, and the financial basis. Assets are evaluated on scientific principals; the market basis evaluates the regulatory and competitive landscape faced by each company; financial evaluation takes place through a variety of metrics relative to the subsector to which each company belongs. A top-down approach is taken on the level of sector allocation within the portfolio. The investment team divides healthcare into a number of subsectors and seeks to identify relative value on a subsector basis. These measures include sector revenue multiples, earnings multiples, and forward growth estimates and prospects. To stay current, the investment team evaluates subsectors on a continually rotating basis and allocation flows are adjusted as appropriate. Fixed Income Our investment teams seek to generate investment alpha within their specialist areas utilizing a foundation of fundamentally driven top-down and bottom-up research. Strategies are tailored to meet individual portfolio and client objectives and benefit from independent risk monitoring and oversight. Key points: • Active management, operating globally, aiming to deliver outperformance • Utilising diversified sources of alpha to improve risk-return profiles • Specialist decision makers, working within allocated risk budgets • Collaborative research process with global perspective • Derivatives capability for both active and liability management We seek to give our client added value by exploiting market inefficiencies in interest rates, currency, inflation expectations, investment grade credit, emerging market debt and high yield. Aberdeen Investments has dedicated portfolio managers and analysts in the United Kingdom, North America and Asia that operate as teams, delegating investment decision-making to specialists, depending on their knowledge and expertise. Our investment structure enables us not only to follow a disciplined investment process while allowing flexibility to manage portfolios for a wide variety of client requirements. This may range from strategies which employ multiple sources of uncorrelated returns to those that are focused on a particular specialist area. We aim to deliver superior performance across the full range of our fixed income capabilities. We use derivatives, such as interest rate and credit default swaps, for efficient portfolio management, to identify opportunities to add value and to match liability exposures. Aberdeen Investments examines the material risks of an investment across a spectrum of considerations including financial metrics, regional and national conditions, industry specific factors and ESG risks. Although ESG investing is not a principal strategy for most fixed income products, Aberdeen Investments considers and assesses how these issues are managed and mitigated as well as the opportunities they might create for the issuer. A subset of the Fixed Income Investment Team also offers a Fund Finance private credit strategy, which is focused on debt investment into syndicated subscription line loans (also known as capital call facilities) to closed end, private markets funds that are owned or controlled by private equity, real estate fund, infra-structure fund, secondary fund, private credit fund, or other private investment vehicles (“Financial Sponsors”). These loans are used by Financial Sponsors to bridge fund investment activity and are typically structured as multicurrency, revolving credit facilities with a legal tenor under 3 years. The loans are collateralized by the uncalled commitments of fund LPs. The decision to make a loan is heavily dependent on the credit quality and diversification of the collateral, the presence of formal first ranking security over the collateral and the level of overcollateralization supporting the loan. The investment manager targets loans which are supported by a robust level of uncalled commitments from high credit quality, institutional investors which may or may not have an external credit rating. The

investment manager will conduct legal due diligence on both the fund documentation and the credit facility documentation (including all security arrangements) before making any investment. The investment manager will undertake a detailed analysis of the credit quality and experience of the Financial Sponsor, including the Financial Sponsor’s capital under management, its investment strategy, performance track-record, decision making structures and governance. The investment manager will also diligence the credit quality of the financial sponsor through meeting the Financial Sponsor and/or reference calls to Limited Partners, intermediaries and other lenders and service providers. Commodity ETFs Aberdeen Investments uses a “passive” or representative sampling index-tracking approach to attempt to achieve its investment objective for the Commodity ETFs. Aberdeen Investments will invest in only a representative sample of the instruments in the index, meaning it may invest in a sample of the securities in the Index whose risk, return and other characteristics closely resemble the risk, return and other characteristics of the index as a whole, and may invest in or gain exposure to instruments not contained in the index or in financial instruments, with the intent of tracking the index. In managing the assets of the Commodity ETFs, Aberdeen Investments does not invest in instruments based on our view of the investment merit of a particular instrument nor does it conduct conventional investment research or analysis or forecast market movement or trends. Aberdeen Investments seeks to remain fully invested at all times in financial instruments that, in combination, track the returns of the index without regard to market conditions, trends or direction. Aberdeen Investments will rebalance its portfolio when the index rebalances. Alternative Investment Strategies (Hedge Funds) We consider hedge fund strategies as a set of investment trading strategies that can offer potential diversification benefits for investors in traditional asset classes. Due to the potential non-traditional nature of hedge strategy returns, performance is not necessarily correlated with traditional investment markets or indices, such as equities or bonds. We believe that, through understanding the properties and behavior of different strategies, portfolios can be created that are not solely dependent on market direction for returns. Such investments can therefore be potentially diversifying for investors in traditional asset classes. In this regard we offer both active and passive approaches to these non-traditional sources of returns. In constructing active portfolios, we believe one of the key focuses should be the understanding, monitoring and management of risk. Risk exposures and market sensitivities must be appropriate to the longer-term investment objective. We also believe that value can be added through active portfolio management to reflect strategic and tactical views and opportunities. Throughout the investment process, we believe that the best outcomes are delivered by making team-based, high-conviction decisions. We have a track record of building multi-manager hedge fund portfolios through: • Proprietary research and understanding prospective managers and their strategies well. This is how we understand the investment proposition and develop conviction in a manager’s ability to deliver on their stated investment strategy. • Conduct proprietary style and strategy research to develop views on different strategies, their potential return characteristics and the underlying drivers of their future returns. • Thoroughly investigate the non-investment risks associated with various investments, and do not invest if these risks are deemed too high regardless of the perceived strength of an investment proposition. • Assess the collective risks in a portfolio of strategies and managers. • Understand the overall exposures in your portfolios and ensure they reflect your investment views and the portfolio objectives. While individual investments may reflect appropriate risk exposures, the aggregated portfolio may not be appropriately weighted. • Committee based approach to portfolio management and construction, led by the team’s Governance and Investment Committee. Real Estate and Real Assets

Real Estate Multi-Manager (“REMM”) The core aspects of Aberdeen Investments’ investment philosophy in real estate are as follows: • We can manage risk; we cannot manage market returns. This means every investment decision is essentially a risks-bundle selection decision. We think long-term, taking advantage of short-term, irrational behavior. • We follow a process, which does not allow distraction from long-term goals. Our process is global but implemented locally. This provides a common language for team-based decision making. • We build high-conviction portfolios, bottom up. We do our own research, only investing in what we understand. • We invest on the basis of quality. The focus on risk selection is encapsulated in the investment thesis approach – a comprehensive understanding of macro and capital markets risk factors like interest rates and capital flows on the one hand, and fundamentals and micro risk factors like supply and demand on the other, to select at every point in the cycle, the appropriate risks bundle. This in turn leads to an understanding of the return drivers of a strategy, and an awareness of when to realize those returns. The focus on risk management and investment thesis defines our investment philosophy and approach. In investment execution and process, we are defined by quality. The starting point to any mandate is an open and transparent discussion with the client to understand the investment objectives and decide the investment parameters, including risk tolerance. We believe that an open discussion is an important first step to building our relationship with our clients, and that a transparent process on an on-going basis is necessary for a successful long-term partnership. Once the investment objectives and parameters are agreed, we will begin portfolio construction, the starting point of which is our “read” of the markets globally, i.e., understanding where the different cycles are at for all the major markets in which we are looking to invest, i.e., the interest rate, capital value, rental value and construction cycles, and assessing what types of risks we want to take in the short, medium and long term based on how we think those risks will be compensated. We incorporate the macro views of our investment team, which considers if a market is over- or underpriced, and where opportunities are. From these macro analyses, we then drill deeper into identifying where the best risk-adjusted opportunities are in each market currently and may arise in the near future, which we articulate through our investment thesis. At Aberdeen Investments, every investment must be underpinned by a clear investment thesis. Research is an integral part of our process. Research is carried out in-house and focused on the practical application of research for the benefit of investments and clients. The REMM team is actively engaged in market research activities. While our research involves inputs from external sources, all our research outputs including interpretation, modelling and house views are carried out internally. Real Assets The Real Assets strategy aims to provide investors with options for investing across the real assets continuum. This strategy focuses on natural resources funds (including funds with a focus on energy, timber, agriculture, commodities, and/or other natural resources) and private real estate (including distressed real estate). The funds also invest a portion of their portfolios in co-investments and may also invest in opportunistic secondaries. The marketability and value of any such investments will depend upon many factors beyond the control of the Real Assets funds. In addition, there can be no assurance that any investor will receive any distribution from a fund. Investing in the funds involves a risk of loss that investors should be prepared to bear. Investors in the funds should refer to the Governing Documents of the applicable fund for complete information on investment strategies employed by the Fund and the corresponding risks associated with such investment strategies. Investors in the funds should carefully consider, among other factors, the following material risks involved with Aberdeen Investments’ investment strategies. Concession Infrastructure

The concession infrastructure team manages funds that make investments into social and economic infrastructure projects undertaken through the award of concessions by central/local government counterparties or Public Private Partnership (“PPP”) style transactions where the revenue is derived from longdated contracts with high quality off-takers. Investment Strategy Risks As with any investment, there is no guarantee that a portfolio will achieve its investment objective. Investing in securities involves risk of loss that clients should be prepared to bear. However, clients should be aware that not all of the risks listed below will pertain to every account as certain risks may only apply to certain strategies. It is not possible to identify all of the risks associated with investing and the particular risks applicable to a client account will depend on the nature of the account, its investment strategy or strategies and the types of securities held. Additionally, given the volume of new rules and regulations in the industry, we are continuously reviewing the application of our risks. While we seek to manage accounts so that risks are appropriate to the strategy, it is often not possible or desirable to fully mitigate risks. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. Clients and other investors should understand that they could lose some or all of their investment and should be prepared to bear the risk of such potential losses. Clients and other investors should read carefully all applicable informational materials and offering or Governing Documents, including offering memorandums and prospectuses prior to retaining Aberdeen Investments to manage an account or investing in any Aberdeen Investments investment product. Clients and other investors should be aware that while Aberdeen Investments does not limit its advice to particular types of investments, mandates may be limited to certain types of securities or to the recommendation of investment advisers or managed funds and may not be diversified. The accounts managed by Aberdeen Investments are generally not intended to provide a complete investment program for a client or investor. Clients and other investors are responsible for appropriately diversifying their assets to guard against the risk of loss. Below is a summary of the material risks associated with our significant strategies and methods of analysis. These risks may apply both to products Aberdeen Investments offers as well as to the underlying investments in client portfolios and funds. Not all possible risks are described below, and not all risks apply to all mandates. Please refer to the prospectus, investment management agreement, or other relevant offering document for the vehicle. Absolute Return Strategy Risk – Absolute return funds employ certain techniques that are intended to reduce risk and volatility in the portfolio and provide protection against a decline in the fund’s assets. They are not designed to outperform stocks and bonds in strong markets and there is no guarantee of positive returns or that the portfolio’s objective will be achieved. Adjustable-Rate Risk – Adjustable rate securities are securities that have interest rates that are reset at periodic intervals, usually by reference to some interest rate index or market interest rate. Some adjustable-rate securities are backed by pools of mortgage loans. Although the rate adjustment feature may act as a buffer to reduce sharp changes in the value of adjustable-rate securities, these securities are still subject to changes in value based on changes in market interest rates or changes in the issuer’s creditworthiness. Because the interest rate is reset only periodically, changes in the interest rates on adjustable-rate securities may lag changes in prevailing market interest rates. Also, some adjustable-rate securities (or, in the case of securities backed by mortgage loans, the underlying mortgages) are subject to caps or floors that limit the maximum change in interest rate during a specified period or over the life of the security. Because of the resetting of interest rates, adjustable-rate securities are less likely than non-adjustable rate securities of comparable quality and maturity to increase significantly in value when market interest rates fall. Allocation Risk – The allocation among different investment opportunities may have a significant effect on a portfolio’s value when one of these investments is performing more poorly than others. There will be transaction costs which may be significant over time because both the direct investments and derivative positions will be adjusted periodically to reflect our view of market and economic conditions. In addition, there

is a risk that certain allocation decisions may not achieve the desired results and, consequently, a portfolio may incur losses. Artificial Intelligence (“AI”) Risk – Aberdeen Investments, its staff, and its third-party service providers may use AI technology with respect to certain business processes. AI technologies are highly reliant on the accuracy, adequacy, completeness and objectivity of their underlying data, and any inaccuracies, deficiencies or biases in this data could lead to errors affecting decision-making. AI models are complex and may produce output or take action that is incorrect (i.e., hallucinate), AI technology and regulation of AI are uncertain and evolving, which could result in significant and disruptive changes to Aberdeen Investments and the companies, sectors, or industries in which it invests. Aberdeen Investments rely on services provided by third parties who use or may use AI technology over which Aberdeen Investments have limited visibility regarding the accuracy and completeness of such tools. Bank Loans – Bank loans include floating and fixed rate debt obligations. Floating rate loans are debt obligations issued by companies or other entities with floating interest rates that reset periodically. Floating rate loans are secured by specific collateral of the borrower and are senior to most other securities of the borrower (e.g., common stock or debt instruments) in the event of bankruptcy. Floating rate loans are often issued in connection with recapitalizations, acquisitions, leveraged buyouts, and refinancing. Floating rate loans are typically structured and administered by a financial institution that acts as the agent of the lenders participating in the floating rate loan. Floating rate loans may be acquired directly through the agent, as an assignment from another lender who holds a direct interest in the floating rate loan, or as a participation interest in another lender’s portion of the floating rate loan. Borrowing Risk – Borrowing creates leverage. The use of leverage may subject investments to additional risk and could magnify losses. It also adds to any given portfolio expenses, and at times could effectively force a portfolio to sell securities when it otherwise might not want to do so. Business Continuity Risk – We have adopted a business continuity plan to maintain critical functions in the event of a partial or total building outage affecting our offices or a technical problem affecting applications, data centers or networks. The plan is designed to limit the impact on clients from any business interruption or disaster, including those related to key third party service providers. Nevertheless, our ability to conduct business may be curtailed by a disruption in the infrastructure that supports our operations and the regions in which our offices are located. While Aberdeen Investments and its service providers have established business continuity plans in the event of, and risk management systems to prevent, such incidents, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. The firm may be subject to adverse effects caused by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred). A pandemic, epidemic or other public health concern, natural disaster, the occurrence of terrorism, military, geopolitical and other actions, may result in loss of life, property damage, and disruptions to commerce and reduced economic activity. Investments may be adversely affected by declines in the equity markets, changes in interest rates, reduced liquidity and economic activity caused by force majeure events. Additionally, events that impact infrastructure (physical infrastructure, telecommunications, transportation) could have a material effect on sales, liquidity and the ability for the firm to perform its obligations to clients. Cash Flow Risk – The yields available from equity investments in real estate depend in large part on the amount of income generated and expenses incurred. If the investments do not generate revenues sufficient to meet operating expenses, including debt service, tenant improvements, leasing commissions and other capital expenditures, clients may be required to fund or borrow additional amounts to cover fixed costs, and the cash flow of such client account (and, with respect to investment funds, its ability to make distributions to shareholders) will be adversely affected. Although each client will be investing in a range of investments, all real estate investments are speculative in nature and the possibility of partial or total loss of capital exists. Co-Investment Opportunities – With respect to certain pooled investment vehicles, from time to time, abrdn Inc. may, in its sole discretion offer co-investment opportunities to select clients. abrdn Inc. is not expected to offer co-investment with respect to all of a fund’s investments and may allocate any such opportunities in its sole discretion, including for example, on the basis of contractual rights to co-investments provided to some

