Daiwa Asset Management (America) Ltd: investment adviser

With respect to these Investment Funds, our investment management services are tailored to conform to the parameters and investment guidelines that DAM specifies, including with regard to the kind of securities in which a fund invests and positional limits, and we anticipate that we will similarly tailor our services if engaged to manage other portfolios. Certain of the Investment Funds have contracts with unaffiliated subadvisors that provide us additional investment research and information. In addition, we provide investment advisory services to institutional clients on a discretionary basis tailored to their particular investment objectives and guidelines as in investment advisory agreements entered into with such clients. We also provide certain other portfolio oversight services (but not investment advice) to DAM, as described below in Item 10 under “Other Financial Industry Activities and Affiliations.” As of March 31, 2026, we had $5,959,831,087 in assets under management on a discretionary basis.

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If termination occurs prior to the end of a calendar quarter, a final fee is normally payable on a prorata basis. Our fees are paid directly by DAM, which collects fees from its client funds. Our practices relating to the selection of brokers and dealers and related fees are described below in Item 12 under “Brokerage Practices.”

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We do not engage in short sales or related strategies designed to profit from decreases in an investment’s value. DAMA may invest in initial public offerings (“IPOs”) and other primary offerings. IPOs are typically new issues of equity. IPOs have many of the same risks as small company stocks. IPOs do not have trading history, and information about the company may be available only for recent periods. An Investment Fund’s purchase of shares issued in IPOs also exposes it to the risks inherent in those sectors of the market where these new issuers operate. The market for IPO issuers has been volatile and share prices of newly priced companies have fluctuated in significant amounts over short periods of time. An Investment Fund may be limited in the quantity of IPO and secondary offering shares that it may buy at the offering price, or an Investment Fund may be unable to buy any shares of an IPO or secondary offering at the offering price. An Investment Fund’s investment return earned during a period of substantial investment in IPOs may not be sustained during other periods when the Investment Fund makes more limited, or no, investments in IPOs. As the size of an Investment Fund increases, the impact of IPOs on the Investment Fund’s performance generally would decrease; conversely, as the size of an Investment Fund decreases, the impact of IPOs on the Investment Fund’s performance generally would increase. Investment Risks Investing in securities of any kind involves risks of loss that clients must be willing to bear. There is no guarantee that the investment strategy selected by a client will result in the client’s investment objective being met, nor is there any guarantee of profit or protection from loss. Past performance is no guarantee of future results. Clients and potential clients should consider the following factors: Investment Selection. We may select or recommend investments in part based on information and data filed by the issuers of those securities with various government regulators or made directly available to us by the issuers of securities or through sources other than the issuers. Although we seek to evaluate that information and data and seek independent corroboration when we consider it appropriate and when it is reasonably available, we may not be able to confirm the completeness, genuineness or accuracy of that information and data, and, in some cases, complete and accurate information will not be readily available. The likelihood that clients will realize income or gains depends on our skill and expertise. -8-

Focused Investment Risk. To the extent that an Investment Fund focuses its investments in a particular industry, that Investment Fund’s portfolio will be more susceptible to events or factors affecting companies in that industry. These may include, but are not limited to, governmental regulation, inflation, rising interest rates, cost increases in raw materials, fuel and other operating expenses, technological innovations that may render existing products and equipment obsolete, competition from new entrants, high research and development costs, increased costs associated with compliance with environmental or other regulation and other economic, market, political or other developments specific to that industry. Also, an Investment Fund may invest a substantial portion of its assets in companies in related sectors that may share common characteristics, are often subject to similar business risks and regulatory burdens and whose securities may react similarly to the types of events and factors described above, which will subject the Investment Fund to greater risk. An Investment Fund also will be subject to focused investment risk to the extent that it invests a substantial portion of its assets in a particular issuer, market, asset class, country or geographic region. Future Regulatory Change is Impossible to Predict. The securities markets are subject to comprehensive statutes, regulations and margin requirements. In addition, regulatory authorities and securities exchanges are typically authorized to take extraordinary actions in the event of a market emergency, including, for example, the retroactive implementation of speculative position limits or higher margin requirements, the establishment of daily price limits and the suspension of trading. The regulation of securities is a rapidly changing area of law and is subject to modification by government and judicial action. The effect of any future regulatory change on an Investment Fund is impossible to predict but could be substantial and adverse. Investments in Smaller Companies. Certain Investment Funds may invest in small and/or unseasoned companies. While smaller companies generally have potential for rapid growth, they often involve higher risks because they lack the management experience, financial resources, product diversification and competitive strengths of larger companies. These factors make smaller companies far more likely than their larger counterparts to experience significant operating and financial setbacks that threaten their short-term and long-term viability. In addition, in many instances the frequency and volume of trading in their securities is substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations, and exiting investments in such securities at appropriate prices may be difficult, subject to substantial delay or impossible. When making large sales on behalf of a client, we may have to sell (or recommend the sale of) portfolio holdings at discounts from quoted prices or may have to make (or recommend) a series of small sales over an extended period of time due to the trading volume of smaller company securities. While the nature of our strategies may reduce some of the risks associated with investing in less mature companies, these risks cannot be eliminated. Debt and Other Fixed Income Securities. Certain Investment Funds may invest in fixed income securities. Fixed income securities are subject to interest rate, market, and credit risk. Interest rate risk relates to changes in a security’s value because of changes in interest rates generally. Even though such instruments are investments that may promise a stable stream of income, the prices of such securities are inversely affected by changes in interest rates and, therefore, are subject to the risk of market price fluctuations. In general, the values of fixed income securities increase -9-

