Boston Partners: investment adviser

Boston Partners has been in business, through its predecessor companies, since 1970 and has an additional division: Weiss Peck & Greer (“WPG Partners”). Boston Partners is the parent of (1) Boston Partners Securities L.L.C. (“Boston Partners Securities”), a limited purpose broker-dealer, which offers interests in registered and unregistered funds advised by Boston Partners or its affiliates; (2) Boston Partners Trust Company (“BPTC”), a non-depository trust company formed in New Hampshire, which offers interests in bank collective investment trusts; and (3) Boston Partners (UK) Limited (“Boston Partners UK”), a private limited company formed in the United Kingdom. Boston Partners UK provides sales and client services to institutional clients in Europe. The actual discretionary investment management services are delegated to Boston Partners.

B. Types of Advisory Services Boston Partners provides investment supervisory services, also known as asset management services. Boston Partners provides continuous investment advice on a fully discretionary basis to institutions, including registered investment companies, and to high net worth individuals for a variety of investment strategies. This brochure relates only to BPPW, where Boston Partners refers to Boston Partners Global Investors, Inc. and BPPW refers specifically to Boston Partners Private Wealth. BPPW provides investment supervisory services to individuals and their related entities such as family trusts. BPPW’s services focus on asset allocation and investment management considering a client’s investment objectives and assets as well as other objectives such as generational wealth transfer and tax minimization. BPPW’s services include security and manager selection consistent with the client’s investment and other objectives. BPPW’s services are provided by Boston Partners’ employees who also manage portfolios for other clients of Boston Partners such as institutions. BPPW clients may be invested in some Boston Partners’ products. BPPW investment strategies are offered primarily through separate accounts although BPPW clients may be encouraged to invest in registered and unregistered funds managed by Boston Partners or unrelated managers. Boston Partners offers investment advisory services to investment companies (or portfolios or series thereof) registered under the Investment Company Act of 1940 including the Boston Partners Mutual Funds, which are part of The RBB Funds, Inc. Boston Partners, or an affiliate, serves as general partner or - 1Boston Partners re: Boston Partners Private Wealth

investment adviser and/or sponsor, or has some financial interest in various investment partnerships or limited liability companies, and other separately managed and/or commingled accounts, as discussed further in Item 11 below ("Proprietary Accounts"). Boston Partners typically seeds Proprietary Accounts to develop new investment strategies prior to offering such strategies to clients. BPPW clients may be encouraged to invest in the Boston Partners Mutual Funds or a Proprietary Account managed by Boston Partners. BPPW offers advice on a wide range of securities and contracts. Investments include: equities (stocks), preferred stock, fixed income securities, convertible securities, convertible preferred stock with fixed or adjustable rates, warrants, SMA programs, investment company securities (mutual funds shares), various money market instruments, depository receipts, and common stock issued by foreign issuers, foreign currencies and currency hedges, forward contracts, exchange traded funds or unit investment trusts, and various derivative or hybrid securities and investment techniques, including but not limited to futures contracts, options contracts, swaps and contracts for differences. Initial public offerings (IPOs) are available to Boston Partners’ clients in certain circumstances. Investments for BPPW clients will also include equity and fixed income securities managed by managers not related to Boston Partners to gain access to other investment strategies. Boston Partners’ investment personnel share security information internally, or on a more limited basis with its affiliates. Information will be shared through periodic reports of holdings, formal meetings, and informal discussions among investment personnel. Employees of Boston Partners who are registered representatives of Boston Partners Securities offer investment opportunities in mutual funds and interests in private investment vehicles. BPPW clients may be offered investment opportunities by BPPW personnel who are registered representatives of Boston Partners Securities.

C. Tailored Relationships BPPW services include asset allocation planning, proprietary investment offerings, external manager selection, and general wealth consulting. BPPW’s customized asset allocation advice and individualized services consider investment objectives, risk tolerance, and investment-time horizon. BPPW coordinates trust and estate, tax and financial planning services through third party arrangements. Investments include publicly traded securities as well as mutual funds and private investment vehicles. BPPW’s role for fund investments is limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of BPPW calculating its investment advisory fee. BPPW’s clients are under absolutely no obligation to consider or make an investment in a private investment fund. Investment management assignments may be governed by client guidelines, either standard BPPW guidelines, or guidelines submitted by the client. Clients may impose reasonable restrictions on the types of investments made by BPPW and BPPW will assess those restrictions and discuss with the client the potential effect on the portfolio of restrictions that BPPW deems material.

D. Managed Account Programs Additionally, Boston Partners provides discretionary, investment management services to clients of various wrap-fee programs (“SMA Programs”) offered by investment adviser/broker-dealers (“Sponsors”). Under these arrangements, the Sponsors provide various services, which typically include investment management, trade execution, custody, performance monitoring, reporting, and other services for an all-inclusive fee. - 2Boston Partners re: Boston Partners Private Wealth

Boston Partners participates in a Sponsor’s Unified Management Account Program (“Model Program"). Under a Model Program, Boston Partners provides a model portfolio to the Sponsor, and the Sponsor executes transactions for its client accounts taking into consideration the individual needs of the particular client. Under a Model Program, Boston Partners does not render individualized investment management services to the Sponsor’s client. The process for security selection for accounts for SMA Programs and Model Programs is the same as for Boston Partners’ other accounts and the securities selected for the SMA and Model Programs will be the same securities as Boston Partners’ other accounts in the same product, except for differences due to client imposed restrictions or operational limitations. Boston Partners does not execute trades for the Model Programs and SMA programs that are traded through the program sponsor. Therefore, Model Program and SMA program investment decisions cannot be aggregated with trades for other Boston Partners’ accounts usually traded by the Boston Partners’ trading desk. SMA and Model Program trade instructions are handled by a separate department within Boston Partners. Because of the operational requirements of the SMA and Model Programs, instruction of trades to the Sponsors will likely be later than instructions of trades to a broker for trades done for Boston Partners’ other accounts by the Boston Partners’ trading desk and trades for Boston Partners’ other accounts will most likely commence before trades for SMA and Model Programs have been communicated to the Sponsors. Boston Partners tries to ameliorate this conflict by limiting the difference in time between the issuance of trade orders to brokers by the Boston Partners’ trading desk for its other accounts and the instructions of trades to the Sponsors. For example, Boston Partners’ order instruction program is set up to notify the Boston Partners’ trading desk and the SMA and Model Programs departments of a trade contemporaneously. Boston Partners seeks to manage the delivery of trading instructions to the Sponsors to ensure that the trading opportunities are fair and equitable to all SMA and Model Program clients. This could involve simultaneous trade instructions but more typically involves a rotation system. The rotation system is used to prevent the Sponsors from trading for the same securities at the same time and potentially affecting the price for the securities. The rotation system may not be effective for preventing multiple Sponsors trading for the same security at the same time as Boston Partners has no input or control over when the Sponsors execute trades communicated to them by Boston Partners. A rotation system could disadvantage clients of Sponsors who are not first in the rotation list for a trade. BPPW does not currently sponsor a SMA or Model program, however, BPPW could sponsor a SMA Program in the future for its clients.