but not all clients, and the size of investor commitments to the funds, vehicles, and separately managed accounts. The allocation of co-investment opportunities may involve a benefit to Aberdeen Investments including, without limitation, fees or carried interest from the co-investment opportunity and capital commitments to other funds. abrdn Inc. may form committed co-investment vehicles both during and following a fund’s fundraising period to participate alongside a fund in investment opportunities that Aberdeen Investments has determined in good faith exceed prudent diversification levels for such fund. The capital committed to such co-investment vehicles would not be included in the overall size limitation on a fund’s investment program. Further, it is possible that funds managed by Aberdeen Investments may compete with each other for the same limited co-investment opportunities. Collateralized Loan Obligations (“CLOs”) – CLOs are trusts or other special purpose entities that are backed by a pool of loans. Such loans may include domestic and foreign senior secured loans, senior unsecured loans and subordinate corporate loans, some of which may be below investment grade or equivalent unrated loans. CLOs issue classes or “tranches” that vary in risk and yield, and may experience substantial losses due to actual defaults, decrease of market value due to collateral defaults and disappearance of subordinate tranches, market anticipation of defaults, and investor aversion to CLO securities as a class. The risks of CLOs depend largely on the type of the underlying loans and the tranche of CLOs in which the client invests. In addition, CLOs carry risks including interest rate risk, credit risks and default risks. Certain CLOs may not hold loans directly, but rather, use derivatives such as swaps to create “synthetic” exposure to the collateral pool of loans. Commodity Risk - The daily performance of the current or “spot” price of certain commodities has a direct impact on performance. To the extent a portfolio has significant exposure to a particular commodity sector, the account may be more susceptible to loss due to adverse occurrences affecting that sector, including a decline in the price of commodities in such sector. The NAV of the portfolio will be also affected by movements in commodity prices generally and by the way in which those prices and other factors affect the prices of the commodity futures contracts. Commodity prices generally may fluctuate widely and may be affected by numerous factors. Competitive Investment Environment – The activity of identifying, completing and realizing limited offering investments is highly competitive and involves a high degree of uncertainty. We may, at times, be in competition with other funds and managers with similar investment objectives for the acquisition of the same targets. Conflicts of Interest – Due to the structure of Aberdeen Investments, it is possible that we may hold or trade the same securities and instruments as underlying fund managers in which we or an affiliate invest. Additionally, we may utilize similar techniques and strategies as those adopted by our underlying fund managers. As a result, we may directly or indirectly compete with our underlying managers and investment vehicles on an “arm’s length” basis. In the event that knowledge of a conflict of interest does arise, we will endeavor to ensure that it is resolved fairly and at arm’s length. Concentration Risk – A strategy that concentrates in companies in a specific industry means that its performance will be closely tied to the performance of a particular market segment. Concentration in these companies may present more risks than if it were broadly diversified over numerous industries and sectors of the economy. A downturn in these companies would have a larger impact on the portfolio than once that does not concentrate in such companies. At times, the performance of these companies will lag the performance of other industries or the broader market as a whole. Convertible Bond Arbitrage – Underlying fund managers may engage in convertible bond arbitrage and the positions intended to offset one another may not move as expected. In addition to the risks associated with fixed income, these types of strategies have risks associated with equity investments. Although the underlying fund manager is expected to hedge all equity exposure, there can be no assurance that such exposures will not exist or that such hedges will be effective. Convertible Securities Risk – The value of a convertible security will vary based on the perceived value of the equity security underlying the convertible security. Convertible securities are frequently issued with a call feature that allows the issuer to choose when to redeem the security, which could result in the accounts being forced to redeem, convert, or sell the convertible security under circumstances unfavorable to the accounts. In

addition, if the value of the equity security underlying the convertible security declines enough, the convertible security is more likely to be valued as a debt security and subject the accounts to the risks of debt securities as described herein. Counterparty Risk – A portfolio may be exposed to the credit risk of counterparties with which, or the brokers, dealers, custodians and exchanges through which, it deals in connection with the investment of its assets, whether engaged in exchange-traded or off-exchange transactions. Credit/Default Risk – An issuer or guarantor of a fixed income security, or the counterparty to a derivatives or other contract, may be unable or unwilling to make timely payments of interest or principal, or to otherwise honor its obligations. The issuer or guarantor may default, causing a loss of the full principal amount of a security. The degree of risk for a particular security may be reflected in its credit rating. There is the possibility that the credit rating of a fixed income security may be downgraded after purchase, which may adversely affect the value of the security. Investments in fixed income securities with lower ratings tend to have a higher probability that an issuer will default or fail to meet its payment obligations. Credit Spread Risk – Changes in credit spreads will affect the value of financial instruments. Credit spreads represent the credit risk premiums required by market participants for a given credit quality. When credit spreads widen, the value of investments in fixed income securities tend to fall and this decrease in value may not be offset by higher income from new investments. Credit spreads can be driven by macroeconomic factors as well as issue specific factors. Cross-Class Liabilities – If the investment vehicle held by an underlying manager offers multiple share classes, there is the potential that losses in a share class not held may have an adverse effect on its NAV. Currency Hedging Risks – There can be no guarantee or assurance that any attempt to protect against adverse currency movements will be successful. As such, hedging transactions may result in a poorer overall performance and any realized loss resulting from these currency hedging strategies may also affect the level of redemptions required of our underlying managers. In extreme circumstances, this may result in the concentration of the underlying manager’s investments in less liquid or illiquid investments. Currency Risk – Fluctuations in currency exchange rates may negatively affect the value of a portfolio’s investments or reduce its returns. Cybersecurity Risk – Aberdeen Investments, like all companies, is susceptible to operational, information security, and related risks. In general, cybersecurity incidents can result from deliberate attacks or unintentional events (arising from external or internal sources) that may cause Aberdeen Investments to lose proprietary information, suffer data corruption, physical damage to a computer or network system or lose operational capacity. Breaches in cybersecurity include, but are not limited to, AI spoofing, infection by malicious software, such as malware or computer viruses or gaining unauthorized access to digital systems, networks or devices that are used to service Aberdeen Investments’ operations (e.g., through “hacking,” “phishing” or malicious software coding) or other means for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of Aberdeen Investments or its service providers or the issuers of securities in which Aberdeen Investments invest have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the inability of Aberdeen Investments’ clients to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs. Aberdeen Investments and its clients could be negatively impacted as a result. In addition, work-from-home arrangements by the portfolio, Aberdeen Investments or their service providers could increase the above risks, create additional data and information accessibility concerns, and make Aberdeen Investments or their service providers susceptible to operational disruptions, any of which could adversely impact their operations. Furthermore, Aberdeen Investments may be an appealing target for cybersecurity threats such as hackers and malware. Debt Securities Risk – Debt securities in which an account may be invested may be unrated or lower-rated and may have a risk profile closer to that of an equity security. Compared to other debt securities, those issues with the lowest investment-grade ratings (often called "junk bonds") are considered to have speculative

characteristics. Debt securities that are below investment grade or unrated generally are considered predominately speculative with respect to the issuer's capacity to pay interest and repay principal according to the terms of the obligation and, therefore, carry greater investment risk, including the possibility of default and bankruptcy. They are likely to be less marketable and more adversely affected by economic downturns than high-quality debt securities. Changing interest rate environments (whether downward or upward) impact the various sectors if the economy in different ways. During periods when interest rates are low (or negative), yield (or total return) may also be low and fall below zero. Investments may be subject to heightened levels of interest rate risk because the U.S. Federal Reserve (“the Fed”) has sharply raised interest rates from relatively low levels and has signaled an intention to continue to do so until current inflation levels re-align with the Fed’s long-term inflation target. To the extent the Fed continues to raise interest rates, there is a risk that rates across the financial system may rise. The accounts may invest in debt securities without considering the maturity of the instrument. Debt securities have varying levels of sensitivity to changes in interest rates. In general, the price of a debt security can fall when interest rates rise and can rise when interest rates fall. Securities with longer maturities can be more sensitive to interest rate changes. Therefore, changes in interest rates both in the U.S. and outside the U.S. may affect the accounts' debt investments unfavorably. Deposit Bank Risk - Fund assets may be exposed to risks facing the fund’s depository banks. These may be pronounced in regional and foreign banks, or smaller banks subject to less stringent regulatory requirements than mid- and large-size banks. As a result, such institutions may be more susceptible to the risk of insolvency and being placed in receivership default. In addition, in the event of a receivership, small and regional banks may not receive the same government backing to protect depositors in the same manner that larger, more systemically important banks have or may in the future receive. The laws of certain countries may place limitations on the ability to recover assets if a non-U.S. bank, agent or depository becomes insolvent or enters bankruptcy. If a fund’s depository bank fails, there is no guarantee that the fund’s assets on deposit with the bank becomes accessible in the short term and can be permanently lost to the extent it is uninsured. Depositary Receipts – Depositary receipts may be issued in a sponsored program, where an issuer has made arrangements to have its securities traded in the form of depositary receipts, or in an unsponsored program, where the issuer may not be directly involved. The holders of depositary receipts that are unsponsored generally bear various costs associated with the facilities, while a larger portion of the costs associated with sponsored depositary receipts are typically borne by the foreign issuers. Investments in unsponsored depositary receipts may be subject to the risks that the foreign issuer may not be obligated to cooperate with the U.S. depository, may not provide additional financial and other information to the depository or the investor, or that such information in the U.S. market may not be current. The depository of an unsponsored facility frequently is under no obligation to distribute shareholder communications received from the issuer of the deposited securities or to pass through the voting rights to facility holders with respect to the deposited securities. Available information concerning the issuers may not be as current for unsponsored depositary receipts and the prices of unsponsored depositary receipts may be more volatile than would be the case if the receipts were sponsored by the issuers. Derivatives Risk – Derivatives are financial instruments that have a value which depends upon, or is derived from, the value of something else, such as one or more underlying securities, pools of securities, options, futures, indices or currencies. Derivatives are speculative and may hurt investment performance. The potential benefits to be derived from the portfolio’s options, futures and derivatives strategy are dependent upon the portfolio managers’ ability to discern pricing inefficiencies and predict trends in these markets, which decisions could prove to be inaccurate. Gains or losses involving derivative instruments may be substantial, because a relatively small price movement in the underlying security(ies), instrument, currency or index may result in a substantial gain or loss. Derivatives will typically increase exposure to the principal risks to which a fund or client is otherwise exposed, and the following additional risks: • Speculative Exposure Risk – To the extent that a derivative or practice is not used as a hedge, the portfolio is directly exposed to its risks. Gains or losses from speculative positions in a derivative may be much greater than the derivative’s original cost. For example, potential losses from writing uncovered call options and from speculative short sales are unlimited.

Hedged Exposure Risk – Losses generated by a derivative or practice used for hedging purposes should be substantially offset by gains on the hedged investment. However, while hedging can reduce or eliminate losses, it can also reduce or eliminate gains. Correlation Risk – Portfolios are exposed to risk that changes in the value of a hedging instrument will not match those of the investment being hedged. Counterparty Risk – Derivative transactions depend on the creditworthiness of the counterparty and the counterparty’s ability to fulfill its contractual obligations. Other Derivatives Risks – Fixed income derivatives are subject to interest rate risk. In addition, certain derivatives may be subject to illiquid securities risk, mispricing or valuation complexity, market risk and management risk. The Adviser may need to sell securities at inopportune times to satisfy margin or payment obligations under derivatives investments. Changes in regulation relating to the use of derivatives and related instruments could potentially limit or impact the portfolio’s ability to invest in derivatives, limit the Advisers’ ability to employ certain strategies that use derivatives and/or adversely affect the value of derivatives and performance.

