Genesis Investment Management, LLP: investment adviser

The Firm currently has a corporate partner, individual partner(s) (whose number may vary from time to time, but as of the date of this Brochure is one) and a trust (the “Trust”, together with the corporate partner and individual partner(s), the “Genesis Partners”) and operates through a series of boards/committees and appointments described below. The Firm has a single office at The Smiths Building, 179 Great Portland Street, London, W1W5PL United Kingdom. The Firm serves as an investment manager, investment adviser or sub-adviser to various clients, including, but not limited to, pension plans, endowments, foundations, investment companies and governmental entities. Following the Firms decision to wind down in late 2024 the Firm no longer actively manages client assets.

Principal Ownership Affiliated Managers Group, Inc. (“AMG”), a publicly-traded company (NYSE: AMG) with equity investments in boutique investment management firms, owns a majority of the equity interests of the Firm. AMG holds its majority interest in the Firm indirectly through three wholly owned subsidiaries: AMG Genesis, LLC, AMG Atlantic Holdings Ltd and AMG New York Holdings Corp. AMG also holds equity interests in other investment management firms (“AMG Affiliates”). Each of the AMG Affiliates, including the Firm, is operated autonomously and independently, except, with respect to the Firm, as described in this Brochure. Further information on both AMG and AMG’s Affiliates is provided in Item 10. The remaining interest in the Firm is owned by the Genesis Partners and the Genesis Investment Management, LLP Continuation Trust (the “Continuation Trust”), which acts as the Trust and facilitates the recycling of partnership interests and future awards for the benefit of the individual partner(s). The Genesis Partners and the Continuation Trust in aggregate own approximately 46.5% of the equity in issue and AMG owns approximately 53.5%. Further details on these individual partner(s) are included in the Brochure Supplement.

The Firm The Firm is registered in England and Wales as a limited liability partnership Following the decision to wind down its operations, the Firm no longer has any employees and no longer actively manages client assets. The only remaining holding left in its funds is a single sanctioned Russian security that will be held until it can be lawfully divested. The Firm is managed by the Operating Board which is comprised of a Non-Executive Chair and the Managing Partner. The GIM Operating Board has overall responsibility for managing the Firm. There are no formal committees following the Firm ceasing business activities.

Advisory Services The Firm ceased conducting investment advisory services during 2025 following its decision to wind down its business operations.

Wrap Fee Programmes The Firm does not have any involvement in wrap fee programmes whereby clients select an investment adviser to manage funds through an investment programme presented to the clients by a third-party programme sponsor and clients generally pay the wrap programme sponsor a single fee (called a “wrap fee”) for consulting, brokerage, custodial, portfolio monitoring, and investment management services and such sponsor pays a portion of the wrap fee to the investment adviser.

Foreign Exchange (“FX”) Transactions FX transactions for client accounts are generally limited to those necessary to settle trades in emerging market securities which are not denominated in US Dollar. The key factors in informing the Firm’s approach on FX are; FX is not a discretionary part of the investment management process; FX transactions are undertaken to minimise operational risk and maximise efficiency and best execution. The Firm does not hedge directly against currency fluctuations between the currencies of emerging markets stocks and uses a base currency of US Dollar. For clients who have not elected to use the FX platform, the Firm will instruct the client’s custodian to execute the necessary FX transaction. This is done either through standing instructions communicated to the custodian when the account is established or at the time settlement instructions are sent to the custodian for a particular transaction. The custodian is responsible for executing FX transactions, including the timing and applicable rate of such execution pursuant to its own internal processes. Where a client has arrangements in place with its custodian regarding the execution of FX transactions, such arrangements may impact the overall fees and expenses charged to the client by the custodian. Therefore, all such FX transactions are effected with the client’s custodian, and the Firm does not seek to obtain different FX rates from other sources. Because of various local limitations regarding transactions for some restricted currencies, transactions in restricted currencies are often effected by each client’s custodian pursuant to standing instructions (both the Genesis Funds and separate account clients). The Firm also instructs other types of FX transactions, such as those related to dividend and interest repatriation. Where possible such FX activity will utilise an FX trading platform.

Assets Under Management As of 31st December 2025, the Firm’s assets under management (“AUM”) on a discretionary basis were nil (2024: US$578 million). The Firm does not have any AUM on a non-discretionary basis. Please see the Firm’s Form ADV Part 1A – Item 5.F for more information.