E. Client Assets As of December 31, 2025, Boston Partners Private Wealth managed approximately $104.720 million on a discretionary basis, and $168.344 million on a non-discretionary basis.

B. Fee Billing BPPW is compensated for its services on the basis of fees calculated as a percentage of assets under management either in arrears or in advance, as negotiated with the client. Fees are generally calculated as of a specific date (usually quarter-end), on an average of the first and last day values of the preceding calendar quarter, or on the average of month end values for the three months in the quarter. Typically, fees are based on the aggregate market value of all assets under management within the client’s account, including but not limited to cash, cash equivalents, securities, and accruals. Adjustments are usually made to reflect additions or withdrawals which exceed certain thresholds during a calendar quarter. To the extent any such assets are invested in a commingled fund or SMA Program, the commingled fund/SMA Program will also charge investment management fees for such assets. In such cases, the client would be paying a management service fee and investment management fee for assets invested in the commingled fund/SMA Program. Fees are generally calculated and invoices submitted to clients on a quarterly basis. Compensation is payable within 30 days after presentation of an invoice. Clients may arrange to have such fees debited directly from their account held at the custodian for credit to BPPW subject to applicable law. In most cases, both BPPW and the client may unilaterally terminate the investment advisory agreement on (usually 30 days) written notice to the other party. If the advisory relationship terminates on other than the end of the specified billing period, fees are prorated and an adjustment made. Any prepaid, unearned fees are refunded to the client. Closing an account does not affect either the client’s or BPPW’s responsibilities for previously initiated transactions or for balances due in the account.

C. Other Fees, including Custodian Fees, Mutual Fund Expenses, Brokerage and Other Transaction Costs BPPW will not receive any compensation other than management fees and brokerage and research services for managing the assets of the clients’ portfolios. The clients will incur other expenses to third parties such as custody, accounting and brokerage costs. A client may pay fees to the custodian or broker holding the client’s assets. The client’s custodian or broker is selected by the client and the fees paid by the client may be negotiated separately or BPPW may negotiate such fees. A client will also be responsible for brokerage transaction fees for transactions done for the client’s account. A discussion of Boston Partners’ broker selection and trading process is set forth in Item 12. BPPW receives brokerage and research services within the meaning of Section 28(e) of the Securities Exchange Act of 1934 (the “Exchange Act”) and the regulations interpreting such section. A client’s transaction costs are likely to be higher when BPPW receives brokerage and research services as a result of such transactions. - 4Boston Partners re: Boston Partners Private Wealth

D. Fees Paid in Advance, and Refunds if Advisory Contract is Terminated Before End of Billing Period A client may request to be billed “in advance” or “in arrears”. A refund of pre-paid investment advisory fees shall be made where a client has been billed “in advance”, has made a full period payment to BPPW and has terminated its investment advisory contract, in writing, before the end of the billing period. The investment advisory fee shall be prorated according to the number of days in the billing period during which BPPW was responsible for management of the client’s assets. Advisory fee refunds are initiated automatically by BPPW and can be made by check or federal wire at the client’s direction.

E. Compensation to Supervised Persons BPPW’s staff may be compensated based upon a percentage of the revenue generated from new client assets. This compensation is payable from BPPW’s advisory fees and not directly from the client. BPPW is not compensated based upon commission revenue, although BBPW receives brokerage and research services from the transactions done for a client’s account with unaffiliated brokers. 5.E.1. The receipt of compensation for the promotion of BPPW’s products presents a conflict of interest and gives supervised persons an incentive to recommend investment products based upon the compensation received, rather than a client’s needs. Boston Partners addresses such potential conflicts of interest with a supervisory structure that reviews the suitability of each investment product for a prospective client. 5.E.2. A client could purchase certain of Boston Partners’ fund products through an unaffiliated entity, although the cost to the client would likely be greater than if the product were purchased directly through Boston Partners. 5.E.3. Not applicable 5.E.4. Not applicable

Boston Partners recognizes this conflict and has a trade aggregation and allocation policy (the “TAA Policy”) that requires all accounts to be treated fairly and equitably over time. The Boston Partners’ compliance team reviews trade allocations regularly for any deviation from the TAA Policy of equitable trade allocations. - 5Boston Partners re: Boston Partners Private Wealth

Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies Used 8.A.1. Boston Partners In managing clients’ assets, BPPW formulates an overall investment management strategy which considers the client’s individual investment objectives, risk tolerance, and lifestyle needs. BPPW designs an asset allocation strategy for each client which works in conjunction with the client’s overall wealth management plan. The strategy considers the client’s risk tolerance and return objectives to design a portfolio that combines lower return, lower risk investment classes, such as high-quality fixed income, with higher return seeking asset classes such as equities, including but not limited to mutual funds, exchange traded funds, separate accounts, and individual equity securities. BPPW uses the Boston Partners investment process and BPPW clients are likely to be invested in Boston Partners’ investment strategies. Boston Partners’ investment philosophy is grounded in certain “fundamental truths” to investing (“Three Circle”), each proven to have worked over meaningful periods of time and in a variety of market environments: 1. Low valuation stocks outperform high valuation stocks 2. Companies with strong fundamentals, e.g. high and sustainable returns on invested capital, outperform companies with weak fundamentals. 3. Stocks with positive business momentum, e.g. rising earnings estimates, outperform stocks with negative business momentum. Boston Partners constructs well-diversified portfolios that consistently possess these three characteristics; they are simple rules that limit downside risk, preserve capital and maximize the power of compounding. BPPW may also recommend or select external investment managers to manage a portfolio of equity or fixed-income securities for the client’s account.