Deterioration of Market Conditions – In the case of extreme and continued market disruptions, attractive investment returns may be adversely affected. Continued market disruption or deterioration of market conditions and uncertainty could result in decreases in the market values of existing or potential investments. Additionally, liquidity may be affected, resulting in the inability to sell or liquidate investments at favorable times or prices. These circumstances may adversely impact the ability to meet investment objectives. Distressed Investments – Underlying fund managers may invest in securities and obligations of companies that are experiencing financial or business difficulties, including companies involved in bankruptcy or other reorganization and liquidation proceedings. Distressed securities generally trade significantly below “par” or full value because investments in such securities and debt of distressed issuers or issuers in default are considered speculative. These investments involve a substantial degree of risk and may not compensate investors adequately for the risks they assume. Due to the degree of complexity and unpredictability of bankruptcy and other insolvency proceedings, investors may be adversely affected. Due Diligence Process – The due diligence process that we intend to undertake may not reveal all material facts or circumstances. Any due diligence process involves subjective analysis and there can be no assurance that this process will reveal all issues related to the potential allocation of assets to underlying fund managers. Early Termination of Portfolio Funds – The governing documents of some underlying funds in fund-of-fund products include provisions that would enable the general partner, the manager, or a percentage in interest of the limited partners to terminate such underlying funds prior to the end of their respective stated terms. Early termination of an underlying fund may result in (i) the portfolio receiving distributions of immature or illiquid securities or (ii) the portfolios’ inability to invest all of its committed capital as anticipated, either of which could have a material adverse effect on performance. Moreover, a portfolio fund may, among other things, in certain circumstances be permitted to terminate the portfolios’ interest in such portfolio fund. Effect of Substantial Redemptions – Occasionally, investors may make large redemptions or purchases in a fund, which may cause the fund to have to sell securities or invest additional cash. These transactions may adversely affect a fund’s performance and increase transaction costs. In addition, for fund of funds, redemptions by investors in the underlying funds held by a strategy within a short period of time may require the underlying fund manager to liquidate positions more rapidly than desired. This may lead to a reduction in value of the underlying funds’ assets or a disruption of the investment strategy. Additionally, this may lead to an increase in the concentration of the underlying funds in illiquid assets which could, in turn, reduce the liquidity of the shareholder’s position. Significant investment in certain Aberdeen Investments funds or underlying funds in fund-of-fund products may also subject the investor to anti-dilution levies, which are fees charged by fund managers on investors buying and selling units in a fund. These fees may be applied at any combination of the purchase and sale of a unit and may have adverse effects on the returns of the investment. The buying or selling of underlying investments in response to a request to purchase or redeem shares will generally incur transaction costs. To the extent that these costs are not reflected in the issue or redemption price paid by or to the shareholders, they will act to dilute the interests of continuing shareholders.

Emerging Markets Risk – Foreign investment risk may be particularly high if a portfolio invests in emerging market securities that are economically tied to countries with developing economies. These securities may present market, credit, currency, liquidity, legal, political and other risks different from, or greater than, the risks of investing in developed foreign countries. Environmental Risk– In addition to Force Majeure incidences, infrastructure-related issuers can have substantial environmental impacts. Ordinary operations or operational accidents may cause major environmental damage, which could cause infrastructure-related issuers significant financial distress, substantial liabilities for environmental cleanup and restoration costs, claims made by neighboring landowners and other third parties for personal injury and property damage, and fines or penalties for related violations of environmental laws or regulations. Infrastructure-related issuers may not be able to recover these costs from insurance. Failure to comply with environmental laws and regulations may trigger a variety of administrative, civil and criminal enforcement measures, including the assessment of monetary penalties, the imposition of remedial requirements, and the issuance of orders enjoining future operations. Voluntary initiatives and mandatory controls have been adopted or are being discussed both in the United States and worldwide to reduce emissions of “greenhouse gases” such as carbon dioxide, a by-product of burning fossil fuels, and methane, the major constituent of natural gas, which many scientists and policymakers believe contribute to global climate change. These measures and future measures could result in increased costs to certain companies in which we may invest. Equity Securities Risk – Equity securities represent an ownership interest, or the right to acquire an ownership interest, in an issuer. Equity securities also include, among other things, preferred stocks, convertible stocks and warrants. The values of equity securities, such as common stocks and preferred stocks, may decline due to general market conditions which are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. They may also decline due to factors which affect a particular industry or industries, such as labor shortages or increased production costs and competitive conditions within an industry. Equity securities generally have greater price volatility than fixed income securities. Your portfolio at any point in time may be worth less than the amount that you invested, even after taking into account the reinvestment of dividends and distributions. Regardless of how well an individual investment performs, if financial markets go down, you could lose money. Event Arbitrage – Arbitrage opportunities may exist in securities which are subject to tender offers, exchange offers, mergers, liquidations, reorganizations, bankruptcies, or other extraordinary corporate transactions. Although it is expected that the underlying fund managers hedge such exposures, there can be no guarantee that these hedges will either be in place or be effective. Focus Risk –A portfolio which invests a larger percentage of its assets in a relatively small number of issuers may be subject to greater risks than a more diversified account. That is, a change in the value of any single investment held by a portfolio may affect the overall value of the account more than it would affect an account that holds a greater number of investments. Foreign (Non-U.S.) Risk – Foreign countries in which the Adviser may invest may have markets that are less liquid, less regulated and more volatile than U.S. markets. The value of a portfolio’s investments may decline because of factors such as unfavorable or unsuccessful government actions, reduction of government or central bank support and political or financial instability. To the extent a portfolio focuses its investments in a single country or only a few countries in a particular geographic region, economic, political, regulatory or other conditions affecting such country or region may have a greater impact on performance relative to a more geographically diversified fund. Forward Commitment Risk – When a portfolio engages in when-issued, delayed delivery or forward commitment transactions (e.g., “to be announced” securities or TBAs), the portfolio relies on the counterparty to consummate the sale. Failure to do so may result in the strategy missing the opportunity to obtain a price or yield considered to be advantageous. Such transactions may also have the effect of leverage on the strategy and may cause it to be more volatile. Additionally, these transactions may create a higher portfolio turnover rate.

Forward Foreign Currency Contracts –We may enter into forward foreign currency contracts, which are types of derivative contracts whereby we may agree to buy or sell on behalf of a client a country’s currency at a specific price on a specific date, usually 30, 60, or 90 days in the future for a specific exchange rate on a given date. These contracts may, however, fall in value due to foreign market downswings or foreign currency value fluctuations. A fund or client may enter into forward foreign currency contracts for investment purposes, for risk management (hedging) purposes, and to increase flexibility, depending on the mandate. An investment of hedging strategies may be unable to achieve their objectives. These risks are in addition to the general “Derivatives Risks” described above. Futures Contracts – We may enter into futures contracts on behalf of clients, including currency, bond, commodity, index and interest rate futures, for investment purposes, for risk management (hedging) purposes, and to increase flexibility. The volatility of futures contracts prices has been historically greater than the volatility of stocks and bonds. The liquidity of the futures markets depends on participants entering into offsetting transactions rather than making or taking delivery. To the extent participants decide to make or take delivery, liquidity in the futures market could be reduced. In addition, futures exchanges often impose a maximum permissible price movement on each futures contract for each trading session. A portfolio may be disadvantaged if it is prohibited from executing a trade outside the daily permissible price movement. General Partner Risk – Governing Documents often limit the circumstances under which a general partner, manager and their affiliates can be held liable to a private fund. As a result, investors may have a more limited right of action in certain cases than they would otherwise have in the absence of this provision. Geopolitical Risk – The market values of securities or other assets will fluctuate, sometimes sharply and unpredictably, due to changes in general market conditions, overall economic trends or events, governmental actions or intervention, actions taken by the US Federal Reserve or foreign central banks, market disruptions caused by trade disputes or other factors, political developments, investor sentiment and other factors that may or may not be related to the issuer of the security or other asset. Economies and financial markets throughout the world are increasingly interconnected. Economic, financial or political events, trading and tariff arrangements, terrorism, civil unrest, natural disasters and other circumstances in one country or region could have profound impacts on global economies or markets. As a result, whether or not the Fund invests in securities of issuers located in or with significant exposure to the countries directly affected, the value and liquidity of the Fund’s investments may be negatively affected. In addition, any spread of an infectious illness, public health threat or similar issue could reduce consumer demand or economic output, result in market closures, travel restrictions or quarantines, and generally have a significant impact on the world economy, which in turn could adversely affect the Fund’s investments. Growth Investing Risk – As a category, growth stocks may underperform value stocks (and the stock market as a whole) over any period of time. Because the prices of growth stocks are based largely on the expectation of future earnings, growth stock prices can decline rapidly and significantly in reaction to negative news about such factors as earnings, the economy, political developments, or other news. High Yield Risk – Portfolios that invest in high yield securities, lower-rated or unrated securities, may be subject to greater levels of credit and liquidity risk than accounts that do not invest in such securities. These securities are considered predominately speculative with respect to the issuer’s continuing ability to make principal and interest payments. An economic downturn or period of rising interest rates could adversely affect the market for these securities and lead to liquidity risk. If the issuer of a security is in default with respect to interest or principal payments, an account may lose its entire investment. Inflation/ Deflation Risk – Inflation risk is the risk that the real value (i.e., nominal price of the asset adjusted for inflation) of assets or income from investments will be less in the future because inflation decreases the purchasing power and value of money (i.e., as inflation increases, the real value of assets can decline). Inflation rates may change frequently and significantly as a result of various factors, including unexpected shifts in the domestic or global economy and changes in monetary or economic policies (or expectations that these policies may change). Investments may not keep pace with inflation, which would adversely affect the real value of shareholders’ investment. This risk is greater for fixed-income instruments with longer maturities.

Deflation risk is the risk that prices throughout the economy decline over time. Deflation may have an adverse effort on the creditworthiness of issuers and may make issuer default more likely, which may result in a decline in the value of a portfolio’s assets. Additionally, many infrastructure-related issuers may have fixed income streams and, therefore, be unable to pay higher dividends. The market value of infrastructure-related issuers may decline in value in times of higher inflation rates. The prices that an infrastructure-related issuer can charge users of its assets may not always be linked to inflation. In this case, changes in the rate of inflation may affect the forecast profitability of the infrastructure-related issuer. Index Tracking Risk –The performance of an index tracking portfolio and the index may differ from each other for a variety of reasons. For example, the portfolio incurs operating expenses and portfolio transaction costs not incurred by the index. Index tracking risk may also occur because of differences between the investments held in the portfolio and those included in the index, pricing differences, differences in transaction costs, holding of uninvested cash, differences in timing of the accrual of dividends or interest, the requirements to maintain pass-through tax treatment, portfolio transactions carried out to minimize the distribution of capital gains to shareholders, changes to the index or the need to meet various new or existing regulatory requirements, among other reasons . The portfolio may be delayed in purchasing or selling investments included in the index. In addition, the portfolio may not be fully invested in the investments included in the index at all times or may hold investments that are not included in the index. In addition, the use of a representative sampling approach may cause a portfolio to not track the return of the index as would be the case if the portfolio purchased all of the instruments in the index or invested in them in the exact proportions in which they are represented in the index. There is no guarantee that the portfolio’s investment results will closely correspond, before fees and taxes, to the performance of the index or that the portfolio will achieve its investment objective. Market disruptions and regulatory restrictions could have an adverse effect on the portfolio’s ability to track the index. Errors in index data, index computations or the construction of the index in accordance with its methodology may occur from time to time and may not be identified and corrected by the index provider for a period of time or at all, which may have an adverse impact on the portfolio. Initial Public Offering (“IPO”) Risk – Prices of securities bought in an IPO may rise and fall rapidly, often because of investor perceptions rather than economic reasons. Insurance Risk – When owning or managing properties, there are additional risks that might not present themselves as compared to traditional asset classes. While the properties may in some cases be insured, this is no way an insurance of investment or principal and there are various uninsured and/or uninsurable risks that are present (such as natural disaster) and therefore investment carries greater risk of loss. Inside Information – From time to time, we may come into possession of material, non-public information concerning an entity in which an account has invested or proposes to invest. Possession of that information may limit our ability to buy or sell securities of the entity on behalf of a client. Interest Rate Risk – Changes in interest rates will affect the value of a portfolio’s investments in fixed income securities, and changes in interest rate expectations can also affect the value of both equity and fixed income securities. When interest rates rise, the value of investments in fixed income securities tend to fall, and this decrease in value may not be offset by higher income from new investments. Interest rate risk is generally greater for fixed-income securities with longer maturities or durations. Increases in the market’s expectations for future interest rates can cause a decrease in the value of equity securities with longer duration growth priced into them. Inverse Floating Rate Securities Risk – The interest payment received on inverse floating rate securities “inverse floaters”) generally will decrease when short-term interest rates increase. Inverse floaters are derivatives that involve leverage and could magnify a client’s gains or losses.

Investment Company and Exchange-Traded Fund (“ETF”) Risk – An investment in an investment company or ETF involves substantially the same risks as investing directly in the underlying securities. An investment company or ETF may not achieve its investment objective or execute its investment strategy effectively, which may adversely affect your portfolio’s performance. A portfolio must pay its pro-rata portion of an investment company’s or ETF’s fees and expenses. Shares of a closed-end investment company or ETF may trade at a premium or discount to the net asset value of its portfolio securities. To the extent that a portfolio invests in ETFs, the portfolio may be subject to, among other risks, tracking error risk and passive and, in some cases, active management investment risk. An active secondary market in ETF shares may not develop or be maintained and may be halted or interrupted due to actions by its listing exchange, unusual market conditions or other reasons. There can be no assurance that an ETF’s shares will continue to be listed on an active exchange. In addition, portfolio shareholders bear both their proportionate share of the portfolio’s expenses and similar expenses incurred through the portfolio’s ownership of the ETF. Issuer Risk – The value of a security may decline for a number of reasons which directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer’s goods or services, as well as the historical and prospective earnings of the issuer and the value of its assets. Key Person Risk – Underlying funds are generally reliant on certain key investment personnel employed in managing assets. Termination, disability, death, or departure of key personnel could adversely affect the underlying fund and its performance. Legal, Tax, and Regulatory Risk – Legal, tax and regulatory changes may occur in the future that may adversely affect investors. The effects of any future regulatory change are impossible to predict and could have substantial adverse effects on both investors and investment strategies. Limited Capacity Opportunities – We manage assets for multiple portfolios that may from time to time have overlapping investment mandates. Where an investment opportunity is of limited capacity, an allocation process will need to ensure each of the competing accounts is treated equitably over time in determining whether an account may participate and to what extent. Limited Operating History – At times, as we launch new strategies, certain of our investment teams may have a limited operating history and little or no past performance in the strategy they manage. Limits on Hedged Strategies – While certain underlying managers, in whose funds our funds of funds may invest, may use “market neutral” or “relative value” hedging or arbitrage strategies, this in no respect should be taken to imply that the fund’s investments with such money underlying managers are without risk. Substantial losses may be recognized on “hedge’ or “arbitrage” positions, and illiquidity and/or default on one side of a position can effectively result in the position being changed. Every market neutral or relative value strategy involves exposure to some second order risk of the market, such as the implied volatility in convertible bonds or warrant, the yield spread between similar term government bonds, or the price spread between different classes of stock for the same underlying firm. Further, many “market neutral” investment managers employ limited directional strategies that expose such money managers to certain market risk. Liquidity Risk – In certain situations, it may be difficult or impossible to sell an investment in an orderly fashion at an acceptable price. This includes investors in funds that may lock them up, possibly for multiple years. Investors in such funds must be able to bear the risk of investment for an extended period of time. Managed Futures Strategy/Commodities Risk – Exposure to the commodities markets (including financial futures markets) through investment in managed futures programs may cause greater volatility than investments in traditional securities. Prices of commodities and related contracts may fluctuate significantly over short periods for a variety of reasons, including changes in interest rates, supply and demand relationships and balances of payments and trade; weather and natural disasters; and governmental, agricultural, trade, fiscal, monetary and exchange control programs and policies. The commodity markets are subject to temporary distortions and other disruptions. U.S. futures exchanges and some foreign exchanges have regulations that limit the amount of fluctuation in futures contract prices which may occur during a single business day. Limit prices have the effect of precluding trading in a particular contract or forcing the liquidation of contracts at disadvantageous times or prices.