when prevailing interest rates fall and decrease when interest rates rise. The level of interest rates at various maturities is affected by macroeconomic factors relating to economies generally, such as the level of inflation, and by governmental policies that can be difficult to predict. In addition, interest rate levels at differing maturities do not necessarily vary in a predictable pattern. 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 or decrease significantly in value when market interest rates fall or rise, but the extent and frequency of the applicable interest rate resets may not match market developments. Market risk relates to the changes in the risk or perceived risk of an issuer, country, or region. Credit risk relates to the ability of the issuer to make payments of principal and interest. The values of fixed income securities may be affected by changes in the credit rating or financial condition of the issuing entities. Fixed Income securities denominated in non-U.S. currencies are also subject to the risk of a decline in the value of the denominating currency relative to the U.S. dollar. Furthermore, debt security markets are typically “dealer” markets and, depending upon the security in question, may be subject to wide variations in quoted prices and not offer predictable levels of liquidity, especially with respect to complex structured debt products. Interest Rate Risk. Debt securities can lose value because of interest rate changes. For example, debt securities tend to decrease in value if interest rates rise. Debt securities with longer maturities generally are more sensitive to interest rate changes than those with shorter maturities. In addition, short-term and long-term interest rates do not necessarily move in the same direction or by the same amount. Changes in interest rates can also cause certain types of debt obligations to become subject to prepayment risk or duration extension risk. These include securities such as mortgagebacked securities and bonds with embedded call or put options. Credit Risk. An Investment Fund could lose money if the issuer or guarantor of a fixed income security (including a security purchased with securities lending collateral), the counterparty to a derivatives contract or a repurchase agreement, a borrower of portfolio securities, or the issuer or guarantor of collateral, is unable or unwilling, or is perceived (whether by market participants, rating agencies, pricing services or otherwise) as unable or unwilling to make timely principal and/or interest payments, or to otherwise honor its obligations. The risk that such issuer, guarantor or counterparty is less willing or able to do so is heightened in market environments where interest rates are rising. The downgrade of the credit rating of a security or of the issuer of a security held by an Investment Fund may decrease its value. Securities are subject to varying degrees of credit risk, which are often reflected in credit ratings. Measures such as average credit quality may not accurately reflect the true credit risk of the Investment Fund. This is especially the case if the Investment Fund consists of securities with widely varying credit ratings. Therefore, an Investment Fund with an average credit rating that suggests a certain credit quality may in fact be subject to greater credit risk than the average would suggest. This risk is greater to the extent an Investment Fund uses leverage or derivatives in connection with the management of the Investment Fund, which would be magnified in the event that initial or variation margin is not provided by the counterparty to such transactions (or not provided below a certain threshold amount). Non-U.S. Exchanges and Markets. The investment strategies of certain Investment Funds may involve trading on non-U.S. exchanges and markets in Latin American countries. Trading on such exchanges and markets may involve certain risks not applicable to trading on U.S. or Japanese - 10 -