Boston Partners’ Investment Process. All Boston Partners’ strategies share the same philosophy and process. A centralized research team of fundamental and quantitative analysts supports the portfolio managers and the firm’s value equity discipline. - 6Boston Partners re: Boston Partners Private Wealth

Boston Partners’ investment process is grounded in bottom-up fundamental analysis. Efficient and repeatable, the investment process is designed to identify “characteristics that work”: attractive valuation, sound business fundamentals and improving business momentum. Additionally, a strict sell discipline is employed when an investment reaches market valuation, or if business fundamentals weaken or if the catalyst reverses. The process is executed within a team-oriented culture with individual accountability and clarity of having final decision making portfolio managers. Boston Partners’ investment process begins with quantitative screening to cull a target-rich universe based on the Three Circle characteristics for its fundamental research. Boston Partners casts its net wide, scoring thousands of stocks worldwide every day based on fundamental, valuation and momentum criteria. Boston Partners validates each candidate’s screening score by using customized reporting tools to evaluate the company’s financial history. This enables Boston Partners to identify efficiently bona fide candidates within its Three Circle stock selection framework and provides a roadmap for fundamental research. Boston Partners’ fundamental research incorporates the full menu of public filings, industry information and management discussion. Boston Partners uses its professional judgment to assess each company’s intrinsic value and its prospects for achieving it. Research findings are formally discussed during Boston Partners’ scheduled weekly meetings. Portfolio managers are the final decision makers and every investment professional is accountable for the holdings in Boston Partners’ portfolios. The Global Sustainability offering is designed for investors seeking broad-based exposure to best in class companies across market capitalizations with attractive sustainability profiles. The strategy looks for investments that meet two primary requirements: (1) superior Three-Circle characteristics relative to the benchmark, and (2) high quality and/or improving sustainability characteristics. Boston Partners’ investment strategies include several long/short equity products which include selling securities short. The securities sold short may not be considered “value” securities but are considered to be overvalued by Boston Partners based on its quantitative screening and fundamental security analysis. For certain portfolios, Boston Partners uses single name security swaps, negotiated on a bilateral basis and not cleared through a central clearing facility. Swaps are used to provide exposure in markets where physical trading is not allowed or to obtain exposure to a security to manage margin requirements more efficiently. Boston Partners’ use of such swaps in the global long/short product is substantial. The use of swaps adds counterparty risk and additional operational risk to the investment process. In certain cases, different Boston Partners’ portfolios may hold a security both long and short. These cases include where the long position is a significant underweight to the index weighting for the security or the portfolio managers have a different proposed holding period, short-term versus longterm. These situations require prior approval of Boston Partners’ Co-Chief Investment Officer (the “Co-CIO”) and periodic review of the simultaneous long and short positions by the Co-CIO. There will be a conflict between client accounts holding the positions long and short at the same time if two portfolio managers desire to exit the positions at the same time. To avoid more favorable treatment for one client over the other, the transactions would generally be placed with two different brokers at the same time, unless trading believes that there would be a substantial risk of a cross trade between accounts occurring or any other circumstances suggest harm to one or more of the clients.

8.A.2. - US Issuer Definition.

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Absent any extenuating circumstances, Boston Partners will typically treat as US issuers the following companies that are incorporated outside the US: 1. Any issuer that reports its principal executive office as located in the US; or 2. Any issuer that Boston Partners reasonably believes meets 4 of the following criteria: a. common stock of the issuer is essentially solely publicly traded in the US. Issuers that have listings in non US markets but for which there is no meaningful volume in those markets will also be treated as being solely publicly traded in the US. b. common stock of the issuer is not listed in an index of non US securities by MSCI; c. the issuer is listed as being a US issuer by Factset; d. the Chief Executive Officer and 2 of the other top 5 executives of the issuer work a material portion of their time from a US office; e. at least 35% of revenue, on average over the preceding 3 years, is generated from US sources; f. at least 25% of employees are located in the US.

B. Material Risks for Investment Strategies or Method of Analyses Used The primary risk for BPPW clients is loss of capital. The underlying sources of this risk are: valuation risk (risk of over paying), balance sheet risk (inadequate liquidity, excessive leverage, asset-liability mismatch of the issuer), business risk (operational risk inherent in the business that could result in economic losses that threaten its viability as a going concern or the sustainability of its economic profits) and for certain strategies macroeconomic risk stemming primarily from the actions of governments. BPPW seeks to mitigate these three sources of risk by applying the characteristics-based investment process described in Item 8A to produce a diversified portfolio that consistently possess superior valuation, fundamental quality/profitability and improving business momentum and to focus on similar characteristics of the investment philosophies of unrelated managers selected by BPPW for its clients. When investments for BPPW clients include securities managed by managers not related to Boston Partners, there is risk that BPPW, in its selection and monitoring of managers and funds, will not identify appropriate external investment managers or investment products for client portfolios. Further, there is risk that an external investment manager or investment product does not meet BPPW’s expectations over time. The past performance of such managers and investment products is in no way an indication of future performance. For those products using swaps, there is also counterparty risk; this risk is mitigated using financially strong counterparties. There will also be liquidity risk for certain positions held across multiple portfolios resulting in a large holding for which Boston Partners has discretionary management or voting control. Boston Partners’ monitors the liquidity characteristics of each investment strategy monthly. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a subscription agreement, where the client will establish that they are qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with their investment. In valuing the assets of any private investment fund when calculating its advisory fee, BPPW relies on the most recent valuations provided by the fund’s sponsor. When a fund sponsor has not provided - 8Boston Partners re: Boston Partners Private Wealth