Management Risk – The Advisers and portfolio managers apply their own investment techniques and risk analyses in making investment decisions and there can be no guarantee that these decisions will achieve the desired results. In addition, the Adviser may select securities that underperform the relevant market or other funds with similar investment objectives and strategies. Market Capitalization Risk (Small-, Mid- and Large-Cap Stocks Risk) – To the extent an investment emphasizes small-, mid-, or large-cap stocks, it takes on the associated risks. At any given time, any of these market capitalizations may be out of favor. Compared to small- and mid-cap companies, large-cap companies may be less responsive to changes and opportunities, but their returns have sometimes led those of smaller companies, often with lower volatility. The stocks of small- and mid-cap companies may fluctuate more widely in price than the market as a whole, may be difficult to sell when the economy is not robust or during market downturns, and may be more affected than other types of stocks by the underperformance of a sector or during market downturns. In addition, compared to large-cap companies, small- and mid-cap companies may depend on a more limited management group, may have a shorter history of operations, and may have limited product lines, markets or financial resources. There may also be less trading in small- or mid-cap stocks, which means that buy and sell transactions in those stocks could have a larger impact on a stock’s price than is the case with large-cap stocks. Market Risk – The value of a portfolio’s assets will fluctuate along with the markets. The value of your investments may decline, sometimes rapidly and unpredictably, simply because of economic changes or other events that affect large portions of the market. Mortgage-Related and Other Asset-Backed Securities Risk – Mortgage-related and other asset-backed securities often involve risks that are different from or more acute than risks associated with other types of debt instruments. Generally, rising interest rates tend to extend the duration of fixed rate mortgage-related securities, making them more sensitive to changes in interest rates. Consequently, in a period of rising interest rates, if an account holds mortgage-related securities, it may exhibit additional volatility. This is known as extension risk. In addition, adjustable and fixed rate mortgage-related securities are subject to prepayment risk. When interest rates decline, borrowers may pay off their mortgages sooner than expected. This can reduce the returns of an account because the account may have to reinvest that money at the lower prevailing interest rates. Compared to other fixed income investments with similar maturity and credit, mortgage-related securities generally increase in value to a lesser extent when interest rates decline and generally decline in value to a similar or greater extent when interest rates rise. Multi-Jurisdictional Investment – The investments we make may be subject to a variety of jurisdictions, each of which may have unique economic, political, social, cultural, business and labor environments, laws, regulations, accounting practices and business customs. These differences may be considerable, and no single method of investment can be applied uniformly or be expected to produce uniform results. Multi-Manager Investing Risk – A fund-of-fund strategy’s relative performance is subject to the investment decisions made by each underlying fund or manager. The performance of a small number of underlying funds or managers could affect overall performance. Additionally, underlying funds may compete with one another from time to time for the same positions in the market and may potentially hold opposite positions in the same securities. Consequently, there can be no assurance that a diversification strategy implemented will be successful. Our funds of funds will seek to obtain diversification by investing with a number of different investment managers with diverse strategies. However, since our funds will allocate their assets to the multiple investment managers who make their trading decisions independently, it is possible that various underlying managers may take substantial positions in the same security or group of securities at the same time. Multiple Levels of Fees and Expense Risk – Funds–of-funds and multiple manager strategies will generally incur certain fees at two levels: the funds of funds vehicle and the underlying funds themselves. These fees potentially include both management and performance fees, which may increase the expense of the strategy, thus affecting investor returns. Additionally, investor returns may be adversely affected during periods in

which there are overall portfolio losses due to the potential that performance fees may be earned by one or more of the underlying portfolio managers. Municipal Securities Risk – A portfolio may be impacted by events in the municipal securities market. Municipal bonds can be significantly affected by political and economic changes, including inflation, as well as uncertainties in the municipal market related to taxation, legislative changes, or the rights of municipal security holders. Municipal bonds have varying levels of sensitivity to changes in interest rates. Interest rate risk is generally lower for shorter-term Municipal bonds and higher for long term Municipal bonds. No Voluntary Withdrawal – Voluntary withdrawals from Private Markets Funds generally are not permitted, which will be set forth in the fund agreements. As a result, limited partners will generally not be able to liquidate their investments prior to the end of each fund’s term. A withdrawing limited partner may not be entitled to immediate payment for its interest. Any withdrawal of a limited partner may reduce the amount of capital available for investment or other activities. Non-Discretionary and Advisory Account Risk – There may be circumstances where Aberdeen Investments provides advice in writing concerning an underlying fund or manager, but an advisory or non-discretionary client chooses not to act on that advice. Aberdeen Investments may or may not have made a discretionary investment in or with the underlying fund or manager for its discretionary clients. If, subsequently, Aberdeen Investments’ opinion of such underlying fund or manager changes and Aberdeen Investments decides to redeem from the underlying fund or manager on behalf of its discretionary clients, Aberdeen Investments may or may not inform its other clients of the decision to redeem. Therefore, advisory clients should not rely on stale advice from Aberdeen Investments to make investments in or with underlying funds or managers. Non-Diversification Risk – A portfolio may invest in securities of a relatively few issuers. Therefore, the performance of one or a small number of holdings can affect a portfolio’s overall performance. Operational Risk – A portfolio may suffer a loss arising from shortcomings or failures in internal processes, people or systems, or from external events. This risk can arise from many factors ranging from routine processing errors to potentially costly incidents related to, for example, major systems failures. Options Risk – In order for a call option to be profitable, the market price of the underlying security must rise sufficiently above the exercise price to cover the premium and transaction costs. These costs will reduce any profit that might have realized had it bought the underlying security at the time it purchased the call option. For a put option to be profitable, the market price of the underlying security must decline sufficiently below the exercise price to cover the premium and transaction costs. By using put options in this manner, an account will reduce any profit it might otherwise have realized from appreciation of the underlying security by the premium paid for the put option and by transaction costs. If a put option is sold, there is a risk that we may be required to buy the underlying asset at a disadvantageous price. If a call option is sold, there is a risk that we may be required to sell the underlying asset at a disadvantageous price. If an account sells a call option on an underlying asset that an account owns and the underlying asset has increased in value when the call option is exercised, the account will be required to sell the underlying asset at the call price and will not be able to realize any of the underlying asset’s value above the call price. For some portfolios, the ability of the portfolio to achieve its investment objective is partially dependent on the successful implementation of its option strategy. PIPEs Risk – Some portfolios may engage in private investments in public equity (“PIPE”) transactions, which involve the purchase of securities directly from a publicly traded company or its affiliates in a private placement transaction, typically at a discount to the market price of the company’s common stock. In a PIPE transaction, the portfolio may bear the price risk from the time of pricing until the time of closing. Equity issued in this manner is often subject to transfer restrictions and is therefore less liquid than equity issued through a registered public offering. The portfolio may bear the price risk from the time of pricing until the time of closing and may be subject to lockup agreements that prohibit transfers for a fixed period of time. In addition, because the offering of the securities in a PIPE transaction is not registered under the Securities Act, the securities are “restricted” and cannot be immediately resold by the investors into the public markets. Accordingly, PIPE securities may be deemed illiquid and therefore may be subject to risks associated with illiquid securities.

Passive Investment Risk – Some portfolios passively track indices. Because the portfolio is not “actively” managed, unless a specific security is removed from the index, the portfolio generally would not sell an investment because of the investment’s performance or due to our internal operational due diligence screening process. Additionally, unusual market conditions may cause the index provider to postpone a scheduled rebalance or reconstitution, which could cause the index to vary from its normal or expected composition. Therefore, the portfolio’s performance could be lower than other products that may actively shift their portfolio assets to take advantage of market opportunities or to lessen the impact of a market decline or a decline in the value of one or more investments. As the portfolio may not fully replicate the index, it is subject to the risk that the investment strategy of the Adviser or sub-adviser, as applicable, may not produce the intended results. Political and Economic Risk – Economic and/or political instability could lead to legal, fiscal and regulatory changes or the reversal of legal, fiscal, regulatory and/or market reforms. Portfolio Turnover Risk – High portfolio turnover may result in greater transaction costs which may reduce performance. The sale of portfolio securities may also result in greater realization and/or distribution to shareholders of gains or losses as compared to a fund with less active trading, which may include short-term gains taxable at ordinary income tax rates. Preferred Stock Risk – Preferred stocks include convertible and non-convertible preferred and preference stocks that are senior to common stock. Preferred stocks are equity securities that are senior to common stock with respect to the right to receive dividends and a fixed share of the proceeds resulting from the issuer’s liquidation. Some preferred stocks also entitle their holders to receive additional liquidation proceeds on the same basis as holders of the issuer’s common stock, and thus represent an ownership interest in the issuer. Depending on the features of the particular security, holders of preferred stock may bear the risks disclosed herein regarding equity or fixed income securities. Real Asset Risk – Potential liability for environmental contamination or compliance with environmental laws could result in substantial costs. The operating costs and performance of the portfolio funds generally may be affected by the obligation to pay for the cost of complying with existing environmental laws, ordinances and regulations, as well as the cost of complying with future legislation or environmental problems that materially impair the value of the portfolio funds’ properties or other investments. Investment in REITs and real estate involves the risks that are associated with direct ownership of real estate and with the real estate industry in general. REITs whose underlying properties are concentrated in a particular industry or geographic region are subject to risks affecting such industries or regions. The securities of REITs involve greater risks than those associated with larger, more established companies and may be subject to more abrupt or erratic price movements because of interest rate changes, economic conditions, and other factors. Securities of such issuers may lack sufficient market liquidity to enable a portfolio to effect sales at an advantageous time or without a substantial drop in price. The returns from REITs may trail returns from the overall market. Additionally, there is always a risk that a given REIT will fail to qualify for favorable tax treatment. REITs may be leveraged, which increases risk. Certain REITs charge management fees, which may result in layering the management fee paid by a portfolio. Real Property and Infrastructure Risk – We will be subject to the risks inherent in the ownership, operation, repositioning and development of real estate and real estate-related businesses and assets. These risks include, but are not limited to, the burdens of ownership of real estate property; general and local economic conditions; the supply and demand for properties; the competition for real estate assets; energy and supply shortages; fluctuations in the average occupancy and room rates for hotel properties; the financial resources of tenants, buyers and sellers; changes in building, environmental and other laws and/or regulations; changes in real estate property tax rates; changes in interest rates and the availability of mortgage funds which may render the sale or refinancing of properties difficult or impracticable; negative developments in the economy that depress travel activity; environmental liabilities; contingent liabilities on disposition of assets; uninsured or uninsurable casualties; natural disasters, terrorist attacks; and war and other factors which are beyond our control. There is no assurance that there will be a ready market for resale of investments because investments will generally not be liquid. Illiquidity may result from the absence of an established market for the investments, as well as legal or contractual restrictions on their resale by our firm or our investments. The yields available from equity investments in real property depend in large part on the amount of income generated and expenses incurred. If

the investments do not generate revenues sufficient to meet operating expenses, including debt service, tenant improvements, leasing commissions and other capital expenditures, clients may be required to fund or borrow additional amounts to cover fixed costs, and the cash flow of such client account (and, with respect to investment funds, its ability to make distributions to shareholders) will be adversely affected. Repurchase Agreements Risk – In the instance that an underlying fund manager enters into a repurchase agreement for a security, there can be no guarantee that the transferee of the securities in the agreement will not default. Therefore, any investment of the sort bears the risk of default of the transferee. Restrictions on Transfer and Illiquidity of Shares – The shares held in private funds, including funds of funds and the underlying funds are generally not registered under any securities laws and, therefore, cannot be resold in a public market. Consequently, investors do not have the right to withdraw their investment other than in accordance with the prescribed redemption procedures of the underlying funds. These redemption procedures may be suspended due to certain circumstances that could further affect withdrawals. This potential illiquidity of shares could adversely affect NAV and result in delays in receiving redemptions. Investors may at times be restricted from redemption from certain of our private funds. Secondary Investments – There is no established market for purchasing or selling existing portfolio fund interests (“Secondary Interests”) on the secondary market and although there has been an increasing volume of sales of Secondary Interests, no liquid market is expected to develop. Moreover, the market for Secondary Interests has been evolving and is likely to continue to evolve. It is possible that competition for appropriate investment opportunities may increase, thus reducing the number of investment opportunities available to the Funds and adversely affecting the terms upon which investments can be made. Accordingly, there can be no assurance that some of the funds will be able to identify sufficient investment opportunities or that they will be able to acquire Secondary Interests on attractive terms. In addition, in the cases where funds acquire an interest in a portfolio fund in a secondary transaction, the Funds may acquire contingent liabilities of the seller of the interest. Sector Risk – To the extent that a fund or client has a significant portion of its assets invested in securities of companies conducting business in a broadly related group of industries within an economic sector, the fund or client may be more vulnerable to unfavorable developments in that economic sector than funds that invest more broadly. Short Sale Risk – Short sales are subject to special risks. A short sale involves the sale by an account of a security that it does not own with the hope of purchasing the same security at a later date at a lower price. An account may also enter into a short position through a forward commitment or a short derivative position through a futures contract or swap agreement. If the price of the security or derivative has increased during this time, then the account will incur a loss equal to the increase in price from the time that the short sale was entered into plus any premiums and interest paid to the third party. Therefore, short sales involve the risk that losses may be exaggerated, potentially losing more money than the actual cost of the investment. Short Term Trading Risk – Short-term trading may result in increased turnover, higher than normal brokerage commissions (including soft commissions) and other expenses. SPAC Risk – Some portfolios may invest in Special Purpose Acquisition Companies (“SPACs”), collective investment structures that pool funds in order to seek potential acquisition opportunities. Unless and until an acquisition is completed, a SPAC generally invests its assets (less an amount to cover expenses) in U.S. Government securities, money market fund securities and cash. SPACs and similar entities may have no operating history or ongoing business other than to seek a potential acquisition. If an acquisition that meets the requirements for the SPAC is not completed within a predetermined period of time, the invested funds are returned to the entity’s shareholders. Investments in SPACs may be illiquid and/or be subject to restrictions on resale. Sustainable Investing Risk – Aberdeen Investments’ Sustainable strategy could cause it to perform differently compared to other strategies. Sustainable investing considerations may be linked to long-term rather than short-term returns. The criteria related to the Aberdeen Investments’ Sustainable Investing strategy, including the exclusion or inclusion of securities of companies in certain industries, sectors, regions