exchanges and is frequently less regulated. For example, certain of those exchanges may not provide the same assurances of the integrity (financial and otherwise) of the marketplace and its participants as do U.S. or Japanese exchanges and regulation by the SEC and Japanese regulators. There also may be less regulatory oversight and supervision by the exchanges themselves over transactions and participants in such transactions on those exchanges. Some non-U.S. exchanges are “principals’ markets” in which settlement is the responsibility only of the individual member with whom the trader has dealt and is not the responsibility of an exchange or clearing association. Furthermore, trading on certain non-U.S. exchanges may be conducted in such a manner that all participants are not afforded an equal opportunity to execute certain trades and may also be subject to a variety of political influences and the possibility of direct government intervention. Investments in non-U.S. markets are also subject to the risk of fluctuations in the exchange rate between the local currency and the dollar or yen and to the possibility of exchange controls. Foreign brokerage commissions and other fees are also generally higher than in the United States. Non-U.S. Investments. Investment in non-U.S. issuers or securities principally traded outside the United States and Japan are likely to involve certain special risks due to economic, political and legal developments, including favorable or unfavorable changes in currency exchange rates, exchange control regulations (including currency blockage), expropriation of assets or nationalization, imposition of withholding taxes on dividend or interest payments and possible difficulty in obtaining and enforcing judgments. Furthermore, issuers of such securities are subject to different, often less comprehensive accounting reporting and disclosure requirements. The securities of some foreign companies and foreign securities markets are less liquid and at times more volatile than comparable U.S. and Japanese securities and securities markets. Emerging Markets. The risks of foreign investments described above apply to an even greater extent to investments in emerging markets, including certain Latin American countries. The securities markets of emerging market countries are generally smaller, less developed, less liquid and more volatile than the securities markets of the U.S., Japan and other developed foreign markets. Disclosure and regulatory standards in many respects are less stringent than in the United States and developed foreign markets. Accounting and auditing standards in many markets are different, and sometimes significantly differ from those applicable in the United States, Europe or Japan. In particular, the accounting standards with respect to inflation must be clearly understood in order to analyze a balance sheet. Frequently there is substantially less publicly available information about companies located in emerging markets than there is about companies in more developed jurisdictions. There also may be a lower level of monitoring and regulation of securities markets in emerging market countries, and regulation of the activities of investors in those markets and enforcement of existing regulations has often been extremely limited. Economies in emerging markets generally are heavily dependent upon international trade and, accordingly, have been and may continue to be affected adversely by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. The economies of these countries also have been and may continue to be adversely affected by economic conditions in the countries with which they trade. The economies of countries with emerging markets may also be predominantly based on only a few industries or dependent on revenues from particular commodities. In addition, custodial services and other costs relating to investment may be more - 11 -

expensive in emerging markets than in many developed foreign markets, which could reduce a client’s income from those securities. In many cases, governments of emerging countries continue to exercise significant control over their economies, and government actions relative to the economy, as well as economic developments generally, may affect the capacity of issuers of emerging country debt instruments to make payments on their debt obligations, regardless of their financial condition. In addition, there is a heightened possibility of expropriation or confiscatory taxation, imposition of withholding taxes on interest payments or other similar developments that could affect investments in those countries. There can be no assurance that adverse political changes will not cause an investor to suffer a loss of any or all its investments and, in the case of fixed-income securities, interest thereon. Many emerging countries are undergoing important political and economic changes that are making their economies more free-market oriented. However, there could be future political and economic changes that may return the situation to closed and centrally controlled economies with price and foreign exchange controls. Many of these countries lack the legal, structural and cultural basis for the establishment of a dynamic, orderly, market-oriented economy. Many of the promising changes that are being seen at present could be reversed, causing significant impact on a client’s investment returns. Settlement Risk. Settlement and clearance procedures in certain foreign markets differ significantly from those in the United States and Japan. Foreign settlement and clearance procedures and trade regulations also may involve certain risks (such as delays in payment for or delivery of securities) not typically associated with the settlement of U.S. and Japanese investments. At times settlements in certain foreign countries have not kept pace with the number of securities transactions. If we cannot arrange to settle a trade or settlement is delayed in a purchase of securities, an Investment Fund may miss attractive investment opportunities and certain of its assets may be uninvested with no return earned thereon for some period. If we or DAM cannot arrange to settle or settlement is delayed in a sale of securities, an Investment Fund may lose money if the value of the security then declines or if it has contracted to sell the security to another party, the Investment Fund could be liable for any losses incurred. Currency Risk. The value of an Investment Fund may be affected favorably or unfavorably by changes in currency rates and exchange control regulations. Some currency exchange costs may be incurred when investments are changed from one country to another. Currency exchange rates may fluctuate significantly over short periods of time. Such changes generally are determined by the forces of supply and demand in the respective markets and the relative merits of investments in different countries, actual or perceived changes in interest rates and other complex factors, as seen from an international perspective. Currency exchange rates can also be affected unpredictably by intervention by governments or central banks (or the failure to intervene) or by currency controls or political developments. Foreign Taxes. It is possible that certain dividends and interest directly or indirectly received by an Investment Fund from sources within foreign countries will be subject to withholding taxes imposed by those countries. In addition, an Investment Fund may be subject to capital gains taxes in some of the foreign countries where we purchase and sell securities on the Investment Fund’s - 12 -