any updated valuations, BPPW will use the most recent valuation obtained from the sponsor of the investment, or if none, then the valuation shall reflect initial purchase price (and/or a value as of a previous date), the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than original purchase price. Areas in which BPPW does business are susceptible to natural disasters (e.g., fire, flood, earthquake) and outbreaks of serious contagious disease (e.g., MERS, COVID-19, etc.). The occurrence of a natural disaster or outbreak could adversely affect and severely disrupt the business operations, economies and financial markets of many countries, even beyond the site of the disaster or outbreak, and could adversely affect BPPW’s investment program and/or its ability to do business. Similarly, terrorist attacks, or precautions taken to prevent them, could adversely affect industries in which BPPW invests or could affect the areas in which it does business. Other acts of war could also have a material adverse effect on the financial condition of industries or countries in which BPPW invests.

C. Material Risks In Recommending Primarily a Particular Type of Security

Boston Partners does not effect security transactions for client portfolios through any of its affiliated broker-dealers. 2. investment company or other pooled investment vehicle (including a mutual fund, closedend investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) Boston Partners acts as an investment adviser or sub-adviser to various registered investment companies. Boston Partners has arrangements that are material to its advisory business or its clients as follows: WPG Opportunistic Value Fund Manager, L.L.C. is the general partner of WPG Partners Opportunistic Value Fund, L.P. Boston Partners is the sole member of the general partner WPG Opportunistic Value Fund Manager, L.L.C. Boston Partners Hedged Equity L.L.C. serves as the general partner to the Boston Partners Long/Short Equity L.P. Boston Partners is the sole member of the general partner Boston Partners Hedged Equity L.L.C. Boston Partners serves as the investment manager of the Boston Partners Global Equity Pooled Fund (Canada) and the Boston Partners International Equity Pooled Fund (Canada). 3. other investment advisor or financial planner RIAM US is a registered investment adviser with the SEC. From time to time, Boston Partners refers clients to this affiliate or hires this affiliate as a subadviser. Boston Partners UK is a private limited company that provides sales and client services to institutional clients in Europe. The actual discretionary investment management services are delegated to Boston Partners. 4. futures commission merchant, commodity pool operator, or commodity trading advisor Boston Partners is not a futures commission merchant. - 10 Boston Partners re: Boston Partners Private Wealth

Transtrend, B.V. is registered with the CFTC as a CTA and regulated by the NFA. Transtrend is an adviser to a fund sponsored by Boston Partners. 5. banking or thrift institution Boston Partners Trust Company, a New Hampshire trust company which is wholly owned by Boston Partners, provides trust management services through collective investment trusts. Certain Boston Partners’ personnel are considered shared personnel of Boston Partners Trust Company. 6. accountant or accounting firm 7. lawyer or law firm 8. insurance company or agency 9. pension consultant 10. real estate broker or dealer 11. sponsor or syndicator of limited partnerships

D. Material Conflicts of Interest There are no conflicts regarding the relationship of BPPW with its corporate affiliates that would be considered material because the corporate affiliates do not engage in businesses that present a direct conflict with the interests of BPPW’s clients. There can be potential conflicts for Boston Partners in taking actions on behalf of its clients, as addressed in the subsequent sections.

The Code sets forth trading limitations and/or prohibitions on certain types of securities for personal accounts, defines holding and blackout period limitations, requires mandatory preclearance of certain securities, and mandates reporting of initial holdings information upon employment, quarterly transaction reporting, and annual holdings reporting. Boston Partners reviews these reports to ensure appropriate pre-approvals were obtained and to identify conflicts of interest. Furthermore, upon employment, and annually thereafter, individuals are required to certify compliance with the Code. Individuals may directly, or indirectly through investments in Proprietary Accounts or Boston Partners Mutual Funds, own, buy and/or sell securities which Boston Partners recommends to its clients, subject to the personal trading limitations noted above. Such transactions may also include trading in securities in a manner that differs from or is inconsistent with advice given to clients. Boston Partners periodically becomes privy to material nonpublic information of securities issuers. This results in Boston Partners being unable to transact in such securities until such time as the information becomes public. The Code defines policies to monitor, restrict, if necessary, and educate about investing when in possession of material, non-public information. Boston Partners has a fund where the portfolio manager has a significant investment in such fund: WPG Partners Opportunistic Value Fund, L.P. Boston Partners treats this account as a client account for purposes of the Code of Ethics employee personal trading requirements, as the fund is available for client investments and is considered a marketable strategy. The fund present a conflict because the portfolio manager could allocate a limited opportunity investment to the fund rather than to all clients. Boston Partners reviews the fund for allocation decisions to address this conflict.

B. Participation or Interest in Client Transactions Boston Partners will buy or sell securities or investment products for clients in which Boston Partners or a related person has some financial interest, and buys or sells for itself securities that it also purchases for clients. Boston Partners recognizes that potential conflicts arise from its participation in client interests and has taken reasonable measures to mitigate such conflicts. Employees of Boston Partners who are registered representatives of Boston Partners Securities sell limited partnership interests, limited liability company interests or shares in its registered or unregistered funds in which Boston Partners or any affiliate may have an investment which may be substantial. From time to time, Boston Partners, or an affiliate, provides seed money to a new investment company, separate account or other pooled investment vehicles managed by Boston Partners and receives in exchange shares or other interests issued by such vehicles. Boston Partners has an incentive to encourage clients to invest in its private investment funds to increase the size of such funds. Increasing the size of such funds may (a) lower overall expenses of the fund, some of which Boston Partners may have responsibility for; (b) permit greater marketing of the fund which will generate greater fee revenue for Boston Partners, or (c) allow Boston Partners or an affiliate to redeem its investment capital in such vehicle. Boston Partners maintains client suitability procedures to address these potential conflicts.