or countries, may result in a portfolio forgoing opportunity to buy certain securities when it might otherwise be advantageous to do so, or selling securities for ESG reasons when it might be otherwise disadvantageous for it to do so. In addition, there is a risk that the companies identified as appropriate for investment in Sustainable strategies by the Adviser do not operate as expected when addressing ESG issues. There are significant differences in interpretations of what it means for a company to have positive ESG characteristics. While the Adviser believes its definitions are reasonable, the portfolio decisions it makes may differ with other investors’ or advisers’ views. For integrated funds, to the extent the ESG factors are used to evaluate investments, the consideration of such factors may adversely affect performance. Not every ESG factor may be identified or evaluated for every investment as we focus on the most material ESG risks to understand the impact on a company’s financial and operational performance. ESG characteristics may not be the only factors considered and, as a result, the issuers in which a Fund invests may not be issuers with favorable ESG characteristics or high ESG ratings. The application of ESG factors may result in a portfolio performing differently than other products and strategies in its peer group that do not consider ESG factors. Swaps/Contracts for Differences – Swaps/Contracts for Differences involve greater risks than direct investment in the underlying securities, because swaps are subject to the risks related to “Derivatives” described above, including counterparty credit risk. These transactions or instruments are also subject to the particular risk that they could result in losses if the underlying asset or reference does not perform as anticipated. In a total return swap or contract for differences transaction, one party agrees to pay the other party an amount equal to the total return of a defined underlying asset (such as an equity security or basket of such securities) or a non-asset reference (such as an index) during a specified period of time. In return, the other party would make periodic payments based on a fixed or variable interest rate or on the total return from a different underlying asset or non-asset reference. Such transactions can have the potential for unlimited losses. Tax Reclaim Risk - Funds managed by the adviser may be entitled to tax reclaims related to portfolio holdings in certain jurisdictions. Dividend and interest income from non-U.S. portfolio holdings received by a Fund are generally subject to non-U.S. withholding taxes and are recorded on ex-dividend date. The Fund generally files for tax reclaims for the refund of such withholding taxes according to tax treaties. Tax reclaims that are deemed collectible are booked as a tax reclaim receivable for the Fund. The actual receipt and timing of receipt of a tax reclaim varies depending on the foreign jurisdiction and receipt of reclaims in certain jurisdictions may be significantly delayed. Tax Risk – Tax laws and regulations applicable to an account are subject to change, and unanticipated tax liabilities could be incurred by investors as a result of such changes. Investors should consult their own tax advisers to determine the potential tax-related consequences of investing. Underlying Manager Risk – Funds of funds will directly invest in underlying funds managed by third-party managers that may or may not be affiliated with us and over which we do not exercise control. Therefore, our funds will not have an active role in the day-to-day management of the underlying funds. Underlying managers may not be registered as investment advisers with the U.S. SEC and their funds may not be registered as investment companies. Moreover, our funds will generally not have an opportunity to evaluate the specific investments made by underlying funds. As a result, the return of our funds will depend in large part on the performance of these unrelated third-party managers. It is expected that in the instance of the redemption of assets or termination of an underlying manager, the resultant assets and cash proceeds will be invested with a replacement underlying manager. This could result in increased turnover rates and higher corresponding brokerage fees and commissions. The risk that our fund's performance is closely related to the risks associated with the securities and other investments held by the underlying funds in which it invests and that the ability of the fund to achieve its investment objective will depend upon the ability of such underlying funds to achieve their investment objectives. Some of the risks that managers of underlying funds are subject to include: • style drift; • regulatory risks; • counterparty default;

• changes in interest rates; • departure of key personnel; and • redemptions from the underlying manager’s funds. Investments in exchange-traded funds are also subject to market risk, tracking error, the potential for trading at a discount or premium to their net asset value, bid/ask spread risk as well as the risks of the underlying securities they hold. Valuation Risk – If market conditions make it difficult to value some investments, Aberdeen Investments may internally value these investments using fair value pricing or other methods in line with valuation policies and procedures. In these cases, the value determined for an investment could differ from the value realized upon such investment’s sale. The price that a portfolio could receive upon the sale of any particular investment may differ from Aberdeen Investments’ internal valuation of the investment, particularly for securities that trade in thin or volatile markets or that are valued using a fair valuation methodology or a price provided by an independent pricing service. As a result, the price received upon the sale of an investment may be less than the value ascribed by the Adviser, and the portfolio could realize a greater than expected loss or lower than expected gain upon the sale of the investment. The Adviser’s ability to value its investments may also be impacted by technological issues and/or errors by pricing services or other third-party service providers. In our funds of funds, since interests in the underlying funds may be illiquid and the underlying assets of the underlying funds may similarly consist of illiquid investments, it will be difficult to determine the market value of the interests. The value of an investment in the fund may fluctuate. Instability in the securities markets may also increase the risks inherent in the fund’s investments. No assurance can be given that the fund will return to Limited Partners all or any part of their contributed commitment. There is no established market for Secondary Interests or for the privately held portfolio investments of private investment fund sponsors, and there may not be any comparable companies for which public market valuations exist. In addition, the General Partner may not have access to all material information relevant to a valuation analysis. As a result, the valuation of Secondary Interests and co-investments may be based on imperfect information and subject to inherent uncertainties and determining fair values and negotiating favorable acquisition prices may be difficult. Value Investing Risk – As a category, value stocks may underperform growth stocks (and the stock market as a whole) over any period of time. Value investing attempts to identify companies that a portfolio manager believes to be undervalued. Value stocks typically have prices that are low relative to factors such as earnings, cash flow or dividends. A value investing style may perform better or worse than equity portfolios that focus on growth stocks or that have a broader investment style. Volatility Risk – The prices of commodities contracts and all derivatives, including futures and options, can be highly volatile. Funds are subject to the risk that trading activity in securities in which the funds invest may be dramatically reduced or cease at any time, whether due to general market turmoil, problems experienced by a single issuer or a market sector or other factors. If trading in particular securities or classes of securities is impaired, it may be difficult for a fund to properly value any of its assets represented by such securities. Warrants and Rights Risk – A strategy may purchase or otherwise receive warrants or rights. Warrants and rights generally give the holder the right to receive, upon exercise, a security of the issuer at a stated price. A strategy may use warrants and rights in a manner similar to its use of options on securities. Risks associated with the use of warrants and rights are generally similar to risks associated with the use of options. Unlike most options, however, warrants and rights are issued in specific amounts, and warrants generally have longer terms than options. Warrants and rights are not likely to be as liquid as exchange-traded options backed by a recognized clearing agency. In addition, the terms of warrants or rights may limit a strategy’s ability to exercise the warrants or rights at such time, or in such quantities, as the strategy would otherwise wish.

We occasionally may engage in business activities with some or all of these companies, subject to our policies and procedures governing how we handle conflicts of interest. We may use our affiliates to provide other services to our clients to the extent permitted under applicable law. We provide advice for numerous clients. We may advise some clients or take actions for them that differ from recommendations or actions taken for other clients. We are not obligated to recommend to clients any investments that we may recommend to or purchase or sell for other clients. Our employees regularly share information, perceptions, advice and recommendations about market trends, the valuations of individual securities, and investment strategies, except where prohibited by ethical walls established by us or by applicable law or regulation. Persons associated with us may have investments in securities that are recommended to clients or held in client accounts, subject to compliance with our policies regarding personal securities trading. abrdn Inc. has registered under the U.S. Commodity Futures Trading Commission (“CFTC”) with the National Futures Association (“NFA”) as a Commodity Pooled Operator (“CPO”). Broker-Dealer and Registered Representatives Aberdeen Fund Distributors LLC (“AFD”), a wholly owned subsidiary of abrdn Inc., is a limited-purpose broker-dealer formed to distribute our proprietary mutual funds and coordinate the private placement of our private funds. There are no trades executed through AFD. Certain of our management persons are registered, or have an application pending to register, as registered representatives of AFD. The ETFs are distributed by ALPS Distributors, Inc. (“ALPS”), which is an unaffiliated third-party broker dealer. AFD and ALPS have entered into a distribution agreement allowing representatives of ALPS to sell funds managed by abrdn Inc., and representatives of AFD to sell the ETFs. No solicitation fees are paid under either agreement, and distribution staff does not receive direct incentive or economic benefits for sales performance, other than the regular salary and bonus paid by abrdn Inc. Investment Companies We serve as an investment adviser and administrator for a number of U.S. registered investment companies. We also serve as a sub-adviser for various other U.S. registered investment companies. Investment Advisers In rendering investment advisory services, we may use the resources of additional investment adviser subsidiaries of Aberdeen Group plc. These affiliates have entered into an MOU with us pursuant to which investment professionals from each affiliate may render portfolio management, research or trading services to our clients. We may share personnel, research and other resources with our affiliated U.S. registered investment advisers (abrdn Asia Limited in Singapore and abrdn Investments Limited in the United Kingdom) and a number of unregistered foreign entities under our personnel sharing procedures. In executing trades on behalf of our clients, we may use the resources of our Aberdeen Group plc affiliates. These affiliates have entered into a global trading agreement pursuant to which professionals from each affiliate may execute trades on behalf of our clients. The use of affiliates to execute trades under the global trading agreement does not alter or change the entity making investment decisions for the client accounts. Limited Partnerships or Similar Private Funds

We sponsor and serve as investment adviser to several private funds organized as limited partnerships, limited liability companies or non-U.S. entities. abrdn Inc. and its affiliates may also serve as the general partner or managing member of these private investment vehicles. Our affiliates also serve as investment adviser to certain private funds and provide investment management services to limited partnership vehicles with U.S. investors. These funds may be domiciled in the U.S., as in the case of a Delaware partnership, or outside the U.S., as in the case of a Cayman corporation. Collective Investment Trusts We serve as investment adviser to Collective Investment Trusts (“CIT”) sponsored by unaffiliated Trust Companies. Participation in Privately Offered Investment Vehicles abrdn Inc., its affiliates, officers and employees may participate individually in privately offered investment vehicles in which clients are solicited to invest. abrdn Inc. or its affiliates may act as adviser or general partner (or in a similar capacity) to these investment vehicles, may receive management fees, and may participate in any profits generated by these investment vehicles. Participation by affiliates, officers, and employees in such investments on such terms and the receipt of such compensation may be an incentive for such employees to devote an increased amount of time to the management of such vehicles to the detriment of other client account or investment vehicles. Aberdeen Investments has policies and procedures in place to mitigate this conflict. Other Material Relationships Principals and employees of Aberdeen Investments may serve as officers, advisors, directors or provide comparable management functions for public companies and/or portfolio companies in which clients directly or indirectly invest, as well as for investment institutions that may invest in Aberdeen-managed funds. In addition, such principals and employees may provide other services to public companies and/or portfolio companies and may receive compensation in connection therewith. Principals and employees of Aberdeen Investments may be provided access to confidential information relating to public companies and/or portfolio companies in which clients may directly or indirectly invest. As a result, clients may, under certain circumstances, be prohibited for a period of time from engaging in transactions with respect to the securities of such public companies and/or portfolio companies, which prohibition may have an adverse effect on clients. Selection or Recommendation of Other Advisers Aberdeen Investments may select other investment advisers for its clients. Business Alliances Our strategic partnerships and associate businesses play a vital role in our global distribution model as an effective way to reach clients in key markets around the world. The following summary provides an overview of our more significant business alliances: Standard Life (formerly Phoenix Group) In February 2021, Aberdeen Investments announced the reshape and refocus of the existing relationship with Phoenix Group (“Phoenix”) so that both companies can be strong independent partners for the next 10 years, focused on growing their own respective businesses and growing their partnership in asset management. To this end, Aberdeen Group plc sold the Standard Life brand to Phoenix Group which simplifies and clarifies the original sale of our Standard Life long-term insurance business. In February 2025, Phoenix completed its name change to Standard Life PLC (“Standard Life”). Aberdeen Group plc currently owns 10.4% of Standard Life. Heng An Standard Life Heng An Standard Life (HASL) is a life insurer owned 50% by Aberdeen Group plc and based in Tianjin, China. It is not a listed company. It was formed in 2003 as a joint venture between Standard Life plc and Tianjin TEDA International (“TEDA”). TEDA is the Tianjin Economic-Technological Development Area; it is the state-owned Tianjin economic enterprise board. HASL has 10 provincial branches across 8 provinces

and sales offices over 80 cities and offers a comprehensive suite of health, life and savings products. Assets are managed by HASL’s in-house investment team. In July 2020 HASL purchased an insurance subsidiary in Hong Kong from Aberdeen Group plc. In January 2021 HASL was granted permission to open a pensions insurance company in China and recently launched its first pension product. Archax In August 2022, Aberdeen Group plc made a $20m investment in Archax, a UK-based digital asset exchange. Aberdeen Investments then made a follow-on investment of $1m in October 2025 bringing Aberdeen Investments’ stake in Archax to 11.0%. Archax provides access to blockchain-based digital assets and is the first digital securities exchange to be approved by the FCA with permissions covering trading, custody and brokerage. Aberdeen Group plc’s strategic partnership with Archax allows investors to access investment opportunities through digital securities, connect to existing offerings in a new way through tokenization and facilitate a shift towards greater operating efficiencies through the adoption of new technologies like blockchain. Stagecoach Aberdeen Investments has agreed to replace Stagecoach as the sponsoring employer of the Stagecoach Group Pension Scheme (“SGPS”). This deal enhances benefits for over 22,000 members and includes an initial uplift of 1.5% to pensions and better inflation protection. Aberdeen Investments will manage the SGPS’ assets and take on responsibility for its funding, ensuring long-term security and potential for further benefits linked to the scheme’s financial performance.