behalf. Tax treaties between certain countries and Japan may reduce or eliminate such taxes. Depending on the investment strategy selected, it may be impossible to predict in advance the rate of foreign tax an Investment Fund will directly or indirectly pay since the amount of the Investment Fund’s assets to be invested in various countries may not be known. Clients and potential clients should consult their own tax advisors about such matters. Inflation Risk. Debt securities can lose value because of changes in the rate of inflation. For example, fixed rate debt securities tend to decrease in value as inflation rises due to the declining purchasing power of cashflows generated by these securities. Inflation-indexed debt securities (e.g., Treasury inflation-protected securities are subject to the effect of changes in market interest rates caused by factors other than inflation (i.e., real rates). Spread Risk. Investment Fund returns are affected by changes in the spreads over risk-free rates of the underlying sectors and assets. In particular, an Investment Fund that is systematically overweighted in spread product would lose value if spreads widen. This systematic risk is dependent on the Investment Fund’s exposure to various fixed income asset classes with varying degrees of spread risk. Corporate Debt Securities Risk. Corporate debt securities include corporate bonds, debentures, notes (which are transferable securities listed or traded on a regulated market) and other similar corporate debt instruments, including convertible securities. Debt securities may be acquired with warrants attached. Corporate income-producing securities may also include forms of preferred or preference stock. The rate of interest on a corporate debt security may be fixed, floating or variable, and may vary inversely with respect to a reference rate. The rate of return or return of principal on some debt obligations may be linked or indexed to the level of exchange rates between the USD and a different currency or currencies. In addition, corporate debt securities may be highly customized and as a result may be subject to, among others, liquidity risk and pricing transparency risks. Corporate debt securities are subject to the risk of the issuer’s inability to meet principal and interest payments on the obligation and may also be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity. When interest rates rise, the value of corporate debt securities can be expected to decline. Debt securities with longer maturities tend to be more sensitive to interest rate movements than those with shorter maturities. Company defaults can impact the level of returns generated by corporate debt securities. An unexpected default can reduce income and the capital value of a corporate debt security. Furthermore, market expectations regarding economic conditions and the likely number of corporate defaults may impact the value of corporate debt securities. Issuer Risk. The value of a security may decline for a number of reasons that directly relate to the issuer, such as management performance, major litigation, investigations or other controversies, changes in the issuer’s financial condition or credit rating, changes in government regulations affecting the issuer or its competitive environment and strategic initiatives such as mergers, acquisitions or dispositions and the market response to any such initiatives financial leverage, reputation or 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. A change in the financial condition of a single issuer may affect one or more other issuers or securities markets as a whole. - 13 -

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a member of the DSG Group could invest or divest proprietary holdings in a security, and that investment or divestment could negatively impact the price paid or received in a transaction in the same or a related security by one of our clients; or

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a member of the DSG Group could invest client assets in a security in which a member or clients of the DSG Group has already invested, solely for the purpose of increasing the value of the DSG Group’s or its clients’ investment.