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BPPW will not obtain any transaction-based compensation for any investment in any separate account or private investment vehicles in which it solicits clients to invest by prohibiting trading through affiliated broker-dealers as noted in its affiliated brokerage policy. While Boston Partners does not place trades through affiliated brokers, it executes securities trades through brokerage firms with which it maintains other advantageous relationships, such as commission share arrangements for brokerage and research services more commonly referred to as soft dollars. In these cases, the broker may expect commission business in return or Boston Partners may be incented to use client commission dollars for non-research items or inappropriately allocate mixed use items. Boston Partners has established a Trade Management Oversight Committee to evaluate brokerage services and to review commissions paid to brokers. In addition, Boston Partners maintains a Best Execution Policy and Client Commissions Practices to assist in its monitoring efforts. Where appropriate, Boston Partners recommends that clients purchase shares of the Proprietary Accounts or Boston Partners Mutual Funds for which Boston Partners, or an affiliate, receives an investment management fee and/or certain performance-based fees for its services. In addition, Boston Partners recommends the purchase or sale by a client of securities purchased, sold, or owned by the Proprietary Accounts or Boston Partners Mutual Funds. Boston Partners will not recommend or cause a client to enter into transactions for the purpose of benefiting the direct or indirect securities holdings of Boston Partners or its affiliates or employees and addresses these conflicts through its suitability, affiliated investments, and allocation policies. Portfolio transactions by the Proprietary Accounts or Boston Partners Mutual Funds will not be subject to restrictions on employee trading as a result of any beneficial interest that Boston Partners or its principals or employees may have as outlined in the firm’s personal trading policies.

C. Personal Trading Please see response to Item 11(A).

D. Recommendations of Securities to Clients From time to time senior executives of public or certain private companies such as hedge funds, investment advisers, broker-dealers, or investment banks (Value-Added Investors) may invest in Boston Partners’ private funds. Their investment could create a potential conflict if Boston Partners were to invest in the securities of companies affiliated with these investors. To address potential information sharing issues, Boston Partners has developed Value-Added Investor Procedures to identify and monitor potential conflicts. These procedures will apply to BPPW clients. Furthermore, Boston Partners as well as various affiliates and employees of Boston Partners or its affiliates own units or shares in the Proprietary Accounts or Boston Partners Mutual Funds. In addition, Boston Partners or its affiliates or employees have a managerial interest in such Proprietary Accounts as a general or supervising partner, or have an otherwise financial interest, including but not limited to the receipt of investment management and/or certain performance-based fees, in the Proprietary Accounts or Boston Partners Mutual Funds. The interests of Boston Partners, its affiliates and its employees are, at times, significant in such investment vehicles. This investment provides an incentive for Boston Partners to favor such Proprietary Accounts and Boston Partners Mutual Funds when allocating investment opportunities. Furthermore, while Boston Partners typically aggregates client orders of separately managed accounts with Proprietary - 13 Boston Partners re: Boston Partners Private Wealth

Accounts and Boston Partners Mutual Funds, there are instances whereby Boston Partners places orders independently for different accounts and/or strategies, in particular, trades for Sponsors. In such circumstances, trades for one group of accounts, including but not limited to Proprietary Accounts or Boston Partners Mutual Funds, are placed before trades for another group of accounts. As a consequence, one group of accounts may be trading in a less favorable trading environment than the other or may receive a more favorable allocation than the other. Boston Partners addresses these conflicts where possible through its TAA Policy as well as its simultaneous management and principal transaction policies but, as described above, trades for SMA and Model Programs, and for directed brokerage accounts will likely trade after other Boston Partners’ accounts. Boston Partners manages portfolios that invest on a “long-only” basis and also manages portfolios that use short sales. In certain cases, Boston Partners may be purchasing or holding certain securities for its long only portfolios while simultaneously selling those securities short for other portfolios. Generally, the Boston Partners’ portfolios purchasing or holding the securities would have a long-term favorable view of the price of the stock while the portfolios selling the stock short would have a negative trading view of the stock or may be selling the stock short as part of a strategy involving other securities transactions. Some portfolios that are allowed to sell securities short also pay Boston Partners a performancebased fee. Boston Partners has an incentive to favor the portfolios paying Boston Partners a performance fee when allocating execution opportunities. Boston Partners manages these conflicts through its short sales and simultaneous management policies. Various subsidiaries of ORIX Corporation also own the same securities that Boston Partners selects for investment. Aggregate holdings among the subsidiaries, including Boston Partners, may cause ownership to be significant. In these instances, Boston Partners might need to impose limitations on holdings, possibly preventing strategies from being fully implemented. Boston Partners regularly seeks new clients, including corporate securities issuers with pension funds and/or general operating assets which require investment management advice. Boston Partners’ investment recommendations policy precludes Boston Partners from investing in the securities of those issuers to enhance Boston Partners’ ability to be appointed a manager of the assets of such corporate issuers; any such investment requires a typical fundamental analysis. Additionally, Boston Partners or its employees have an opportunity to invest in limited opportunity securities of various issuers. Boston Partners’ TAA Policy and the Code are designed to mitigate these conflicts. Accounts managed by Boston Partners have different fee structures. Certain accounts pay Boston Partners a greater fee than other accounts. In addition, Boston Partners charges certain accounts a performance fee. Differing fee structures cause an incentive for Boston Partners to allocate certain investment opportunities to higher fee paying accounts. Similarly, Boston Partners has an incentive to effect cross transactions between clients to position profitable trades into higher paying and/or performance fee accounts. Even in situations in which Boston Partners believes there is no disadvantage to its clients, such transactions nonetheless create an inherent conflict of interest because Boston Partners has a duty to obtain the most favorable price for both the selling client and the purchasing client. Boston Partners has developed allocation and aggregation policies to mitigate these conflicts. Boston Partners will not undertake cross transactions except at a client’s request for two or more accounts of the client. BPPW periodically discusses securities which are held in client accounts with external investment professionals including, but not limited to, broker-dealers and investment professionals at other registered and non-registered investment advisory firms when sourcing and analyzing investment ideas. These discussions may include but are not limited to - 14 Boston Partners re: Boston Partners Private Wealth

economic factors, market outlook, sector and industry views, and general and/or specific information regarding securities which are held in client accounts. Discussion of specific securities creates a conflict which could disadvantage Boston Partners’ clients if the external parties were to act upon this non-public information, including but not limited to front-running and scalping either particular securities or numerous securities in a similar sector to the extent such information is known about Boston Partners’ holdings. Boston Partners’ Investment Recommendations Policy, Selective Disclosure Policy, and the Code establish policies prohibiting discussion of client investments for non-business purposes. Boston Partners permits discussions with and disclosure of security holdings to sell-side brokers. However, Boston Partners precludes disclosing to buy-side investment professionals whether or not Boston Partners owns a particular security when discussing investment ideas, disclosing its immediate intent to purchase or sell a particular security, or making consensus decisions to trade a security in a particular direction.