The Code mitigates potential conflicts of interest by requiring, among other things, pre-clearance of transactions in Reportable Securities (as defined in the Code) placed in reportable accounts. The Code restricts the purchase and sale by Access Persons for their accounts of Reportable Securities, which have been purchased or sold for funds or clients within specified time limits. Except under certain limited circumstances, Access Persons may not engage in a personal transaction in a Reportable Security for which an order for a fund or client is pending or within seven (7) calendar days before or after execution of a client order. This blackout period does not apply to transactions in certain large cap securities of a de minimis value. Access Persons are subject to reporting obligations, including completing quarterly transaction and annual holdings reports. Access Persons are required to direct their brokers to send copies of all brokerage confirmations and statements to their local Risk & Compliance Department. Alternatively, Access Persons can have the information sent by the broker via electronic feed, if available. Our procedures recognize that some Access Persons either reside in countries or maintain brokers where such statements are not regularly issued or available, and therefore these individuals are exempt from providing quarterly statements within a specific time period. In such circumstances, brokerage statements or their equivalent holdings reports must be provided as available. Employees must fully acknowledge the terms of the Code on an annual basis. Any employee who violates the Code may be subject to verbal or written warnings and censures, monetary sanctions, disgorgement, suspensions or dismissal, among other punitive actions. Additionally, the Code includes provisions for employees relating to the confidentiality of client information, a prohibition on insider trading, a rumors policy, dollar restrictions on the value of accepted gifts and entertainment and requires that certain outside business activities are approved in advance. Clients or prospective clients may request a free copy of the Code by contacting Aberdeen Investments at (215) 405-5700. Our Approach to Potential Conflicts of Interest Various parts of our brochure discuss potential conflicts of interest that arise from our asset management business model. We disclose these conflicts due to the fiduciary relationship we have with our clients. Where potential conflicts of interest arise from our fiduciary activities, we take steps to mitigate, or at least disclose, them. Conflicts arising from fiduciary activities that we cannot avoid are mitigated through written policies and procedures and/or otherwise disclosed. Potential conflicts may arise from new products or services, operational changes, new reporting lines and market developments. Gifts and Entertainment We have policies and procedures in place which prohibit employees from accepting gifts, entertainment and other things of material value that may create a conflict of interest or give the appearance of a conflict of interest. Additionally, our employees may not offer gifts, entertainment or other things of material value that could be viewed as attempting to unduly influence the decision-making of any client or other business partner. In general, our policies dictate that giving and receiving gifts or participating in entertainment cannot occur if the value and/or the frequency of the gift or entertainment are deemed excessive or extravagant. The policies impose specific dollar restrictions and require compliance approval of gifts and entertainment. Additional restrictions regarding gifts apply to our employees who are registered representatives of our affiliated brokerdealer. Participation or Interest in Client Transactions

Potential conflicts of interest may exist if an investment adviser or one of its related persons buys or sells for client accounts, securities in which the adviser or a related person has a material financial interest. We may recommend to clients that they buy or sell shares of an investment company or other investment product in which we have some financial interest by serving as adviser or sub-adviser to a fund or other product. Some of the private funds that we manage are subject to a performance-based incentive fee. Employees providing advice to these funds may also hold interests in such performance-based funds and may also provide investment advisory services with respect to similarly managed accounts that are not subject to performance fees. Aberdeen Investments has also established and seeded a number of Incubator Accounts for the purpose of establishing a performance record to enable abrdn Inc. or one of its affiliates to offer such a portfolio’s investment style to clients. Aberdeen Investments will from time to time invest in the same securities as other client accounts. A conflict of interest exists because Aberdeen Investments will benefit from the favorable investment performance of the Incubator Accounts. In order to address such potential conflicts of interest Aberdeen Investments has allocation policies and restrictions that equally apply to these accounts. We may manage accounts similarly in that we may buy or sell the same securities for private funds, Registered Funds, segregated mandates and other account types. These transactions must be consistent with our trade allocation procedures so that no client is favored over another. In addition, and only in accordance with our policies and procedures, employees are permitted to invest in securities (including those recommended to clients) for their own accounts. abrdn Inc. may recommend to clients other products offered by abrdn Inc. or our affiliates. abrdn Inc. may also invest funds into other funds managed by abrdn Inc. or our affiliates. In these instances, it may appear that our interest in selling the product or service could conflict with the client’s expectation. Where we direct clients into an Aberdeen-managed product or strategy, we will obtain client consent. Where investing in Aberdeen-managed products on behalf of fund vehicles, management fees for the affiliated fund may be waived in order to avoid conflicts of interest and to comply with applicable regulatory requirements. Our officers or directors may sit on the boards, and board committees, of publicly traded clients. In addition, employees may buy or sell securities for a client where we may have a material interest in a security or issuer of a security. A material interest could include owning a security, office, directorship, significant contract, interest or relationship which is likely to affect the person’s judgment. In these cases, abrdn Inc. or our employees could benefit from the success of a client’s investments because of our interest in the security or issuer of the security. We maintain procedures to mitigate these potential conflicts. We may purchase and sell securities for accounts funded with our own assets, which also is known as “seed capital.” These accounts are intended to establish a performance history for a new or potential product or service. We may earn a profit on our seed capital investments. Adviser for Multiple Accounts We serve as investment adviser or sub-adviser to client accounts, including registered investment companies. Consistent with our fiduciary obligations, we may give advice with respect to funds or accounts we manage that may differ from action taken by our firm on behalf of other funds or accounts. We are not obligated to recommend, buy or sell–or to refrain from recommending, buying or selling–any security that any of abrdn Inc., our affiliates or our Access Persons, may buy or sell for their own accounts or for the accounts of any other client. Any company associated with abrdn Inc. that wishes to purchase or sell securities of the types purchased for clients may do so only in a manner consistent with our fiduciary obligations. We are not obligated to refrain from investing in securities held by funds or accounts it manages, except if the investments violate the Code. Insider Trading and Use of Expert Networks We have adopted market conduct policies and procedures in accordance with Section 204A of the Advisers Act, which establishes procedures to prevent the misuse of material non-public information by abrdn Inc., our officers, directors and employees. Any officer, director or employee who fails to observe the insider trading policy risks serious sanctions, including dismissal and personal liability. From time to time, employees of abrdn Inc. may obtain, either voluntarily or involuntarily, material non- public information that is not available to other investors or other confidential information which, if disclosed, would

likely affect an investor’s decision to buy, sell or hold a security. Such information may be provided from various possible sources including upon execution of a non-disclosure agreement, as a result of serving on the board of directors of a portfolio company or serving on ad hoc or official creditors' committees. Under applicable law, employees are generally prohibited from disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether that person is an Aberdeen Investments client. Accordingly, should an employee receive, either voluntarily or involuntarily, material non-public information with respect to an issuer, it may be prohibited from communicating such information to, or using such information for the benefit of, clients, which could limit the ability of clients to buy, sell or hold investments and can also result in an underlying security or investment being priced inconsistently across clients. Even if abrdn Inc. or our affiliates request material non-public information, abrdn Inc. shall have no obligation or responsibility to disclose such information to, or use such information for the benefit of, any person (including abrdn Inc. clients), even if failure to do so would be detrimental to the interests of such person. In this connection, abrdn Inc. has adopted policies governing the treatment of material non-public information, and established procedures reasonably designed to prevent the misuse of material non-public information by abrdn Inc. and our personnel. Under the policy, abrdn Inc. employees are not permitted to use material non-public information obtained by any department or affiliate of abrdn Inc. in the course of its business activities or otherwise, in effecting purchases and sales in securities transactions for our clients or for their personal accounts. Consequently, we may not be able to engage in investment activity that they would otherwise take were they not in receipt of such information, even if a failure to act on such information may ultimately be detrimental to our clients. In addition, use of such information would also be prohibited by the policies referenced herein. Aberdeen Investments may utilize expert network services to obtain market, sector, company or other information. There may be an inherent conflict of interest in such arrangements as the experts are financially incented to provide information to justify their position within the network. Aberdeen Investments has policies and procedures in place to deal with such conflicts as well as risk of receiving inside information via the use of expert network services. Other Conflicts of Interest From time to time, clients or certain financial intermediaries may approach abrdn Inc. to request that we make contributions to certain charitable or political organizations. Because our contribution may result in the financial intermediary or our employees or representatives recommending us or our affiliated investment advisers’ products to their underlying clients, the solicitation or contribution raises potential conflicts of interest. Consequently, we maintain procedures to ensure that charitable contributions are not made for the purpose of influencing business and a Political Contributions Policy, which places restrictions on firm and employee political contributions. Moreover, there may be certain circumstances where a fund has closed, or a client has terminated and unanticipated proceeds have subsequently been paid to the fund or client. In such a circumstance, where it is impracticable and/or or uneconomical (e.g., the estimated costs of escheating the entire remaining amount, including the costs of an escheatment specialist, mailing, legal, check distribution, etc.) to find and remit the proceeds to the fund or client or escheat the proceeds to a state or where the amount is de minimis, then such proceeds may be donated to a third party 501(c)(3) charitable organization, as selected by an appropriate delegate of abrdn Inc., e.g., a charitable committee. In the instances of Private Fund closures, if any such unanticipated proceeds have been received more than two years following the closure, the Adviser will remit the unanticipated proceeds back to the issuer or, if impossible to do so, donate the proceeds to charity, unless such proceeds exceed $200,000, in which case the abrdn Inc. Board of Directors will determine if alternative actions should be considered. None of Aberdeen Investments’ funds or assets may be contributed to any U.S. political candidate or political party. This ban includes contributions to U.S. political action committees (“PACs”). Additionally, employees are prohibited from making contributions to any person running for or holding a U.S. city, county, state or other municipality-related position. This prohibition includes contributions to U.S. city, county, state or other municipality-related PACs.

Access Persons are permitted to serve on the boards of directors of non-profit organizations such as educational institutions, charitable foundations, or other civic organizations. Access Persons are not permitted to serve on the board of directors of any publicly traded company without prior authorization. Authorization is generally based upon a determination that the board service would not bring Aberdeen Investments into disrepute and has been considered appropriately in terms of actual or potential conflicts. In general, all Access Persons’ outside business activities are tracked and reviewed by abrdn Inc.’s Risk & Compliance Department to ensure they do not conflict with the duty that we owe to clients.

In selecting broker-dealers and in effecting portfolio transactions we seek to obtain best execution. As described in more detail further below under Commission Rates, we will not select broker-dealers solely on the basis of commission rates and steps associated with seeking best execution include: (1) determining each client’s trading requirements; (2) selecting appropriate trading methods, venues, and agents to execute the trades under the circumstances; (3) evaluating market liquidity of each security and taking appropriate steps to avoid excessive market impact; (4) maintaining client confidentiality and proprietary information inherent in the decision to trade; and (5) reviewing the results on a periodic basis. We review the above criteria on an ongoing basis. We do not consider the sales of shares of Registered Funds it advises as a factor in the selection of broker-dealers to execute portfolio transactions for a Registered Fund. When selecting or recommending for client transactions, a broker or service provider, we will consider, among other things, the following:

Professional reputation; Ability to provide clear, impartial and expert advice; Understanding of and presence in the relevant market; and Potential for or actual conflicts of interest.

If a client requires preauthorization of trades, such trades may not be commingled or “batched” for purposes of execution with orders for the same securities for other accounts we manage. Therefore, such trades may be executed subsequent to the trades executed for other accounts we manage and at different prices and commission rates which may be better or worse than the rates received for batched trades. We may use Electronic Communications Networks (“ECN”) or Alternative Trading Systems (“ATS”) to execute when, in our judgment, the use of an ECN or ATS may result in equal or more favorable overall executions for the transactions. With regards to our Alternative Investment Solutions (“AIS”) products, we do not arrange trades with any broker or dealer; our fund of hedge funds does not typically use brokers to transact for funds or third-party clients as the investments made for such clients are generally in open-ended investment funds engaged in a continuous offering. In assessing a firm’s trading controls, AIS would expect the Manager to have in place a formal best execution policy prescribing the roles and processes involved in order to achieve the desired trading outcomes. AIS will discuss with the third-party Manager how best execution of trading is formally reviewed as a part of the firm’s risk committee and that sufficient reporting is produced detailing performance and exceptions. AIS would also expect to see a daily review of executed trades undertaken whereby any trades with an inconsistent price relative to similar trades in instruments at the time of execution would be investigated. AIS will also review the oversight of Compliance in terms of the sufficiency of the sample size reviewed relative to the firm’s overall trading, examples of where Compliance monitoring of best execution has identified failures or weaknesses and an assessment as to what extent Compliance is confirming procedures have been followed versus challenging whether best execution has actually been achieved. The advice and investment activity conducted with regards to property funds generally relates to privately offered securities in partnerships or similar relevant structures that invest in real estate or real estate-related assets. We may invest in property funds which are marketed to abrdn Inc. by placement agents; either the fund or the third-party manager bears the associated placement agent fees. Occasionally, we may recommend the purchase of a secondary interest in a privately offered security being offered by a broker. In such cases, clients