However, other than sharing certain back office facilities (for example, human resources) that are provided by Daiwa Capital Markets America Inc., a DSG subsidiary, we do not have relationships that are material to our business practices with any other DSG subsidiary or entity controlled by DSG, and, subject to the discussion below under Item 11, "Code of Ethics, Participation or Interest in Client Transactions and Personal Trading – Other Trading Activities of Our Affiliates," we, DSG and its subsidiaries and controlled entities have firewalls and other procedures in place to prevent our advisory personnel from having knowledge of those entities’ activities or taking their interests and practices into account in connection with our investment management activities. Those procedures forbid us to accept instructions or limitations from other members of the DSG Group concerning our investment decisions or recommendations on behalf of our clients, and we do not do so. Further, investments made by the DSG Group (for itself and on behalf of its clients) are typically in liquid securities of companies with higher market capitalizations, and therefore it would be unlikely that an investment made on behalf of a client would be affected by the transactions in any securities by a DSG Group member or on behalf of its clients. Other than our engagement by DAM, as described above in Item 4 under “Advisory Business,” and the possibility that we may utilize broker-dealer subsidiaries of DSG to conduct transactions on behalf of the Investment Funds we manage, as further described below in Item 13 under “Brokerage Practices,” we do not have arrangements in connection with our investment advisory business with firms controlled by DSG.

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It should be noted DAMA utilizes Itaú Asset Management (“Itaú”) as sub-advisers for certain clients, executes certain transactions for clients through their brokerage affiliates, may trade in the publicly held securities of Itaú’s affiliates and may receive research, in some cases customized research, in exchange for the direction of brokerage to Itaú’s brokerage affiliates. In an effort to mitigate potential and/or existing conflict of interests, Itaú, and its affiliates, will be held neutral to their client’s benchmark if the affiliate is a client benchmark constituent. If an affiliate is not a constituent in client’s benchmark, the investment weight of the affiliate will be zero. Finally, DAMA will prohibit personal securities transactions in the securities of Itaú, and its affiliates, in the Code of Ethics. Daiwa Asset Management Co. Ltd. and Daiwa Asset Management (America) have a relationship management consignment agreement as it pertains to Drucker Institute. The scope is to provide administrative and sales support for Drucker related funds. DAMA is registered as a commodity trading advisor with the U.S. Commodity Futures Trading Commission and is a member of the National Futures Association.

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In the event of any violation of our Code of Ethics, we may impose such sanctions as we deem appropriate (including, without limitation, a letter of censure or suspension or termination of employment). Personal Trading Our directors, officers, certain employees and other specified persons (“supervised persons”) who may be aware that one of our Investment Funds is purchasing or selling a particular security or has such a purchase or sale under consideration may not engage in securities transactions (except with respect to certain excepted securities) without preclearance, and generally may not engage at all in transactions in securities in which an Investment Fund has or may acquire an interest. Each supervised person is subject to reporting requirements in respect of purchases or sale of securities in which he or she (or other persons covered by the reporting requirements in the Code of Ethics) has or acquires any direct or indirect beneficial ownership. Principal Trades DSG, its subsidiaries and other members of the DSG Group may buy or sell securities for their own accounts, and may act as dealers in securities that we determine to buy or sell for an Investment Fund. A conflict of interest may exist in a principal trade because of the incentive to generate a profit by buying or selling from inventory. However, we will not knowingly engage in a such a “principal transaction” on behalf of an Investment Fund with one of our affiliates unless, before such a principal transaction is settled, in accordance with Section 206(3) of the U.S. Investment Advisers Act of 1940, we disclose to the Investment Fund in writing the capacity in which our affiliate is acting, including relevant information to allow the Investment Fund to assess the desirability of the trade from such Investment Fund’s perspective, and obtain the consent of the Investment Fund to such transaction.

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Agency Cross Transactions We will not knowingly engage in agency cross transactions (i.e., transactions between client accounts we, or we and one of our affiliates, manage in which we or one of our affiliates is paid a brokerage fee) without obtaining written consent in the same manner that applies in the case of principal transactions. Other Trading Activities of Our Affiliates DSG has many subsidiaries and controlled entities in the financial industry, including other investment advisers and broker-dealers. Those entities may engage in transactions in the same securities that we buy and sell on behalf of our clients, both as principals for their own account and as brokers or advisers for other customers or clients. Those transactions may occur at or about the same time as the transactions we engage in for our clients, and the investment position or action may be different from, or inconsistent with, an action or position taken for or recommended to one of our clients, resulting in potential adverse impact, or in some instances benefit, to one or more affected client. We do not have advance knowledge of those transactions, and those affiliates do not have advance knowledge of the transactions in which we engage on behalf of our clients. As a result of sharing by DAM and its subsidiaries of certain back office facilities in Japan, personnel who engage in back-up trade reconciliation and certain other administrative activities have retrospective access to information concerning client trades on the part of DAM and all of its subsidiaries; however, neither DAM nor its other subsidiaries engage in transactions in the same kind of securities that we trade on behalf of our clients. We, DSG and its subsidiaries and controlled persons also have firewalls and other procedures in place to prevent our and their personnel from gaining or utilizing information about our and their respective principal and client transactions and transactions that are being considered, either as principals or on behalf of our clients or their respective clients. (See Item 10 above for additional disclosures related to trading activities of our affiliates.)