Other Jurisdictions The Firm is registered with the SEC under the Investment Advisers Act of 1940, as amended and the financial services that the Firm provides are regulated by the Financial Conduct Authority under UK laws.

The Genesis Funds are not registered under the Investment Company Act of 1940, and none of the interests in the Genesis Funds are registered under the Securities Act of 1933, as amended. Accordingly, interests in the Genesis Funds were offered exclusively to investors satisfying the applicable eligibility and suitability requirements either in private placement transactions within the United States or in offshore transactions. None of the Genesis Funds are currently soliciting or accepting subscriptions from additional investors. No offer to sell interests in any Genesis Fund is made by the descriptions in this Brochure, and as noted interests in the Genesis Funds are available only to investors that are properly qualified, as determined by the Firm or its affiliates in its or their sole discretion. As of 31st December 2025, the side pockets are valued at nil. Genesis is no longer actively managing assets.

Additional Fees and Expenses Payable by Clients The Firm is no longer earning fees. Brokerage commissions, transaction fees, service provider fees (e.g., fund administrator, and securities lending agent), and other related costs and expenses will be incurred by the client at the time the final trade is settled. Execution of client transactions typically requires payment of brokerage commissions by clients. Item 12 entitled “Brokerage Practices” further describes the factors that the Firm considers in selecting or recommending brokers for the execution of transactions and determining the reasonableness of their compensation (e.g., commissions). Investment activity may also involve other transaction fees payable by clients, such as sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. In addition, clients may incur certain charges imposed by custodians, depositaries, broker/dealers, third-party investment consultants, and other third parties, such as custodial fees, consulting fees, administrative fees, and transfer agency fees.

Fees for Investment of Client Assets in Third‐Party Mutual Funds, Private Funds, and Other Pooled Investment Vehicles Following the Firm’s decision to wind down, it no longer conducts investment activities. Fees for the Sale of Securities Neither the Firm nor its partners or personnel receive, directly or indirectly, any compensation from the sale of securities or investments that are purchased or sold for a client’s account. The Firm is compensated through the stated management fee agreed upon in the investment management/advisory agreement. Accordingly, the Firm believes that it does not have any conflicts of interest regarding the receipt of additional compensation relating to the client assets that it manages, except as specifically disclosed from time to time.

the Firm, is operated autonomously and independently, and except as described in this Brochure, the Firm does not have any business dealings with these AMG Affiliates and does not conduct any joint operations with them. Moreover, the AMG Affiliates do not formulate advice for the Firm’s clients. As such, AMG’s ownership interest in the Firm does not, in the Firm’s view, present any potential conflict of interest for the Firm with respect to our clients. More information regarding AMG, including its public filings and a list of all AMG Affiliates, is available at www.amg.com. The Firm has entered into an arrangement with AMG for the provision of marketing support. See ‘Item 14 – Relationships with Solicitors’ for more information. The Firm is no longer accepting new subscriptions and its funds are therefore no longer being marketed. AMG holds (indirectly) equity interests in the Firm and in certain AMG Affiliates, some of which may also be broker/dealers. As a result of AMG’s equity interest in the Firm, the AMG Affiliates may be considered “related persons” to the Firm for the purposes of this Brochure. The Firm does not have any business dealings with AMG or the AMG Affiliates and does not conduct any joint operations with them. Neither AMG nor the AMG Affiliates formulate advice for the Firm’s clients and do not, in the Firm’s view, present any potential conflict of interest with the Firm.

Other Financial Activities Neither the Firm nor any of its management persons are registered, or have an application pending to register, as a broker/dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of one of the foregoing types of entities.

Genesis Investment Management, LLP THE SMITHS BUILDING 179 GREAT PORTLAND STREET LONDON W1W 5PL UNITED KINGDOM Telephone: +44 2072 017200 Email: legalandcompliance@giml.co.uk Attention: Legal & Compliance Department, Conflicts of Interest Policy Request

Code of Ethics The Firm has a fiduciary duty to its clients and accordingly has adopted a Code of Ethics (the “Code”) that applies to all partners and personnel. The Code describes the standard of conduct the Firm requires of

its partners and personnel and sets forth restrictions on certain activities, including personal trading in accounts owned, managed or beneficially owned by the individual. The Code’s provisions also include requirements relating to areas such as gifts and business hospitality, confidentiality of information, the provision and solicitation of political and charitable contributions and outside appointments. The Code prohibits all personal political contributions for any purpose to a U.S. federal, state or local government elected official, candidate, or entity (including any political action committee) without the written consent of the CCO. By setting forth the regulatory and ethical standards to which the Firm’s partners and personnel must adhere, the Code supports our efforts to promote a high level of professional ethical conduct in furtherance of our fiduciary duty to our clients. The Code is reviewed at least annually and approved by the GIM Operating Board.