may be required to pay a fee to the broker offering the interest on behalf of a seller. We do not receive client referrals from broker-dealers or third parties. For funds of funds, investments in open-ended investment funds are facilitated through the appropriate transfer agent. On occasion, our hedge funds client portfolios may receive security positions as part of a distribution or liquidation of an underlying fund or special purpose fund. While we generally execute transactions in these securities through the same broker-dealer where the Aberdeen Investments fund’s account was established, there are no limitations on which broker-dealers may be used or the commission rates or similar charges paid. For Commodity ETFs, the funds’ sub-adviser is responsible for trading portfolio securities on behalf of the Funds, including selecting broker-dealers to execute purchase and sale transactions or in connection with any rebalancing or reconstitution of the Index, subject to the supervision by abrdn Inc. In selecting the brokers or dealers for any transaction in Commodities Instruments, the selection is based on factors deemed relevant, including but not limited to, the breadth of the market in the security or instrument; the price of the security or instrument; the reasonableness of the commission or mark-up or mark-down, if any; execution capability; settlement capability; back office efficiency; and the financial condition of the broker, dealer or counterparty, both for the specific transaction and on a continuing basis. The overall reasonableness of commissions paid is evaluated by the sub-adviser, subject to supervision by abrdn Inc., based upon its knowledge of available information as to the general level of commissions paid by other institutional investors for comparable services. Brokers may also be selected because of their ability to handle special or difficult executions, such as may be involved in large block trades, less liquid securities, broad distributions, or other circumstances. Certain clients may have similar investment mandates; however, investment opportunities, strategies, or specific purchases or sales vary in amounts, terms or timing. In connection with creation and redemption orders for the ETFs that consist of cash, Aberdeen Investments may select to transact with the creating or redeeming Authorized Participant in their capacity as broker dealers for the purchase or sale of securities due to their ability to manage such large block trades or for other reasons. With respect to advisory model delivery accounts (including UMA accounts) and advisory or discretionary SMA accounts, abrdn Inc. will utilize a third-party service provider to deliver model portfolio recommendations and model changes to the Sponsors or TAMPs. abrdn Inc. seeks to treat clients fairly and equitably over time, by delivering model changes to our service provider and investment instructions for our other discretionary accounts to our trading desk, where possible, simultaneously for certain strategies or approximately at the same time for other strategies. The service provider will then deliver the model changes to each Sponsor or TAMP on a when-traded, randomized full rotation schedule. All Sponsors and TAMPs that receive model changes will be included in the rotation schedule. With respect to Municipal SMA accounts which do not utilize a model delivery approach, abrdn Inc. will be responsible for trading portfolio securities on behalf of the clients in a third-party trading system. Brokers-dealers selected to execute purchase or sale transactions include those on the Aberdeen Investments approved list. UMA Sponsors will be responsible for determining how and whether to implement the model portfolio or model changes and implementation of any client specific investment restrictions. The Sponsors are solely responsible for determining the suitability of the model portfolio for each model delivery client, executing trades and seeking best execution for such clients. As it relates to SMA accounts, abrdn Inc. will be responsible for managing the account on the basis of each client’s financial situation and objectives, the day-to-day investment decisions, best execution, accepting or rejecting client specific investment restrictions and performance. The SMA Sponsors or RIAs will collect suitability information. For dual contract SMAs, abrdn Inc. will confirm suitability of the client in the investment strategy based on the client’s investment objectives, time horizon, and risk tolerances. Our thirdparty service provider will monitor client specific investment restrictions on a day-to-day basis, except for our Municipal SMA accounts which will be monitored by our internal team in a third-party trading system. For equity SMA accounts, trades will be traded by the Sponsor or may be executed through a “step-out transaction,”- or traded away- from the client’s Sponsor if doing so is consistent with Aberdeen Investments’ obligation to obtain best execution. For fixed income strategies, Aberdeen Investments is responsible for the execution and allocation of trades. When placing trades, we will generally aggregate orders where it is possible

and in the client’s best interests. In the event we are not comfortable that a Sponsor can obtain best execution for a specific security and trading away is infeasible, we may exclude the security from the model. When trading away, trading costs are not covered by the Wrap Program fee and may result in additional costs to the client. In some instances, step-out trades are executed without any additional commission, mark-up, or mark-down, but in many instances, the executing broker-dealer may impose a commission or a mark-up or mark-down on the trade. Typically, the executing broker will embed the added costs into the price of the trade execution, making it difficult to determine and disclose the exact added cost to clients. In this instance, these additional trading costs will be reflected in the price received for the security, not as a separate commission, on trade confirmations or on account statements. In determining best execution for SMA accounts, abrdn Inc. takes into consideration that the client will not pay additional trading costs or commission if executing with the Sponsor. While UMA accounts are invested in the same strategies and may perform similarly to SMA accounts, there are expected to be performance differences between them. There will be performance dispersions between UMAs and other types of accounts because Aberdeen Investments does not have discretion over trading and there may be client specific restrictions for SMA accounts. Certain operational differences in the trade execution process and timing of cash flows may result in Aberdeen Investments having already commenced trading for its discretionary client accounts before the model delivery and SMA accounts have executed Aberdeen Investments' recommendations. In this event, trades placed for the model delivery and SMA clients may be subject to price movements, particularly with large orders or where securities are thinly traded, that may result in model delivery and SMA clients receiving less favorable prices than our other discretionary clients. Aberdeen Investments has no discretion over transactions executed by model delivery clients and is unable to control the market impact of those transactions. These timing delays or other operational factors associated with the implementation of trades may result in advisory and model delivery and SMA clients receiving materially different prices relative to other client accounts. In addition, the constitution and weights of stocks within model portfolios may not always be exactly aligned with similar discretionary accounts. This may create performance dispersions within accounts with the same or similar investment mandate. Commission Rates We seek to minimize the expenses incurred for effecting portfolio transactions to the extent consistent with the interests and policies of our clients. However, we will not select broker-dealers solely on the basis of “posted” commission rates. We will not always seek in advance competitive bidding for the most favorable commission rate applicable to any particular portfolio transaction. Although we generally seek competitive commission rates, we will not necessarily pay the lowest commission. Transactions may involve specialized services on the part of the broker-dealer involved, resulting in higher commissions. The reasonableness of commissions is based on the broker-dealer’s ability to provide best execution. For Equities, a global commission rate analysis is completed at least annually using external data, and from these results we maintain a rate card for standard execution and electronic trading. The rates used may still occasionally deviate from these in certain circumstances. Fixed income trades are placed based on best price and execution as determined by our review of solicited bids/offers. We may contact several companies in soliciting any bid/offer. Potential avenues of execution are placed in competition with one another to the extent reasonably possible whenever the portfolio managers look to buy or sell a bond. One of our measures of achieving best execution is executing a transaction with a qualified and capable counterparty that bids or offers the most favorable price under the circumstances. When buying or selling fixed income securities in dealer markets, we may prefer to deal directly with market-makers in the securities. We will typically affect these trades on a net basis and will not pay the market-maker any commission, commission-equivalent or markup/markdown other than the “spread.” A “spread” is the difference between the price paid (or received) by our firm and the price received (or paid) by the marketmaker in trades with other broker-dealers or other customers. Brokers through whom we execute trades may receive compensation from exchanges, market-makers and other intermediaries related to orders routed by the broker to those intermediaries.

In appointing a broker or service provider for client transactions, we will consider the proposed level of fee given, among other things:

The scope of activities to be undertaken in relation to the client transaction; Local market rates for the activities to be undertaken in relation to the client transaction; and The ability to deliver the transaction in a timely fashion and in the best interest of the client.

Research As a result of MiFID II requirements, Aberdeen Investments pays “execution only” commission rates, paying for research for equities out of its assets. Aberdeen Investments does not engage in commission sharing arrangements or “soft dollars”. While our policy is to seek best execution, we may select a broker for a portion of our trades which charges higher transaction costs if we determine in good faith that the cost is reasonable in relation to the value of the brokerage services provided. Despite these potential conflicts, we believe that we are able to negotiate costs on client transactions that are competitive and consistent with our policy to seek best execution. In addition, we do not enter into agreements or understandings with any brokers regarding the placement of securities transactions because of the research they provide. However, we do have an internal procedure for allocating transactions in a manner consistent with our execution policy to brokers that we have identified as providing superior executions and research of particular benefit to clients. Brokerage for Client Referrals We may use solicitation agreements. We do not consider, in selecting or recommending broker-dealers, whether we or an affiliate have a relationship with a broker-dealer or third party, or whether we or an affiliate receive client referrals from a broker-dealer or third party. A client may direct us to use the services of a particular broker-dealer in executing transactions for that client’s account. In some cases, the directed broker may have recommended our firm as a manager for that account. As stated previously, it is possible that such an account may suffer adverse effects from this direction, depending on market conditions. Directed Brokerage We do not routinely recommend, request or require that any client execute transactions through any specific broker or service provider. However, we occasionally receive requests from clients to direct a portion or all of the commissions earned on their account through a specific broker-dealer in order to generate a benefit for the client under such terms and arrangements as the client may negotiate with the particular broker or dealer. Where a client has directed the use of a particular broker-dealer, we may not be in a position to freely negotiate commission rates or spreads, to obtain volume discounts, or to select broker-dealers on the basis of best execution. In situations where the client has directed us to direct trades to a select broker, the client must forfeit best execution and should understand that we will enter into such arrangements on a “best efforts” basis. If a client directs us to use a particular broker-dealer for a transaction, it will not be commingled or “batched” for purposes of execution with orders for the same securities for other accounts we manage. Client-directed transactions may result in higher commissions, greater spreads, or less favorable net prices than might be the case if we were empowered to freely negotiate commission rates or spreads, or to select broker-dealers on the basis of best execution. It is abrdn Inc.’s policy to accept these requests only under certain circumstances. With regard to the hedge funds in which clients invest, securities are generally purchased directly from the issuer or general partner, without the assistance of a broker‐dealer and without the payment of a brokerage commission. With regard to securities distributed from the underlying funds in which Aberdeen Investments clients invest, Aberdeen Investments has discretion to select a broker‐dealer to effect securities transactions. In selecting broker‐dealers to effect securities transactions, Aberdeen Investments seeks to obtain best execution by considering factors including, but not limited to, execution quality, price, the level of service offered, reliability, experience in liquidating distributions from hedge funds and other such factors as Aberdeen Investments deems relevant and beneficial to the applicable Aberdeen Investments clients. Broker‐dealers utilized by Aberdeen Investments are reviewed on an ongoing basis.

We may have certain accounts that were referred to us through the recommendation of third parties, including consultants that may also be broker-dealers, or may have certain pre-existing financial arrangements or relationships with a particular broker-dealer. Clients obtained from these third parties may instruct us to direct some or all of their brokerage transactions to the third party’s broker-dealers, or we may otherwise allocate brokerage to these or related broker-dealers. As stated previously, in situations where the client has directed us to direct trades to a particular broker, the client must forfeit best execution and should understand that we will only enter into such arrangements on a “best efforts” basis. We may also buy from such third parties certain services or products used in our investment advisory business (such as software or research publications) or pay registration or other fees toward or otherwise assist in sponsoring such third parties’ industry forums, seminars or conferences. We do not use client commissions to pay for these services. Trade Errors and Corrections In the event that we identify a trade error, our policy states that we ensure that the error is resolved in the best interests of the client. We review all trade errors to ensure they are resolved timely and accurately and the client account is put in a position as if the error had not occurred. Trade errors resulting in losses to client accounts will be compensated accordingly. To the extent a trade error in a client account results in a gain, we allow the client to keep the benefit, unless the gain offsets a related loss, in which case any such gains and losses are netted unless prohibited by applicable regulation or a specific agreement with the client. In general, compensation is expected to be limited to direct monetary losses and will not include any amounts that abrdn Inc. deems to be speculative or uncertain, nor will it cover investment losses not caused by the error. Sub-advisers are responsible for their own execution of trades and are therefore not covered under Aberdeen Investments’ Trade Error Governance Principles. Sub-advisers are, however, expected to have sufficient policies and procedures with regards to trade error management that are in line with Aberdeen Investments’ policy. abrdn Inc. will, when appropriate, review sub-adviser trade error policies and procedures and periodically review with the sub-advisers whether any trade errors were resolved in conformity with policies and procedures disclosed to Aberdeen Investments. Cross-Trades We may cross-trade between and among certain client accounts, including certain of our SMA accounts, in accordance with our written cross-trading procedures. We will only consider engaging in cross-transactions to the extent permitted by applicable law and will, to the extent required by law, obtain the necessary client consents. Clients may revoke their consent for agency cross-transactions at any time. When a potential cross trade involves a fund or account that has a significant beneficial ownership by Aberdeen Investments or its affiliates and control persons, it will be considered whether this transaction should be treated as a principal transaction under Aberdeen Investments’ procedures (and separate criteria would apply), rather than as a cross transaction. Under Aberdeen Investments’ procedures, cross trades are not permitted from or to any fund or other account deemed to comprise “plan assets” pursuant to regulations under the Employee Retirement Income Security Act of 1974, or to or from a Registered Fund, without consideration of additional regulatory restrictions or approvals that are required by applicable law. Cross Transactions are also prohibited with our Incubator Accounts. For fund of fund products, we could in some instances arrange for a transaction between two or more of the funds, in which one fund buys an interest in an underlying fund or other investment from, or sells such investment to, another fund managed by Aberdeen Investments. Each of these cross transactions is affected at “fair value,” which is generally the Net Asset Value of the underlying fund. Aberdeen Investments receives no compensation (other than its management fee and incentive fee), directly or indirectly, for effecting a particular cross transaction. Although Aberdeen Investments will receive no compensation for cross transactions, underlying funds may assess customary transfer fees or commissions in connection with any such cross transaction. Cross transactions may inure to the benefit of the selling and buying funds. Avoidance of redemption fees, taking on aged positions with the avoidance of soft and hard lockups, and the preservation of high water marks, are examples of other value added benefits that can inure to the benefit of the buying or selling funds when applicable.