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Our selection of an executing broker is not based solely upon whether the broker offers the lowest possible commission cost (or transaction fee), but rather whether the transaction represents the best qualitative execution, taking into consideration the overall level of customer service and various factors. The brokers on our approved list do not provide execution-only services, and we almost always pay the same level of brokerage commissions to all brokers that we use on behalf of our clients in a particular country. Among the factors we consider in broker selection are the responsiveness of the broker to us in connection with transactions for our clients, promptness of execution, quality of execution, cost, reputation, financial responsibility and research-related services that the broker furnish to us. While we do not maintain “soft dollar” arrangements (i.e., arrangements pursuant to which our clients would pay higher brokerage commissions than they otherwise would in return for our receipt of research or ancillary transaction-related services), we may take into account the quality of research in selecting the broker placement on the approved broker list. That research includes the type of research materials that fall within the safe harbor for the use of soft dollars established by Section 28(e) of the Securities Exchange Act of 1934, including, among others, analyses and reports concerning issuers, industries, securities and economic factors. We have a committee, consisting of our President, Trader, Portfolio Manager and Chief Compliance Officer that evaluates brokers on a semi-annual basis to determine the addition or deletion of brokers from our approved list. The committee assesses the quality of the research services that we obtained from various brokers during the previous period, and that assessment is one of the factors we consider in selecting the brokers and will use (subject to the possible occurrence of developments with respect to a particular broker that may lead us to stop using that broker and, perhaps, to recommend the substitution of a new broker on the approved broker list). This may give us an incentive to select a broker on the basis of the research it provides rather than on the basis of execution capabilities. However, we do not otherwise take into account the particular research we receive from a broker in selecting brokers to effect client transactions. During our last review, most of the brokers on the approved broker list provided us with research services that factored into our decision.

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With this background, our trader who is responsible for executing a particular transaction selects the specific broker to be used on the basis of trading expertise in the transaction in question, including the ability to execute transactions with unusual characteristics (such as high volume or in low liquidity situations). Subject to the policies described above, we may direct some trades on behalf of clients to brokers controlled by DSG. While in some cases it may be possible to effect particular transactions through other broker-dealers at lower commission cost, we believe the commissions charged by affiliated brokers are reasonable in relation to the full range and quality of services provided to us and are not higher than the commissions that would be charged by similar services by non-affiliated broker-dealers. Soft Dollar Practices While we do not maintain “soft dollar” arrangements, we may take into account the quality of the research provided by the brokers. Research provided by the brokers may be used in servicing our Investment Funds. Trade Aggregation and Sequencing We do not aggregate the purchase or sale of securities for the Investment Funds. While aggregation may decrease the transactional expense to clients that participate in an aggregated trade, we manage each Investment Fund on an individualized basis and do not believe we would obtain materially reduced transactional costs by seeking to engage in trade aggregation. Our trade desk places orders with brokers for the securities trades of our Investment Funds in the order in which they are received from the portfolio managers for each Investment Fund. Because we do not bunch the orders or average price the trades of Investment Funds, if a security being traded is common to more than one Investment Funds (including an Investment Fund that includes the investment assets of our affiliates or employees (an “Affiliated Account”)), securities price fluctuations during the course of a day could cause one client account (including an Affiliated Account) trading in a particular security to receive a better or worse price than other Investment Funds trading in that same security. In addition, in certain instances, the fact that we do not bunch the orders of our Investment Funds may cause Investment Funds to pay higher commission and other transaction costs than would be the case if we bunched client orders and thereby obtained the benefits of lower pricing associated with larger combined orders.

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Our President and Chief Compliance Officer will also engage in an immediate review in circumstances that raise a concern, such as when one of them is alerted to a potential violation of our trading compliance rules, a possible deviation from applicable investment strategies and restrictions, the existence of a potential conflict of interest between us (or our employees) and an Investment Fund (or with respect to which we provide analyses or advice), a possible violation of cash holding requirements or unusual portfolio performance. We report to DAM on a monthly and semi-annual basis concerning the Investment Funds and our assessment of their outlook.

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