Personal Trading The Firm is no longer actively trading or making investment decisions. The Funds hold only one sanctioned security as noted above. The risks associated with personal trading are therefore no longer applicable to the Firm.

Participation or Interest in Client Transactions The Firm is no longer soliciting or taking new subscriptions from clients or partners / personnel of the Firm. The risks associated with participation or interest in client transactions are therefore no longer applicable to the Firm.

The Firm has maintained a small investment in one Genesis Fund since its inception. This investment was intended to satisfy the minimum number of investors. For several other vehicles, the Firm or one of its affiliates may hold ‘founder shares’ to satisfy local requirements.

Insider Trading/Material Non‐Public Information The Firm is no longer actively engaged in trading activities. All partners and personnel of the Firm are subject to the Affiliated Managers Group, Inc. Insider Trading Policy and Procedures (the “AMG Insider Trading Policy”). The AMG Insider Trading Policy broadly prohibits the use of material, non-public information, and also imposes restrictions on the trading of AMG’s stock. In addition, the Firm’s Code of Ethics also includes policies and procedures prohibiting the use of material non-public information that are designed to prevent insider trading by any partners or personnel of the Firm. In accordance with these policies, any matter which may involve inside information is required to be brought to the attention of the Legal and Compliance Department prior to any trading activity.

Gifts and Business Hospitality The Firm’s Code of Ethics includes policies and procedures regarding giving or receiving gifts and business hospitality between the Firm’s partners, personnel and certain third parties (e.g. vendors, broker/dealers, consultants, etc.) to help mitigate the potential for conflicts of interest surrounding these practices. In general, the Firm monitors the amount (i.e., value and frequency) of gifts and business hospitality that may be provided to and by partners and personnel to these parties, and requires the pre-approval of certain items by the CCO. The Firm specifically monitors for any potential conflicts of interest with respect to individual instances of gifts or hospitality, as well as patterns of the same over time, to prevent the interests of the Firm and its partners and personnel from being placed ahead of the interests of clients. Gifts and hospitality of any sort to clients and certain US public and foreign officials are prohibited without the prior consent of the CCO.

Charitable Contributions The Firm is no longer involved in making donations to charitable enterprises. The solicitation of charitable contributions from clients or potential clients is forbidden.

Political Contributions The Firm prohibits its partners and personnel from making political contributions on behalf of the Firm or to be reimbursed for personal political contributions, or from making political contributions for the purpose of securing or retaining business. All requests for political or campaign contributions from clients or potential clients are required to be declined. The solicitation of political or campaign contributions from clients or potential clients is forbidden.

Distribution of the Code The Firm is winding down its operations and no longer has any employees nor does it intend to hire any new employees. The Firm is also not taking any new subscriptions and has minimal operational stakeholders. The Firm is firmly committed to making its partners, personnel and clients aware of the requirements within the Code of Ethics. All partners and personnel are provided with a copy of our Code at the time of hire and annually thereafter, and each must affirm that they have received a copy of the Code, and that they have read and understand its provisions. Additionally, the Legal and Compliance Department conducts periodic compliance training that addresses the requirements of the Code and the other policies described in this Item. A current copy of the Firm’s Code is available at all times to partners and staff via the Firm’s SharePoint and also available to clients or prospective clients upon request, and may be obtained by contacting: Genesis Investment Management, LLP THE SMITHS BUILDING 179 GREAT PORTLAND STREET LONDON W1W 5PL UNITED KINGDOM Email: legalandcompliance@giml.co.uk Attention: Legal and Compliance Department, Code of Ethics Request

The Firm is not directly related to any brokers but may be considered affiliated with other brokers as a result of the common ownership with AMG. With respect to such brokers which may be viewed as affiliated to the Firm through AMG, the Firm does not use such entities to execute trades on behalf of its clients. The Firm may have many other relationships with brokerage firms. For example:

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the Firm may invest client assets in securities issued by brokers or their affiliates.