Foreign Exchange (“FX”) Transactions We may execute currency transactions on an active basis through our currency trading desk, except where market restrictions in some emerging currencies exist and execution for trade settlement is arranged by the custodian directly. In addition, certain of our asset management clients may direct their currency trades to their custodian banks for execution via standing instructions, and in such cases as well as in the case of restricted emerging currencies, we may not know the precise execution time of the FX trade and cannot influence the exchange rates applied to these trades. Aggregation and Allocation We may, to the extent appropriate, permissible and/or feasible, aggregate multiple client orders for the purchase or sale of the same security to achieve best execution. Part filled orders are allocated to those clients participating in the order on a pro-rata basis (subject to rounding and certain minimum size thresholds). If prorata allocations are deemed inappropriate, we may implement an alternative approach in order to deliver fair access to trading opportunities for all eligible accounts. In the instance that an order is not completed on the same trading day, the partial fill will be allocated pro-rata among participating clients, unless otherwise directed or deemed inappropriate for best execution. Any unexecuted orders will continue until the block order is complete. We seek to allocate opportunities to all clients in a consistent, fair manner. In accordance with our written policies and procedures, we may take special considerations when deciding on allocations, provided they are deemed fair and equitable to all clients. These special considerations may include–but are not limited to–cash flow changes; specialized investment objectives or restrictions of a particular client; specific bond trades; directed brokerage; limit orders; market restrictions; lot size; open bulk orders (market-to-market); new portfolio fundings; fungibility of certain security types; or new issuance allocations (debt or equity). Allocations may also take into consideration factors such as the particular market restrictions, size, nature, identity, or number of positions in a client’s portfolio, concentration and size of holdings, industry and sector exposure, purchase cost and cash availability, ability to obtain meaningful position sizes, liquidity, investment imbalances, prior participation in similar opportunities, limitations on the availability of an investment, special needs, trading considerations, whether the allocation would result in an account receiving an amount lower than the typical transaction size or an “odd lot”; and other factors. Aberdeen Investments does not typically aggregate orders for its hedge fund clients. For such clients we seek to allocate transactions and opportunities among the various accounts in a manner we believe to be as equitable as possible over time, considering each account’s objectives, programs, limitations and capital available for investment. AIS has fair allocation policies and procedures for managing the allocation of any new but limited capacity in a third-party fund which is deemed a suitable investment for more than one client portfolio. We apply the same general principles equally to decisions on which underlying funds or managers would be suitable to be recommended for advisory clients as for making decisions to invest for discretionary clients. However, since Aberdeen Investments does not have discretion over allocation decisions in advisory accounts, it is likely that the actual allocations will differ as between discretionary and advisory accounts. In addition, there may be situations where we provide advisory advice concerning an underlying fund or manager where there is no discretionary account for which the underlying fund or manager is suitable (or where there is no cash available in the discretionary account to make an investment) or vice versa. There may also be situations where Aberdeen Investments advises an advisory client not to invest in an underlying fund or manager, but in which Aberdeen Investments does make an investment for its discretionary accounts. Finally, there may be situations where an advisory client sources an underlying fund or manager and asks for Aberdeen Investments’ advice, and even if Aberdeen Investments provides a favorable opinion on that underlying fund or manager, Aberdeen Investments may not invest in an underlying fund or manager for a variety of reasons. The results of any of these scenarios could, and it should be expected will, reasonably result in a divergence in performance between and among the various accounts over which Aberdeen Investments acts with discretion and for which Aberdeen Investments provides advisory advice. We engage in real assets, real estate, and concession infrastructure asset and investment management activities for a limited number of clients; this creates the potential for a conflict of interest when allocating deals between clients. In order to manage any such conflict, we operate a deal introduction and allocation procedure which is intended to fulfill a number of criteria:

Providing a practical, consistent and efficient method of deal introduction and deals allocation; Ensuring consistent fair and equal treatment of clients in deal introduction and deals allocation; Ensuring compliance with requirements in Investment Management Agreements in connection with deal introduction and deals allocation; and Providing a transparent and auditable control for deal introduction and deals allocation.

Representing several investors typically works to the benefit of all, but conflicts between different mandates can arise if there were a limited number of units available in a specific fund and where different clients have the similar investing preferences at the same time. If this scenario arises, we would run a fully transparent process where we would inform the clients about the situation. We would then offer to split the available units between the different parties, on a pro-rata (to their individual applications) basis. We may make co-investments along with clients in Private Markets Funds. When undertaking investment management activities for clients, the duty owed to that client shall prevail over any owed to Aberdeen Investments, to its managers, employees or any other person directly or indirectly linked to Aberdeen Investments by control or to any other third party, including any other client. When opportunities for coinvestments arise, Aberdeen Investments may allocate any such opportunities in its sole discretion but typically takes into consideration factors like the basis of the size of investor’s investment or assets managed by Aberdeen Investments, an investor’s stated desire to participate in co-investments, Aberdeen Investments’ determination of the appropriateness of offering a co-investment opportunity, an investor’s ability to execute such offer and the approval of transaction counterparties, and/or the benefit of a strategic partnership with the investor or a third party. Any investor participating in a co-investment must satisfy independently the investor qualification standards and other regulatory conditions applicable to such co investment and, in any event, Aberdeen Investments and its affiliates shall reserve the final right to accept or reject the participation of such investors in the co-investment opportunity. Inevitably, not all clients, including clients with similar investment strategies, can participate in every investment opportunity, and clients who do participate in an investment cannot always participate to the same degree. abrdn Inc. may determine that a limited supply of a particular opportunity or investment or other factors noted above may preclude the participation of some clients in a particular investment opportunity or trade. Similarly, when abrdn Inc. determines to exit a position for some clients, other clients may not always participate, may not participate at the same time, or may not participate to an equal degree. In order to address potential conflicts of interest all are subject to pro-rata allocation procedures. Any exception to pro-rata allocation requires further review and approval. Where transactions for an account are not aggregated with other orders, including directed brokerage accounts, or not netted against orders for the account or other accounts, the account may not benefit from a better price, lower commission rate, or lower transaction cost. Aggregation and netting of trades may disproportionately benefit some accounts relative to other accounts due to the relative amount of savings obtained. In order to avoid conflicts arising from limited capacity available for investment in or with an underlying fund or manager that is identified as suitable for investment by both an advisory client and by Aberdeen Investments for its discretionary accounts, Aberdeen Investments will apply procedures that are designed to create a fair result under the circumstances.

Depending on the asset class and account type, reviews of rules are conducted during daily pre- and post-trade monitoring, as well as coding updates prompted by changes in mandate investment guidelines and regulatory updates. Any coding discrepancies are addressed during this process. The team is included in the system’s change of mandate workflows, and any change automatically necessitates a review of the rules. Periodic reviews may also be undertaken to ensure compliance with client investment guidelines. We have policies and procedures in place to address any investment guideline breaches. Private Markets Fund investments are generally not monitored on our trade order management system. However, due to these mandates having broad restrictions and because subscriptions and redemptions in these asset classes are generally only offered periodically, compliance with their investment guidelines are performed as part of the ongoing investment due diligence process. AIS portfolio guidelines are coded into another order management system, which provides systematic pre-trade and post-trade guideline checking. For investment guidelines which cannot be automated in a system, the private market teams undertake manual monitoring on a risk-based approach. Reports to Clients We provide each client with written monthly or quarterly market and investment reports, which include cash balance, transaction records, position reports and account valuation. Additional reports may be provided upon a client’s request.

Where applicable, cash payments for client solicitations will be structured to comply fully with regulatory requirements. In some cases, we make revenue sharing payments to advisory firms to promote our sub-advisory services or for placing our advisory services on their preferred or recommended list. The presence of these revenue sharing payments and the basis on which an advisory firm compensates its professional may create an incentive for an advisory firm or its professionals to select our sub-advisory services. These revenue sharing payments may be significant to certain advisory firms and, as a result, may be an important factor in their willingness to select our sub-advisory services. In no event will we compensate a third-party solicitor for a referral if that solicitor serves as a sponsor, decisionmaker or fiduciary of any U.S. pension or profit-sharing plan. We may engage and compensate entities to provide prime brokerage and other services (including client account statement preparation) to client accounts. In addition, other third parties may provide certain shareholder servicing and/or distribution support services in connection with the sale of shares of our mutual funds or other funds that we service. These third parties may do so either directly or through intermediaries (e.g., broker-dealers) and may, in some instances, refer clients into such funds. These third parties (and the intermediaries through whom the funds are available) may receive cash compensation for these services out of our own resources. Our firm, or our affiliates, may be compensated in connection with the sale of shares of either our mutual funds or other funds that such entity services. In addition, our sales and client service employees’ compensation may be linked to sales of our Registered Funds.

In the event that a U.S. unregistered pooled fund liquidates, we will engage a PCAOB accountant to conduct a liquidation audit and distribute the audited financials promptly upon completion of the audit, as applicable. If investors in the unregistered pooled funds do not receive audited financial statements in a timely manner (as described above), then they should contact Aberdeen Investments immediately. In addition, we may be deemed to have custody in certain situations in which clients may grant us the authority to debit their custody accounts for advisory fees and capital calls, and clients may also request that we forward client instructions to private placement fund custodians with regard to client subscription and withdrawal requests. Aberdeen Investments does not take physical custody of clients’ assets and other than custody relating to its authority to debit client accounts previously described and custody relating to the management U.S unregistered pooled funds; Aberdeen Investments does not have custody of client assets and ensures that all clients’ assets are maintained with qualified custodians that distribute account statements to clients at least quarterly. Clients are encouraged to compare statements received from us with statements received from their client account custodians. Clients should also carefully review their custodian statements to ensure they reflect the appropriate activity in their account. If there are differences between a client’s custodian statement and an Aberdeen Investments account statement, or if a client has not received their account custodian statement, they are instructed to contact their client service representative.

We exercise discretion in a manner consistent with the stated investment objectives for a particular client account. We may accept advisory accounts with limited or no discretion or non-discretionary accounts where investments are client-directed pursuant to an investment management agreement. We may also be limited in the type or quantity of securities purchased or held due to certain regulatory or internal compliance restrictions. Client investment guidelines and restrictions must be provided to us in writing. As it relates to discretionary arrangements, Aberdeen Investments generally is not required to provide notice to consult with, or seek the consent of its clients prior to engaging in transactions. Please refer to Item 4 of this Brochure for additional information on clients’ ability to tailor investment guidelines.

We require ISS to provide recommendations based on our own customized voting policy which is tailored to Aberdeen Investments’ views and approach but remain conscious that all voting decisions, where we have been given voting authority, are our own on behalf of our clients. We consider ISS’s recommendations and those based on our custom policy as input to our voting decisions. We make use of the ISS benchmark research and recommendations and those recommendations based on our own custom policy as input to our voting decisions. Where our analysts make a voting decision that is different from the custom policy recommendations policy, they will provide a rationale for such decisions which will be made available upon request. In order to make proxy voting decisions, an Aberdeen Investments analyst assesses the resolutions at general meetings of companies held in our active investment portfolios. This analysis will be based on our knowledge of the company but will also make use of the custom and benchmark recommendations provided by ISS as described above. The product of this analysis will be a final voting decision instructed through ISS and applied to all funds for which Aberdeen Investments has been appointed to vote. There may be certain circumstances where abrdn Inc. may take a more limited role in voting proxies. We will not vote proxies for client accounts in which the client contract specifies that abrdn Inc. will not vote. We may abstain from voting a client proxy if the voting is uneconomic or otherwise not in clients’ best interests. For companies held only in passively managed portfolios, Aberdeen Investments custom policy recommendations provided by ISS will generally be used to automatically apply our votes. We have scope to intervene to test that this delivers appropriate results and will on occasions opt to instruct a vote different to custom recommendations if we consider this to be in clients’ best interests. If voting securities are part of a securities lending program, we may be unable to vote while the securities are on loan. However, we have the ability to recall shares on loan or to restrict lending when required, in order to ensure all shares have voted. In addition, certain jurisdictions may impose share-blocking restrictions at various times which may prevent abrdn Inc. from exercising our voting authority. We recognize that there may be situations in which we vote at a company meeting where we encounter a conflict of interest. Such situations include, but are not limited to: • An investee company that is also a segregated client. • An investee company where an Executive Director or Officer of our company or that of Aberdeen Group plc or another affiliate is also a Director of that company. • An investee company where an employee of Aberdeen Group plc or an affiliate or subsidiary is a Director of that company. • A significant distributor of our products. • Any other companies which may be relevant from time to time. We have adopted procedures within our proxy voting process to identify where a conflict exists. These procedures are designed to ensure that our voting decisions are based on our client’s best interests and are not impacted by any conflict. Clients may obtain a free copy of abrdn Inc.’s proxy voting policies and procedures and/or proxy voting records for their account by contacting us at (215) 405-5700. Aberdeen Investments publishes Listed Company Investment Principles & Voting Policies, which describe our approach to stewardship, engagement and proxy voting across companies worldwide. Voting decisions and rationales are available upon request. Clients that have not granted abrdn Inc. voting authority over securities held in their accounts will receive their proxies in accordance with the arrangements they have made with their service providers.

Aberdeen Investments may file claims on behalf of clients in class actions where we have the authority to do so. In other instances, Aberdeen Investments may provide a client with the appropriate holdings and trade information to enable the client to participate or opt-out of the class action at the client’s discretion.

China, India, Latin America, Thailand, Singapore Equity

Asia, China Small & Mid Cap

GEM Small Cap

Global, Europe, Japan, UK, US, EAFE Small Cap

US Small Cap

GEM Equity

Asia incl. Income; GEM Income, Sustainable, ex China; US incl. Income; Europe incl. Income; Global incl. Income, Infrastructure, Impact; Japan UK incl. Income, Value, Ethical; EAFE Single Country

Equity funds where e.g., Art. 9, Impact, SDG, where there is a client outcome in addition to performance target UK Mid Cap Global Mid Cap US Mid Cap

Fixed Income: Fee Schedule Category

Strategies

EM Aggregate Specialist

First $100m bps.

Next $150m bps.

Next $250m bps.

Over $500m bps.

Frontier Bonds

EM Credit – Specialist

SDG

EM Credit

EM Corporate, Sustainable

EM Sovereign

EMD - Sovereign Hard Currency, EMD - Sovereign Local Currency

EM Credit – Single market

Indian Bonds

APAC Credit – Specialist

High Yield

APAC – Credit

Asian Bond/Credit

Global & Dev Market Credit Specialist

High Yield - Global, European Climate/Article 9

Global & Dev Market Aggregate

Strategic Bond

Global & Dev Market Credit

Global, European, UK, US Corporate, Sustainable Corporate

Global Rates

Global Government Bonds, Global Inflation Linked

Global & Dev Market Short Term

Short Dated Enhanced Income, Short duration GILB, Short Duration Corporate

Dev Market Rates

Euro Government Bonds

Sterling Rates

Sterling Government Bonds

US Municipal Bonds

National, Ultra Short Duration, Short Duration High Yield, Intermediate