Boston Partners attempts to achieve these results by choosing broker-dealers to execute transactions based on various factors, including but not limited to: (1) the value, quality and breadth of their services, (2) their professional capabilities (including use of capital), and (3) the comparative brokerage commission rates which they offer. Accordingly, transactions will not always be executed at the lowest available price or commission, but will be within a generally competitive range as Boston Partners does not adhere to any rigid formula in making the selection of any particular broker-dealer for portfolio transactions, but weighs a combination of factors. Boston Partners has no duty to seek in advance competitive bidding for the most favorable commission rate applicable to any particular portfolio transaction or to select any brokerdealer on the basis of its purported or “posted” commission rate, but will endeavor to be aware of the current level of the commissions of eligible broker-dealers and to minimize the expenses incurred for effecting client transactions to the extent consistent with the interests and policies of the accounts. Although Boston Partners generally seeks competitive commission rates, it will not necessarily pay the lowest commission. Transactions may involve specialized services on the part of the broker-dealer involved and thereby entail higher commissions than would be the case with other transactions requiring more routine services.

12.A.1. Research and Other Soft Dollar Benefits Boston Partners may use client commissions to acquire both proprietary research created by a broker-dealer firm and other research products created by non broker-dealer third parties - 15 Boston Partners re: Boston Partners Private Wealth

as defined by the July 18, 2006 interpretive guidance issued by the SEC regarding the “soft dollar” safe harbor of Section 28(e) of the Exchange Act. When Boston Partners obtains brokerage and research services as a result of client transactions, Boston Partners receives a benefit, as Boston Partners does not have to pay for such services. Boston Partners uses client commission arrangements (“CCAs”) for both proprietary and third-party research services. CCAs are a mechanism that enables Boston Partners to accrue research commission credits with an executing broker providing execution services and later direct the executing broker to pay other brokers/vendors for qualifying proprietary and third-party research services. These arrangements enable Boston Partners to determine more accurately the value of brokerage services by separating the traditional bundled commission into two components, execution and research. Research services and products include, but are not limited to: 1) research reports on particular industries and companies, 2) comprehensive database services which provide current and/or historical information on securities and companies, SEC filings, and earnings estimates, 3) quotation, trading and news systems which provide current market data and news, 4) economic surveys and analysis which provide economic and political forecasting tools, 5) fundamental industry analysis, 6) quantitative technical analysis, 7) Boston Partners’ order management system, and 8) various other products and services providing assistance to Boston Partners in the performance of its investment decision-making responsibilities and/or trade execution and settlement. Where a product or service obtained with commission dollars provides both research and non-research assistance, Boston Partners makes a reasonable allocation of the cost which may be paid for with commission dollars. The portion of the cost of a mixed-use product that is not allocable to research is paid by Boston Partners. Broker-dealers who provide research services may receive a commission which is in excess of the commission another broker-dealer would charge if, in the judgment of Boston Partners, the higher commission is reasonable in relation to the value of all the brokerage and research services rendered. Boston Partners maintains a fluid commission budget that fluctuates in size subject to the nature, quantity, and quality of the brokerage execution and research services acquired throughout the year. These services are evaluated on a continuous basis as follows:

Execution Services: the execution capabilities of each broker are continuously monitored by the Director of Equity Trading and the transaction costs are analyzed by a third party provider to ensure the costs are commensurate with industry standards. Key criteria for execution include: access to natural liquidity, electronic trading tools, expertise in stocks/sectors, client access, program trading capabilities, capital commitment, derivatives trading, international trading expertise, and anonymity. The Director of Equity Trading is responsible for negotiating the commission rates for these services with each broker. Broker Research Independent Research Provider (IRP): a majority of the research services utilized by Boston Partners’ portfolio managers, analysts and traders are evaluated on a service by service basis and individually rated by the event consumer via an on-line voting application. Additional research services are acquired through a packaged subscription whereby the fee is negotiated based on the nature, quantity, and quality of the research offered. The aggregated result of these two research valuation methodologies forms the overall compensation level assigned to each provider. Typical research services consumed include: access to corporate management, analyst calls, - 16 Boston Partners re: Boston Partners Private Wealth

conferences, idea generation, bespoke research, models, macro research and stock/industry analysis. Brokerage Services, Market Data, Quotation Systems, and Analytics: this component of the budget is initially established at the beginning of the year and will fluctuate as new services are added and existing services are maintained/terminated at their renewal period.

Research services from the execution of transactions for client accounts are used by Boston Partners to manage all of its clients’ accounts without differentiation between clients whose transactions generate such research and those that do not. Accordingly, certain brokerage commissions paid by one account are applied towards payment for research services that are not used in the service of that account. Nor does Boston Partners attempt to allocate the costs or benefits of research services among its clients, believing that the research services received will help Boston Partners fulfill its overall duties to client accounts over which it has discretionary authority. Furthermore, advisory fees are not reduced as a result of Boston Partners’ use of such research services. Boston Partners does not engage expert networks to provide research to it. Boston Partners does not accept a client that will not allow Boston Partners to obtain brokerage and research services as a result of transactions in the client’s account.