Notwithstanding such relationships or business dealings with these brokers, the Firm has a fiduciary duty to its clients to seek best execution when trading with these firms, and has implemented policies and procedures to monitor its efforts in this regard.

Best Execution – Selection Factors for Brokers As noted above, the Firm has a duty to seek best execution of transactions for client accounts. “Best execution” is generally understood to mean the most favourable cost or net proceeds reasonably obtainable under the circumstances. In seeking best execution, the Firm looks for the best combination of transaction price, quality of execution (e.g., the speed of execution, the likelihood the trade will be executed, etc.), sourcing liquidity and other valuable services that an executing broker may provide. The Firm, in seeking best execution, will make this selection based on a number of factors, which may include, but are not limited to, the following: the broker’s financial soundness; the broker’s ability to effectively and efficiently execute, report, clear, and settle the order; the broker’s ability to commit capital; the broker’s ability to timely and accurately communicate with the Firm’s Dealing Desk and settlements team; the broker’s commission rates; and similar factors. Northern Trust are an outsourced provider of Broker Services in markets and/or securities where it is the designated broker and for these securities these same obligations for best execution apply.

Best Execution The GIM Operating Board has responsibility for best execution and oversees the Firm’s brokerage practices. The Investment Manager has an established process for determining the brokers to be used in executing trades and the general level of commissions to be paid to each broker which will be utilised as applicable when the time comes to exit the one remaining position in the fund side pockets

Broker Approval Process The Firm only has one remaining position as noted previously. This process will be applicable at the point when it can be lawfully divested. Prior to using a broker, the Firm conducts a general due diligence review of the broker and will consider various criteria including, but not limited to, creditworthiness and appropriate regulatory authorisation. The CCO approves such brokers but if a broker fails to satisfy one of the criterion, additional due diligence will be performed and the approval of the GIM Operating Board is also required. As the Firm is no longer engaged in trading activity, brokers will be assessed and approved as appropriate at the time the final transaction is executed.

Monitoring The Firm is no longer engaged in trading activity but it will monitor and review broker performance and the reasonableness of brokerage commissions if and when it engages in the final transaction to sell the one remaining holding in its funds. As part of the dealing process, the Firm monitors broker executions against other traded prices shown on Bloomberg. The internal procedures relating to brokerage practices are maintained in a written Best Execution policy

which is reviewed by the GIM Operating Board but there are no active broker relationships. The policy will be followed regarding broker engagement if and when the sanctioned asset can be sold lawfully.

Please refer to Item 4 above for a description of arrangements relating to FX transactions for client accounts.

Research and Soft Dollar Benefits The Firm is no longer actively engaged in investment management activities and therefore does not require research services. The Firm is not involved in any soft dollar arrangements.

Commission Sharing Arrangements The Firm is not involved in any CSAs.

Trade Aggregation and Allocation When two or more portfolios are simultaneously engaged in the purchase or sale of the same security, the Firm may, but is not obligated to, combine and aggregate the transactions to form a “bunched trade” or “block trade.” In such cases, these accounts will receive the average price of the transactions in that security for the day. Trades in the same security for different accounts will be accumulated for a reasonable period of time to allow for aggregation, unless a particular account’s interest would be unduly prejudiced. The Firm may, but is not required to, aggregate orders into block trades where the Firm believes this is to be appropriate, in the best interests of the client accounts, and consistent with applicable legal requirements. Transactions executed in a block will typically be allocated to the participating client accounts before the close of the business day. Since more than one account’s orders are included in a block trade, the Firm has adopted a policy of using a “pro rata allocation” to allocate the trade among each account whose order makes up part of the block. Under a pro rata allocation, as securities are being purchased or sold as part of the block trade, the securities are being allocated to (or away from, in the case of a sale) accounts in the proportion by which each account’s order size (as determined by the portfolio manager at the time of order entry) makes up a percentage of the entire block. In cases where the Firm is unable to fulfil a block trade the same day (i.e., purchase or sell all securities within the block trade), those securities that have been purchased or sold by the end of the day will generally be allocated pursuant to the Firm’s pro rata allocation methodology.