12.A.2. Brokerage for Client Referrals

12.A.3. Directed Brokerage 12.A.3.a. 12.A.3.b In some circumstances, clients designate a broker-dealer through which trades are to be effected or introduced, typically under such terms as the client negotiates with the particular broker-dealer. Clients do so to defray consulting fees or participate in a commission recapture program. Where a client directs Boston Partners to use a broker-dealer, Boston Partners is generally not able to negotiate commissions or spreads or to select brokers-dealers based on best execution. Under these circumstances a disparity typically exists between the commissions or spreads charged to clients who direct brokerage transactions and the commissions or spreads charged to Boston Partners’ other clients who do not instruct Boston Partners to use a particular broker-dealer. As a result, Boston Partners may be unable to achieve the most favorable execution of client transactions. Direction of transactions to brokers by clients may cost clients money. Boston Partners typically fills directed or preferred trades at the end of block trading activity for a security which is being traded by the product line. Accordingly, transactions for clients that direct or prefer brokerage may be subject to price movements, particularly in the case of illiquid securities or large orders, which could result in the client receiving a price that is less favorable than the price obtained for a block order. Under these circumstances, the direction by a client of a particular broker or dealer to execute trades may result in higher - 17 Boston Partners re: Boston Partners Private Wealth

commissions, greater spreads, or less favorable net prices than might be the case if Boston Partners were able to negotiate commission rates or spreads freely, or to select brokers or dealers based on best execution. From time to time Boston Partners aggregates or “blocks” for execution directed or preferred orders for the same securities with other managed account orders and step-out clearance and settlement to accommodate the directed relationships. SMA Programs SMA Program transactions are typically executed with the Sponsor due to the all-inclusive fee structure. Boston Partners will trade away from the Sponsor when the Sponsor does not have the capability to effect transactions in a particular security or when Boston Partners believes that trading away will provide it with best price, and/or execution of orders taking into consideration all of the factors Boston Partners typically considers in its best execution analysis which are described in Boston Partners’ Best Execution Policy, a copy of which is available upon request. When Boston Partners trades its SMA Program accounts away from the Sponsor and alongside its other client separately managed, Proprietary Accounts and Boston Partners Mutual Funds, the trade may be stepped out to the Sponsor, and the execution price is generally marked up or marked down to reflect the commission charged on the transaction by the executing broker dealer. Commissions, and other expenses, incurred for any transactions executed with broker dealers other than the Sponsor, are typically borne by the client. For this reason, as a general matter, the Sponsor expects Boston Partners generally to use the execution services of the Sponsor to effect transactions for the account. Therefore, it is important for clients who enroll in a SMA Program where Boston Partners serves as the investment adviser to satisfy themselves that the program is suitable for them due to the additional commission incurred by them when Boston Partners trades away from the Sponsor. When execution occurs through the Sponsor, Boston Partners does not have brokerage discretion, which may affect the timeliness of execution. Furthermore, clients should understand that Boston Partners does not have the ability to negotiate commissions or other costs for the execution of transactions in the client’s account since such execution costs are included in the all-inclusive fee charged by the Sponsor. Therefore, it is essential the clients in a SMA Program satisfy themselves that the Sponsor is able to provide best price and execution of orders. New Issues Boston Partners participates from time to time in IPOs for either short-term trading or for investment purposes. Product lines participate to varying degrees, and some product lines generally do not participate at all, such as Global Sustainability and Managed Account Program product lines. Other product lines may only participate to a limited degree, including but not limited to the Boston Partners’ Large Cap, Mid Cap, Global, International and Emerging Market Equity strategies. The amount of performance contribution varies from year-to-year depending on IPO availability and prevailing market conditions. Boston Partners cannot guarantee continued access to IPOs or any ability to profit from them in the future. In determining its indication of interest and allocation, WPG Partners primarily considers: (i) the account’s investment objectives and restrictions, (ii) risk and turnover tolerance; (iii) cash - 18 Boston Partners re: Boston Partners Private Wealth

availability; (iv) size of the account; (v) nature and size allocation of the new issue; (v) FINRA Rules 5130 and 5131; and (vi) commitment to the security. When participating for short-term trading, Boston Partners primarily considers the market capitalization of the security when determining the suitability of an IPO for a product line. For IPOs that are suitable for two or more product lines, the number of shares received from the broker will be split pro-rata based on the assets of the participating product lines. The distribution of shares from the IPO is then allocated among client accounts within a product line. If sufficient shares are available, all accounts within the product line participate pro-rata based on their assets under management, subject to cash availability and investment suitability. When the amount of shares allocated to Boston Partners is insufficient for all accounts to participate pro-rata, the allocation will be based on an account receiving the lesser of a 0.1% position weighting at cost, or 10 consecutive flipped IPO allocations, whereby the account is the sole participant in the trade, again subject to cash availability and investment suitability. An account will continue to be “filled” until the aforementioned target is reached before proceeding to the next account in the rotation. In reaching the target, an account may have an opportunity to participate in 10 consecutive flipped IPOs. Advisory clients with large accounts usually receive a greater number of allocations in flipped IPO securities and the cash proceeds that result from such transactions. Conversely, clients with small accounts typically receive a lesser number of IPO allocations and the cash proceeds that result from such transactions. Additionally, clients with smaller accounts may not receive any flipped IPOs for an extended period depending on how many large accounts are in the same product line and listed before them in the rotation. If the IPO is an investment that will be held as part of Boston Partners’ regular investment strategy and the issue is suitable for two or more product lines, the shares received from the broker-dealer will be split based upon the indication of interest submitted by the portfolio manager for the product line. IPOs retained for investment purposes adhere to Boston Partners’ investment strategies. Cross Trades Boston Partners will not undertake cross transactions except at a client’s request for two or more accounts of the client.