Initial Public Offerings (“IPOs”) An initial public offering is a company’s first offer of stock for sale to the public. Depending on the interest in this initial offering, the Firm’s access to these newly offered shares may be limited in amount at the time of the initial offering. The Firm is no longer operating and has not and will not participate in the future in any initial public offerings and other securities with limited availability (collectively, “IPOs”) since making its decision to wind down in late 2024.

Trade Errors and Trade Error Accounts If a trade error were to occur, it is the Firm’s policy to make the client account whole. Also, if a client account were to benefit from a trade error, any profits would remain with the account (unless the client instructed otherwise). Any material breach of an investment restriction would be disclosed to the client. Internally such a material matter is required to be reported immediately to the CCO who in turn would

inform the wider group of partners. Where possible, procedures are put in place to ensure that such an incident does not recur.

Genesis Investment Management, LLP THE SMITHS BUILDING 179 GREAT PORTLAND STREET LONDON W1W 5PL UNITED KINGDOM Telephone: +44 (0) 20 3880 7522 Email: clientservice@giml.co.uk Attention: Client Service, Report Query

Custodian statements reflect the official books and records for the accounts managed. The Firm may be deemed, under the federal securities laws, to have custody of client assets by virtue of the fact that it also serves as the investment manager and the general partner of one or more of the Genesis Funds referenced in Item 7. In neither capacity (as the investment manager nor as the general partner) does the Firm have actual physical custody of any client assets or securities invested in such Genesis Fund; rather, all such assets are held in the name of the applicable Genesis Fund by an independent qualified custodian. Each such Genesis Fund is audited annually, and investors receive annual financial statements, as required by applicable law.

For the Genesis Funds, the appointment of the Firm as investment manager, the scope of the authority and investment objectives and limitations are outlined in the relevant offering documents and the governing agreements of the relevant Genesis Fund.

Class Action Suits and Other Legal Actions As a general matter, the Firm provides instructions to custodians regarding tender offers and rights offerings for securities in client accounts. Due to the fact that the Firm is unlikely to be under any obligation to, and typically does not, take any legal action with regard to class action suits relating to securities purchased by the Firm for its clients any class action suits and other legal actions would be carefully considered by the Firm on a case by case basis after seeking appropriate legal advice.

However, it is the responsibility of the custodian appointed by the client to ensure that the Firm receives notice of the relevant proxies sufficiently in advance of the relevant meeting to allow the Firm to vote. Also given the underlying markets in which the Firm invests, the Firm may encounter other administrative obstacles in voting proxies on behalf of clients including share blocking and language requirements. The Firm has implemented proxy voting guidelines and procedures intended to protect the value of shareholder investments and designed to reasonably ensure that the Firm votes proxies in the best interest of clients. In voting proxies, we seek to both maximise the long-term value of our clients’ assets and to cast votes that we believe to be fair and in the best interest of the affected client(s). The Firm instructs the voting agent (see below) on how to vote and the voting agent in turn liaises with the relevant custodian. Records are maintained as to the manner in which proxies are voted and are distributed to clients in accordance with their reporting requirements (see Item 13). Such reports include further information when a decision has been made to vote against management. Where clients have not delegated proxy voting authority to the Firm, such clients may on occasion seek information or advice from the Firm as to how the Firm views the relevant issues. On certain occasions, the Firm may contact those clients for whom it does not have proxy voting authority and advise such clients of how it intends to vote for other client accounts. Whilst the Firm has the right to cast votes, this is not relevant given the single sanctioned security being the only holding.

Voting Agent See above regarding the Firm’s OWD.

Conflicts of Interest If a material conflict should arise between the Firm’s interests and those of the clients, it is the Firm’s policy to advise the client of such conflict and obtain their consent or instruction as to how to vote. Details of how the Firm has voted in the past five years on a particular security held in one or more of the Genesis Funds are available on the Firm’s website. Separate account clients (which have delegated proxy voting authority to the Firm) may use the contact details below to request the details of how votes were instructed by the Firm for their account. The Firm’s Proxy Voting Guidelines are available on the Firm’s website. If you would like to review how the Firm voted on a particular security for your account, or if you would like further information on the proxy agent’s proxy voting policy guidelines, please contact:

Genesis Investment Management, LLP THE SMITHS BUILDING 179 GREAT PORTLAND STREET LONDON W1W 5PL UNITED KINGDOM Telephone: +44 (0) 20 3880 7522 Email: Bhattacharjee@giml.co.uk Attention: Proxy Voting Guidelines Request