B. Order Aggregation Allocation and Aggregation of Orders Boston Partners manages numerous accounts, including separately managed accounts, Proprietary Accounts, Boston Partners Mutual Funds, and Managed Account Programs. Accounts in these distribution vehicles have similar investment objectives. Additionally, accounts in different product lines with different investment objectives frequently trade in the same securities. Despite such similarities, portfolio decisions relating to Boston Partners’ accounts are made independent of each other in light of differing conditions and the performance resulting from such decisions will differ from client to client. BPPW accounts invested in Boston Partners’ products will trade alongside Boston Partners’ institutional accounts following the rules set forth below. There are instances where Boston Partners will not purchase or sell securities at the same time or proportionate amounts for all eligible clients or will purchase long for one investment strategy while selling short for another investment strategy. Therefore, not all clients will necessarily participate in the same investment opportunity or participate on the same basis. - 19 Boston Partners re: Boston Partners Private Wealth

In allocating investments among clients of the same investment strategy (including in what sequence orders for trades are placed), Boston Partners will use its best reasonable business judgment and will take into account such factors as the investment objectives and strategies of the clients, position weightings, cash availability, risk tolerance, size of the account, and a client’s request for directed brokerage all in order to provide, on balance, a result that Boston Partners in good faith believes is fair and equitable to each client over time. If the same investment decision is made for two or more accounts within or across investment strategies, Boston Partners will seek to aggregate such transactions for the same security into a single “bunched” order to obtain best execution and/or price for participating accounts. However, various factors including, but not limited to, portfolio construction or liquidity contribute to Boston Partners’ decision on whether to advance or delay the purchase or sale of a security for one group of Boston Partners’ accounts. Trades for SMA and Model Programs will not be aggregated with trades for Boston Partners’ other accounts because of the requirement to provide instructions to, or trade through, the Sponsor. To ensure fair and equitable treatment of clients, Boston Partners considers the sequence in which Managed Account Program trades are delivered to the market and has created a process that seeks to achieve overall fair and equitable treatment to all Managed Account Program participants over time. Boston Partners generally groups client accounts of a product line into the following categories: I) accounts for which Boston Partners has full trading authority without any direction as to the brokers to be used by Boston Partners; II) accounts for which Boston Partners has been directed to use one or more particular brokers; and III) accounts that are part of a Managed Account Program or similar program where the client pays a fee to the Sponsor that includes all execution costs. Boston Partners generally fills directed or preferred trades (Category II trades) at the end of block trading activity for a particular security and does not combine these trades with a block order (“sequenced” trades). In instances where investment decisions result in transactions that will occur in both the SMA and Model Program (Category III) and Boston Partners’ other discretionary accounts (Category I) trade instructions will be released contemporaneously to Boston Partners’ trading desk and the SMA and Model Programs department. However, trade notifications to the SMA and Model Program Sponsors are not concurrent. SMA and Model Program participants may trade the same securities before, at the same time, or close time proximity to, Boston Partners’ other discretionary accounts; however the trading of Boston Partners’ other discretionary accounts will be independent to the Managed Account Program trade rotation process. Therefore, Category I and III trades may compete against one another in the marketplace and may result in less favorable prices for either category. Boston Partners will generally rotate the trading order of Category III groups each calendar day so that one group will not be advantaged or disadvantaged by consistently trading before or after another group of accounts. Each Managed Account Program will be considered a separate group for purposes of the rotation sequence. There are certain exceptions to this aggregation/rotation methodology. For example, one or more of the accounts in Category II may be aggregated with accounts in Category I for certain transactions if Boston Partners believes it is reasonably likely that such aggregation will result in best execution. This may not be likely for Category III accounts that are part of a SMA Program for which Boston Partners manages substantial assets or where the Sponsor has discouraged or prohibited trading away from the Sponsor because of cost, administrative, or other client relations issues.

- 20 Boston Partners re: Boston Partners Private Wealth

In addition, an account’s position in the rotation is skipped if there is an issue with the readiness of the account to trade, including but not limited to questions regarding suitability, reconciliation issues, and communication systems failures with the particular account. For BPPW client account, equity securities transactions are routed through the firm’s institutional trading desk and are subject to pre-clearance and centralized execution in accordance with the TAA Policy to promote fair and consistent trade allocation across institutional and wealth management clients. When aggregating orders of a particular strategy is determined to be in the best interest of clients, the following allocation guidelines are used for all portfolios which are participating in the execution under the same trading circumstances (i.e., price limits, time of entry, etc.):

Aggregated orders filled in their entirety will be allocated among the participating accounts as determined by either: i) pro-rata by account market value or ii) an account’s target weighting for a particular security.

For partial allocations, the executed portion of the transaction will be allocated on i) a pro-rata basis, which may be to the nearest round lot, with each portfolio involved receiving a percentage of the executed portion of the order based upon each portfolio’s percentage of the original order or ii) by an account’s target weighting for a particular security. In the event of a de minimis allocation, the trader has the authority to determine an appropriate allocation methodology.

Transaction costs, including brokerage commission allocations, are shared pro-rata based upon each client’s participation in the executed portion of the transaction. The allocation generally will be made at the average execution price, or at prices mathematically closest to the average price, for accounts participating in a particular aggregated transaction. Every effort will be made to use a single average price for such allocations, and the trader has the responsibility for all necessary documentation. Notwithstanding any of the foregoing, an aggregated order may be allocated on a basis different from noted above if all clients receive fair and equitable treatment over time. The trader is charged with making this determination.

C. Regular Reports BPPW typically provides clients with a report of account holdings, transaction summaries, and performance data either monthly or quarterly. BPPW may also provide account aggregation reporting services that can incorporate investment assets that are not part of the assets that BPPW manages for the client (the “Excluded Assets”). The client and/or his/her/its other advisors that maintain trading authority, and not BPPW, shall be exclusively responsible for the investment performance of the Excluded Assets. BPPW may provide monitoring or implementation services for the Excluded Assets. If BPPW is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and BPPW shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may engage BPPW to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between BPPW and the client. All reports from BPPW are in addition to any communication which a client receives from the client’s other service providers, such as custodians and prime brokers. At a client’s reasonable request, BPPW provides additional information as mutually agreed between the client and BPPW. Investors in Boston Partners’ private funds will receive reports directly from the fund administrator which, in the case of the Boston Partners private funds, may be supplemented by reports from BPPW. Managed Account Program clients receive reporting directly from the Sponsor.